U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
September 7, 2017
Final Economic Impact Analysis for the National Emission Standards for Hazardous Air Pollutants: Publicly Owned Treatment Works Risk and Technology Review

 Introduction
   This report is the economic impact analysis (EIA) for the final Publicly Owned Treatment Works (POTW) Risk and Technology Review (RTR) standards. These standards further amend the POTW National Emission Standards for Hazardous Air Pollutants (NESHAP) Subpart VVV, which was originally promulgated in October, 1999 (67 FR 57572) and initially amended in October, 2002 (67 FR 64742). These standards set regulations based on the assessed Maximum Achievable Control Technology (MACT) available at the time. Final promulgation of these amended standards as a result of this RTR is scheduled to occur under court order by October 16, 2017. There are estimated to be 13 facilities subject to the POTW NESHAP, which specifies requirements for existing POTW as well as new or reconstructed POTW, with subcategorization for POTW that do ("Group 1") and do not ("Group 2") accept industrial wastewater regulated by another NESHAP. Group 1 POTW can be thought of as acting as a control for the industries they accept NESHAP regulated wastewater from.
   The total costs for this rule is estimated to be $790, which is incurred through facilities familiarizing themselves with the rule. This cost will be incurred in the year following promulgation of the rule. There are no additional emission control costs or additional emission reductions associated with this rule. With the exception of the addition of a requirement for initial notification, the EPA is not finalizing any changes to the requirements for existing Group 1 and Group 2 POTW. In addition, revisions to the requirements for new or reconstructed Group 1 facilities are not anticipated to incur additional costs and there are no revisions for new or reconstructed Group 2 facilities.
   Costs of the Final Rule
   The final rule revises the current standard to establish a requirement that existing Group 1 (2 of the 13 affected entities) and Group 2 POTW (11 of the 13 affected entities) submit an initial notification of applicability to the rule one year after publication of the final rule in the Federal Register. As all 13 facilities have already complied with this requirement and do not need to re-notify the EPA, the only costs for these facilities are those related to familiarizing themselves with the rule amendments. These costs are estimated to be $61 per affected facility, or $790 for all 13 facilities. However, it should be noted that, based on public comment, additional POTW may become subject and incur the cost of an initial notification of applicability to the EPA. This cost is estimated to be $240 per facility.
   Requirements for new or reconstructed Group 1 POTW are revised so that instead of complying with either the applicable NESHAP for which they are acting as control or complying with this rule, whichever is more stringent, they must comply with both rules. However, the EPA does not anticipate that there will be any new Group 1 facilities constructed in the next 3 years, therefore there are no additional costs associated with this revision.
   There are no new practices, processes or control technologies identified for new or reconstructed POTW in the Group 2 subcategory, therefore there are no revisions to those requirements in the current POTW NESHAP. 
   Net employment impacts resulting from this final rule will be negligible. Additionally, there are no significant impacts on a substantial number of small entities (SISNOSE) as a result of this rule. 
   The costs of the final rule encompass only the costs associated with initial familiarization of this rule by the 2 existing Group 1 and 11 existing Group 2 sources. The estimated costs are $61 per source. The nationwide total reporting costs attributable to the affected entities for this rule are therefore estimated to be $790. The recordkeeping and reporting burden for the EPA is estimated to be $0.
 Economic Impact Estimates
   The national economic impact assessments of the rule are insignificant. The one-time cost of $61 per facility is 0.001 percent, or less, of reported sewer service charges in 2015 for each of the affected entities. Therefore, the estimated national economic impacts from the rule are considered to be minimal. 
   EPA estimated the labor necessary to comply with the notification requirement as a result of this rule and converted this number to full-time equivalents (FTEs) by dividing by 2,080 (40 hours per week multiplied by 52 weeks). The one-time labor requirement estimated for complying with the final option is 0.004 FTEs. EPA notes that this type of FTE estimate cannot be used to make assumptions about the specific number of people involved or whether new jobs are created for new employees. This suggests that net employment impacts (that is, all employment impacts of any kind) resulting from this final rule will be negligible. 
   A small business screening analysis was conducted to determine if any of the identified affected entities are small entities, as defined by the U.S. Small Business Administration (SBA). The SBA defines small publicly owned entities as those serving a population of 50,000 or less. As shown in table 1, none of the 13 potentially affected entities are considered small. Therefore, there are no significant impacts on a substantial number of small entities (SISNOSE) from this final rule.
   
   
   
Table 1. Population served by the affected entities (2014)
                                   Facility
           Population of the government entity or population served
Hopewell Regional Waste Water Treatment Facility
                                    67,000
New York City Department of Environmental Protection Coney Island Water Pollution Control Plant
                                  8.5 million
New York City Department of Environmental Protection North River Water Pollution Control Plant
                                  8.5 million
Gulf Coast Waste Disposal Authority Bayport Facility
                                  4.6 million
Gulf Coast Waste Disposal Authority 40-Acre Facility
                                  4.6 million
Gulf Coast Waste Disposal Authority Washburn Tunnel Facility
                                  4.6 million
Milwaukee Metropolitan Sewer District Jones Island Waste Water Treatment Plant
                                  1.1 million
Milwaukee Metropolitan Sewer District South Shore Waste Water Treatment Plant
                                  1.1 million
American Bottoms Regional Waste Water Treatment Facility
                                    67,000
Orange County Sanitation District - Plant 1
                                  2.5 million
Orange County Sanitation District - Plant 2
                                  2.5 million
Albuquerque Southside Water Reclamation Facility
                                    600,000
Omaha Papillion Creek WWTP
                                    450,000

