November 2005 Impacts of Other Solid Waste Incinerator Rule on Affected Small Entities Draft Report Prepared for Gayle Kline ICF Consulting 9300 Lee Highway Fairfax, VA 22031 For delivery to William Nickerson U. S. Environmental Protection Agency Headquarters Office of Policy, Economics, and Innovation Ariel Rios Building 1200 Pennsylvania Avenue, NW Washington, DC 20460 Prepared by Katherine Heller Thomas Holloway Jeff Coburn Alex Rogozhin RTI International Health, Social, and Economics Research Research Triangle Park, NC 27709 EPA Contract Number 68 W 02 045 RTI Project Number 0208687.003.054 EPA Contract Number RTI Project Number 68 W 02 045 0208687.003.054 Impacts of Other Solid Waste Incinerator Rule on Affected Small Entities Draft Report November 2005 Prepared for Gayle Kline ICF Consulting 9300 Lee Highway Fairfax, VA 22031 For delivery to William Nickerson U. S. Environmental Protection Agency Headquarters Office of Policy, Economics, and Innovation Ariel Rios Building 1200 Pennsylvania Avenue, NW Washington, DC 20460 Prepared by Katherine Heller Thomas Holloway Jeff Coburn Alex Rogozhin RTI International* Health, Social, and Economics Research Research Triangle Park, NC 27709 * RTI International is a trade name of Research Triangle Institute. iii CONTENTS Section Page Section 1 Introduction ........................................................................................................ 1 1 1.1 Objective of this Analysis ................................................................................. 1 2 1.2 Organization of this Report ............................................................................... 1 2 Section 2 Identifying OSWI Units and Characterizing their Owners................................... 2 1 2.1 Identifying OSWI Units .................................................................................... 2 1 2.2 Identifying Small and Potentially Small Entities Owning OSWI Units .............. 2 2 Section 3 Estimating Costs Under Alternative Compliance Options ................................... 3 1 3.1 Locating OSWI Units, Rural OSWI, and Landfills............................................ 3 1 3.2 Estimating Costs for Compliance or Switching to Landfilling ........................... 3 1 3.2.1 Estimating Landfill Switching Costs ( Option 1) .................................... 3 2 3.2.2 Estimating Costs of Complying with OSWI Rule ( Option 2) ................. 3 2 3.2.3 Identifying Each OSWI's Cost Minimizing Compliance Option............ 3 3 Section 4 Detailed Examination of Selected OSWI............................................................. 4 1 4.1 Summary of Interview Results .......................................................................... 4 1 4.2 Revision of Costs Based on Interview Results................................................... 4 5 4.3 Summary .......................................................................................................... 4 7 Section 5 Conclusions ........................................................................................................ 5 1 References ........................................................................................................................ R 1 iv Appendixes A: List of OSWI Units.............................................................................................. A 1 B: OSWI Contact List .............................................................................................. B 1 C: Supporting Memoranda........................................................................................ C 1 v LIST OF TABLES Number Page 2 1 Number of OSWI by Owner Category....................................................................... 2 2 2 2 Ownership Size Distribution of OSWI Units.............................................................. 2 3 3 1 Rural Landfills That May Be Eligible for Exemption................................................. 3 1 4 1 OSWI Units to be Contacted to Assess Validity of Estimated Impacts ....................... 4 2 4 2 Revised and Original Data and Cost Estimates .......................................................... 4 3 4 3 Revised and Original Compliance Option Costs and Cost to Revenue Ratio ( CRR)........................................................................................................................ 4 6 4 4 Summary of Projected Impacts .................................................................................. 4 8 1 1 SECTION 1 INTRODUCTION On November 9, 2000, pursuant to the requirements of Section 129 of the Clean Air Act,

EPA published a notice announcing that the Administrator would promulgate new source performance standards ( NSPS) and emission guidelines for Other Solid Waste Incinerators ( OSWIs) by November 15, 2005. Subsequent to that notice, a consent decree requiring that EPA propose regulations for the OSWI source category by November 30, 2004, and promulgate by November 30, 2005 was agreed upon. On December 9, 2004, EPA published proposed rules setting standards for OSWIs for the following pollutants: particulate matter, sulfur dioxide,

hydrogen chloride, oxides of nitrogen, carbon monoxide, lead, cadmium, mercury, and dioxins and dibenzofurans.

In the preamble's discussion of the economic impacts of the rule, EPA estimated that if all of the affected units installed controls to comply with the proposed standards, the cost would be approximately $ 63 million per year. However, EPA concluded that it would be more costeffective for most OSWI units to use an alternative waste disposal method ( landfilling) rather than installing the controls necessary to comply with the proposed standards. EPA noted that the number of OSWI units has declined in recent years because of cheaper alternative disposal methods. EPA conducted an analysis of several model units that determined that switching from incineration to landfilling would actually result in a cost savings for many OSWIs. EPA stated that, because most existing OSWI units would incur no additional cost by switching to landfilling, the economic impacts of the rule are negligible.

On February 7, 2005, the Small Business Administration's Office of Advocacy submitted comments on the proposed rule, stating its concern that the basis for EPA's certification that the rule would not have a significant impact on a substantial number of small entities ( SISNOSE), as required by section 605 ( b) of the RFA, " ignored the proposal's impact on existing incineration units located in small school districts, other small governmental jurisdictions, and small organizations." Specifically, the Office of Advocacy expressed concern regarding EPA's assertion that all affected units would switch to landfilling rather than installing the required controls, incurring negligible, if any, cost. The Office of Advocacy challenged this assertion because it did not believe that EPA had sufficient understanding of the number of affected OSWIs or the number of affected OSWIs that are owned by small entities, and because it did not believe that EPA adequately determined the economic impacts on actual owners of affected units. The Office of Advocacy argued that EPA's cost estimate based on model units ( rather than 1 2 actual units) and national average costs ( rather than locality specific actual costs) did not adequately address whether certain small entities may incur costs.

1.1 Objective of this Analysis To address the data and methodological issues raised by SBA and other commenters to the proposed rule, EPA's Office of Policy Economics and Innovation undertook this analysis,

directing RTI, International ( RTI) to gather information on potential OSWI units currently operating and their owners, estimate their baseline operating costs, identify nearby landfills to which they may send their waste if they stop incinerating it, and estimate the costs of disposing of their waste by landfilling instead of incineration. The cost of continuing to operate the incinerator in compliance with the rule was then estimated, and each OSWI's compliance and landfill costs were compared. EPA assumed that the facilities would then choose to respond to the rule using their lower cost option ( complying with the OSWI rule and continuing to incinerate or shutting down the incinerator and sending the waste to a landfill). To assess the magnitude of the impact on each OSWI's owner, the lower cost of compliance was compared with the owner's baseline revenues. To assess the validity of the analysis conducted using existing data, nine OSWI owned by small entities were contacted and interviewed to determine the accuracy of the data and assumptions. Based on data gathered during these interviews,

estimated costs were re estimated under each compliance option for several of the OSWI, and compared with the costs estimated using existing data.

The investigation generally confirmed the conclusions reached by EPA's analysis at proposal. For each OSWI, the estimated cost of landfilling the waste was less than the estimated cost of complying with the rule. For the vast majority of OSWI units, landfilling offered absolute cost savings. Interviews with OSWI estimated to have high cost to revenue ratios under conservative ( high end) throughput assumptions indicated that the analysis using existing data generally over estimated throughput and thus over estimated costs. After incorporating interview results, no small entities that own OSWI units are projected to incur costs exceeding one percent of revenues.

1.2 Organization of this Report The report presents the results of the analysis in the following sections. Section 2 presents a characterization of existing OSWI units and their owners. Section 3 describes the estimated costs of waste management alternatives: complying with the OSWI rule and continuing to operate the incinerator, or of shutting down the incinerator and sending the waste to a landfill. In addition, Section 3 describes estimated impacts on small entities owning OSWI units. Section 4 1 3 assesses the validity of the analysis by interviewing 9 OSWI units owned by small entities.

Section 5 presents our conclusions. Several appendices provide additional details. 2 1 SECTION 2 IDENTIFYING OSWI UNITS AND CHARACTERIZING THEIR OWNERS The analysis addressed the data issues raised by SBA and other commenters to the proposed rule, by gathering additional information about potentially affected facilities and their owners. The first step was to compile an extensive list of " candidate" OSWI units, then narrow the list to those believed to be currently in operation and in scope for the rule.

2.1 Identifying OSWI Units A list of potential OSWI was compiled by combining data from several sources:

  the OSWI inventory compiled for the proposed rule,

  an updated OSWI inventory provided by OAQPS,

  the National Emissions Inventory Draft 2002 database,

  permits,

  comments on the previous analysis,

  data provided by EPA Regions and States, and   a commercially available database of municipal waste facilities maintained by Chartwell, Inc.

Initially, the inventory included potential OSWI units identified through any of the sources, resulting in a list of approximately 500 potential OSWI. Units were then eliminated if it was learned that they are not currently in operation, or are not in scope for the regulation. The major difference between the inventory presented here and the inventory developed for proposal is due to the removal of units believed to have ceased operation. For example, data from the state of Illinois led us to remove more than 100 of the units that had been in earlier inventories; the evidence that they had shut down was corroborated by their absence from the 2002 NEI. Many other potential OSWI units were identified as human or animal crematories or other types of combustion units not classified as OSWI. Currently, the database for this analysis contains 173 OSWI units believed to be operating and in scope. Table 2 1 shows the ownership distribution of these OSWIs. 2 2 Table 2 1. Number of OSWI by Owner Category Owner Category Number of OSWI Federal 27 State 9 County 10 City 12 School district 48 Commercial 7 Nonprofit 60 Total 173 2.2 Identifying Small and Potentially Small Entities Owning OSWI Units Data from a variety of sources was used to characterize the owners of the OSWI units as small or not small. City and county governments were characterized based on data from the Census of Governments ( 2002). School districts were characterized based on data from the National Center for Education Statistics ( 2005). Commercial and non profit entities were characterized based on data from publicly available sources such as entities' annual reports and from Dun & Bradstreet's commercially available database.

