IEc
Draft:
May
2005
1
See
"
Human
Health
and
Ecological
Risk
Assessment
Support
to
the
Development
of
Technical
Standards
for
Emissions
from
Combustion
Units
Burning
Hazardous
Wastes:
Background
Document"
November
1998.

2
We
did
not
include
an
analysis
to
assess
the
potential
magnitude
of
property
value
benefits
caused
by
the
MACT
standards
due
to
limitations
of
the
benefits
transfer
approach
and
because
property
value
benefits
likely
overlap
with
some
human
health
and
ecological
benefits.
As
a
result,
including
property
value
benefits
may
result
in
doublecounting
The
benefits
assessment
also
does
not
examine
how
secondary
impacts
such
as
emissions
from
increased
coal
use
at
combustion
sources
that
stop
burning
hazardous
waste
as
fuel
may
result
in
human
health
and
ecological
damages.

6­
1
BENEFITS
ASSESSMENT
CHAPTER
6
______________________________________________________________________________

This
chapter
presents
the
benefits
assessment
for
the
HWC
MACT
replacement
standards.
To
evaluate
the
benefits
resulting
from
emissions
reductions
at
hazardous
waste
combustion
facilities,
we
extrapolate
from
results
presented
in
EPA's
1998
multiple
pathway
human
health
and
ecological
risk
assessment.
1
Based
on
the
results
of
that
risk
assessment,
we
estimate
benefits
incremental
to
those
achieved
under
the
2002
Interim
Standards.
2
In
addition,
this
chapter
briefly
discusses
how
the
HWC
MACT
replacement
standards
may
affect
waste
minimization
activities
at
hazardous
waste
combustion
facilities.

The
chapter
is
organized
into
six
sections:


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


Human
Health
Benefits
Analysis:
Describes
the
approach
for
characterizing
human
health
benefits
from
the
risk
results
and
presents
results
of
our
health
benefits
analysis.
Where
possible,
we
assign
monetary
values
to
risk
reductions
using
economic
valuation
techniques.
We
also
describe
IEc
Draft:
May
2005
6­
2
benefits
to
sensitive
sub­
populations
in
quantitative,
non­
monetary
terms.


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


Ecological
Benefits
Analysis:
Explains
the
methodology
and
results
from
the
ecological
benefits
assessment
conducted
in
support
of
the
1999
Standards
and
describes
the
expected
ecological
benefits
of
the
replacement
standards.


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


Conclusions:
Summarizes
key
findings
from
the
benefits
assessment.

This
benefits
analysis
builds
upon
the
results
and
discussions
presented
in
the
1999
Assessment
and
the
1999
Addendum.
These
documents
are
cited
as
source
material
for
the
current
analysis
because
they
generally
provide
a
reasonable
approximation
of
the
2002
Interim
Standards
baseline.
However,
it
is
important
to
note
that
the
2002
Interim
Standards,
not
the
1999
standards,
represent
the
baseline
for
the
HWC
MACT
replacement
standards.
This
Assessment
clearly
indicates
those
instances
where
we
use
the
1999
analyses
to
approximate
the
2002
Interim
Standards
baseline.

It
is
also
important
to
note
that
the
benefits
analysis
is
based
on
trial
burn
emissions
data.
As
explained
in
Chapter
3,
the
characteristics
of
waste
fed
during
normal
operations
may
differ
significantly
from
the
characteristics
of
waste
fed
during
trial
burns.
Facilities
often
"
spike"
the
waste
feed
during
trial
burns
with
high
levels
of
metals,
chlorine,
and
mercury.
Consequently,
the
emissions
estimates
supporting
the
benefits
analysis
are
likely
to
overestimate
"
typical"
emissions.
Therefore,
we
may
overstate
true
benefits.
Conversely,
if
several
systems
stop
burning
hazardous
waste
as
a
result
of
the
replacement
standards,
we
may
underestimate
benefits
associated
with
such
systems.
IEc
Draft:
May
2005
3
Although
we
extrapolate
benefits
from
the
estimates
presented
in
the
1999
Assessment
and
the
1999
Addendum,
the
2002
Interim
Standards
serve
as
the
baseline
of
our
analysis.
The
2002
Interim
Standards
are
generally
similar
to
the
standards
examined
in
the
1999
Assessment
and
Addendum;
therefore,
these
1999
analyses
serve
as
a
reasonable
approximation
of
the
2002
Interim
Standards
baseline.

4
See
"
Human
Health
and
Ecological
Risk
Assessment
Support
to
the
Development
of
Technical
Standards
for
Emissions
from
Combustion
Units
Burning
Hazardous
Wastes:
Background
Document"
November
1998.

6­
3
BENEFITS
QUANTIFICATION
OVERVIEW
To
quantify
the
benefits
of
the
HWC
MACT
replacement
standards,
we
extrapolate
from
benefits
associated
with
the
1999
Standards,
as
estimated
in
the
1999
Assessment.
3
This
section
provides
an
overview
of
the
methods
used
to
extrapolate
the
incremental
benefits
of
the
replacement
standards
from
those
estimated
for
the
1999
standards.
Ideally,
our
analysis
would
reflect
the
risk
reductions
associated
with
the
2002
Interim
Standards
rather
than
the
1999
Standards.
However,
EPA
did
not
conduct
a
separate
risk
assessment
for
the
Interim
Standards.
Because
the
Interim
Standards
for
incinerators,
cement
kilns,
and
lightweight
aggregate
kilns
are
nearly
the
same
as
the
1999
Standards,
risk
reductions
resulting
from
the
Interim
Standards
are
likely
to
be
similar
in
magnitude
to
those
associated
with
the
1999
standards.
Therefore,
we
assume
that
the
benefits
estimates
in
the
1999
Assessment
are
a
reasonable
proxy
for
benefits
realized
under
the
2002
Interim
Standards.

For
the
1999
Assessment,
we
estimated
the
avoided
incidence
of
mortality
and
morbidity
associated
with
reductions
in
particulate
matter
(
PM)
emissions.
4
Morbidity
effects
included
respiratory
and
cardiovascular
illnesses
requiring
hospitalization,
acute
and
chronic
bronchitis,
acute
upper
and
lower
respiratory
symptoms,
minor
restricted
activity
days
(
MRADs),
and
work
loss
days
(
WLDs).
The
risk
assessment
estimated
risk
reductions
for
each
of
these
health
endpoints
for
16
spatial
zones
surrounding
each
facility,
using
concentration­
response
functions
derived
from
the
epidemiological
literature
and
population
data
for
each
spatial
zone.
These
results
were
also
based
on
estimates
of
ambient
PM
concentrations
developed
for
the
analysis.

For
the
current
assessment
we
scaled
the
results
of
the
1999
Assessment
to
reflect
current
conditions
and
emission
reductions
achieved
under
the
HWC
MACT
replacement
standards.
Since
the
1999
Assessment
was
completed,
several
facilities
have
either
closed
or
stopped
burning
hazardous
waste;
therefore,
we
incorporate
such
changes
in
the
HWC
MACT
universe
into
our
estimates
of
the
benefits
associated
with
the
replacement
standards.
Similarly,
the
emissions
reductions
expected
under
the
replacement
standards
are
different
than
those
associated
with
the
1999
standards,
even
for
facilities
that
still
burn
hazardous
waste.
Our
analysis
of
the
replacement
standards
accounts
for
these
differences.
It
is
important
to
note
that
the
benefits
presented
here
and
in
the
1999
Assessment
represent
only
a
portion
of
the
benefits
associated
with
this
rule,
as
inadequate
information
is
available
to
measure
many
of
the
potential
human
health
and
ecological
benefits
of
the
rule.
IEc
Draft:
May
2005
5
OMB
guidance
recommends
that
federal
agencies
conduct
probabilistic
assessments
of
the
benefits
associated
with
new
regulation.
Office
of
Management
and
Budget.
Informing
Regulatory
Decisions:
2003
Report
to
Congress
on
the
Costs
and
Benefits
of
Federal
Regulations
and
Unfunded
Mandates
on
State,
Local,
and
Tribal
Entities.
2003.

6
"
Human
Health
and
Ecological
Risk
Assessment
Support
to
the
Development
of
Technical
Standards
for
Emissions
from
Combustion
Units
Burning
Hazardous
Wastes:
Background
Document
­
Final
Report,"
November
1998.

7
The
Agency
expects
that
hazardous
waste­
burning
kilns
that
are
able
to
use
feed
control
to
achieve
emissions
reductions
will
also
generate
cement
kiln
dust
(
CKD)
with
a
lower
toxicity
than
prior
to
feed
control
(
in
particular,
lower
SVM
content)
(
USEPA
"
Selection
of
MACT
Standards
and
Technology,"
Chapter
12
of
Volume
3
Technical
Support
Document
for
HWC
MACT
Standards,
July
1999.)
The
risk
assessment
did
not
address
the
potential
human
health
and
ecological
benefits
associated
with
reduced
toxicity
CKD.

8
A
less
detailed
screening­
level
analysis
was
used
in
the
1999
Assessment
to
identify
the
potential
for
ecological
risks.

9
For
a
more
detailed
discussion
of
the
land
use
characterization,
see:
Zachary
Pekar
and
Tony
Marimpietri,

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

6­
4
The
benefits
estimates
in
this
assessment
are
presented
as
point
estimates
rather
than
in
probabilistic
terms.
5
Although
probabilistic
estimates
would
provide
valuable
information
about
the
uncertainty
associated
with
the
benefits
of
the
HWC
MACT
replacement
standards,
probabilistic
analysis
was
not
amenable
to
our
methodology,
as
the
1999
Assessment
did
not
express
benefits
in
probabilistic
terms.
In
certain
cases,
however,
we
present
monetized
estimates
as
a
range
to
reflect
uncertainty
in
the
value
of
avoided
adverse
health
impacts.

RISK
ASSESSMENT
OVERVIEW
The
basis
for
the
benefits
analysis
in
the
1999
Assessment
was
a
multiple­
pathway
risk
assessment
developed
by
the
Economics,
Methods
and
Risk
Analysis
Division
in
EPA's
Office
of
Solid
Waste.
This
risk
assessment
was
designed
to
estimate
baseline
risks
from
hazardous
waste
combustion
emissions,
as
well
as
expected
risks
after
the
1999
MACT
standards
were
implemented.
6
This
section
provides
an
overview
of
the
risk
assessment,
which
analyzed
both
human
health
and
ecological
risks
that
result
from
direct
and
indirect
exposure
to
emissions
from
facilities
that
burn
hazardous
waste.
7
As
part
of
this
effort,
EPA
conducted
a
multiple
pathway
analysis
modeling
both
inhalation
and
ingestion
pathways
was
used
to
estimate
human
health
risks.
8
The
risk
assessment
used
a
statistically­
based
stratified
random
sampling
approach
in
which
76
hazardous
waste
combustion
facilities
and
their
site­
specific
land
uses
and
environmental
conditions
were
characterized.
9
The
facilities
randomly
selected
for
the
study
included:
43
on­
site
incinerators,
13
IEc
Draft:
May
2005
10
According
to
the
risk
assessment,
the
random
sample
of
65
facilities
ensures
that
the
probability
of
modeling
at
least
one
high­
risk
facility
is
90
percent.
The
other
11
combustion
facilities
were
selected
for
the
risk
assessment
at
Proposal.
Because
these
11
facilities
were
not
selected
at
random,
they
are
handled
differently
than
the
65
randomly
selected
facilities
in
extrapolating
risks
to
reflect
the
universe
of
facilities.

11
PM
is
not
evaluated
in
the
screening
for
ecological
risks.
Also,
the
national
risk
assessment
did
not
include
an
assessment
of
the
risk
posed
by
non­
dioxin
products
of
incomplete
combustion
(
PICs)
due
to
the
lack
of
sufficient
emission
measurements.

12
Includes
divalent
mercury
(
via
ingestion),
elemental
mercury
(
via
inhalation),
and
methylmercury
(
via
ingestion).
We
recognize
that
these
chemicals
are
not
all
HAPs;
however,
the
risk
assessment
analyzed
all
chemical
constituents
covered
by
the
rule
for
which
sufficient
data
were
available.
Both
chromium
(
III)
and
chromium
(
VI)
were
evaluated
in
the
risk
assessment.

13
The
methodology
used
to
develop
the
eco­
toxicological
criteria
is
largely
a
product
of
the
ecological
risk
assessment
work
conducted
to
support
the
development
of
the
Hazardous
Waste
Identification
Rule
for
process
waste.

6­
5
commercial
incinerators,
15
cement
kilns,
and
five
lightweight
aggregate
kilns.
10
The
current
Assessment
adjusts
the
estimates
from
the
1999
Assessment
to
project
the
human
health
benefits
of
the
replacement
standards.

The
risk
assessment
evaluated
health
impacts
associated
with
dioxins
and
furans,
selected
metals,
and
PM.
11
The
selected
metals
modeled
in
the
risk
assessment
included
the
following:
antimony,
arsenic,
barium,
beryllium,
cadmium,
chromium
copper,
cobalt,
lead,
manganese,
mercury,
nickel,
selenium,
silver,
and
thallium.
12
The
risk
assessment
modeled
the
fate
and
transport
of
the
emissions
of
these
pollutants
to
estimate
concentrations
in
soils,
air,
surface
waters,
and
sediments.
To
assess
human
health
risks,
concentrations
of
each
pollutant
were
converted
to
estimated
doses
for
exposed
populations
using
exposure
factors
such
as
inhalation
and
ingestion
rates.
The
risk
assessment
calculated
cancer
and
non­
cancer
risks
using
these
doses,
if
the
appropriate
health
benchmarks
were
available.

This
Assessment
compares
the
ecological
benefits
that
may
be
associated
with
the
replacement
standards
with
those
achieved
under
the
1999
Standards,
largely
based
on
differences
in
the
emissions
reductions
achieved
under
each
set
of
regulations.
In
the
1999
Assessment,
soil,
surface
water
and
sediment
concentrations
were
compared
to
eco­
toxicological
criteria
representing
protective
threshold
values
to
assess
potential
ecological
risks.
13
Because
these
criteria
were
based
on
de
minimis
ecological
effects
and
thus
represented
conservative
values,
an
exceedence
of
the
ecotoxicological
criteria
did
not
necessarily
indicate
ecological
damage;
it
simply
suggested
that
potential
damages
could
not
be
ruled
out.