The criteria used to define " small" are those set by the Regulatory Flexibility Act as amended by the Small Business Regulatory Enforcement Fairness Act ( SBREFA); the criteria differ for businesses, governments, and organizations. Business definitions refer to the parent company of any affected OSWI. Small businesses are defined by the Small Business Administration and published in 13 CFR 121.201; the definitions are set by NAICS code and generally depend on the number of employees or company annual receipts. Small governmental jurisdiction is the government of a city, county, town, school district, or special district with a population less than 50,000. Both of these criteria are relatively clear and given adequate data,

straightforward to apply. The definition of " small organization" is " any not for profit enterprise which is independently owned and operated and is not dominant in its field" ( 5 USC 601).

Determining whether an organization is dominant is somewhat ambiguous. To be conservative,

we assume that all the nonprofits are potentially small ( i. e., not dominant) and initially treat all nonprofits as if they were small entities; however, in subsequent steps of the analysis we use estimated cost to revenue ratios to focus on entities with potentially larger impacts. 2 3 Table 2 2 shows the number of OSWI owner entities of each type, and the number that are identified by these criteria as small ( or assumed to be small, in the case of nonprofit organizations). The number of OSWI differ from the number of entities because a single entity can own multiple OSWI. Note that, because all nonprofits are treated as if they are small, more than 60 percent of OSWI are identified as being potentially owned by small entities. Appendix A provides a listing of the 173 OSWI units and indicates whether the owner is a small entity.

Additional information is shown in Appendix C, Memorandum 1.

Table 2 2. Ownership Size Distribution of OSWI Units Owner Category Number of OSWI Number of OSWI Owned by Small or Potentially Small Entitiesa Number of Small or Potentially Small Entitiesa Federal 27 0 0 State 9 0 0 County 10 4 4 City 12 10 10 School district 48 31 27 Commercial 7 3 3 Nonprofita 60 60 48 Total 173 108 92 a All nonprofit organizations are treated as if they are small. 3 1 SECTION 3 ESTIMATING COSTS UNDER ALTERNATIVE COMPLIANCE OPTIONS Section 2, above, describes the identification and characterization of OSWI units that are believed to be operating and covered by the proposed rule. The list of OSWI units, along with a file of solid waste landfills ( from the Chartwell Atlas database), were submitted for GIS processing so they could be mapped to the nearest two landfills using straightline distances. The GIS analysis output results file was then combined with the OSWI and landfill databases to pull in tipping fees and other relevant information.

3.1 Locating OSWI Units, Rural OSWI, and Landfills Each OSWI unit was geo coded to establish its location. Once the OSWI were located,

the metropolitan statistical area ( MSA) closest to each OSWI was identified. Seven Institutional Waste Incinerators ( IWIs) were identified that met the definition of a rural IWI by being more than 50 miles from the border of a metropolitan statistical area ( MSA). These 7 rural IWIs are listed in Table 3 1. Under the provisions of the final rule, these 7 rural IWIs may be able to petition for exemption. These rural OSWI were flagged in the database.

Table 3 1. Rural Landfills That May Be Eligible for Exemption RTI ID Facility Name City State 17 Kirksville College of Osteopathic Medicine Kirksville MO 159 Alpena Comm College Alpena MI 209 Dartmouth College Hanover NH 274 Jeffers High School Painesdale MI 290 Laughlin Air Force Base Del Rio TX 420 University of Alaska Fairbanks AK 432 USAF Clear Clear USA AK For each OSWI in the database, the two nearest landfills in the Chartwell database were identified, and information on their tipping fees was gathered from Chartwell, Inc. These data are shown in Memorandum 2, in Appendix C.

3.2 Estimating Costs for Compliance or Switching to Landfilling For purposes of this analysis, it was assumed that there are two primary compliance options. Option 1 is to switch from incinerating waste to landfilling. Option 2 is to comply with 3 2 the final OSWI rule and continue incinerating. The cost for both options was calculated, and OSWI owners are assumed to choose the lower cost option.

3.2.1 Estimating Landfill Switching Costs ( Option 1)

First, the cost of landfilling waste currently being incinerated was estimated for each OSWI, based on actual throughput data where available, and based on average incinerator capacity when actual throughput data was not reported. Missing data were filled based on reported capacities and operating days. Separate statistics for Very Small Municipal Waste Combustors ( VSMWCs) and IWIs were developed. Using the units that reported throughput data, a lower end capacity estimate was computed using the 10th percentile throughput for each class of incinerator ( VSMWCs and IWIs), a midrange capacity estimate using the arithmetic average throughput, and an upper end capacity estimate using the 90th percentile throughput.

To compute transportation cost to the landfills, a hauling fee of $ 0.50/ ton/ mile ( Heimlich,

2005) was assumed. Using the throughput estimates, reported tipping fee from the Chartwell database, and the estimated hauling fee, the estimated disposal cost for the closest and second closest landfills was calculated. Landfill distances and tipping fees were based on site specific data for each OSWI ( see Appendix C, Memorandum 2, Table 3). We selected the lower of these land disposal costs as the landfill cost ( see Appendix C, Memorandum 3, Table 4).

EPA had estimated at proposal that landfilling would often represent absolute cost savings relative to baseline incinerator costs. To test this assertion, baseline incineration costs were estimated using site specific incinerator throughput data as described above and a regression of the incinerator operating costs that were developed for the proposal ( excluding capital recovery because this will be incurred whether the incinerator is operating or not). For details on the regression analysis and cost estimation, please refer to Appendix C, Memorandum 3.

Finally, net switching costs were calculated as landfill cost minus incinerator operating costs. Negative switching costs indicated OSWI for which landfilling represents an absolute cost savings.

3.2.2 Estimating Costs of Complying with OSWI Rule ( Option 2)

To estimate the costs of complying with the OSWI rule, RTI calculated compliance costs for each OSWI using a regression of the OSWI compliance costs that were developed for the proposal. For details on the regression analysis and cost estimation, please refer to Appendix C,

Memorandum 3. 3 3 3.2.3 Identifying Each OSWI's Cost Minimizing Compliance Option Assuming that each OSWI would choose to comply using its lowest cost option ( Option 1: Switch to Landfill or Option 2: Comply with OSWI Rule), the estimated costs for each option for each OSWI were compared. Option 1 ( Landfilling) was found to be the lower cost option for all OSWI. Appendix C, Memorandum 3, Table 4 shows estimated baseline OSWI operating costs, landfilling costs, and compliance costs for each OSWI unit.

At this stage in the analysis, using central tendency estimates of throughput, landfilling is projected to be less expensive than complying with the rule for all 173 OSWI units, and only 12 of the 173 are expected to incur positive costs by switching to landfilling. The remaining 161 are projected to experience cost savings. 4 1 SECTION 4 DETAILED EXAMINATION OF SELECTED OSWI The next stage in the analysis is to estimate potential impacts on small entities owning OSWI units, and to select a small number of them for interviews to assess the reliability of our estimated impacts. The severity of impacts on small entities is usually measured in terms of the ratio of costs of compliance to owner entity revenues, the cost to revenue ratio or CRR.

For all 108 OSWI owned by small or potentially small entities, compliance costs were calculated assuming ( 1) upper end incinerator throughput estimates, and ( 2) that entities choose the cost minimizing compliance option. CRRs were then calculated for each entity ( for entities owning more than one OSWI unit, costs were summed across the units). The entities chosen for interviews were those with the highest projected CRRs under these assumptions. In short, more detailed information was gathered for those entities that might experience high compliance costs.

For details on these calculations, please see Appendix C, Memorandum 3, Table 5.

As a result of this approach, nine entities were contacted. Those entities include all the entities projected to experience CRRs greater than 0.5% assuming high incinerator throughput.

The nine entities include eight small government jurisdictions and one small business. This analysis found:

  Eight OSWI units owned by six nonprofits have positive costs, but none of the entities have costs exceeding 0.1 percent of revenue.

  Twelve OSWI units owned by 12 small governments have positive costs; 8 have CRR of approximately 1 percent or greater.

  One OSWI unit owned by a small business has a CRR greater than 1 percent.

The nine entities contacted to obtain information about actual OSWI operations and costs are shown in Table 4 1, and contact details are in Appendix B.

Among these units, OSWI 39 ( Seagull Sanitation Systems) is commercially owned. All the others are owned by small governmental entities, including towns, counties, and a school system. ( OSWI 274 is an IWI owned by Jeffers High School.)

4.1 Summary of Interview Results Of the nine facilities contacted, three have already shut their incinerators down, and six are still operating their incinerators. Of these six facilities, three plan to shut their incinerators down eventually ( before the compliance deadline for the final OSWI rule), one plans to seek an 4 2 Table 4 1. OSWI Units to be Contacted to Assess Validity of Estimated Impacts RTI ID OSWI Name Cost Based on High End Throughput ($/ year) Owner Revenue ($ million/ year) Estimated CRR 39 Seagull Sanitation Systems $ 167,474 1.75 9.57%

130 Town of Readsboro Incinerator $ 82,601 1.02 8.07%

143 Ossipee Incinerator Facility $ 116,922 9.28 1.26%

144 Town of Candia $ 123,666 8.64 1.43%

145 Town of Litchfield Incinerator & Recycling Facility $ 410,381 16.3 2.52%

146 Wilton Recycling Center $ 533,882 8.23 6.49%

149 Hebron Bridgewater Refuse District $ 80,108 2.15 3.73%

150 Shelby County Community Services $ 69,174 7.05 0.98%

274 Jeffers High School $ 38,801 2.10 1.85%

exemption to the OSWI rule, one plans to comply with the OSWI rule, and one is currently undecided whether to comply or shut down.

Those units still in operation were asked about actual waste throughput, operating hours,

and operating costs. Based on the responses, the original estimates of daily waste throughput were substantially overestimated ( 3 to 6 times), due to the fact that capacity information was used in the original estimates, rather than actual throughput, which was unavailable at the time.

The original estimates of operating hours were mostly overestimated ( 1 to 8 times); the original estimates were based on averages for the type of OSWI ( VSMWC or IWI), because actual information on operating hours was unavailable at the time. The information collected on operating costs was somewhat unclear and was sometimes provided for the entire operation, not just the incinerator. Operating costs for just the incinerator were provided in only three cases;

one claimed to have practically zero cost, while the other two had higher costs than previously determined, indicating the original estimates of operating costs may have been underestimated ( 30 to 40 percent of actual costs). Table 4 2 shows data used in initial estimates and data collected during interviews for the nine OSWI.

Some of the contacts were aware of the OSWI rule and noted that they have several years before the rule is implemented. Consequently, they had not yet completed any cost estimates for either complying or landfilling. Only one of the facilities has an add on control device. The incinerator at this facility is newly installed, with state of the art equipment, wet scrubber, and 4 3 Table 4 2. Revised and Original Data and Cost Estimates RTI ID Facility Name Road Distance ( miles) Tipping Fee ($/ ton) Annual Quantity ( tpy) LF Disposal Costs ($/ yr) Baseline Incinerator Operating Costs ($/ yr) Compliance Costs ($/ yr)

39 Seagull Sanitation Systems, Pebbly Beach Disposal Site Incinerator,

Avalon, CA Closed ( Original Estimate)

( 40.88)

($ 42.87)

( 3,182)

($ 201,453)

($ 133,830)

($ 333,295)

130 Town of Readsboro Incinerator, Readsboro,

VT Closed ( Original Estimate)

( 26.04)

($ 45.00)

( 3,358)

($ 194,851)

($ 138,710)

($ 342,994)

143 Ossipee Incinerator Facility, Ossipee, NH Revised Estimate ( Original Estimate) 66.1 ( 7.42) $ 67.00 ($ 55.95) 994.5 ( 4,030) $ 99,500 ($ 240,430) $ 71,453 ($ 157,194) $ 212,971 ($ 379,939)

144 Town of Candia Candia, NH Revised Estimate ( Original Estimate) 33.4 ( 10.08) $ 82.00 ($ 55.95) 1,170 ( 4,030) $ 115,479 ($ 245,790) $ 76,676 ($ 157,194) $ 222,625 ($ 379,939)

145 Town of Litchfield Incinerator & Recycling Facility, Litchfield, NH Revised Estimate ( Original Estimate) 145 ( 12.04) $ 107.60 ($ 80.00) 1,118 ( 6,179) $ 201,352 ($ 531,546) $ 75,135 ($ 215,549) $ 219,765 ($ 498,163)

146 Wilton Recycling Center Wilton, NH Revised Estimate ( Original Estimate) 60.3 ( 8.68) $ 16.67 ($ 80.00) 832 ( 8,060) $ 38,954 ($ 679,780) $ 66,544 ($ 265,980) $ 204,033 ($ 601,609)

149 Hebron Bridgewater Refuse District,

Bridgewater, NH Revised Estimate ( Original Estimate) 50.5 ( 18.5) $ 77.91 ($ 25.90) 637 ( 3,869) $ 65,713 ($ 206,787) $ 60,529 ($ 152,772) $ 86,526 ($ 371,072)

150 Shelby County Community Services,

Shelbyville, IL Closed ( Original Estimate)

( 33.6)

($ 30.00)

( 1,560)

($ 73,008)

($ 88,072)

($ 244,077)

274 Jeffers High School,

Painesdale, MI Revised Estimate ( Original Estimate) 10 ( 39.06) $ 60.00 ($ 54.20) 9.6 ( 445) $ 1,415 ($ 32,784) $ 0 ($ 54,394) $ 50 ($ 182,727) 4 4 continuous emissions monitoring system ( CEMS). Another contact was also unsure how they would respond, stating that they have not yet made a decision whether to install emission controls and comply or shut down and send waste to a landfill. One contact expected to continue operating and would apply for an exemption as a rural IWI, because it is more than 50 miles from the border of the nearest metropolitan statistical area ( MSA). The remaining contacts still operating did not believe they would be able to achieve the limits in the rule, and they are planning to shut down their incinerators.

In addition to cost and compliance issues, some of the contacts cited encroaching development, nuisance complaints, and the age of the incinerator as factors for why they are planning to shut down their incinerators.

For those facilities that may landfill their waste instead of incinerate, contacts stated that they did ( or would) send their waste to landfills different from the ones identified as the closest landfills. Some of the contacts indicated they would send the waste to a transfer station, rather than directly to a landfill. Where contacts did provide landfill information, the landfills RTI originally chose did not match the landfills cited by the contacts; distances transported and tipping fees were generally higher than originally assumed.

Information was also requested from the OSWIs about the revenue for their municipality or commercial enterprise. For the municipalities, the original revenue estimates obtained from Federal government sources were reported to be overestimated ( 3 to 5 times). By contrast, for the only commercial enterprise among the nine contacted, the original revenue estimate appeared to be underestimated ( 55 percent of actual revenue). However, many of the contacts were not certain about the accuracy of their revenue estimates, and RTI did not contact additional staff for more authoritative estimates. Because the original revenue data came from Federal data sources ( Census of Governments and National Center for Education Statistics) and is thus thought reliable, RTI chose to continue to use its original revenue estimates.

The final question to the contacts concerned whether there were other factors besides cost that might influence their decision to incinerate vs. landfill. Through a literature review, some factors that might cause landfilling to be impracticable for some OSWI had been identified, such as harsh climate or long distances to landfills that accept the types of waste they incinerate. The contacts provided some additional examples. Two contacts noted that EPA had overlooked the issue of what to do with the waste that cannot be landfilled, such as the contraband and confidential records they receive from police departments, and the materials they receive from the Department of Fish & Game ( e. g., rabid animal remains). Another contact noted their very 4 5 low incinerator operating costs ( essentially the cost of a match) made any other type of disposal uneconomic at present. A third contact noted that there were political considerations: their stateof the art facility had been funded by the citizens of their municipalities, and they did not want to throw away the substantial sum of money they had already spent. Contacts also generally commented on the limited landfill space and the cost to haul and landfill waste. For additional details, see Appendix C, Memorandum 4.

4.2 Revision of Costs Based on Interview Results Based on the information collected through the telephone contacts, new costs for switching to landfills or complying with the OSWI rule requirements were developed for the nine entities contacted. These costs were compared to the original central tendency costs calculated for these units. The results of this analysis are summarized in Table 4 3. The remainder of this section provides a description of the revised cost estimates generated for the OSWI units as a result of the telephone contacts. For detailed information about the interviews,

see Appendix C, Memorandum 5.

Several key pieces of information have a strong influence on projected costs, particularly incinerator throughput, landfill tipping fees, and the distance to the landfill. For each of the nine facilities, actual throughput based on information received from the telephone conversations was lower, sometimes substantially so, than the original central tendency estimate of throughput.

Landfill tipping fees were generally higher than originally estimated, and landfill distances farther. Revised data are shown in Table 4 2.

Three of the facilities that were contacted ( Seagull Sanitation Systems, Town of Readsboro, and Shelby County Community Services) indicated they are no longer in operation.

Given that their throughput is zero, it is also assumed that their potential costs resulting from the OSWI rule are also zero.

The original throughput estimate for Ossippee was projected to be around 4,000 tpy, but based on the telephone contact, it appears that actual throughput is closer to 1,000 tpy. The landfill tipping fee is higher ($ 67 per ton compared to an estimated $ 60) and the landfill farther ( 66 miles vs. 7).

Similarly, the original throughput estimate for the town of Candia was projected to be approximately 4,000 tpy but is probably closer to 1,000 tpy. The person contacted also indicated that the landfill they use has a higher tipping fee ($ 82 per ton, compared to an original estimate of around $ 60 per ton) and is farther away ( 33 miles vs. 10). 4 6 Table 4 3. Revised and Original Compliance Option Costs and Cost to Revenue Ratio ( CRR)

RTI ID Facility Name Option 1  Shut Down/ Landfill ($/ yr) Option 2

Comply OSWI ($/ yr) Low Cost Option ($/ yr) Cost to

Revenue Ratio CRR> 0.5%?