To
characterize
the
non­
cancer
risks
to
the
populations
listed
above,
the
1999
risk
assessment
divided
the
area
surrounding
each
modeled
combustion
facility
into
16
polar
grid
zones,
as
illustrated
IEc
Draft:
May
2005
6­
6
Exhibit
6­
1
DIAGRAM
OF
16
SECTOR
POLAR­
BASED
GRID
USED
IN
THE
RISK
ASSESSMENT
Waterbody
(
lake)

One
of
16
sectors
U.
S.
Census
Block
Group
0­
2
km
ring
2­
5
km
ring
5­
10
km
ring
10­
20
km
ring
in
Exhibit
6­
1.
For
each
zone,
risk
estimates
were
developed
for
different
age
groups
and
receptor
populations
(
e.
g.,
0­
5
year­
old
children
of
subsistence
fishers).
This
approach
was
used
because
of
geographic
and
demographic
differences
across
polar
grid
zones.
Thus,
individual
risk
results
were
aggregated
across
the
16
zones
associated
with
each
facility
and
weighted
by
the
population
of
each
zone
to
estimate
risk
for
individuals
in
the
affected
area.
An
additional
Monte
Carlo
analysis
was
conducted
to
incorporate
variability
in
exposure
factors
such
as
inhalation
and
ingestion
rates.

HUMAN
HEALTH
BENEFITS
This
section
describes
in
greater
detail
our
approach
for
characterizing
human
health
benefits
associated
with
the
HWC
MACT
replacement
standards.
Based
on
the
results
of
the
1999
Assessment,
we
identify
those
pollutants
for
which
emission
reductions
are
expected
to
improve
human
health
or
the
environment.
We
then
summarize
the
relevant
results
from
the
risk
assessment
for
the
pollutants
of
concern,
expressing
results
in
terms
of
the
avoided
incidence
of
each
health
endpoint.
Where
possible,
we
assign
monetary
values
to
these
benefits
through
benefits
transfer.

Our
methods
for
assessing
the
human
health
benefits
of
the
HWC
MACT
replacement
standards
vary
by
health
endpoint.
To
simplify
this
discussion,
we
divide
our
description
of
methods
into
two
sections
 
one
focusing
on
benefits
from
cancer
risk
reductions
and
another
focusing
on
IEc
Draft:
May
2005
14
Cancer
incidence
estimates
were
based
on
direct
and
indirect
exposure
pathways
for
all
non­
subsistence
receptors,
excluding
recreational
anglers.
Population
risks
could
not
be
calculated
for
recreational
anglers
because
detailed
population
data
were
not
available
for
this
receptor
population.

6­
7
benefits
from
non­
cancer
risk
reductions.
We
divide
the
discussion
in
this
way
because
the
interpretation
of
risk
reductions
for
carcinogenic
pollutants
is
different
than
the
interpretation
of
benefits
associated
with
other
pollutants.
As
explained
above,
for
both
cancer
and
non­
cancer
benefits,
we
focus
on
population
risks
because
these
results
form
the
basis
for
assessing
the
total
benefits
of
the
HWC
MACT
replacement
standards.
In
general,
these
results
encompass
the
entire
population,
although
risk
reductions
for
some
pollutants,
such
as
lead,
only
affect
children.
In
these
cases,
we
focus
our
analysis
on
individuals
19
years
of
age
and
younger.

Approach
for
Assessing
Benefits
from
Cancer
Risk
Reductions
Our
approach
for
evaluating
cancer
risk
reductions
varies
by
pollutant.
For
dioxin,
we
extrapolate
from
results
presented
in
the
1999
Assessment,
proportionately
adjusting
the
benefits
estimate
in
the
1999
Assessment
to
reflect
the
emissions
reduction
achieved
under
the
replacement
standards.
To
make
this
proportional
adjustment,
we
assume
a
constant
number
of
avoided
cancer
cases
per
gram
of
reduced
dioxin
emissions.
This
adjustment
can
be
expressed
as
follows:

B
c,
replacement=(
E
dioxin,
replacement/
E
dioxin,
1999)
x
B
c,
1999
where
B
c,
replacement
=
Cancer­
related
benefits
under
the
replacement
standards,
E
dioxin,
replacement
=
Reduction
in
dioxin
emissions
under
the
replacement
standards,
E
dioxin,
1999
=
Reduction
in
dioxin
emissions
under
the
1999
Standards,
and
B
c,
1999
=
Cancer­
related
benefits
under
the
1999
Standards.

For
other
carcinogenic
pollutants,
adequate
data
were
not
available
to
extrapolate
from
results
presented
in
the
1999
Assessment.
To
characterize
reductions
in
cancer
risk
for
these
pollutants,
we
review
results
from
the
1999
Assessment
and
describe
how
cancer
risk
reductions
for
these
pollutants
may
be
different
under
the
replacement
standards.

Summary
of
Cancer
Risk
Analysis
in
the
1999
Assessment
The
1999
Assessment
used
a
two­
tiered
approach
for
assessing
benefits
associated
with
reduced
cancer
risk.
First,
the
risk
assessment
estimated
cancer
risk
reductions
for
all
non­
subsistence
receptors
in
the
vicinity
of
each
combustion
facility.
These
risk
reduction
estimates
were
derived
from
median
individual
risk
values
and
population
data
for
the
non­
subsistence
population.
14
Carcinogens
in
the
risk
assessment
included
dioxins/
furans,
arsenic,
beryllium,
cadmium,
chromium
(
VI),
and
nickel.
For
the
second
tier
of
the
analysis,
the
risk
assessment
estimated
cancer
risk
IEc
Draft:
May
2005
15
In
a
December
30,
1997
benefits
methodology
memorandum,
we
noted
that
summing
these
estimates
may
pose
the
potential
for
double­
counting,
considering
that
dioxin­
contaminated
food
ingestion
is
also
evaluated
on
the
local
level
(
Industrial
Economics,
Incorporated,
Social
Science
Discussion
Group.
Handbook
for
Non­
Cancer
Valuation:
Draft.
Prepared
for
U.
S.
EPA,
1997,
as
cited
in
U.
S.
EPA,
Assessment
of
the
Potential
Costs,
Benefits,
and
Other
Impacts
of
the
Hazardous
Waste
Combustion
MACT
Standards:
Final
Rule,
Office
of
Solid
Waste,
July
1999).
However,
if
we
make
the
assumption
that
most
of
the
agriculture
products
produced
within
20
kilometers
of
the
facility
are
consumed
outside
the
local
area,
we
then
minimize
the
double­
counting
potential.
A
follow­
up
phone
call
with
EPA
and
Research
Triangle
Institute,
the
contractor
that
prepared
the
Combustion
Risk
Assessment,
confirmed
that
this
in
fact
is
a
reasonable
assumption.

16
The
benefits
discussion
that
follows
in
the
rest
of
this
paragraph
is
adapted
from
EPA,
Regulatory
Impact
Analysis
of
the
Final
Industrial
Boilers
and
Process
Heaters
NESHAP:
Final
Report,
February
2004.

6­
8
reductions
associated
with
the
ingestion
of
dioxin­
contaminated
foods
grown
or
raised
near
combustion
facilities
but
distributed
nationwide.
The
risk
assessment
then
calculated
total
cancer
risk
reductions
by
summing
the
avoided
cancer
cases
estimated
for
each
tier
of
the
analysis.
15
That
is,

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

Approach
for
Assessing
Benefits
from
Non­
Cancer
Risk
Reductions
Similar
to
our
analysis
of
reduced
cancer
risk,
our
analysis
of
reduced
risk
for
other
health
effects
varies
by
pollutant.
For
particulate
matter,
we
estimate
benefits
associated
with
avoided
morbidity
and
mortality
impacts
based
on
PM
emissions
reductions
expected
under
the
HWC
MACT
replacement
standards
and
the
results
of
the
1999
Assessment.
For
lead
and
mercury,
sufficient
data
was
not
available
to
extrapolate
results
from
the
1999
Assessment.
To
evaluate
reduced
health
risks
associated
with
these
pollutants,
we
review
the
results
from
the
1999
Assessment
and
describe
in
qualitative
terms
how
such
risks
may
be
different
under
the
replacement
standards.

Benefits
from
Reduced
Exposure
to
Particulate
Matter
Epidemiological
studies
have
linked
PM
(
alone
or
in
combination
with
other
air
pollutants)
to
a
series
of
adverse
health
effects.
16
PM
can
accumulate
in
the
respiratory
system
and
aggravate
health
problems
such
as
asthma,
or
it
can
penetrate
deep
into
the
lungs
and
lead
to
even
more
serious
health
problems.
These
health
effects
include
premature
death,
respiratory
symptoms
and
disease,
diminished
lung
function,
and
weakened
respiratory
tract
defense
mechanisms.
Children,
the
elderly,
and
people
with
cardiopulmonary
disease,
such
as
asthma,
are
most
at
risk
from
these
health
effects.
IEc
Draft:
May
2005
17
U.
S.
EPA,
Regulatory
Impact
Analysis
of
The
Final
Industrial
Boilers
and
Process
Heaters
NESHAP:
Final
Report,
February
2004.

18
U.
S.
EPA,
Final
Regulatory
Impact
Analysis
of
the
Clean
Air
Interstate
Rule,
March
2005.

19
Research
Triangle
Institute,
Human
Health
and
Ecological
Risk
Assessment
Support
to
The
Development
of
Technical
Standards
for
Emissions
from
Combustion
Units
Burning
Hazardous
Wastes:
Background
Document,
prepared
for
U.
S.
EPA,
Office
of
Solid
Waste,
July
1999.

20Pope,
C.
A.
3rd,
M.
J.
Thun,
M.
M.
Namboodiri,
D.
W.
Dockery,
J.
S.
Evans,
F.
E.
Speizer,
and
C.
W.
Heath,
Jr.
1995.
Particulate
air
pollution
as
a
predictor
of
mortality
in
a
prospective
study
of
U.
S.
adults.
American
Journal
of
Respiratory
and
Critical
Care
Medicine,
151:
669­
674,
as
cited
in
Research
Triangle
Institute,
op.
cit.

21
Krewski
D.,
R.
T.
Burnett,
M.
S.
Goldbert,
K.
Hoover,
J.
Siemiatycki,
M.
Jerrett,
M.
Abrahamowicz,
and
W.
H.
White.
2000.
Reanalysis
of
the
Harvard
Six
Cities
Study
and
the
American
Cancer
Society
Study
of
Particulate
Air
Pollution
and
Mortality.
Special
Report
to
the
Health
Effects
Institute,
Cambridge
MA,
July
2000.

22
Pope,
C.
A.,
III,
R.
T.
Burnett,
M.
J.
Thun,
E.
E.
Calle,
D.
Krewski,
K.
Ito,
and
G.
D.
Thurston.
2002.
"
Lung
Cancer,
Cardiopulmonary
Mortality,
and
Long­
term
Exposure
to
Fine
Particulate
Air
Pollution."
Journal
of
the
6­
9
Since
performing
the
risk
assessment
for
the
1999
Assessment,
EPA
has
updated
its
methods
for
evaluating
human
health
benefits
to
reflect
recent
advances
in
air
quality
modeling
and
human
health
benefits
modeling.
To
estimate
PM
exposure
for
the
1999
risk
assessment,
the
Agency
used
the
Industrial
Source
Complex
Model­
Short
Term
Version
3
(
ISCST3).
More
recent
EPA
benefits
analyses
have
used
more
advanced
air­
quality
models.
For
example,
the
Agency's
assessment
of
the
industrial
boilers
and
process
heaters
NESHAP
used
the
Climatological
Regional
Dispersion
Model
(
CRDM),
which
uses
a
national
source­
receptor
matrix
to
estimate
exposure
associated
with
PM
emissions.
17
Similarly,
the
Agency's
analysis
of
the
final
Clean
Air
Interstate
Rule
(
CAIR)
used
the
Community
Multi­
Scale
Air
Quality
Model(
CMAQ),
which
also
accounts
for
the
long­
range
transport
of
particles.
18
In
contrast,
ISCST3
modeled
exposure
only
within
a
20­
kilometer
radius
of
each
emissions
source
for
the
1999
risk
assessment.
19
To
the
extent
that
PM
is
transported
further
than
20
km
from
each
emissions
source,
the
1999
risk
assessment
may
have
underestimated
PM
exposure.
In
addition,
to
estimate
exposure
in
the
1999
risk
assessment,
EPA
used
block­
group
data
from
the
1990
Census.
More
recent
studies
use
data
from
the
2000
Census.

More
recent
EPA
benefits
analyses
also
apply
a
different
concentration­
response
function
for
PM
mortality
than
that
used
for
the
1999
risk
assessment.
In
1999,
EPA
used
the
concentrationresponse
function
published
by
Pope,
et
al.
in
1995.20
Since
that
time,
health
scientists
have
refined
estimates
of
the
concentration­
response
relationship,
and
EPA
has
updated
its
methodology
for
estimating
benefits
to
reflect
these
more
recent
estimates.
In
its
regulatory
impact
analysis
of
the
nonhazardous
boiler
MACT
standards,
EPA
used
the
Krewski,
et
al.
re­
analysis
of
the
1995
Pope
study
to
estimate
avoided
premature
mortality.
21
In
addition,
EPA's
regulatory
impact
analysis
of
the
Clean
Air
Interstate
Rule
applies
the
latest
reanalysis
of
the
cohort
analyzed
in
the
1995
Pope
study
(
Pope,
et
al.,
2002).
22
The
2002
Pope
study
estimates
a
relative
risk
factor
(
1.06)
lower
than
those
estimated
IEc
Draft:
May
2005
American
Medical
Association.
287:
1132­
1141.

23
Work
loss
days
and
minor
restricted
activity
days
do
not
necessarily
affect
a
worker's
income
and
do
not
generally
require
hospitalization.
Both,
however,
result
in
lost
economic
productivity
and
consequently,
a
loss
to
society.