Yes/ No 39 Seagull Sanitation Systems, Pebbly Beach Disposal Site Incinerator Closed ( Original Estimate)

($ 67,623)

($ 333,295)

($ 67,623)

( 9.57%)

( Yes)

130 Town of Readsboro Incinerator Closed ( Original Estimate)

($ 56,140)

($ 342,994)

($ 56,140)

( 8.07%)

( Yes)

143 Ossipee Incinerator Facility Revised Estimate ( Original Estimate) $ 28,047 ($ 83,236) $ 212,971 ($ 379,939) $ 28,047 ($ 83,236) 0.30%

( 1.26%) No ( Yes)

144 Town of Candia Revised Estimate ( Original Estimate) $ 38,803 ($ 88,595) $ 222,625 ($ 379,939) $ 38,803 ($ 88,595) 0.45%

( 1.43%) No ( Yes)

145 Town of Litchfield Incinerator & Recycling Facility Revised Estimate ( Original Estimate) $ 126,216 ($ 315,997) $ 219,765 ($ 498,163) $ 126,216 ($ 315,997) 0.78%

( 2.52%) Yes ( Yes)

146 Wilton Recycling Center Revised Estimate ( Original Estimate)  $ 27,590 ($ 413,801) $ 204,033 ($ 601,609)  $ 27,590 ($ 413,801)   0.34%

( 6.49%) No ( Yes)

149 Hebron Bridgewater Refuse District Revised Estimate ( Original Estimate) $ 5,184 ($ 54,015) $ 86,526 ($ 371,072) $ 5,184 ($ 54,015) 0.24%

( 3.73%) No ( Yes)

150 Shelby County Community Services Closed ( Original Estimate)

($ 15,088)

($ 333,295)

($ 15,088)

( 0.98%) No ( Yes)

274 Jeffers High School Revised Estimate ( Original Estimate) $ 1,415 ( $ 21,610) $ 50 ($ 182,727) $ 50 ( $ 21,610) 0.002%

( 1.85%) No ( Yes) 4 7 The town of Litchfield was projected to have annual throughput of over 6,000 tpy but is currently operating at around 1,000 tpy. The landfill they would likely use also has a higher tipping fee ($ 108 per ton, compared to the initial estimate of $ 80) and is farther away ( 145 miles vs. 12).

The throughput at the Wilton Recycling Center was projected to be around 8,000 tpy but is actually around 800 tpy. The transfer station they may use has a lower tipping fee ($ 17 per ton compared to $ 80) but is farther away ( 60 miles compared to 9).

The OSWI unit in the Hebron Bridgewater refuse district is processing approximately 600 tpy compared to an original estimate of approximately 3,800 tpy. The landfill that is likely used has a higher tipping fee ($ 72 per ton vs. $ 26) and is farther away ( 51 miles vs. 19) than originally thought.

Jeffers High School reported extremely low waste throughput ( 9.6 tpy compared to the original estimate of 445 tpy). Their costs are negligible ( the cost of a match), compared to our estimated costs of $ 54,400 per year. They plan to petition for a rural OSWI exemption, because they are located more than 50 miles from the nearest MSA.

Tables 4 2 and 4 3 present the revised costs for each of the entities contacted. Because three of the units are not operating, their actual costs are zero. While some of the elements of the cost estimation are higher than we had estimated, costs are uniformly lower ( generally much lower) because reported throughputs were much lower than our estimated throughputs. As a result, none of the OSWI have CRRs exceeding 1 percent based on our revised estimates. Only one ( 145, Litchfield, NH) has revised costs exceeding 0.5 percent of revenues.

4.3 Summary The analysis identified 117 entities that own OSWI believed to be in operation and subject to the rule. Ninety two of the 117 are small entities or are nonprofit entities that are assumed small. Of the 117 entities identified from publicly available sources, the telephone interviews determined that three were no longer operating their OSWI, reducing the number of entities with operating OSWI to 114, of which 89 are small or assumed small. Using central tendency throughput assumptions and the information obtained during the interviews, 105 entities, including 83 small or assumed small, are projected to save money by switching to a landfill. No entity, small or otherwise, is projected to incur costs exceeding one percent of revenues. Four entities, all small governments, are projected to have CRRs exceeding 0.1 4 8 percent. Only one entity is projected to have a CRR exceeding 0.5 percent. Table 4 4 summarizes these impacts.

Table 4 4. Summary of Projected Impacts RTI OSWI ID Entity Type Small Entitya Original Projection of Medium Throughput CRR Revised Projection of Medium Throughput CRRb Original Projection of High Throughput CRR Revised Projection of High Throughput CRRb 145 Gov yes 1.94% 0.78% 2.52% 0.78%

146 Gov yes 5.03% 6.49%

144 Gov yes 1.03% 0.45% 1.43% 0.45%

143 Gov yes 0.90% 0.30% 1.26% 0.30%

149 Gov yes 2.52% 0.24% 3.73% 0.24%

132 Gov yes 0.08% 0.08% 0.18% 0.18%

116 Com no 0.01% 0.01% 0.02% 0.02%

142 Com no 0.01% 0.01% 0.04% 0.04%

299 Gov no 0.01% 0.01% 0.01% 0.01%

130 Gov yes 5.48% 0 8.07% 0 150 Gov yes 0.21% 0 0.98% 0 39 Com yes 3.86% 0 9.57% 0 140 Gov yes 0.41% 0.41%

184 Gov yes 0.18% 0.18%

439 Gov no 0.12% 0.12%

274 Gov yes 0.01% 1.85% 0.01%

120 Gov no 0.07% 0.07%

483 Gov yes 0.04% 0.04%

473 NP yes 0.02% 0.02%

468 Gov no 0.01% 0.01%

390 NP yes 0.01% 0.01%

420 NP yes 0.01% 0.01%

422 NP yes 0.01% 0.01%

426 NP yes 0.01% 0.01%

415,416,417c NP yes 0.01% 0.01%

Blanks indicate projected cost savings.

aEntities that are small or assumed to be small ( in the case of nonprofits).

bCRRs for entities that were interviewed were revised, others were not changed.

cThese three units are owned by the same entity. 5 1 SECTION 5 CONCLUSIONS At EPA's direction, RTI undertook an independent estimate of facility specific costs of compliance and costs of landfilling for over 170 OSWI identified as currently operating and in scope for the rule. The objective of this analysis was to address concerns raised by commenters on the proposed OSWI rule, including concerns about the accuracy of the profile of affected small entities, concerns about the methods employed by EPA in analyzing costs and impacts for proposal ( such as use of national averages and model plants), and concerns about the validity of EPA's assertion that costs for affected small entities would be low, and many affected entities would experience cost savings by switching from incineration to landfilling. This supplemental analysis attempts to respond to those concerns by focusing on actual units that are operating and in scope, paying particular attention to small businesses, and using site specific information on throughput and costs.

The cost estimations used current, publicly available, site specific data and were based on a regression of the model facility costs from the analysis for the proposed rule. In general, our estimated costs supported EPA's assertion in the Preamble to the proposed OSWI rule that costs for OSWI would be low, and that most owners would experience absolute cost savings by switching to landfilling. The analysis estimated that 12 OSWI would incur positive compliance costs and none are expected to incur costs greater than 1 percent of revenue.

To assess the accuracy of the estimated costs, and the validity of the conclusions, costs of compliance were estimated assuming high end throughput, and the nine OSWI owned by small entities that were estimated to have costs exceeding 0.5 percent of baseline revenues were contacted for in depth interviews about their operations and expected response to the rule. All other OSWI owners, small and otherwise, were estimated to have CRRs less than 0.5 percent.

The interviews revealed that three of the nine had already shut down operations. Of the remaining six, three more expect to shut down prior to the rule's implementation. One other will likely petition for a rural OSWI exemption. Of the remaining two, one expects to continue operating although it is not sure it will be able to comply with the rule without additional investment. The final OSWI is unsure how it will respond, as it has not yet investigated its compliance options.

For the six OSWI currently operating, information on actual throughput, landfill choices,

and operating parameters and costs was collected during the interviews. Uniformly, interviews 5 2 revealed that the estimation based on 90th percentile throughput had overestimated throughput.

In addition, the contacts revealed that they did not send their waste to the nearest landfill, as the cost estimation had assumed. While the cost per ton of landfilling was sometimes higher than estimated, because actual throughput was generally much smaller than estimated, revised costs were uniformly lower than originally estimated. When costs were re estimated based on interview data, none of the six small entities with operating OSWIs had costs exceeding one percent of owners' revenues. Only one has costs exceeding 0.5 percent of revenues. Thus, RTI concludes that EPA's assessment at proposal that costs of complying with the rule would generally be relatively small, and that many OSWI, including most of those owned by small entities, would experience cost savings as a result of the rule, is probably correct. R 1 REFERENCES Barr, L., and T. Holloway, RTI. October 4, 2005. " OSWI Inventory Information Received from EPA Regions and States." Memorandum submitted by RTI to project file.

Chartwell Information, EBI, Inc. 2004. The Directory & Atlas of Solid Waste Disposal Facilities. Eighth Edition. Chartwell Information, EBI, Inc.

CAAPP Permit Denial. 2003. " Robbins Resource Recovery Partners, LP." Prepared by Illinois Environmental Protection Agency, Division of Air Pollution Control.

Coburn, J., T. Holloway, and K. Heller. October 10, 2005. " Selection of Small Entities for Detailed Cost Analysis." Memorandum submitted by RTI to W. Nickerson, U. S. Environmental Protection Agency, Office of Policy, Economics, and Innovation, through G. Kline, ICF.

Dun & Bradstreet. Small Business Solutions. < http:// smallbusiness. dnb. com/ default. asp? bhcd2= 1127767288>.

Heimlich, J. E. Ohio State University, Fact Sheet: Landfills. < http:// ohioline. osu. edu/ cdfact 0111. html>. Accessed 2005.

Holloway, T., and J. Coburn. October 26, 2005. " Additional Reasons Why Landfilling Infeasible for Small Entities." Memorandum submitted by RTI to W. Nickerson, U. S. Environmental Protection Agency, Office of Policy, Economics, and Innovation, through G. Kline, ICF.