24
To
account
for
the
increase
in
population
since
the
1990
census
was
taken,
we
also
adjusted
the
avoided
incidence
estimates
by
the
ratio
of
the
population
at
the
national
level
(
corresponding
to
the
concentration­
response
function)
for
the
year
2000
census
vs.
the
1990
census.

6­
10
in
the
Krewski
and
1995
Pope
analyses
(
1.18
and
1.17,
respectively).
To
the
extent
that
the
2002
Pope
study
is
more
accurate
than
the
two
earlier
studies,
we
may
over
estimate
the
mortality
benefits
of
the
HWC
MACT
replacement
standards.

To
assess
benefits
from
reduced
exposure
to
particulate
matter
in
1999,
we
first
estimated
the
number
of
excess
mortality
and
morbidity
cases
in
the
baseline
and
under
various
1999
MACT
standard
scenarios.
Morbidity
impacts
included
the
following:


upper
respiratory
symptoms,


lower
respiratory
symptoms,


chronic
bronchitis,


acute
bronchitis,


hospital
admissions
associated
with
cardiovascular
disease,


hospital
admissions
associated
with
respiratory
illness,


work
loss
days,
and

minor
restricted
activity
days
(
MRAD).
23
We
then
subtracted
the
number
of
cases
post­
MACT
from
the
number
of
cases
in
the
baseline
to
determine
potential
avoided
deaths
and
morbidity
impacts.

To
assess
the
benefits
of
the
HWC
MACT
replacement
standards,
we
adjusted
the
avoided
incidence
estimates
from
the
1999
Assessment
to
reflect
PM
emissions
reductions
under
the
replacement
standards
(
incremental
to
the
2002
Interim
Standards)
and
changes
in
the
HWC
MACT
universe
since
the
1999
Assessment
was
completed.
For
cement
kilns,
lightweight
aggregate
kilns,
and
incinerators,
we
multiply
the
1999
benefits
estimate
by
two
factors
specific
to
each
source
category:
an
emissions
factor
and
a
sources
factor.
The
emissions
factor
is
the
ratio
of
the
emissions
reductions
to
be
achieved
under
the
replacement
standards
to
the
emissions
reductions
under
the
1999
Standards.
Similarly,
the
sources
factor
is
the
ratio
of
the
number
of
sources
in
each
category
(
e.
g.,
cement
kilns)
in
2005
and
the
number
of
sources
in
each
category
in
1999.24
For
liquid
boilers,
solid
boilers,
and
hydrochloric
acid
production
furnaces,
we
extrapolated
from
the
1999
incinerator
results
using
a
similar
approach,
except
that
we
used
an
exposed
population
factor
(
i.
e.,
the
ratio
of
the
population
currently
exposed
to
boiler
and
HCl
production
furnace
emissions
to
the
population
IEc
Draft:
May
2005
25
Based
on
the
population
estimated
in
the
1999
Assessment.

26
U.
S.
EPA,
The
Benefits
and
Costs
of
the
Clean
Air
Act,
1970
to
1990,
October
1997.

27
Benefits
estimate
was
converted
to
2002
dollars
using
the
GDP
Deflator.

6­
11
exposed
to
incinerator
emissions
in
1999)
instead
of
a
sources
factor.

We
estimated
the
exposed
populations
for
hazardous
waste­
burning
boilers
and
HCl
production
furnaces
using
the
same
GIS
methods
as
the
1999
Assessment
(
e.
g.,
a
16
sector
overlay).
Nonetheless,
the
extrapolated
estimates
are
subject
to
additional
uncertainty,
especially
for
solid
fuelfired
boilers
and
HCl
production
furnaces
because
they
are
limited
in
number
and
may
be
poorly
represented
by
the
incinerator
facilities
analyzed
in
the
1999
Assessment.

Benefits
from
Reduced
Exposure
to
Lead
The
primary
health
effect
associated
with
chronic
exposure
to
lead
is
damage
to
the
central
nervous
system.
Children
are
particularly
sensitive
to
the
effects
of
lead
and
excess
exposure
can
affect
a
child's
nervous
system
and
cognitive
development.
The
HWC
MACT
replacement
standards
will
reduce
lead
emissions
by
approximately
2.5
tons
per
year
under
the
Agency
Preferred
Approach,
or
less
than
0.01
pounds
per
person,
based
on
the
population
included
in
the
1998
risk
assessment.
25
The
1999
standards
were
expected
to
reduce
lead
emissions
by
89
tons
per
year,
or
0.17
pounds
per
person,
and
were
expected
to
annually
reduce
cumulative
lead
exposures
for
two
to
seven
children
age
0­
5
from
above
to
below
10
µ
g/
dL.
The
annual
benefits
associated
with
the
replacement
standards
are
expected
to
be
more
modest,
reducing
cumulative
lead
exposures
from
above
to
below
10
µ
g/
dL
for
fewer
than
two
to
seven
children
age
0­
5
per
year.

EPA's
retrospective
analysis
of
the
Clean
Air
Act,
Benefits
and
Costs
of
the
Clean
Air
Act,
1970
to
1990,
monetizes
the
benefits
of
reduced
lead
emissions
by
relating
high
blood
lead
levels
with
adverse
IQ
impacts.
26
The
analysis
estimates
annual
benefits
of
approximately
$
41
billion
associated
with
reduced
lead
emissions
of
234,000
tons
per
year.
27
However,
the
relationship
between
reduced
lead
emissions
and
IQ
improvements
is
not
linear,
so
we
cannot
extrapolate
from
these
results
to
estimate
benefits
associated
with
reduced
lead
emissions
under
the
HWC
MACT
replacement
standards.
IEc
Draft:
May
2005
28
The
benefits
discussion
that
follows
in
the
rest
of
this
paragraph
is
adapted
from
EPA,
Regulatory
Impact
Analysis
of
the
Final
Industrial
Boilers
and
Process
Heaters
NESHAP:
Final
Report,
February
2004.
Additional
information
related
to
the
health
effects
associated
with
mercury
are
provided
in
chapter
9
of
this
report.

29
EPA,
Regulatory
Impact
Analysis
of
the
Final
Industrial
Boilers
and
Process
Heaters
NESHAP:
Final
Report,
February
2004.

30U.
S.
EPA,
Regulatory
Impact
Analysis
of
the
Clean
Air
Mercury
Rule:
Final
Report,
March
2005.

6­
12
Benefits
from
Reduced
Exposure
to
Mercury
Reduced
mercury
emissions
under
the
HWC
MACT
replacement
standards
may
generate
a
range
of
human
health
benefits.
28
A
reduction
in
mercury
emissions
is
likely
to
reduce
the
deposition
of
mercury
in
lakes,
rivers,
and
streams,
which
will
subsequently
reduce
bioaccumulation
of
methylmercury
in
fish.
Since
consumption
of
fish
containing
methylmercury
may
cause
adverse
health
effects,
reductions
in
the
bioaccumulation
of
methylmercury
in
fish
could
lead
to
human
health
benefits.

When
humans
consume
fish
containing
methylmercury,
the
ingested
methylmercury
is
absorbed
into
the
blood
and
distributed
to
tissue
throughout
the
body.
In
pregnant
women,
methylmercury
can
be
passed
on
to
developing
fetuses
and
lead
to
a
number
of
neurological
disorders
for
these
unborn
children.
These
disorders
may
lead
to
learning
disabilities
and
developmental
problems
likely
to
adversely
affect
children's
future
earnings
potential.
These
effects
can
occur
at
doses
that
do
not
affect
the
mother.
In
addition,
children
who
consume
fish
containing
methylmercury
may
develop
neurological
disorders
as
well.
A
more
detailed
description
of
the
benefits
associated
with
reduced
mercury
exposure
is
presented
in
EPA's
regulatory
impact
analysis
of
the
non­
hazardous
boiler
MACT
standards
and
in
the
Agency's
regulatory
impact
analysis
of
the
Clean
Air
Mercury
Rule.
29,30
Since
the
numerical
relationship
between
mercury
exposure
and
the
health
effects
described
above
is
highly
uncertain,
we
do
not
quantify
the
benefits
associated
with
reduced
mercury
emissions
under
the
HWC
MACT
replacement
standards.
Instead,
we
present
a
qualitative
discussion
of
the
benefits
that
might
result
from
the
replacement
standards
for
mercury.

Benefits
from
Reduced
Exposure
to
Chlorine
This
analysis
does
not
quantify
the
benefits
associated
with
reductions
in
chlorine
emissions.
The
HWC
MACT
replacement
standards
are
expected
to
reduce
total
chlorine
emissions,
a
combination
of
hydrogen
chloride
(
HCl)
and
chlorine
gas
(
Cl
2)
emissions,
by
approximately
107
to
127
tons
per
year
for
the
Floor
options
and
107
tons
per
year
for
the
Agency
Preferred
Approach
(
Exhibit
6­
3).
Hydrogen
chloride
is
corrosive
to
the
eyes,
skin,
and
mucous
membranes.
Acute
IEc
Draft:
May
2005
6­
13
inhalation
can
cause
eye,
nose,
and
respiratory
tract
irritation
and
inflamation,
and
pulmonary
edema.
Chronic
occupational
inhalation
has
been
reported
to
cause
gastritis,
bronchitis,
and
dermatitis
in
workers.
Long
term
exposure
can
also
cause
dental
discoloration
and
erosion.
No
information
is
available
on
the
reproductive
or
developmental
effects
in
humans.
Chlorine
gas
inhalation
can
cause
bronchitis,
asthma,
swelling
of
the
lungs,
headaches,
heart
disease,
and
meningitis.
Acute
exposure
causes
more
severe
respiratory
and
lung
effects
and
can
result
in
fatalities.
No
information
is
available
on
the
reproductive
or
developmental
effects
in
humans.
The
HWC
MACT
replacement
standards
are
expected
to
reduce
chlorine
exposure
for
people
in
close
proximity
to
hazardous
waste
combustion
facilities,
and
are
therefore
likely
to
reduce
the
risk
of
all
of
these
health
effects
among
those
populations.
However,
without
detailed
exposure
modeling
it
is
not
possible
to
quantify
the
benefits
of
reduced
chlorine
emissions
under
the
HWC
MACT
replacement
standards.

Valuation
of
Human
Health
Benefits
To
measure
the
value
of
the
human
health
benefits
associated
with
the
HWC
MACT
replacement
standards,
we
assign
a
monetary
value
to
avoided
cases
of
each
health
endpoint
included
in
the
risk
assessment.
In
general,
two
types
of
estimates
can
be
used
to
characterize
the
value
of
avoiding
an
adverse
health
impact:
willingness­
to­
pay
(
WTP)
estimates
and
cost­
of­
illness
(
COI)
estimates.
Willingness­
to­
pay
estimates
reflect
the
amount
a
person
is
willing
to
pay
to
avoid
an
adverse
health
effect,
while
cost­
of­
illness
estimates
reflect
the
average
medical
costs
associated
with
the
effect
(
e.
g.,
hospitalization
costs,
pharmaceutical
expenditures,
etc.).
Although
the
two
are
based
on
different
concepts,
they
overlap
with
each
other,
as
a
person's
willingness
to
pay
to
avoid
an
adverse
health
effect
is
likely
to
include
avoided
medical
costs.
For
the
purposes
of
estimating
the
benefits
to
society
of
reducing
the
incidence
of
negative
health
impacts,
WTP
estimates
are
more
appropriate
than
COI
estimates
because
they
reflect
factors
such
as
pain
and
suffering
not
captured
by
cost­
of­
illness
estimates.
For
some
health
effects,
however,
a
willingness­
to­
pay
estimate
is
not
available,
in
which
case
a
cost­
of­
illness
estimate
may
be
used.

It
is
important
to
note
that
WTP
is
likely
to
vary
with
changes
in
income.
As
real
income
rises,
individuals
are
generally
willing
to
pay
more
to
avoid
adverse
health
effects.
Similarly,
if
income
falls,
WTP
is
also
likely
to
decline.
Therefore,
when
using
WTP
estimates
to
assess
the
value
of
avoided
health
impacts,
it
is
important
to
ensure
that
the
WTP
estimates
used
in
the
analysis
are
consistent
with
the
study's
income
assumptions.
IEc
Draft:
May
2005
31
Mrozek,
J.
R.,
and
L.
O.
Taylor.
2002.
"
What
Determines
the
Value
of
Life?
A
Meta­
Analysis."
Journal
of
Policy
Analysis
and
Management
21(
2):
253­
270
and
Viscusi,
V.
K.,
and
J.
E.
Aldy.
2003.
"
The
Value
of
a
Statistical
Life:
A
Critical
Review
of
Market
Estimates
Throughout
the
World."
Journal
of
Risk
and
Uncertainty
27(
1):
5­
76.

32
U.
S.
EPA,
Regulatory
Impact
Analysis
for
the
Final
Clean
Air
Interstate
Rule,
March
2005,
Table
4­
11.

33
The
regulatory
impact
analysis
for
the
Clean
Air
Interstate
Rule
presents
central
VSL
estimates
consistent
with
1990
income
($
5.5
million,
in
1999
dollars)
and
2010
income
($
6.0
million,
in
1999
dollars).
To
estimate
a
central
VSL
value
that
reflects
income
in
2005,
we
interpolate
between
these
two
values,
which
yields
a
VSL
estimate
of
$
5.9
million
(
in
1999
dollars).
Adjusting
for
inflation
with
the
GDP
deflator,
this
estimate
is
$
6.2
million
in
year
2002
dollars.
The
CAIR
RIA
provides
low
and
high
VSL
values
consistent
with
income
in
1990
but
does
not
provide
low
and
high
VSL
values
reflecting
income
projections
for
2010.
We
estimated
these
values
by
assuming
that
the
proportional
relationship
between
the
central,
low,
and
high
VSL
values
remains
constant
as
income
changes.