National Emissions Inventory. Draft 2002. U. S. Environmental Protection Agency, Office of Air Quality Planning and Standards. < http:// www. epa. gov/ ttn/ chief/ net/ 2002inventory. html>. Accessed August  September 2005.

U. S. Department of Education. National Center for Education Statistics. 2005. " Census 2000 School District Profiles." < http:// nces. ed. gov/ surveys/ sdds/ main1. asp> and " Search for Public School Districts." < http:// nces. ed. gov/ ccd/ districtsearch/>.

U. S. Department of Commerce. Bureau of the Census. Census of Governments. 2002. " County Governments." < http:// www. census. gov/ prod/ 2005pubs/ gc02x43. pdf>; " Municipal Governments: At or Above 25,000  Finances of Municipal and Township Governments: 2002." < http:// www. census. gov/ prod/ 2005pubs/ gc024x4. pdf>; " Municipal Governments: Below 25,000  Finances of Municipal and Township Governments: 2002." < www. census. gov/ prod/ 2005pubs/ gc024x4. pdf>; and " Municipal Governments: Population Estimates for All Places, 2002." < http:// www. census. gov/ popest/ cities/ SUBEST2004 4. html>. APPENDIX A LIST OF OSWI UNITS A 1 Table A 1. List of OSWI Units RTI_

ID Owner ID Owner Typea OSWI Name City State OSWI Type Small Entityb > 50mi MSA 1 1 1 Naval Air Weapons Station China Lake CA IWI 0 0 9 1 1 National Security Agency Fort Meade MD IWI 0 0 10 1 1 National Security Agency Fort Meade MD IWI 0 0 11 1 1 Naval Surface Warfare Cntr  Indian HD Indian Head MD IWI 0 0 12 1 1 Naval Surface Warfare Cntr  Indian HD Indian Head MD IWI 0 0 18 1 1 Malmstrom AFB Malmstrom AFB MT IWI 0 0 19 1 1 Los Alamos National Laboratory Los Alamos NM IWI 0 0 20 1 1 U. S. Department of the Army Hawthorne NV IWI 0 0 21 1 1 Tinker AFB U. S. Air Force Logistics Ctr Midwest City OK IWI 0 0 23 1 1 U. S. Navy: Weapons Station Goose Creek SC IWI 0 0 24 1 1 U. S. Airforce: Charleston AFB Charleston AFB SC IWI 0 0 25 1 1 U. S. Airforce: Shaw AFB Sumter SC IWI 0 0 26 1 1 Main Base Hill Air Force Base UT IWI 0 0 93 1 1 U. S. Army  Fort Belvoir Fort Belvoir VA IWI 0 0 122 1 1 Navy Salvage Fuel Boiler Plant Norfolk VA VSMWC 0 0 152 1 1 101st Airborne Div./ Fort Campbell Clarksville TN IWI 0 0 153 1 1 88 ABW/ EMP Wright Patterson AFB OH IWI 0 0 290 1 1 Laughlin Air Force Base Del Rio TX IWI 0 1 322 1 1 Naval Security Grp Activity  Winter HBR Gouldsboro ME IWI 0 0 323 1 1 Naval Security Grp Activity  Winter HBR Gouldsboro ME IWI 0 0 324 1 1 Naval Surface Warfare Center Crane Crane IN IWI 0 0 340 1 1 Peterson AFB CES CEV Peterson AFB CO IWI 0 0 408 1 1 U. S. Army Air Defense Art El Paso TX IWI 0 0 431 1 1 U. S. Military Academy West Point NY IWI 0 0 432 1 1 USAF Clear Clear USA AK IWI 0 1 471 1 1 U. S. Department of Justice FBI Richmond VA IWI 0 0 498 1 1 Naval Security Group Activity Sugar Grove WV IWI 0 0 2 2 2 Calif. Dept. of Food & Ag. Truckee CA IWI 0 0 ( continued) A 2 Table A 1. List of OSWI Units ( continued)

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ID Owner ID Owner Typea OSWI Name City State OSWI Type Small Entityb > 50mi MSA 3 2 2 Calif. Dept. of Food & Ag. Truckee CA IWI 0 0 186 2 2 Calif Correctional Center Susanville CA IWI 0 0 22 3 2 PA Dept of Corr/ Dallas Sci Dallas PA IWI 0 0 97 4 7 WIS DOA/ UW Madison  Charter St Heating Plant Madison WI IWI 2 0 98 4 7 WIS DOA/ UW Madison  Charter St Heating Plant Madison WI IWI 2 0 99 4 7 WIS DOA/ UW Madison  Charter St Heating Plant Madison WI IWI 2 0 100 4 7 WIS DOA/ UW Madison  Charter St Heating Plant Madison WI IWI 2 0 101 4 7 University of Wisconsin ( Mad) Safety Dept Madison WI IWI 2 0 299 5 2 Louisiana State Penitentiary Angola LA IWI 0 0 309 6 2 Maryland Department of Hearth & Mental Hygiene

Pub Baltimore MD IWI 0 0 325 7 2 NE Game & Parks Commission Lincoln NE IWI 0 0 439 8 2 Wash State Park & Recreation Comm Olympia WA IWI 0 0 499 9 2 WVDEP  Office of Waste Management Arthurdale WV IWI 0 0 38 10 3 LA Co., Sanitation Dist Pomona CA VSMWC 0 0 120 11 3 Carter County Air Curtain Destruction Elizabethton TN VSMWC 0 0 285 12 3 Kalamaoo Valley Comm Co Kalamaoo MI IWI 0 0 293 13 3 Elgin Community College Elgin IL IWI 0 0 ( continued) A 3 Table A 1. List of OSWI Units ( continued)

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ID Owner ID Owner Typea OSWI Name City State OSWI Type Small Entityb > 50mi MSA 470 14 3 Henrico County Police Glen Allen VA IWI 0 0 484 15 3 Mercer County Vo Tech Mercer PA IWI 0 0 500 16 4 Huntington Sanitary Board Huntington WV IWI 0 0 121 17 4 City of Alcoa Incinerator Friendsville TN VSMWC 1 0 129 18 4 City of Southside Place Incinerator Southside Place TX VSMWC 1 0 130 19 4 Town of Readsboro Incinerator Readsboro VT VSMWC 1 0 132 20 4 Siloam Springs Siloam Springs AR VSMWC 1 0 138 21 4 City of Lufkin Lufkin TX VSMWC 1 0 139 22 4 City of Norfolk Waste Facility Norfolk NE VSMWC 1 0 140 23 4 City of Sulphur Springs Sulphur Springs TX VSMWC 1 0 143 24 3 Ossipee Incinerator Facility Ossipee NH VSMWC 1 0 144 25 4 Town of Candia Candia NH VSMWC 1 0 145 26 4 Town of Litchfield Incinerator & Recycling Facility Litchfield NH VSMWC 1 0 146 27 4 Wilton Recycling Center Wilton NH VSMWC 1 0 ( continued) A 4 Table A 1. List of OSWI Units ( continued)

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ID Owner ID Owner Typea OSWI Name City State OSWI Type Small Entityb > 50mi MSA 149 28 3 Hebron Bridgewater Refuse District Bridgewater NH VSMWC 1 0 6 29 5 Grayslake Community High School 127 Grayslake IL IWI 1 0 45 30 5 Gross School  Dist 95 Brookfield IL IWI 1 0 57 31 5 Diekman School  District 149 Dolton IL IWI 1 0 58 32 5 Berger Vandenberg School Dolton IL IWI 1 0 66 33 5 Marquardt School  District 15 Glendale Heights IL IWI 1 0 69 34 5 Jackson Junior High School Villa Park IL IWI 1 0 72 35 5 Pioneer School West Chicago IL IWI 1 0 79 36 5 Triopia High School  District 27 Concord IL IWI 1 0 89 37 5 Freeport School District 145  Empire School Freeport IL IWI 1 0 90 38 5 Carl Sandburg School  District 145 Freeport IL IWI 1 0 91 39 5 Rock Falls Township High School Rock Falls IL IWI 1 0 165 40 5 Athens Area School District Athens Borough PA IWI 1 0 184 41 5 Burrell School District Lower Burrell City PA IWI 1 0 195 42 5 Chatterton Jr High School Warren MI IWI 1 0 ( continued) A 5 Table A 1. List of OSWI Units ( continued)

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ID Owner ID Owner Typea OSWI Name City State OSWI Type Small Entityb > 50mi MSA 234 117 5 Fitgerald High School Warren MI IWI 1 0 437 43 5 Waldron Area Schools Waldron MI IWI 1 0 469 43 5 Powhatan High School Powhatan VA IWI 1 0 476 44 5 Hollidaysburg Area School District Holidaysburg PA IWI 1 0 477 45 5 Forest Hills School District ( Ele/ Hi) Sidman PA IWI 1 0 480 45 5 Forest Hills School District ( Ele) Sidman PA IWI 1 0 479 46 5 Northern Cambria School District ( Ele/ Mi) Barnesboro PA IWI 1 0 481 47 5 Carmichaels Area School District Carmichaels PA IWI 1 0 482 47 5 Carmichaels Area School District Carmichaels PA IWI 1 0 483 48 5 Purchase Line School District ( Jr/ Sr/ Ele) Commodore PA IWI 1 0 485 49 5 Trinity Area School District Washington PA IWI 1 0 486 50 5 Burrell School District ( Ele) Lower Burrell PA IWI 1 0 487 51 5 Hempfield Area School District ( Sr. High) Greenburg PA IWI 1 0 488 51 5 Hempfield Area School District ( Sr. High) Greenburg PA IWI 1 0 490 52 5 Elizabeth Forward School District  Middle School Incinerator Elizabeth PA IWI 1 0 ( continued) A 6 Table A 1. List of OSWI Units ( continued)

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ID Owner ID Owner Typea OSWI Name City State OSWI Type Small Entityb > 50mi MSA 491 53 5 Keystone Oaks School District  High School Incinerator Pittsburgh PA IWI 1 0 39 54 6 Seagull Sanitation Avalon CA VSMWC 1 0 307 55 7 Marian Manor Healthcare Center Glen Ullin ND IWI 2 0 497 56 6 Grant County Nursing Home Petersburg WV IWI 1 0 61 57 7 Regina Dominican High School Wilmette IL IWI 2 0 63 58 7 Misericordia School  North Chicago IL IWI 2 0 379 59 7 St Clare De Montefalco Parish Grosse Pointe Park MI IWI 2 0 381 60 7 St Gerard Parish Detroit MI IWI 2 0 460 61 7 Piney Forest Healthcare Danville Danville VA IWI 2 0 489 62 7 Bishop McCort High School Johnstown PA IWI 2 0 492 63 7 North Catholic High School  Incinerator, Pyronics Pittsburgh PA IWI 2 0 493 64 7 Sisters of the Holy Spirit Pittsburgh PA IWI 2 0 494 65 7 St. Angela Merici Parish McKeesport PA IWI 2 0 159 66 7 Alpena Comm College Alpena MI IWI 2 1 ( continued) A 7 Table A 1. List of OSWI Units ( continued)

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ID Owner ID Owner Typea OSWI Name City State OSWI Type Small Entityb > 50mi MSA 274 67 5 Jeffers High School Painesdale MI IWI 1 1 17 68 7 Kirksville College of Osteopathic Medici College Kirksville MO IWI 2 1 46 69 5 Goodwin Elem School Cicero IL IWI 0 0 48 69 5 Woodbine School  District 99 Cicero IL IWI 0 0 49 69 5 Sherlock School Cicero IL IWI 0 0 52 69 5 Drexel School District 99 Cicero IL IWI 0 0 53 69 5 Columbus School District 99 Cicero IL IWI 0 0 55 69 5 McKinley School Cicero IL IWI 0 0 56 69 5 Lincoln School  District 99 Cicero IL IWI 0 0 501 69 5 Cicero  East School  Dist 99 Cicero IL IWI 0 0 81 70 5 Springfield Public Schools District 186 Springfield IL IWI 0 0 82 70 5 Springfield High School  District 186 Springfield IL IWI 0 0 83 70 5 Washington Middle School  District 186 Springfield IL IWI 0 0 84 70 5 Southeast High School  District 186 Springfield IL IWI 0 0 85 70 5 Lanphier High School  District 186 Springfield IL IWI 0 0 87 70 5 Franklin Middle School  District 186 Springfield IL IWI 0 0 65 71 5 Addison Trail High School  District 88 Addison IL IWI 0 0 459 72 5 Concord Elementary School Concord VA IWI 0 0 468 73 5 John M Gandy Elementary School Ashland VA IWI 0 0 116 74 6 Ampacet Corporation Deridder LA VSMWC 0 0 118 75 6 BFI Waste Systems of North America  Reserve Reserve LA VSMWC 0 0 ( continued) A 8 Table A 1. List of OSWI Units ( continued)

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ID Owner ID Owner Typea OSWI Name City State OSWI Type Small Entityb > 50mi MSA 495 76 6 Vincentian Home Inc. ( Senior Residence Home) Pittsburgh PA IWI 0 0 142 77 6 Environmental Solutions LLC Cannon Falls MN VSMWC 0 0 4 78 7 Univ Cal, Riverside Riverside CA IWI 2 0 8 79 7 Kansas University Medical Center Kansas City KS IWI 2 0 200 80 7 Colorado State Univ Fort Collins CO IWI 2 0 399 81 7 Texas A & M University College Station TX IWI 2 0 409 82 7 UC  Davis Davis CA IWI 2 0 410 83 7 UCSD/ Campus La Jolla CA IWI 2 0 411 84 7 UCSF/ Parnassus San Francisco CA IWI 2 0 412 85 7 University of NE Swine Research Ithaca NE IWI 2 0 414 86 7 University of Houston Houston TX IWI 2 0 418 87 7 University of Alabama at Birmingham ( Incinerator) Birmingham AL IWI 2 0 419 87 7 University of Alabama at Birmingham ( Incinerator) Birmingham AL IWI 2 0 428 88 7 UNL Manter Hall Lincoln NE IWI 2 0 436 89 7 VPI & State University Blacksburg VA IWI 2 0 ( continued) A 9 Table A 1. List of OSWI Units ( continued)

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ID Owner ID Owner Typea OSWI Name City State OSWI Type Small Entityb > 50mi MSA 462 90 7 University of Virginia  Medical Center Charlottesville VA IWI 2 0 463 90 7 University of Virginia  Medical Center Charlottesville VA IWI 2 0 464 90 7 University of Virginia  Medical Center Charlottesville VA IWI 2 0 465 90 7 University of Virginia  Medical Center Charlottesville VA IWI 2 0 472 91 7 Norfolk International Airport Norfolk VA IWI 2 0 42 92 7 Orlando Sanford Int'l Airport Sanford FL VSMWC 2 0 178 93 7 Boston University # 2 Boston MA IWI 2 0 179 94 7 Boston University Engr & Sci Ctr Boston MA IWI 2 0 217 95 7 Duke University Heating Plant Durham NC IWI 2 0 251 96 7 Hampton University Hampton VA IWI 2 0 302 97 7 M. I. T. Bldg. # 56 Animal Care Facility Cambridge MA IWI 2 0 304 97 7 M. I. T. College of Health Science Cambridge MA IWI 2 0 344 98 7 Purdue University  Wade Utility Plant West Lafayette IN IWI 2 0 374 99 7 Southern Research Institute Birmingham AL IWI 2 0 375 99 7 Southern Research Institute Birmingham AL IWI 2 0 390 100 7 Stanford University Palo Alto CA IWI 2 0 415 101 7 University of Rochester ( Strong Memorial Hosp.) Rochester NY IWI 2 0 ( continued) A 10 Table A 1. List of OSWI Units ( continued)

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ID Owner ID Owner Typea OSWI Name City State OSWI Type Small Entityb > 50mi MSA 416 101 7 University of Rochester ( Strong Memorial Hosp.) Rochester NY IWI 2 0 417 101 7 University of Rochester ( Strong Memorial Hosp.) Rochester NY IWI 2 0 422 102 7 University of Idaho, Holm Research Center Moscow ID IWI 2 0 426 103 7 University of Maryland  Medical School Teaching Fac Baltimore MD IWI 2 0 461 104 7 Mary Washington College Fredericksburg VA IWI 2 0 467 105 7 Randoph Macon College Ashland VA IWI 2 0 473 106 7 Loudoun Hospital Center  Cornwall Campus Leesburg VA IWI 2 0 474 107 7 MWAA  Washington Dulles International Airport Chantilly VA IWI 2 0 475 108 7 Bridgewater College Bridgewater VA IWI 2 0 496 109 7 Duke University Heating Plant Durham NC IWI 2 0 124 110 3 Smith Island Incinerator Ewell MD VSMWC 1 0 134 111 4 City of Aurora Aurora IL VSMWC 0 0 150 112 3 Shelby County Community Services Shelbyville IL VSMWC 1 0 391 113 6 Steepmeadow Club Inc Rock Island IL IWI 1 0 424 114 7 University of Illinois Champaign IL IWI 2 0 ( continued) A 11 Table A 1. List of OSWI Units ( continued)

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ID Owner ID Owner Typea OSWI Name City State OSWI Type Small Entityb > 50mi MSA 209 115 7 Dartmouth College Hanover NH IWI 2 1 420 116 7 University of Alaska Fairbanks AK IWI 2 1 a Owner type key: 1 = Federal, 2 = State, 3 = County, 4 = Municipal, 5 = School district, 6 = Commercial, 7 = Nonprofit.

b Small entity key: 0 = Not small, 1 = Small entity, 2 = Nonprofit, treated as small. APPENDIX B OSWI CONTACT LIST B 1 RTI ID 39 Seagull Sanitation Systems, Pebbly Beach Disposal Site Incinerator 1 Dump Rd, P. O. Box 295 Avalon, CA 90704 Contact: Joanne Long, Site Supervisor ( 310) 510 0675 RTI ID 130 Town of Readsboro Incinerator P. O. Box 246 Readsboro, VT 05350 Contact: Stanley Russell, Chairman of Board ( 802) 423 5405 RTI ID 143 Ossipee Incinerator Facility 50 Chickville Rd Ossipee, NH 03864 6851 Contact: Ron Davis, Supervisor ( 603) 539 4121 RTI ID 144 Town of Candia 74 High St Candia, NH 03034 5751 Contact: Manager ( 603) 483 2892 RTI ID 145 Town of Litchfield Incinerator & Recycling Facility 2 Liberty Way Litchfield, NH 03052 Contact: David Mellon, Manager ( 603) 424 6900 RTI ID 146 Wilton Recycling Center Route 101, P. O. Box 83 Wilton, NH 03086 Contact: Morris Guay ( 603) 654 6150 RTI ID 149 Hebron Bridgewater Refuse District 297 Mayhew Turnpike Bridgewater, NH 03222 Contact: Terry Murphy, Bridgewater Selectman ( 603) 744 5055 Other Contacts: Gerry MacDonald, Manager; John Matthews, Hebron Selectman ( 603) 744 2631; Hank Woolner, Bridgewater Selectman ( 603) 744 5055 B 2 RTI ID 150 Shelby County Community Services 1810 W South 3rd St, P. O. Box 650 Shelbyville, IL 62565 Contact: Office ( 217) 774 5587 RTI ID 274 Jeffers High School 43084 Goodell St Painesdale, MI 49955 Contact: Office ( 906) 482 0580 Jan Maierle, Principal Dan Sternhagen, Superintendent APPENDIX C SUPPORTING MEMORANDA ( Note that Memoranda 1 through 4 reflect facility information prior to contacting the nine small entities with projected costs exceeding 0.5 percent. Thus, the facility counts may differ from those in Sections 4 and 5 of the report, which incorporate interview information.) TO: William Nickerson, EPA THROUGH: Gayle Kline, ICF FROM: Katherine Heller Tom Holloway Leigh Barr Alex Rogozhin DATE: August 15, 2005 SUBJECT: Memorandum 1. Identification of OSWI Facilities and Potential Small Entities Introduction On November 9, 2000, pursuant to the requirements of Section 129 of the Clean Air Act, EPA published a notice announcing that the Administrator would promulgate NSPS standards for Other Solid Waste Incinerators ( OSWIs) by November 15, 2005. On December 9, 2004, EPA published a proposed rule setting standards for OSWIs for the following pollutants: particulate matter, sulfur dioxide, hydrogen chloride, oxides of nitrogen, carbon monoxide, lead, cadmium, mercury, and dioxins and dibenzofurans. The rule is under court order to be finalized by November 2005.