34
Physician
charges
for
hospital
admissions
come
from
Abt
Associates,
Incorporated,
The
Medical
Costs
of
Five
Illnesses
Related
to
Exposure
to
Pollutants,
Prepared
for
U.
S.
EPA,
Office
of
Pollution
Prevention
and
Toxics,
Washington,
DC,
1992,
as
cited
in
U.
S.
EPA,
Assessment
of
the
Potential
Costs,
Benefits,
and
Other
Impacts
of
the
Hazardous
Waste
Combustion
MACT
Standards:
Final
Rule,
Office
of
Solid
Waste,
July
1999.
Hospital
charge
estimates
for
these
illnesses
are
from
A.
Elixhauser,
R.
M.
Andrews,
and
S.
Fox,
Agency
for
Health
Care
Policy
and
Research
(
AHCPR),
Center
for
General
Health
Services
Intramural
Research,
U.
S.
Department
of
Health
and
Human
Services,
Clinical
Classifications
for
Health
Policy
Research:
Discharge
Statistics
by
Principal
Diagnosis
and
Procedure,
1993,
as
cited
in
U.
S.
EPA,
Assessment
of
the
Potential
Costs,
Benefits,
and
Other
Impacts
of
the
Hazardous
Waste
Combustion
MACT
Standards:
Final
Rule,
Office
of
Solid
Waste,
July
1999.
Estimates
of
the
opportunity
cost
of
time
spent
in
the
hospital
is
from
U.
S.
Environmental
Protection
Agency,
The
Benefits
and
Costs
of
the
Clean
Air
Act,
1970
to
1990,
October
1997,
I11­
I12.

6­
14
To
estimate
the
value
of
avoided
cases
of
premature
mortality
under
the
replacement
standards,
we
apply
central,
low,
and
high
WTP
estimates
of
the
value
of
a
statistical
life
(
VSL)
derived
from
two
meta­
analyses
of
the
wage­
risk
VSL
literature.
31
As
indicated
in
the
regulatory
impact
analysis
for
the
Clean
Air
Interstate
Rule
(
CAIR),
these
studies
support
a
95
percent
confidence
interval
ranging
from
$
1
million
to
$
10
million,
with
a
mean
value
of
$
5.5
million
(
all
values
expressed
in
1999
dollars
and
assume
1990
income
levels).
32
To
express
mortality
benefits
in
2002
dollars,
consistent
with
the
cost
estimates
presented
in
Chapter
5,
we
adjust
these
values
to
year
2002
dollars
using
the
GDP
deflator.
In
addition,
because
these
values
reflect
per
capita
income
in
1990,
we
adjust
them
upward
to
reflect
income
in
2005.
These
adjustments
yield
a
central
VSL
value
of
$
6.2
million
(
in
year
2002
dollars)
and
low
and
high
values
of
$
1.1
million
and
$
11.4
million
respectively.
33
To
value
the
mortality
risk
reductions,
we
multiply
the
expected
number
of
avoided
mortality
cases
by
these
central,
low,
and
high
VSL
values.

We
apply
a
similar
approach
to
estimating
the
value
of
avoided
morbidity
impacts.
For
each
of
these
health
effects,
we
multiply
the
expected
number
of
avoided
cases
by
the
corresponding
WTP
or
COI
value.
For
six
of
the
nine
morbidity
effects
included
in
the
risk
assessment,
we
use
WTP
estimates
derived
from
various
sources.
For
acute
bronchitis
and
hospital
admissions
related
to
cardiovascular
disease
or
respiratory
illness,
however,
we
use
COI
estimates.
For
hospital
admissions,
these
estimates
reflect
hospital
charges,
the
costs
of
associated
physician
care,
and
the
opportunity
cost
of
time
spent
in
the
hospital.
34
Because
COI
estimates
do
not
reflect
the
pain
and
suffering
of
the
afflicted
individuals,
these
estimates
may
understate
benefits
associated
with
avoided
IEc
Draft:
May
2005
6­
15
hospital
admissions.
Exhibit
6­
2
summarizes
the
values
associated
with
each
health
endpoint.

Exhibit
6­
2
AVOIDED
COST
OF
CASES
ASSOCIATED
WITH
PM
Illness
Estimated
Cost
Per
Incidence
(
2002
$)

Premature
mortality1
Low:
$
1.1
million
Central:
$
6.2
million
High:
$
11.4
million
Respiratory
illness
hospital
admissions2
$
9,011
Upper
respiratory
symptoms3
$
27
Lower
respiratory
symptoms3
$
18
Chronic
bronchitis4
$
393,530
Acute
bronchitis3
$
419
Cardiovascular
disease
hospital
admissions2
$
15,018
Work
loss
days
(
cost
per
day)
5
$
137
Minor
restricted
activity
days
(
cost
per
day)
4
$
56
Sources:
1
Mrozek,
J.
R.,
and
L.
O.
Taylor.
2002.
"
What
Determines
the
Value
of
Life?
A
Meta­
Analysis."
Journal
of
Policy
Analysis
and
Management
21(
2):
253­
270
and
Viscusi,
V.
K.,
and
J.
E.
Aldy.
2003.
"
The
Value
of
a
Statistical
Life:
A
Critical
Review
of
Market
Estimates
Throughout
the
World."
Journal
of
Risk
and
Uncertainty
27(
1):
5­
76
as
cited
in
U.
S.
EPA,
Regulatory
Impact
Analysis
for
the
Final
Clean
Air
Interstate
Rule,
March
2005.
Estimate
adjusted
to
reflect
2005
income.
2
U.
S.
Environmental
Protection
Agency,
The
Benefits
and
Costs
of
the
Clean
Air
Act,
1970
to
1990,
October
1997,
I11­
I12;
Abt
Associates,
Incorporated,
The
Medical
Costs
of
Five
Illnesses
Related
to
Exposure
to
Pollutants,
Prepared
for
U.
S.
EPA,
Office
of
Pollution
Prevention
and
Toxics,
Washington,
DC,
1992,
as
cited
in
U.
S.
EPA,
Assessment
of
the
Potential
Costs,
Benefits,
and
Other
Impacts
of
the
Hazardous
Waste
Combustion
MACT
Standards:
Final
Rule,
Office
of
Solid
Waste,
July
1999;
A.
Elixhauser,
R.
M.
Andrews,
and
S.
Fox,
Agency
for
Health
Care
Policy
and
Research
(
AHCPR),
Center
for
General
Health
Services
Intramural
Research,
U.
S.
Department
of
Health
and
Human
Services,
Clinical
Classifications
for
Health
Policy
Research:
Discharge
Statistics
by
Principal
Diagnosis
and
Procedure,
1993,
as
cited
in
U.
S.
EPA,
Assessment
of
the
Potential
Costs,
Benefits,
and
Other
Impacts
of
the
Hazardous
Waste
Combustion
MACT
Standards:
Final
Rule,
Office
of
Solid
Waste,
July
1999..
3
Neumann,
J.
E.,
M.
T.
Dickie,
and
R.
E.
Unsworth.
1994.
Industrial
Economics,
Incorporated.
Memorandum
to
Jim
DeMocker,
U.
S.
EPA,
Office
of
Air
and
Radiation.
Linkage
Between
Health
Effects
Estimation
and
Morbidity
Valuation
in
the
Section
812
Analysis
­­
Draft
Valuation
Document.
March
31,
as
cited
in
U.
S.
EPA,
Regulatory
Impact
Analysis
for
the
Final
Clean
Air
Interstate
Rule,
March
2005.
Estimate
adjusted
to
reflect
2005
income.
4
Derived
from
Viscusi,
W.
K.,
W.
A.
Magat,
and
J.
Huber.
1991.
"
Pricing
Environmental
Health
Risks:
Survey
Assessments
of
Risk­
Risk
and
Risk­
Dollar
Trade­
Offs
for
Chronic
Bronchitis."
Journal
of
Environmental
Economics
and
Management
21:
32­
51
as
cited
in
U.
S.
EPA,
Regulatory
Impact
Analysis
for
the
Final
Clean
Air
Interstate
Rule,
March
2005.
Estimate
adjusted
to
reflect
2005
income.
5
Estimated
from
results
of
U.
S.
EPA,
Regulatory
Impact
Analysis
for
the
Final
Clean
Air
Interstate
Rule,
March
2005,
which
estimated
$
180
million
(
1999$)
in
benefits
associated
with
1.4
million
avoided
work
loss
days
in
2010.
Note:
Cardiovascular
disease
is
assumed
to
be
Ischemic
heart
disease.
IEc
Draft:
May
2005
35
U.
S.
Environmental
Protection
Agency
Science
Advisory
Board,
EPA­
SAB­
COUNCIL­
ADV­
04­
004,
Review
of
The
Revised
Analytical
Plan
for
EPA's
Second
Prospective
Analysis­
Benefits
and
Costs
of
The
Clean
Air
Act
1990­
2020,
May
2004.

36
Ibid.

6­
16
Many
of
the
values
in
Exhibit
6­
2
are
derived
from
estimates
presented
in
the
1999
Assessment
or
in
EPA's
regulatory
impact
analysis
of
the
Clean
Air
Interstate
Rule.
We
also
considered
several
alternative
values
available
through
the
Environmental
Evaluation
Research
Inventory
(
EVRI),
an
online
database
designed
by
Environment
Canada
in
conjunction
with
EPA
to
assist
policy
analysts
in
benefits
transfer
applications.
EVRI
summarizes
the
findings
of
numerous
studies
examining
the
benefits
of
specific
improvements
in
environmental
quality.
The
summaries
of
several
studies
in
EVRI
provide
alternative
estimates
for
some
of
the
endpoints
presented
in
Exhibit
6­
2.
None
of
these
alternative
values,
however,
were
more
appropriate
than
the
values
listed
in
Exhibit
6­
2.

Valuing
Lagged
Benefits
Most
of
the
mortality
benefits
associated
with
the
HWC
MACT
replacement
standards
may
not
be
realized
immediately
because
of
a
time
lag
between
changes
in
PM
and
dioxin
exposure
and
the
resulting
change
in
the
mortality
rate.
This
lag
is
important
in
our
assessment
of
the
value
of
the
health
benefits
associated
with
the
replacement
standards
because
society
generally
values
benefits
realized
at
present
more
than
benefits
realized
in
the
future.
To
account
for
society's
preference
for
current
benefits
over
future
benefits,
we
discount
benefits
realized
in
the
future,
expressing
all
benefits
estimates
in
consistent,
present
value
terms.
The
selection
of
a
discount
rate
for
estimating
the
present
value
of
future
benefits,
however,
is
a
complex
issue,
as
the
economic
literature
points
to
two
different
approaches
for
measuring
the
social
discount
rate.
Under
the
"
demand­
side"
approach,
the
social
discount
rate
reflects
"
the
sum
of
a
pure
social
rate
of
time
preference
and
an
adjustment
term
reflecting
future
changes
in
the
marginal
utility
of
consumption
(
future
goods
may
be
worth
less
at
the
margin
as
people
get
richer)."
35
Most
estimates
of
the
social
discount
rate
under
the
demand­
side
approach
fall
within
a
range
of
1
to
4
percent.
In
contrast,
the
"
cost­
side"
approach
to
estimating
the
discount
rate
defines
the
social
discount
rate
in
terms
of
the
shadow
price
of
capital,
which
reflects
the
"
real­
world­
tradeoff
between
present
and
future
consumption
implied
by
the
marginal
productivity
of
capital."
36
Estimated
values
of
the
shadow
price
of
capital
vary
but
generally
fall
within
the
range
of
4
to
10
percent.
To
reflect
benefits
under
both
of
these
approaches,
we
present
two
estimates
of
discounted
benefits,
one
based
on
a
3
percent
discount
rate
and
another
based
on
a
7
percent
discount
rate.

Another
important
issue
is
estimating
the
value
of
lagged
mortality
benefits
is
identifying
the
duration
of
the
lag
associated
with
each
pollutant.
For
PM­
induced
mortality,
this
lag
is
highly
uncertain.
For
PM
2.5
the
Health
Effects
Subcommittee
of
EPA's
Science
Advisory
Board
has
recommended
that
until
additional
research
has
been
completed,
EPA
should
assume
a
segmented
lag
structure
according
to
which
30
percent
of
mortality
reductions
occur
during
the
first
year
after
the
reduction
in
PM
2.5
emissions,
50
percent
occur
evenly
from
the
second
through
fifth
years,
and
20
percent
occur
evenly
from
the
sixth
through
twentieth
years
after
the
initial
reduction
in
PM
2.5
IEc
Draft:
May
2005
37
U.
S.
EPA,
Regulatory
Impact
Analysis
for
the
Final
Interstate
Air
Quality
Rule,
March
2005.

38
Jim
Neumann
and
Bob
Unsworth,
Addenda
to
Mortality
Valuation
Methodology,
internal
memorandum
submitted
to
Jim
DeMocker,
September
28,
1993.

39
Because
the
dioxin­
related
benefits
expected
under
the
replacement
standards
are
relatively
small,
the
benefits
associated
with
each
end
of
this
range
round
to
the
same
value.

6­
17
emissions.
37
The
SAB's
recommendation
applies
only
to
PM
2.5
(
i.
e.,
particles
with
a
diameter
of
less
than
2.5
microns),
but
for
the
purposes
of
this
analysis,
we
apply
the
same
lag
structure
to
particles
larger
than
10
microns
in
diameter.

The
lag
associated
with
cancer
deaths
resulting
from
dioxin
exposure
is
also
highly
uncertain.
Based
on
data
presented
in
the
epidemiological
literature,
we
assume
a
21
to
34
year
lag
between
reduced
dioxin
emissions
and
avoided
cancer­
related
mortality.
38
We
estimate
dioxin­
related
benefit
values
consistent
each
end
of
this
range.
39
Human
Health
Benefit
Results
This
section
presents
the
results
of
our
analysis
of
the
human
health
benefits
associated
with
HWC
MACT
replacement
standards.
We
present
results
for
the
Option
A
Floor,
the
Option
C
Floor,
and
the
Option
D
Floor,
as
well
as
for
the
Agency
Preferred
Approach,
which
represents
a
beyondthe
floor
extension
of
the
Option
A
Floor.
We
quantify
benefits
resulting
from
reduced
PM
and
dioxin
emissions,
but
inadequate
information
was
available
to
measure
benefits
associated
with
other
pollutants.
For
lead
and
mercury,
however,
we
discuss
how
the
benefits
of
the
HWC
MACT
replacement
standards
are
likely
to
differ
from
the
benefits
estimates
presented
in
the
1999
Assessment.
We
also
discuss
the
potential
benefits
associated
with
reduced
emissions
of
hydrogen
chloride
and
chlorine
gas.

In
general,
the
1999
standards
resulted
in
greater
emissions
reductions
than
those
expected
under
the
HWC
MACT
replacement
standards
(
Exhibit
6­
3).
This
finding
is
not
surprising
because
most
of
the
emissions
reductions
that
would
have
been
achieved
under
the
1999
Standards
are
achieved
under
the
2002
Interim
Standards,
which
define
the
baseline
of
our
analysis.
Notably,
PM
emissions
reductions
under
the
Option
D
Floor
are
greater
than
the
PM
emissions
reductions
associated
with
the
1999
standards.
Among
the
HWC
MACT
replacement
options,
the
Option
D
Floor
would
yield
the
most
significant
emissions
reductions
and
human
health
benefits.
The
Agency
Preferred
Approach
would
generate
more
significant
emissions
reductions
and
human
health
benefits
than
the
Option
A
Floor
and
the
Option
C
Floor.
IEc
Draft:
May
2005
6­
18
Exhibit
6­
3
ANNUAL
EMISSIONS
REDUCTIONS
FOR
THE
FINAL
HWC
MACT
REPLACEMENT
STANDARDS
Standard
Particulate
Matter
(
tons/
yr)
Mercury
(
tons/
yr)
SVM/
LVM
(
tons/
yr)
Dioxins/
Furans
(
grams/
yr)
Chlorine
(
tons/
yr)
Agency
Preferred
Approach
2,138
0.2
12.3
0.4
107
Option
A
Floor
1,669
0.2
11.5
0.3
107
Option
C
Floor
1,669
0.2
12.0
0.3
107
Option
D
Floor
3,005
0.6
18.6
0.3
127
1999
Standards
2,449
3.9
97.1
28.7
5,132
Source:
EERGC,
Inc.,
April
29,
2005.

A
summary
of
the
quantified
benefits
for
the
Agency
Preferred
Approach
is
presented
in
Exhibit
6­
4.
Exhibits
6­
5
and
6­
6
summarize
benefits
under
the
Option
A
Floor,
the
Option
C
Floor,
and
the
Option
D
Floor.
We
describe
the
results
in
more
detail
below.
IEc
Draft:
May
2005
6­
19
Exhibit
6­
4
HUMAN
HEALTH
BENEFITS
SUMMARY:
BASELINE
TO
AGENCY
PREFERRED
APPROACH
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
0.005
$
0.03
$
0.01­$
0.02c
$
0.00­$
0.01c
($
0.01­$
0.06)
a
($
0.00­$
0.03)
d
($
0.00­$
0.01)
d
TOTAL
HUMAN
HEALTH
BENEFITS
$
6.32
$
5.96
$
5.62
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
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.
This
range
of
monetized
benefits
reflects
a
21­
34
year
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.
IEc
Draft:
May
2005
6­
20
Exhibit
6­
5
HUMAN
HEALTH
BENEFITS
SUMMARY:
REDUCED
INCIDENCE
OF
ADVERSE
HEALTH
EFFECTS
Type
of
Benefit
Agency
Preferred
Approach
Option
A
Floor
Option
C
Floora
Option
D
Floor
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
0.005
0.004
0.004
0.004
Notes:
a.
In
developing
the
HWC
MACT
replacement
standards,
EPA
also
considered
an
Option
B
Floor.
IEc
Draft:
May
2005
6­
21
Exhibit
6­
6
HUMAN
HEALTH
BENEFITS
SUMMARY:
BASELINE
TO
AGENCY
PREFERRED
APPROACH
(
millions
of
2002
dollars)

Option
Option
A
Floor
Option
C
Floor
Option
D
Floor
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)
IEc
Draft:
May
2005
Exhibit
6­
6
HUMAN
HEALTH
BENEFITS
SUMMARY:
BASELINE
TO
AGENCY
PREFERRED
APPROACH
(
millions
of
2002
dollars)

Option
Option
A
Floor
Option
C
Floor
Option
D
Floor
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
6­
22
Dioxin­
related
Health
Benefits
Dioxin­
related
cancer
deathsb
$
0.03
$
0.01
$
0.00­$
0.01c
$
0.03
$
0.01
$
0.00­$
0.01c
$
0.03
$
0.01
$
0.00­$
0.01c
($
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
($
0.00­$
0.05)
d
($
0.00­$
0.03)
d
($
0.00­$
0.01)
d
TOTAL
HUMAN
HEALTH
BENEFITS
­
MONETIZED
$
6.27
$
5.92
$
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
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.

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
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
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
levels
in
2005
and
were
adjusted
to
2002
dollars
using
the
GDP
deflator.
IEc
Draft:
May
2005
40
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.

41
We
assume
that
this
lag
period
is
approximately
21
to
34
years,
consistent
with
estimates
presented
in
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.

42
U.
S.
EPA,
Exposure
and
Human
Health
Reassessment
of
2,3,7,8­
Tetrachlorodibenzo­
p­
Dioxin
(
TCDD)
and
Related
Compounds:
NAS
Review
Draft,
December
2003.
Note:
Toxicity
risk
factors
presented
in
this
document
should
not
be
considered
EPA's
official
estimate
of
dioxin
toxicity,
but
rather
reflect
EPA's
ongoing
effort
to
reevaluate
dioxin
toxicity.

6­
23
Benefits
from
Cancer
Risk
Reductions
Dioxin
­
Approximately
0.005
cancer­
related
deaths
per
year
are
expected
to
be
avoided
under
the
Agency
Preferred
Approach.
The
three
floor
options
included
in
this
analysis
would
reduce
the
incidence
of
cancer­
related
mortality
by
approximately
0.004
cases
per
year.
These
estimates
reflect
a
cancer
risk
slope
factor
of
1.56
x
105
[
mg/
kg/
day]­
1.
This
cancer
slope
factor
is
derived
from
the
Agency's
1985
health
assessment
document
for
polychlorinated
dibenzo­
p­
dioxins
and
represents
an
upper
bound
95th
percentile
confidence
limit
of
the
excess
cancer
risk
from
lifetime
exposure.
40
The
total
value
of
the
avoided
cancer
deaths
under
the
Agency
Preferred
Approach
ranges
from
less
than
$
10,000
per
year
to
approximately
$
60,000
per
year,
depending
on
assumptions
about
the
lag
between
dioxin
exposure
and
the
time
of
avoided
mortality.
41
For
the
past
several
years
EPA
has
been
conducting
a
reassessment
of
the
human
health
risks
associated
with
dioxin
and
dioxin­
like
compounds.
In
October
of
2004,
the
Agency
submitted
its
reassessment
of
dioxin
risk
to
the
National
Academy
of
Sciences
(
NAS)
for
review.
42
Evidence
compiled
from
this
draft
reassessment
indicates
that
the
cancer
risk
associated
with
dioxin/
furans
may
be
six
times
greater
than
the
risk
estimate
EPA
developed
in
1985,
with
an
upper
bound
cancer
risk
slope
factor
of
1
x
106
[
mg/
kg/
day]­
1
for
some
individuals.
Agency
scientists'
more
likely
(
central
tendency)
estimates
suggest
slope
factors
and
risk
factors
approximately
2­
3
times
higher
than
the
1985
estimate
(
i.
e.,
between
3
x
105
[
mg/
kg/
day]­
1
and
5
x
105
[
mg/
kg/
day]­
1),
based
on
the
available
epidemiological
and
animal
cancer
data.
Risks
could
be
as
low
as
zero
for
some
individuals.
The
alternative
upper
bound
cancer
risk
slope
factor
suggests
that
0.03
premature
cancer
deaths
will
be
avoided
under
the
Agency
Preferred
Approach
because
of
reduced
dioxin
emissions.
This
estimate
does
not
reflect
Agency
policy,
as
EPA
is
currently
awaiting
feedback
on
the
alternative
slope
factor
from
the
National
Academy
of
Sciences.
The
dioxin
standards
for
the
Final
Rule
are
based
on
the
1.56
x
105
[
mg/
kg/
day]­
1
slope
factor
developed
in
1985,
not
the
alternative
slope
factor
currently
under
consideration.
IEc
Draft:
May
2005
43
Other
pollutants
were
found
to
pose
negligible
individual
risks
and
are
not
included
in
the
results.

44
Grandjean,
P.,
K.
Murata,
E.
Budtz­
Jorgensen,
and
P.
Weihe.
2004.
"
Autonomic
Activity
in
Methylmercury
Neurotoxicity:
14­
Year
Follow­
Up
of
a
Faroese
Birth
Cohort."
Journal
of
Pediatrics.
144:
169­
76;
Kjellstrom,
T.,
P.

6­
24
Benefits
from
Non­
Cancer
Risk
Reductions
Most
of
the
human
health
benefits
resulting
from
the
HWC
MACT
replacement
standards
are
associated
with
reduced
emissions
of
particulate
matter.
Additional
non­
cancer
benefits
are
also
likely
to
result
from
reduced
emissions
of
lead,
mercury,
and
chlorine,
although
such
benefits
are
not
quantified
in
this
analysis.
43
Annual
non­
discounted,
non­
cancer
health
benefits
are
valued
at
approximately
$
6.24
million
under
the
Option
A
Floor
and
Option
C
Floor,
$
10.23
million
under
the
Option
D
Floor,
and
$
6.29
under
the
Agency
Preferred
Approach.

Particulate
Matter.
The
HWC
MACT
replacement
standards
are
expected
to
reduce
premature
mortality
by
less
than
one
case
per
year
for
all
four
regulatory
options
included
in
this
analysis.
In
addition,
the
Agency
Preferred
Approach
is
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
Agency
Preferred
Approach,
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.
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).

Mercury.
The
HWC
MACT
replacement
standards
are
expected
to
reduce
mercury
emissions
by
approximately
0.25
tons
per
year,
approximately
93
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
replacement
standards.
However,
because
the
reduction
in
mercury
emissions
resulting
from
the
replacement
standards
represents
a
fraction
of
the
reduction
expected
under
the
1999
Standards,
the
mercury­
related
benefits
of
the
replacement
standards
are
likely
to
be
less
than
the
corresponding
benefits
under
the
1999
Standards.

To
characterize
the
benefits
associated
with
reduced
mercury
emissions,
the
1999
Assessment
measured
changes
in
hazard
quotients
for
populations
living
near
hazardous
waste
combustion
facilities.
For
any
given
population,
the
hazard
quotient
is
the
ratio
of
the
actual
level
of
exposure
to
a
safe
level
of
exposure.
A
hazard
quotient
greater
than
one
implies
that
a
population
is
potentially
at
risk.
The
exposure
quotient
analysis
in
the
1999
Assessment
found
that
the
measurable
benefits
of
reduced
mercury
emissions
under
the
1999
Standards
were
likely
to
be
small
because
baseline
exposures
were
relatively
low.
In
addition,
many
of
the
studies
examining
the
adverse
health
effects
of
mercury
are
inconclusive,
although
three
large­
scale
epidemiological
studies
indicate
that
children
of
women
exposed
to
unsafe
levels
of
mercury
during
their
pregnancies
may
experience
hindered
neuro­
development.
44
EPA's
recent
regulatory
impact
analysis
of
the
Clean
Air
Mercury
Rule
IEc
Draft:
May
2005
Kennedy,
S.
Wallis,
A.
Stewart,
L.
Friberg,
B.
Lind,
P.
Witherspoon,
and
C.
Mantell.
1989.
Physical
and
mental
development
of
children
with
prenatal
exposure
to
mercury
from
fish.
Stage
2:
Interviews
and
psychological
tests
at
age
6.
National
Swedish
Environmental
Protection
Board
Report
No.
3642;
Crump,
K.
S.,
T.
Kjellstrom,
A.
M.
Shipp,
A.
Silvers,
and
A.
Stewart.
1998.
"
Influence
of
prenatal
mercury
exposure
upon
scholastic
and
psychological
test
performance:
benchmark
analysis
of
a
New
Zealand
cohort."
Risk
Analysis.
18(
6):
701­
713;
Davidson,
P.
W.,
G.
J.
Myers,
C.
Cox,
C.
Axtell,
C.
Shamlaye,
J.
Sloane­
Reeves,
E.
Cernichiari,
L.
Needham,
A.
Choi,
Y.
Wang,
M.
Berlin,
and
T.
W.
Clarkson.
1998.
"
Effects
of
prenatal
and
postnatal
methylmercury
exposure
from
fish
consumption
on
neurodevelopment:
outcomes
at
66
months
of
age
in
the
Seychelles
Child
Development
Study."
Journal
of
the
American
Medical
Association.
280(
8):
701­
707;
and
Myers,
G.
J.,
P.
W.
Davidson,
C.
Cox,
C.
F.
Shamlaye,
D.
Palumbo,
E.
Cernichiari,
J.
Sloane­
Reeves,
G.
E.
Wilding,
J.
Kost,
L.
S.
Huang,
and
T.
W.
Clarkson.
2003.
"
Prenatal
methylmercury
exposure
from
ocean
fish
consumption
in
the
Seychelles
child
development
study."
Lancet.
361(
9370):
1686­
92.