In the preamble's discussion of the economic impacts of the rule, EPA estimated that if all of the affected units installed controls to comply with the proposed standards, the cost would be approximately $ 63 million per year. However, EPA concluded that it would be more costeffective for most OSWI units to use an alternative waste disposal method ( landfilling) rather than installing the controls necessary to comply with the proposed standards. EPA noted that the number of OSWI units has declined in recent years because of cheaper alternative disposal methods. EPA conducted an analysis of several model units that determined that switching from incineration to landfilling would actually result in a cost savings for many OSWIs. EPA stated that, because most existing OSWI units would incur no additional cost by switching to landfilling, the economic impacts of the rule are negligible.

On February 7, 2005, the Small Business Administration's Office of Advocacy submitted comments on the proposed rule, stating its concern that the basis for EPA's certification that the rule would not have a significant impact on a substantial number of small entities ( SISNOSE), as required by section 605 ( b) of the RFA, " ignored the proposal's impact on existing incineration units located in small school districts, other small governmental jurisdictions, and small organizations." Specifically, the Office of Advocacy expressed concern regarding EPA's assertion that all affected units would switch to landfilling rather than installing the required controls, incurring negligible, if any, cost. The Office of Advocacy challenged this assertion because it did not believe that EPA had sufficient understanding of the number of affected OSWIs or the number of affected OSWIs that are owned by small entities, and because it did not Nickerson Memorandum 1 August 15, 2005 Page 2 believe that EPA adequately determined the economic impacts on actual owners of affected units. The Office of Advocacy argued that EPA's cost estimate based on model units ( rather than actual units) and national average costs ( rather than locality specific actual costs) did not adequately address whether certain small entities may incur costs.

Identifying potential OSWI units Our analysis addressed the data issues raised by SBA and other commenters to the proposed rule, by gathering additional information about potentially affected facilities and their owners. RTI has compiled a list of potential OSWI by combining data from several sources:

  The OSWI inventory compiled for the proposed rule,   An updated OSWI inventory provided by OAQPS,   The National Emissions Inventory Draft 2002 database,   Permits,   Comments on the previous analysis,   Data provided by EPA Regions and States, and   A commercially available database of municipal waste facilities maintained by Chartwell, Inc.

Initially, we included in our inventory of potential OSWI units any unit identified through any of the sources. We initially compiled a list of approximately 500 potential OSWI. We then eliminated units that we have learned are not currently in operation, or are not in scope for the regulation. The major difference between the inventory presented here and the inventory developed for proposal results from removing units no longer in operation. For example, data from the state of Illinois led us to remove more than 100 of the units that had been in earlier inventories; the evidence that they had shut down was corroborated by their absence from the 2002 NEI. Many other potential OSWI units were identified as human or animal crematories or other types of combustion units not classified as OSWI. Currently, the database for this analysis contains 173 OSWI units believed to be operating and in scope. Table 1 shows the ownership distribution of these OSWI.

Identifying Small and Potentially Small Entities Owning OSWI Units We collected data from a variety of sources to characterize the owners of the OSWI units as small or not small. City and county governments were characterized based on data from the Census of Governments ( 2002). School districts were characterized based on data from the National Center for Education Statistics. Commercial and non profit entities were characterized based on data from publicly available sources and from Dun & Bradstreet's commercially available database.

The criteria used to define " small" are those set by the Regulatory Flexibility Act as amended by the Small Business Regulatory Enforcement Fairness Act ( SBREFA); the criteria differ for Nickerson Memorandum 1 August 15, 2005 Page 3 businesses, governments, and organizations. Business definitions refer to the parent company of any affected OSWI. Small businesses are defined by the Small Business Administration, published in 13 CFR 121.201; the definitions are set by NAICS code and generally depend on the number of employees or company annual receipts. Small governmental jurisdiction is the government of a city, county, town, school district, or special district with a population less than 50,000. Both of these criteria are relatively clear and given adequate data, straightforward to apply. The definition of " small organization" is " any not for profit enterprise which is independently owned and operated and is not dominant in its field." Determining whether an organization is dominant is somewhat ambiguous. To be conservative, we assume that all the nonprofits are potentially small ( i. e., not dominant); however, in subsequent steps of the analysis we exclude entities with very small cost to revenue ratios.

Table 1 shows the number of OSWI owner entities of each type, and the number that are identified by these criteria as small ( or assumed to be small, in the case of nonprofit organizations). Note that, because all nonprofits are treated as if they are small, more than 60 percent of OSWI are identified as being potentially owned by small entities. The data on which these determinations are based are shown in Table 2.

Table 1. Ownership Size Distribution of OSWI Units Owner Category Number of OSWI Number of OSWI Owned by Small or Potentially Small Entities Number of Small or Potentially Small Entities Federal 27 0 0 State 9 0 0 County 10 4 4 City 12 10 10 School District 48 31 27 Commercial 7 3 3 Nonprofita 60 60 48 Total 173 108 92 aAll nonprofit organizations are treated as if they are small.

REFERENCES Barr, L. and T. Holloway, RTI. October 4, 2005. OSWI Inventory Information Received from EPA Regions and States. Memorandum submitted by RTI to project file.

Chartwell Information, EBI, Inc. 2004. The Directory & Atlas of Solid Waste Disposal Facilities. Eighth Edition. Nickerson Memorandum 1 August 15, 2005 Page 4 CAAPP Permit Denial. 2003. Robbins Resource Recovery Partners, LP. Prepared by Illinois Environmental Protection Agency, Division of Air Pollution Control. December 29.

Dun & Bradstreet Small Business Solutions. http:// smallbusiness. dnb. com/ default. asp? bhcd2= 1127767288 Huckaby, J. and B. Lange, Eastern Research Group, Inc. ( ERG). 2004. Inventory, Subcategories, and Model Plants for the Other Solid Waste Incineration ( OSWI) Source Category. Memorandum submitted by ERG to F. Porter, M. Johnson, and B. Shrager, U. S. Environmental Protection Agency. November 23.

Johnson, M. 2005. Re: OSWI Inventory. E mail and attachment from Mary Johnson, U. S. Environmental Protection Agency, to Thomas Holloway, RTI. August 23.

Johnson, M. 2005. Existing OSWI Inventory. E mail and attachment from Mary Johnson, U. S. Environmental Protection Agency, to Thomas Holloway, RTI. August 18.

Keuler, C. 2005. Docket ID No. OAR 2003 0156. E mail and attachments submitted by Cindy Keuler, Alyeska Pipeline Service Co., Environment Department, to Group A and RDocket EPA. Sent on behalf of Carl Rutz, Environmental Manager, Alyeska Pipeline Service Company. February 7.

Montana Air Quality Operating Permit. 2004. U. S. Department of the Air Force, Malmstrom Air Force Base, Montana. Prepared by Montana Department of Environmental Quality, Permitting and Compliance Division. December 11.

National Emissions Inventory. Draft 2002. U. S. Environmental Protection Agency, Office of Air Quality Planning and Standards. Available at http:// www. epa. gov/ ttn/ chief/ net/ 2002inventory. html. Accessed August September 2005.

U. S. Census Bureau. " 2002 Census of Governments." < http:// www. census. gov/ govs/ www/ cog2002. html>. Accessed 2005.