45
U.
S.
EPA.
Regulatory
Impact
Analysis
of
the
Clean
Air
Mercury
Rule:
Final
Report.
March
2005.

46
The
primary
form
of
lead
exposure
to
children
is
via
ingestion
of
contaminated
soil.

6­
25
summarizes
several
other
adverse
health
effects
that
may
be
linked
to
mercury
and
reviews
the
epidemiological
literature
examining
the
link
between
these
effects
and
exposure
to
mercury.
45
Lead.
The
HWC
MACT
replacement
standards
will
reduce
lead
emissions
by
approximately
2.5
tons
per
year
under
the
Agency
Preferred
Approach.
By
comparison,
the
1999
Standards
would
have
reduced
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.
46
Given
the
relatively
modest
emissions
reductions
associated
with
the
replacement
standards,
the
Final
Rule
is
likely
to
reduce
cumulative
lead
exposure
from
above
to
below
10
µ
g/
dL
for
fewer
than
two
to
seven
children
per
year.
The
HWC
MACT
replacement
standards
will
also
result
in
reduced
lead
levels
for
children
in
subpopulations
with
especially
high
levels
of
exposure.
For
instance,
children
of
subsistence
fishermen,
commercial
beef
farmers,
and
commercial
dairy
farmers
who
face
the
greatest
levels
of
cumulative
lead
exposure
are
likely
to
experience
the
most
significant
reductions
in
overall
exposure
as
a
result
of
the
replacement
standards.
The
small
number
of
cases
identified
in
the
1999
Assessment
suggests
that
these
benefits
will
be
small.

Human
Health
Benefits
Summary
As
indicated
in
Exhibit
6­
5,
the
annual
human
health
benefits
associated
with
the
Agency
Preferred
Approach
for
the
HWC
MACT
replacement
standards
include
less
than
one
avoided
premature
mortality,
7.7
avoided
cases
of
chronic
bronchitis,
1.7
fewer
hospital
admissions,
nearly
58
avoided
cases
of
lower
or
upper
respiratory
symptoms,
and
approximately
5,760
avoided
work
loss
or
minor
restricted
activity
days.
Nearly
all
of
these
estimated
benefits
result
from
reduced
PM
emissions,
although
a
small
fraction
are
associated
with
reduced
dioxin
emissions.
The
estimated
non­
discounted
value
for
these
benefits
is
approximately
$
6.32
million
per
year.
The
Agency
Preferred
Approach
is
also
likely
to
generate
additional
health
benefits
that
are
not
quantified,
including
benefits
associated
with
reduced
emissions
of
chlorine,
mercury,
semi­
volatile
metals,
and
IEc
Draft:
May
2005
6­
26
low­
volatile
metals.
This
analysis
quantifies
only
the
human
health
benefits
associated
with
reduced
PM
and
dioxin
emissions.

Human
health
benefits
under
the
Option
A
Floor
and
Option
C
Floor
are
similar
to
those
achieved
under
the
Agency
Preferred
Approach.
Both
options
reduce
premature
mortality
by
less
than
one
case
per
year,
result
in
1.7
fewer
hospital
admissions
on
an
annual
basis,
and
reduce
the
incidence
of
new
chronic
bronchitis
cases
by
nearly
7.7
cases
per
year.
The
number
of
avoided
work
loss
and
minor
restricted
activity
days
under
these
two
options
 
5,716
days
 
is
slightly
lower
than
under
the
Agency
Preferred
Approach.
In
monetary
terms,
the
human
health
benefits
of
the
Option
A
and
C
Floors,
$
6.27
million
in
non­
discounted
benefits,
are
slightly
less
than
the
benefits
associated
with
the
Agency
Preferred
Approach.

Human
health
benefits
associated
with
the
Option
D
Floor
are
more
significant
than
the
benefits
under
the
other
three
options.
Benefits
achieved
under
this
option
include
0.75
avoided
premature
mortality
cases
per
year
(
compared
to
0.46
cases
under
the
Agency
Preferred
Approach),
approximately
2.8
fewer
hospital
admissions,
more
than
12.5
avoided
cases
of
chronic
bronchitis,
approximately
95
avoided
cases
of
lower
or
upper
respiratory
symptoms,
and
approximately
9,400
avoided
work
loss
or
minor
restricted
activity
days.
The
total
nondiscounted
value
of
these
human
health
benefits
is
approximately
$
10.26
million,
which
is
approximately
62
percent
greater
than
the
benefits
associated
with
the
Agency
Preferred
Approach.
This
difference
largely
reflects
the
more
significant
reduction
in
PM
emissions
achieved
under
the
Option
D
Floor
relative
to
the
Agency
Preferred
Approach.
As
indicated
in
Exhibit
6­
3,
PM
emissions
would
decline
by
more
than
3,000
tons
per
year
under
the
Option
D
Floor,
while
the
Agency
Preferred
Approach
would
reduce
PM
emissions
by
2,140
tons
per
year.

Exhibit
6­
7
summarizes
the
quanitifiable
human
health
benefits
across
combustion
source
categories
for
the
Agency
Preferred
Approach
and
the
three
Floor
options.
Overall,
most
of
the
human
health
benefits
associated
with
the
replacement
standards
result
from
reduced
PM
emissions
from
liquid
boilers.
This
concentration
of
benefits
among
liquid
boilers
reflects
the
fact
that
nearly
40
percent
of
the
combustion
systems
regulated
by
the
HWC
MACT
replacement
standards
are
liquid
boilers.
The
second
most
numerous
source
category,
on­
site
incinerators,
represent
approximately
35
percent
of
the
HWC
MACT
universe.
Unlike
on­
site
incinerators,
however,
liquid
boilers
are
not
regulated
under
the
2002
Interim
Standards.
Implementing
new
emissions
controls
at
liquid
boilers
is
therefore
more
likely
to
yield
significant
health
benefits
than
additional
control
measures
at
on­
site
incinerators.
IEc
DRAFT:
May
2005
6­
27
Exhibit
6­
7
SUMMARY
OF
BENEFITS
BY
SOURCE
CATEGORY
Type
of
Benefit
Agency
Preferred
Approach
Option
A
Floor
Option
C
Floor
Option
D
Floor
Annual
Reduction
in
Number
of
Cases
Annual
Nondiscounted
Value
(
2002$

millions)
Annual
Reduction
in
Number
of
Cases
Annual
Nondiscounted
Value
(
2002$

millions)
Annual
Reduction
in
Number
of
Cases
Annual
Nondiscounted
Value
(
2002$

millions)
Annual
Reduction
in
Number
of
Cases
Annual
Nondiscounted
Value
(
2002$

millions)

Cement
Kilns/
Human
Health
Benefits
Dioxin­
related
mortalitya
0.000
$
0.00
0.000
$
0.00
0.000
$
0.00
0.000
$
0.00
PM­
related
mortalitya
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
Respiratory
Illness
Hospital
Admissions
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
0.01
$
0.00
Cardiovascular
Disease
Hospital
Adm.
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
0.01
$
0.00
Chronic
Bronchitis
0.01
$
0.00
0.01
$
0.00
0.01
$
0.00
0.07
$
0.03
Acute
Bronchitis
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
0.06
$
0.00
Lower
Respiratory
Symptoms
0.04
$
0.00
0.04
$
0.00
0.04
$
0.00
0.53
$
0.00
Upper
Respiratory
Symptoms
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
0.06
$
0.00
Minor
Restricted
Activity
Days
2.25
$
0.00
2.25
$
0.00
2.25
$
0.00
28.08
$
0.00
Work
Loss
Days
0.27
$
0.00
0.27
$
0.00
0.27
$
0.00
3.37
$
0.00
Subtotal
­
$
0.00
­
$
0.00
­
$
0.00
­
$
0.03
LWAK/
Human
Health
Benefits
Dioxin­
related
mortalitya
0.000
$
0.00
0.000
$
0.00
0.000
$
0.00
0.000
$
0.00
PM­
related
mortalitya
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
Respiratory
Illness
Hospital
Admissions
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
Cardiovascular
Disease
Hospital
Adm.
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
Chronic
Bronchitis
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
Acute
Bronchitis
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
Upper
Respiratory
Symptoms
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
Minor
Restricted
Activity
Days
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
Work
Loss
Days
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
Subtotal
­
$
0.00
­
$
0.00
­
$
0.00
­
$
0.00
IEc
DRAFT:
May
2005
Exhibit
6­
7
SUMMARY
OF
BENEFITS
BY
SOURCE
CATEGORY
Type
of
Benefit
Agency
Preferred
Approach
Option
A
Floor
Option
C
Floor
Option
D
Floor
Annual
Reduction
in
Number
of
Cases
Annual
Nondiscounted
Value
(
2002$

millions)
Annual
Reduction
in
Number
of
Cases
Annual
Nondiscounted
Value
(
2002$

millions)
Annual
Reduction
in
Number
of
Cases
Annual
Nondiscounted
Value
(
2002$

millions)
Annual
Reduction
in
Number
of
Cases
Annual
Nondiscounted
Value
(
2002$

millions)

6­
28
Incinerator/
Human
Health
Benefits
Dioxin­
related
mortalitya
0.003
$
0.02
0.003
$
0.02
0.003
$
0.02
0.003
$
0.02
PM­
related
mortalitya
0.01
$
0.04
0.01
$
0.04
0.01
$
0.04
0.08
$
0.48
Respiratory
Illness
Hospital
Admissions
0.02
$
0.00
0.02
$
0.00
0.02
$
0.00
0.19
$
0.00
Cardiovascular
Disease
Hospital
Adm.
0.01
$
0.00
0.01
$
0.00
0.01
$
0.00
0.09
$
0.00
Chronic
Bronchitis
0.10
$
0.04
0.10
$
0.04
0.10
$
0.04
1.23
$
0.49
Acute
Bronchitis
0.08
$
0.00
0.08
$
0.00
0.08
$
0.00
1.01
$
0.00
Lower
Respiratory
Symptoms
0.74
$
0.00
0.74
$
0.00
0.74
$
0.00
9.00
$
0.00
Upper
Respiratory
Symptoms
0.09
$
0.00
0.09
$
0.00
0.09
$
0.00
1.04
$
0.00
Minor
Restricted
Activity
Days
71.19
$
0.00
71.19
$
0.00
71.19
$
0.00
867.32
$
0.05
Work
Loss
Days
8.55
$
0.00
8.55
$
0.00
8.55
$
0.00
104.11
$
0.01
Subtotal
­
$
0.10
­
$
0.10
­
$
0.10
­
$
1.05
Coal
Boiler/
Human
Health
Benefits
Dioxin­
related
mortalitya
0.000
$
0.00
0.000
$
0.00
0.000
$
0.00
0.000
$
0.00
PM­
related
mortalitya
0.00
$
0.03
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
Respiratory
Illness
Hospital
Admissions
0.01
$
0.00
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
Cardiovascular
Disease
Hospital
Adm.
0.01
$
0.00
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
Chronic
Bronchitis
0.06
$
0.02
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
Acute
Bronchitis
0.05
$
0.00
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
Lower
Respiratory
Symptoms
0.46
$
0.00
0.03
$
0.00
0.03
$
0.00
0.03
$
0.00
Upper
Respiratory
Symptoms
0.05
$
0.00
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
Minor
Restricted
Activity
Days
41.62
$
0.00
3.17
$
0.00
3.17
$
0.00
3.17
$
0.00
Work
Loss
Days
5.00
$
0.00
0.38
$
0.00
0.38
$
0.00
0.38
$
0.00
Subtotal
­
$
0.05
­
$
0.00
­
$
0.00
­
$
0.00
IEc
DRAFT:
May
2005
Exhibit
6­
7
SUMMARY
OF
BENEFITS
BY
SOURCE
CATEGORY
Type
of
Benefit
Agency
Preferred
Approach
Option
A
Floor
Option
C
Floor
Option
D
Floor
Annual
Reduction
in
Number
of
Cases
Annual
Nondiscounted
Value
(
2002$

millions)
Annual
Reduction
in
Number
of
Cases
Annual
Nondiscounted
Value
(
2002$

millions)
Annual
Reduction
in
Number
of
Cases
Annual
Nondiscounted
Value
(
2002$

millions)
Annual
Reduction
in
Number
of
Cases
Annual
Nondiscounted
Value
(
2002$

millions)

6­
29
HCl
Production
Furnace/
Human
Health
Benefits
Dioxin­
related
mortalitya
0.000
$
0.00
0.000
$
0.00
0.000
$
0.00
0.000
$
0.00
PM­
related
mortalitya
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
Respiratory
Illness
Hospital
Admissions
0.00
$
0.00
0.00
$
0.00
0.01
$
0.00
0.00
$
0.00
Cardiovascular
Disease
Hospital
Adm.
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
Chronic
Bronchitis
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
Acute
Bronchitis
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
Upper
Respiratory
Symptoms
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
Minor
Restricted
Activity
Days
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
Work
Loss
Days
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
Subtotal
­
$
0.00
­
$
0.00
­
$
0.00
­
$
0.00
Liquid
Boiler/
Human
Health
Benefits
Dioxin­
related
mortalitya
0.002
$
0.02
0.002
$
0.01
0.002
$
0.01
0.002
$
0.01
PM­
related
mortalitya
0.45
$
2.80
0.45
$
2.80
0.45
$
2.80
0.67
$
4.18
Respiratory
Illness
Hospital
Admissions
1.19
$
0.01
1.19
$
0.01
1.19
$
0.01
1.77
$
0.02
Cardiovascular
Disease
Hospital
Adm.
0.52
$
0.01
0.52
$
0.01
0.52
$
0.01
0.77
$
0.01
Chronic
Bronchitis
7.54
$
2.97
7.54
$
2.97
7.54
$
2.97
11.23
$
4.42
Acute
Bronchitis
5.72
$
0.00
5.72
$
0.00
5.72
$
0.00
8.52
$
0.00
Lower
Respiratory
Symptoms
50.71
$
0.00
50.71
$
0.00
50.71
$
0.00
75.59
$
0.00
Upper
Respiratory
Symptoms
5.88
$
0.00
5.88
$
0.00
5.88
$
0.00
8.77
$
0.00
Minor
Restricted
Activity
Days
5,026.73
$
0.28
5,026.73
$
0.28
5,026.73
$
0.28
7,492.79
$
0.42
Work
Loss
Days
603.40
$
0.08
603.40
$
0.08
603.40
$
0.08
899.43
$
0.12
Subtotal
­
$
6.17
­
$
6.16
­
$
6.16
­
$
9.18
TOTAL
HEAlTH
BENEFITS
­
$
6.32
­
$
6.27
­
$
6.27
­
$
10.26
IEc
DRAFT:
May
2005
Exhibit
6­
7
SUMMARY
OF
BENEFITS
BY
SOURCE
CATEGORY
Type
of
Benefit
Agency
Preferred
Approach
Option
A
Floor
Option
C
Floor
Option
D
Floor
Annual
Reduction
in
Number
of
Cases
Annual
Nondiscounted
Value
(
2002$

millions)
Annual
Reduction
in
Number
of
Cases
Annual
Nondiscounted
Value
(
2002$

millions)
Annual
Reduction
in
Number
of
Cases
Annual
Nondiscounted
Value
(
2002$

millions)
Annual
Reduction
in
Number
of
Cases
Annual
Nondiscounted
Value
(
2002$

millions)

6­
30
Notes:

a.
Avoided
premature
mortality
benefit
estimates
reflect
a
central
VSL
value
of
$
6.2
million.
This
value
is
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.
Our
VSL
estimate
reflects
income
in
2005
and
was
converted
to
2002
dollars
using
the
GDP
deflator.
IEc
DRAFT:
May
2005
47
Chestnut,
L.
and
R.
Rowe.
1989.
"
Economic
Valuation
of
Changes
in
Visibility:
A
State
of
the
Science
Assessment
for
NAPAP,"
as
cited
in
National
Acid
Preparation
Assessment
Program,
Methods
for
Valuing
Acidic
Deposition
and
Air
Pollution
Effects.
NAPAP
State
of
Science
and
State
of
Technology
Report
No.
27,
Part
B.
December,
as
cited
in
Industrial
Economics,
Incorporated,
"
Initial
Review
of
Potential
Benefits
Associated
with
Hazardous
Waste
Combustion
MACT
Standards,"
Memorandum,
prepared
for
U.
S.
EPA,
30
April,
2002.
..

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

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

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

51
Estimates
presented
in
The
Benefits
and
Costs
of
the
Clean
Air
Act
1990
to
2010
were
expressed
in
year
1990
dollars.
We
convert
to
2002
dollars
using
the
GDP
Deflator.

6­
31
VISIBILITY
BENEFITS
Reductions
in
ambient
PM
concentrations
associated
with
reduced
PM
emissions
under
the
HWC
MACT
replacement
standards
will
improve
visibility
in
some
parts
of
the
U.
S.
Research
has
shown
that
individuals
value
visibility
in
the
places
they
live
and
work
and
in
places
where
they
travel
for
recreational
purposes.
To
estimate
the
value
of
recreational
visibility,
Chestnut
and
Row
(
1989)
examined
WTP
for
improved
visibility
in
recreational
settings.
47
In
addition,
Chestnut
and
Dennis
(
1997)
used
data
representative
of
the
Eastern
United
States
from
McClelland
et
al.
(
1991)
to
measure
WTP
for
visibility
in
residential
areas.
48,49
We
generate
high­
end
and
low­
end
estimates
of
visibility
benefits
associated
with
the
HWC
MACT
replacement
standards
using
two
different
methodologies,
each
based
on
results
presented
in
The
Benefits
and
Costs
of
the
Clean
Air
Act
1990
to
2010
(
the
CAA
Prospective
Analysis).
For
the
first
approach,
we
calculated
the
average
visibility
benefits
per
ton
of
reduced
PM
emissions
using
estimates
of
reduced
PM
emissions
(
823,000
tons
in
2000)
and
visibility
improvements
($
2.55
billion,
in
2002
dollars)
presented
in
the
CAA
Prospective
Analysis.
50,51
Assuming
that
the
relationship
between
visibility
benefits
and
PM
emissions
reductions
is
constant,
we
estimated
visibility
benefits
of
$
3,100
per
ton
of
reduced
PM
emissions.
We
then
multiplied
this
value
by
the
emissions
reductions
expected
under
the
HWC
MACT
replacement
standards
to
generate
a
high­
end
estimate
of
the
visibility
benefits
associated
with
the
replacement
standards.
Following
this
approach,
we
IEc
DRAFT:
May
2005
52
Although
no
quantified
analysis
of
the
proximity
of
facilities
to
Class
1
areas
has
been
performed,
facilities
are
distributed
over
a
wide
area
including
Gulf
of
Mexico
Coast,
Great
Lakes,
and
the
Mississippi
which
include
numerous
recreation
areas.
Also,
the
WTP
of
households
for
increases
in
residential
visibility
is
higher
than
their
WTP
for
recreational
visibility.
The
EPA,
in
The
Benefits
and
Costs
of
the
Clean
Air
Act
1990
to
2010,
estimated
the
WTP
per
household
for
residential
visibility
changes
to
be
$
141,
and
$
65
to
$
137
for
recreational
visibility
changes
in
National
Parks
(
depending
on
household
and
park
location).
Thus,
visibility
benefits
are
likely.

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

6­
32
estimated
visibility
benefits
of
$
6.6
million
under
the
Agency
Preferred
Approach,
$
5.2
million
under
the
Option
A
and
C
Floors,
and
$
9.3
million
under
the
Option
D
Floor.

This
approach
has
several
limitations.
First,
the
CAA
Prospective
Analysis
values
recreational
visibility
(
e.
g.,
visibility
for
Class
1
areas,
most
of
which
are
National
Parks).
52
In
this
Assessment
no
quantified
analysis
of
the
proximity
of
facilities
to
Class
I
areas
has
been
performed.
Second,
this
approach
assumes
that
visibility
improvements
are
related
to
direct
PM
emissions
only.
The
CAA
Prospective
Analysis
evaluated
visibility
improvements
associated
with
direct
PM
emissions
and
emissions
of
PM
precursors
(
e.
g.,
NO
x,
and
SO
2).
Because
some
of
the
visibility
improvements
included
in
the
CAA
Prospective
Analysis
result
from
reduced
emissions
of
PM
precursors
rather
than
direct
PM
emissions,
we
more
than
likely
overestimate
the
visibility
improvements
associated
with
a
one­
ton
reduction
in
direct
PM
emissions.
Therefore,
this
approach
may
overestimate
the
visibility
benefits
of
the
HWC
MACT
replacement
standards.

Our
second
approach
is
based
on
the
relationship
between
the
health
benefits
and
visibility
benefits
associated
with
reduced
concentrations
of
ambient
PM.
EPA's
CAA
Prospective
Study
estimates
roughly
$
87
billion
to
$
137
billion
(
2002
dollars)
in
annual
human
health
benefits
resulting
from
reduced
concentrations
of
ambient
PM
under
the
Clean
Air
Act.
53
Similarly,
the
study
also
estimates
that
the
same
air
quality
improvements
would
yield
annual
visibility
benefits
ranging
from
$
2.6
to
$
3.7
billion.
Based
on
these
figures,
we
estimate
a
ratio
of
PM­
related
visibility
benefits
to
PM­
related
health
benefits
of
0.028.
Applying
this
ratio
to
the
estimated
health
benefits
associated
with
the
HWC
MACT
replacement
standards,
we
estimate
that
the
replacement
standards
would
generate
$
176,000
in
visibility
benefits
under
the
Option
A
and
C
Floors,
$
288,000
in
visibility
benefits
under
the
Option
D
Floor,
and
$
177,000
in
visibility
benefits
under
the
Agency
Preferred
Approach.
These
figures
represent
our
low­
end
estimates
of
visibility
benefits
associated
with
the
replacement
standards.
Similar
to
our
first
approach,
this
approach
only
reflects
visibility
improvements
in
Class
I
areas,
and
it
also
does
not
distinguish
between
benefits
associated
with
reduced
PM
emissions
and
benefits
resulting
from
reduced
emissions
of
PM
precursors.
IEc
DRAFT:
May
2005
54
Threatened
and
endangered
species
and/
or
habitats
were
not
included
in
the
analysis.

55
A
description
of
the
eco­
toxicological
criteria
developed
can
be
found
in
"
Description
of
the
SERA
Methodology,"
Memorandum
Prepared
by
Research
Triangle
Institute,
Prepared
for
the
U.
S.
EPA,
20
February
1998.

6­
33
ECOLOGICAL
BENEFITS
This
section
compares
the
ecological
benefits
presented
in
the
1999
Assessment
with
the
potential
benefits
associated
with
the
HWC
MACT
replacement
standards.
Ecological
benefits
derived
in
the
1999
Assessment
were
based
on
a
screening
analysis
for
ecological
risks
that
compared
soil,
surface
water,
and
sediment
concentrations
with
de
minimis
eco­
toxicological
thresholds
for
adverse
ecological
effects.
Because
these
thresholds
represent
conservative
criteria
for
ecological
risk,
concentrations
in
excess
of
the
eco­
toxicological
thresholds
indicate
the
potential
for
adverse
ecological
effects
and
are
not
necessarily
indicative
of
ecological
damages.
For
this
reason,
the
1999
Assessment
discussed
ecological
benefits
in
qualitative
terms.

The
risk
assessment's
basic
approach
for
determining
whether
ecosystems
and/
or
biota
were
potentially
at
risk
consisted
of
five
steps:


First,
the
risk
assessment
identified
susceptible
ecological
receptors.
Because
combustion
facilities
are
located
in
several
states
across
the
country,
ecological
receptors
for
the
screening
analysis
were
chosen
to
represent
relatively
common
species
and
communities
of
wildlife.
54

Second,
the
risk
assessment
developed
receptor­
specific
eco­
toxicological
criteria
that
represent
acceptable
pollutant
concentrations
(
e.
g.,
at
these
levels,
there
is
a
low
potential
for
adverse
ecological
effects).
55

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


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


Finally,
to
estimate
the
potential
for
adverse
ecological
effects
in
the
study
areas,
the
risk
assessment
totaled
the
number
of
polar
grid
zones
(
for
terrestrial
ecosystems)
and
water
bodies
(
from
aquatic
ecosystems)
with
hazard
quotients
exceeding
one.
Exhibit
6­
1
illustrates
how
the
polar
grid
zones
surrounding
each
facility
are
defined.
IEc
DRAFT:
May
2005
56
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.

6­
34
To
assess
potential
ecological
benefits,
the
risk
assessment
compared
the
surface
area
of
land
or
water
bodies
potentially
at
risk
in
the
baseline
to
the
area
of
potentially
at
risk
land
and
water
bodies
under
the
1999
Standards.
The
difference
between
these
numbers
indicated
the
potential
for
ecological
benefits
under
the
1999
Standards.
The
1999
Assessment
did
not
assign
monetary
values
to
these
potential
benefits
because
the
data
supporting
the
1999
Assessment
identified
no
clear
link
between
hazardous
quotients
in
excess
of
eco­
toxicological
thresholds
and
specific
benefit
measures,
such
as
increased
fish
populations,
for
which
benefits
transfer
could
assign
monetary
values.

Ecological
Benefit
Results
The
ecological
benefit
results
presented
in
the
1999
Assessment
reflect
the
decline
in
dioxin
and
metals
emissions
expected
under
the
1999
Standards.
Lead
was
the
only
pollutant
of
concern
for
aquatic
ecosystems,
while
mercury,
dioxin,
and
lead
were
of
concern
for
terrestrial
ecosystems.
The
1999
Assessment
estimated
dioxin
emissions
would
fall
by
29
grams
per
year
under
the
1999
Standards
and
that
annual
metals
emissions
would
decline
by
approximately
100
tons.
Based
on
these
emissions
reductions,
the
1999
Assessment
estimated
that
eco­
toxicological
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
hazardous
quotients
would
fall
below
levels
of
concern
for
115
to
147
square
kilometers
of
land
under
the
1999
standards.
56
Under
the
Agency
Preferred
Approach
for
the
HWC
MACT
replacement
standards,
EPA
anticipates
a
0.40­
gram
reduction
in
dioxin
emissions
and
a
12.5­
ton
reduction
in
metals
emissions.
Because
these
reductions
are
less
than
those
associated
with
the
1999
Standards,
ecological
benefits
under
the
replacement
standards
are
likely
to
be
smaller
than
those
resulting
from
the
1999
Standards.
However,
the
1999
Assessment
did
not
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
replacement
standards.
Because
the
replacement
standards
represent
the
Agency's
first
attempt
to
limit
emissions
of
hazardous
air
pollutants
from
boilers,
ecological
benefits
associated
with
the
replacement
standards
may
be
concentrated
around
these
facilities.
IEc
DRAFT:
May
2005
57
Although
the
primary
pollutants
which
are
detrimental
to
vegetation
aesthetics
and
growth
are
tropospheric
ozone,
sulfur
dioxide,
and
hydrogen
fluoride,
three
pollutants
which
are
not
regulated
in
the
MACT
standards,
some
literature
exists
on
the
relationship
between
metal
deposition
and
vegetation
health
(
Studies
cited
in
U.
S.
EPA.
Mercury
Study
Report
to
Congress,
Volume
VI:
An
Ecological
Assessment
for
Anthropogenic
Mercury
Emissions
in
the
United
States.
December
1997).

58
See,
for
example,
Brown,
T.
C.
et
al.
1989,
Scenic
Beauty
and
Recreation
Value:
Assessing
the
Relationship,
In
J.
Vining,
ed.,
Social
Science
and
Natural
Resources
Recreation
Management,
Westview
Press,
Boulder,
Colorado,
as
cited
in
Industrial
Economics,
Incorporated,
"
Initial
Review
of
Potential
Benefits
Associated
with
Hazardous
Waste
Combustion
MACT
Standards,"
Memorandum,
prepared
for
U.
S.
EPA,
30
April,
2002;
this
work
studies
the
relationship
between
forest
characteristics
and
the
value
of
recreational
participation.
For
estimates
of
the
WTP
of
visitors
and
residents
to
avoid
forest
damage,
also
see
Peterson,
D.
G.
et
al.
1987,
Improving
Accuracy
and
Reducing
Cost
of
Environmental
Benefit
Assessments.
Draft
Report
to
the
US
EPA,
by
Energy
and
Resource
Consultants,
Boulder,
Colorado,
as
cited
in
Industrial
Economics,
Incorporated,
"
Initial
Review
of
Potential
Benefits
Associated
with
Hazardous
Waste
Combustion
MACT
Standards,"
Memorandum,
prepared
for
U.
S.
EPA,
30
April,
2002;
Walsh
et
al.
1990,
Estimating
the
public
benefits
of
protecting
forest
quality,
Journal
of
Forest
Management,
30:
175­
189,
as
cited
in
Industrial
Economics,
Incorporated,
"
Initial
Review
of
Potential
Benefits
Associated
with
Hazardous
Waste
Combustion
MACT
Standards,"
Memorandum,
prepared
for
U.
S.
EPA,
30
April,
2002;
and
Homes
et
al.
1992,
Economic
Valuation
of
Spruce­
Fir
Decline
in
the
Southern
Appalachian
Mountains:
A
comparison
of
Value
Elicitation
Methods.
Presented
at
the
Forestry
and
the
Environment:
Economic
Perspectives
Conference,
March
9­
1,
1992
Jasper,
Alberta,
Canada,
as
cited
in
Industrial
Economics,
Incorporated,
"
Initial
Review
of
Potential
Benefits
Associated
with
Hazardous
Waste
Combustion
MACT
Standards,"
Memorandum,
prepared
for
U.
S.
EPA,
30
April,
2002.

6­
35
It
is
important
to
note
that
reducing
ecological
risk
below
levels
of
concern
indicates
the
potential
for
ecological
improvements.
It
is
not
clear
that
the
HWC
MACT
replacement
standards
would
necessarily
yield
ecological
benefits
in
areas
surrounding
combustion
facilities.

Forest
Health
and
Aesthetics
A
limited
number
of
ecological
studies
indicate
that
emissions
of
mercury,
lead,
and
chlorides
may
damage
the
health
and
visual
appearance
of
plants,
suggesting
that
forest
health
might
be
adversely
affected
by
emissions
of
these
pollutants.
57
Although
it
is
difficult
to
estimate
the
total
value
of
forest
health,
several
studies
have
examined
its
recreational
value.
58
However,
additional
research
is
necessary
to
fully
understand
the
effects
of
HAPs
on
forest
ecosystems.
Therefore,
we
do
not
quantify
the
forest
health
benefits
associated
with
HWC
MACT
replacement
standards
in
this
analysis.

Productivity
to
Agricultural
Land
IEc
DRAFT:
May
2005
59
Vijayan,
R.
and
S.
J.
Bedi.
1989.
"
Effect
of
chlorine
pollution
on
three
fruit
tree
species
at
Ranoli
near
Baroda,
India."
Environmental
Pollution.
57(
2):
97­
102.

60
U.
S.
Environmental
Protection
Agency,
Addendum
to
the
Assessment
of
the
Potential
Costs,
Benefits,
and
Other
Impacts
of
the
Hazardous
Waste
Combustion
MACT
Standards:
Final
Rule,
July
23,
1999.

61
In
the
long­
term,
waste
minimization
may
take
place
as
companies
upgrade
manufacturing
processes.
However,
increased
waste
management
costs
are
only
one
factor
in
these
larger
decisions.
We
therefore
do
not
anticipate
that
the
replacement
standards
would
cause
a
significant
change
in
the
quantity
of
waste
combusted.

6­
36
Hazardous
air
pollutant
emissions
that
cause
structural
and
aesthetic
damage
to
vegetation
may
affect
vegetation's
growth
potential.
Very
few
studies,
however,
have
examined
the
adverse
agricultural
productivity
impacts
of
emissions.
59
Therefore,
the
potential
for
the
HWC
MACT
replacement
standards
to
enhance
agricultural
productivity
is
highly
uncertain.

WASTE
MINIMIZATION
BENEFITS
As
discussed
in
Chapter
5,
commercial
combustion
facilities
will
experience
increased
costs
under
the
replacement
standards.
To
protect
their
profits,
these
facilities
will
have
an
incentive
to
pass
their
additional
costs
on
to
customers
in
the
form
of
higher
combustion
prices.
In
response
to
higher
prices,
waste
generators
will
then
have
an
incentive
to
reduce
the
quantity
of
hazardous
waste
that
they
generate.
In
1999
EPA
conducted
a
waste
minimization
analysis
to
assess
the
potential
waste
minimization
impacts
of
the
1999
Standards.
Based
on
the
results
of
this
analysis,
we
estimated
that
as
much
as
240,000
tons
of
waste
might
be
reallocated
to
waste
minimization
alternatives
in
response
to
higher
combustion
prices.
60
In
addition,
this
study
indicated
that
short­
term
waste
minimization
activity
is
not
sensitive
to
changes
in
combustion
pricing
when
prices
exceed
$
165
per
ton.
Because
current
pricing
is
well
above
this
threshold,
we
do
not
expect
the
short­
term
waste
minimization
impacts
of
the
HWC
MACT
replacement
standards
to
be
significant.
61
Nevertheless,
short­
term
options
for
waste­
minimization
may
be
limited,
it
is
likely
that
over
the
longer
term
(
e.
g.,
as
production
systems
are
updated)
companies
will
continue
to
seek
alternatives
to
expensive
waste­
management
(
e.
g.,
source
reduction).
To
the
extent
that
increases
in
combustion
prices
provide
additional
incentives
to
develop
and
adopt
more
efficient
processes,
the
HWC
MACT
replacement
standards
may
contribute
to
long­
term
waste
minimization
efforts.
However,
we
are
not
able
to
isolate
and
quantify
the
specific
impact
of
the
HWC
MACT
replacement
standards
on
source
reduction
decisions.
Moreover,
an
increase
in
waste
minimization
over
the
long
run
may
result
in
other
benefits
not
captured
in
this
Assessment.
For
example,
waste
generators
that
engage
in
waste
minimization
will
experience
a
reduction
in
their
waste
handling
costs
and
could
also
reduce
the
risk
related
to
waste
spills
and
waste
management.
The
cost
of
implementing
waste
minimization
IEc
DRAFT:
May
2005
6­
37
technology
has
not
been
assessed
in
this
analysis.
These
costs
are
likely
to
at
least
partially
offset
corresponding
benefits.

Exhibit
6­
8
SUMMARY
OF
ANNUAL
BENEFITS
RESULTING
FROM
THE
HWC
MACT
REPLACEMENT
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
Option
A
Floor
$
0.03
$
0.01
$
0.00­$
0.01
Option
A
Floor
to
Agency
Preferred
Approach
(
Option
A
Beyond­
the­
Floor)
c
$
0.00
$
0.00­$
0.00
$
0.00­$
0.00
Baseline
to
Agency
Preferred
Approach
(
Option
A
Beyond­
the­
Floor)
c
$
0.03
$
0.01­$
0.02
$
0.00­$
0.01
Particulate
Matter
­
Avoided
Mortalityb,
d
Baseline
to
Option
A
Floor
$
2.84
$
2.50
$
2.17
Option
A
Floor
to
Agency
Preferred
Approach
(
Option
A
Beyond­
the­
Floor)
c
$
0.02
$
0.02
$
0.02
Baseline
to
Agency
Preferred
Approach
(
Option
A
Beyond­
the­
Floor)
c
$
2.87
$
2.52
$
2.19
Particulate
Matter
­
Avoided
Morbidity
Baseline
to
Option
A
Floor
$
3.40
$
3.40
$
3.40
Option
A
Floor
to
Agency
Preferred
Approach
(
Option
A
Beyond­
the­
Floor)
c
$
0.02
$
0.02
$
0.02
Baseline
to
Agency
Preferred
Approach
(
Option
A
Beyond­
the­
Floor)
c
$
3.43
$
3.43
$
3.43
Human
Health
Subtotal
­
Agency
Preferred
Approach
Incremental
to
the
Baseline
$
6.32
$
5.96d
$
5.62
Visibility
Benefits:

PM­
related
Visibility
Improvements
Baseline
to
Option
A
Floor
$
0.18
­
$
5.18
$
0.18
­
$
5.18
$
0.18
­
$
5.18
Option
A
Floor
to
Agency
Preferred
Approach
(
Option
A
Beyond­
the­
Floor)
c
$
0.00­$
1.45
$
0.00­$
1.45
$
0.00­$
1.45
IEc
DRAFT:
May
2005
Exhibit
6­
8
SUMMARY
OF
ANNUAL
BENEFITS
RESULTING
FROM
THE
HWC
MACT
REPLACEMENT
STANDARDS
Benefit
Category
and
Pollutant
Monetary
Value
(
millions
of
year
2002
dollars)

Non­
discounted
Three
Percent
Discount
Rate
Seven
Percent
Discount
Rate
6­
38
Baseline
to
Agency
Preferred
Approach
(
Option
A
Beyond­
the­
Floor)
c
$
0.18
­
$
6.63
$
0.18
­
$
6.63
$
0.18
­
$
6.63
IEc
DRAFT:
May
2005
Exhibit
6­
8
SUMMARY
OF
ANNUAL
BENEFITS
RESULTING
FROM
THE
HWC
MACT
REPLACEMENT
STANDARDS
Benefit
Category
and
Pollutant
Monetary
Value
(
millions
of
year
2002
dollars)

Non­
discounted
Three
Percent
Discount
Rate
Seven
Percent
Discount
Rate
6­
39
Visibility
Subtotal
­
Agency
Preferred
Approach
Incremental
to
the
Baseline
$
0.18
­
$
6.63
$
0.18
­
$
6.63
$
0.18
­
$
6.63
TOTAL
BENEFITSd
$
6.50
­
$
12.95
$
6.14
­
$
12.59
$
5.79
­
$
12.25
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
Agency
Preferred
Approach
represents
a
beyond­
the­
floor
version
of
the
Option
A
Floor.
d.
Totals
may
not
add
due
to
rounding.

CONCLUSIONS
As
indicated
in
Exhibit
6­
8,
the
Agency
Preferred
Approach
for
the
HWC
MACT
replacement
standards
is
expected
to
result
in
approximately
$
6.32
million
in
annual
human
health
benefits
and
$
177,000
to
$
6.63
million
in
annual
visibility
benefits.
Specific
benefits
associated
with
the
replacement
standards
include
the
following:


Avoided
premature
mortality.
The
Agency
Preferred
Approach
is
expected
to
reduce
premature
mortality
by
approximately
0.46
cases
per
year,
largely
because
of
reduced
particulate
matter
emissions.
A
small
fraction
of
these
benefits
result
from
reduced
cancer
risk
associated
with
dioxin
emissions.


Avoided
Morbidity.
Reduced
PM
emissions
under
the
Agency
Preferred
Approach
are
expected
to
result
in
7.7
avoided
cases
of
chronic
bronchitis,
IEc
DRAFT:
May
2005
6­
40
1.7
avoided
hospital
visits,
and
approximately
5,760
work
loss
and
minor
restricted
activity
days
avoided.


Reduced
risk
for
mercury.
Reduced
mercury
emissions
under
the
HWC
MACT
replacement
standards
may
reduce
the
risk
of
developmental
disorders
in
children.
When
humans
consume
fish
containing
methylmercury,
the
ingested
methylmercury
is
absorbed
into
the
blood
and
distributed
to
tissue
throughout
the
body.
In
pregnant
women,
methylmercury
can
be
passed
on
to
the
developing
fetus,
adversely
affecting
its
neurological
development.
Children
who
directly
consume
fish
with
high
concentrations
of
methylmercury
may
also
develop
neurological
disorders.
Therefore,
to
the
extent
that
the
HWC
MACT
replacement
standards
reduce
methylmercury
concentrations
in
fish,
they
will
also
reduce
developmental
risks
for
children.
Because
the
expected
reduction
in
mercury
emissions
associated
with
the
replacement
standards
is
small
relative
to
total
mercury
emissions
in
the
U.
S.,
we
do
not
expect
these
benefits
to
be
significant.


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


Potential
improvement
in
visibility.
The
visibility
benefits
of
the
HWC
MACT
replacement
standards
are
highly
uncertain.
Based
on
our
high­
end
and
low­
end
analyses,
we
estimate
visibility
benefits
under
the
Agency
Preferred
Approach
ranging
from
$
177,000
to
$
6.6
million.


Potential
ecological
improvements.
Compared
to
the
1999
Standards,
the
replacement
standards
are
likely
to
produce
less
significant
ecological
benefits.
That
is,
fewer
than
38
square
kilometers
of
water,
and
147
square
kilometers
of
terrestrial
areas
are
expected
to
experience
a
reduction
in
potential
ecosystem
risk.


Increased
forest
health
and
aesthetics.
Reduced
emissions
of
mercury,
lead,
and
chlorides
under
the
HWC
MACT
replacement
standards
may
improve
forest
health.
Because
additional
research
is
necessary
to
fully
understand
the
effects
of
these
HAPs
on
forest
ecosystems,
we
do
not
quantify
the
forest
health
benefits
associated
with
the
replacement
standards.
IEc
DRAFT:
May
2005
6­
41

Increased
productivity
of
agricultural
land.
Hazardous
air
pollutant
emissions
that
cause
structural
and
aesthetic
damage
to
vegetation
may
also
affect
vegetation's
growth
potential.
Very
few
studies,
however,
have
examined
the
adverse
agricultural
productivity
impacts
of
HAP
emissions.
Therefore,
the
potential
for
improvements
in
agricultural
productivity
under
the
replacement
standards
is
highly
uncertain.


Waste
minimization
benefits.
The
Agency
Preferred
Approach
is
unlikely
to
result
in
a
significant
increase
in
waste
minimization
in
the
short
run.
Over
time,
however,
facilities
may
develop
and
adopt
production
technologies
that
reduce
the
generation
of
waste.
Because
of
uncertainty
associated
with
the
cost
and
efficiency
of
future
technologies,
we
do
not
quantify
these
long­
term
impacts.

It
is
important
to
emphasize
that
the
monetized
benefits
presented
in
this
chapter
represent
just
a
portion
of
the
total
benefits
associated
with
the
HWC
MACT
replacement
standards.
We
do
not
assign
a
monetary
value
to
the
ecological
benefits
of
the
rule,
and
in
some
locations
these
benefits
may
be
significant.
In
addition,
specific
sub­
populations
near
combustion
facilities,
including
children
and
minority
populations,
may
be
disproportionately
affected
by
environmental
risks
and
may
therefore
enjoy
more
significant
benefits.
Chapter
7
provides
a
more
detail
discussion
of
the
environmental
justice
and
children's
health
implications
of
the
final
rule.