U. S. Department of Education. National Center for Education Statistics.

Census 2000 School District Profiles. http:// nces. ed. gov/ surveys/ sdds/ main1. asp Search for Public School Districts. http:// nces. ed. gov/ ccd/ districtsearch/

U. S. Department of Commerce. Bureau of the Census. Census of Governments. 2002.

County Governments < http:// www. census. gov/ prod/ 2005pubs/ gc02x43. pdf> Nickerson Memorandum 1 August 15, 2005 Page 5 Municipal Governments: At or Above 25,000   Finances of Municipal and Township Governments: 2002 < http:// www. census. gov/ prod/ 2005pubs/ gc024x4. pdf> Below 25,000  Finances of Municipal and Township Governments: 2002 < www. census. gov/ prod/ 2005pubs/ gc024x4. pdf> and Population Estimates for All Places 2002 http:// www. census. gov/ popest/ cities/ SUB EST2004 4. html Nickerson Memorandum 1 August 15, 2005 Page 6 turning knowledge into practice Table 2. Characterization of OSWI Owners Government Commercial RTI ID Owner Entity OSWI Type Facility Name Ownership Flag a Population Served ( in 2000) Revenue ($ Million) Annual Expenditure ($ Million) Sales ($ million) Employment Small, all nonprofits included 1 1 IWI NAVAL AIR WEAPONS STATION 1 296,800,000 $ 1,853,000.2 0 9 1 IWI NATIONAL SECURITY AGENCY 1 296,800,000 $ 1,853,000.2 0 10 1 IWI NATIONAL SECURITY AGENCY 1 296,800,000 $ 1,853,000.2 0 11 1 IWI NAVAL SURFACE WARFARE CNTR INDIAN HD 1 296,800,000 $ 1,853,000.2 0 12 1 IWI NAVAL SURFACE WARFARE CNTR INDIAN HD 1 296,800,000 $ 1,853,000.2 0 18 1 IWI MALMSTROM AFB 1 296,800,000 $ 1,853,000.2 0 19 1 IWI LOS ALAMOS NATIONAL LABORATORY 1 296,800,000 $ 1,853,000.2 0 20 1 IWI US DEPARTMENT OF THE ARMY 1 296,800,000 $ 1,853,000.2 0 21 1 IWI TINKER AFB US AIR FORCE LOGISTICS CTR 1 296,800,000 $ 1,853,000.2 0 23 1 IWI US NAVY: WEAPONS STATION 1 296,800,000 $ 1,853,000.2 0 24 1 IWI US AIRFORCE: CHARLESTON AFB 1 296,800,000 $ 1,853,000.2 0 25 1 IWI US AIRFORCE: SHAW AFB 1 296,800,000 $ 1,853,000.2 0 26 1 IWI MAIN BASE 1 296,800,000 $ 1,853,000.2 0 93 1 IWI US ARMY  FORT BELVOIR 1 296,800,000 $ 1,853,000.2 0 122 1 VSMWC NAVY SALVAGE FUEL BOILER PLANT 1 296,800,000 $ 1,853,000.2 0 152 1 IWI 101ST AIRBORNE DIV./ FORT CAMPBELL 1 296,800,000 $ 1,853,000.2 0 153 1 IWI 88 ABW/ EMP 1 296,800,000 $ 1,853,000.2 0 322 1 IWI NAVAL SECURITY GRP ACTIVITY WINTER HBR 1 296,800,000 $ 1,853,000.2 0 323 1 IWI NAVAL SECURITY GRP ACTIVITY WINTER HBR 1 296,800,000 $ 1,853,000.2 0 324 1 IWI NAVAL SURFACE WARFARE CENTER CRANE 1 296,800,000 $ 1,853,000.2 0 340 1 IWI PETERSON AFB 21CES CEV 1 296,800,000 $ 1,853,000.2 0 408 1 IWI U. S. ARMY AIR DEFENSE ART 1 296,800,000 $ 1,853,000.2 0 431 1 IWI US MILITARY ACADEMY 1 296,800,000 $ 1,853,000.2 0 471 1 IWI US DEPARTMENT OF JUSTICE FBI 1 296,800,000 $ 1,853,000.2 0 ( continued) Nickerson Memorandum 1 August 15, 2005 Page 7 turning knowledge into practice Table 2. Characterization of OSWI Owners ( continued) Government Commercial RTI ID Owner Entity OSWI Type Facility Name Ownership Flag a Population Served ( in 2000) Revenue ($ Million) Annual Expenditure ($ Million) Sales ($ million) Employment Small, all nonprofit s included 498 1 IWI NAVAL SECURITY GROUP ACTIVITY 1 296,800,000 $ 1,853,000.2 0 290 1 IWI LAUGHLIN AIR FORCE BASE 1 296,800,000 $ 1,853,000.2 0 432 1 IWI USAF CLEAR 1 296,800,000 $ 1,853,000.2 0 2 2 IWI CALIF. DEPT. OF FOOD & AG. 2 33,872,000 $ 151,245.4 0 3 2 IWI CALIF. DEPT. OF FOOD & AG. 2 33,872,000 $ 151,245.4 0 22 3 IWI PA DEPT OF CORR/ DALLAS SCI 2 12,286,268 $ 46.2 0 186 2 IWI CALIF CORRECTIONAL CENTER 2 33,872,000 $ 151,245.4 0 299 5 IWI LOUISIANA STATE PENITENTIARY 2 4,469,635 $ 18,078.5 0 309 6 IWI MARYLAND DEPARTMENT OF HEALTH &

MENTAL HYGIENE PUB 2 5,311,508 $ 20,787.9 0 325 7 IWI NE GAME & PARKS COMMISSION 2 1,713,239 $ 6,001.9 0 439 8 IWI WASH STATE PARK & RECREATION COMM 2 6,067,000 $ 23.8 0 499 9 IWI WVDEP OFFICE OF WASTE MANAGEMENT 2 1,807,436 $ 9,130.2 0 38 10 VSMWC LA CO., SANITATION DIST 3 9,519,338 $ 14,788.2 0 120 11 VSMWC CARTER COUNTY AIR CURTAIN DESTRUCTION 3 56,742 $ 50.3 0 285 12 IWI KALAMAZOO VALLEY COMM CO 3 238,603 $ 128.2 0 293 13 IWI ELGIN CUMMUNITY COLLEGE 3 404,119 $ 162.0 0 470 14 IWI HENRICO COUNTY POLICE 3 262,300 $ 694.6 0 484 15 IWI MERCER COUNTY VO TECH 3 120,293 $ 47.2 0 124 110 VSMWC SMITH ISLAND INCINERATOR 3 27,327 $ 52.0 1 143 24 VSMWC OSSIPEE INCINERATOR FACILITY 3 4,232 $ 9.3 1 149 28 VSMWC HEBRON BRIDGEWATER REFUSE DISTRICT 3 979 $ 2.1 1 150 112 VSMWC SHELBY COUNTY COMMUNITY SERVICES 3 22,893 $ 7.0 1 500 16 IWI HUNTINGTON SANITARY BOARD 4 51,475 $ 50.2 0 134 111 VSMWC CITY OF AURORA 4 142,990 $ 183.9 0 ( continued) Nickerson Memorandum 1 August 15, 2005 Page 8 turning knowledge into practice Table 2. Characterization of OSWI Owners ( continue) Government Commercial RTI ID Owner Entity OSWI Type Facility Name Ownership Flag a Population Served ( in 2000) Revenue ($ Million) Annual Expenditure ($ Million) Sales ($ million) Employment Small, all nonprofits included 121 17 VSMWC CITY OF ALCOA INCINERATOR 4 7,898 $ 18.2 1 129 18 VSMWC CITY OF SOUTHSIDE PLACE INCINERATOR 4 1,552 $ 1.3 1 130 19 VSMWC TOWN OF READSBORO INCINERATOR 4 804 $ 1.0 1 132 20 VSMWC SILOAM SPRINGS 4 10,935 $ 15.9 1 138 21 VSMWC CITY OF LUFKIN 4 32,709 $ 41.0 1 139 22 VSMWC CITY OF NORFOLK WASTE FACILITY 4 23,488 $ 35.1 1 140 23 VSMWC CITY OF SULPHUR SPRINGS 4 14,570 $ 14.2 1 144 25 VSMWC TOWN OF CANDIA 4 3,939 $ 8.6 1 145 26 VSMWC TOWN OF LITCHFIELD INCINERATOR &

RECYCLING FACILITY 4 7,423 $ 16.3 1 146 27 VSMWC WILTON RECYCLING CENTER 4 3,753 $ 8.2 1 46 69 IWI GOODWIN ELEM SCHOOL 5 86,096 $ 36.8 0 48 69 IWI WOODBINE SCHOOL DISTRICT 99 5 86,096 $ 36.8 0 49 69 IWI SHERLOCK SCHOOL 5 86,096 $ 36.8 0 52 69 IWI DREXEL SCHOOL DISTRICT 99 5 86,096 $ 36.8 0 53 69 IWI COLUMBUS SCHOOL DISTRICT 99 5 86,096 $ 36.8 0 55 69 IWI MCKINLEY SCHOOL 5 86,096 $ 36.8 0 56 69 IWI LINCOLN SCHOOL  DISTRICT 99 5 86,096 $ 36.8 0 65 71 IWI ADDISON TRAIL HIGH SCHOOL DISTRICT 88 5 83,148 $ 20.9 0 81 70 IWI SPRINGFIELD PUBLIC SCHOOLS DISTRICT 186 5 118,454 $ 60.1 0 82 70 IWI SPRINGFIELD HIGH SCHOOL  DISTRICT 186 5 118,454 $ 60.1 0 83 70 IWI WASHINGTON MIDDLE SCHOOL  DISTRICT 186 5 118,454 $ 60.1 0 84 70 IWI SOUTHEAST HIGH SCHOOL  DISTRICT 186 5 118,454 $ 60.1 0 85 70 IWI LANPHIER HIGH SCHOOL  DISTRICT 186 5 118,454 $ 60.1 0 87 70 IWI FRANKLIN MIDDLE SCHOOL  DISTRICT 186 5 118,454 $ 60.1 0 459 72 IWI CONCORD ELEMENTARY SCHOOL 5 51,078 $ 30.1 0 ( continued) Nickerson Memorandum 1 August 15, 2005 Page 9 turning knowledge into practice Table 2. Characterization of OSWI Owners ( continued) Government Commercial RTI ID Owner Entity OSWI Type Facility Name Ownership Flag a Population Served ( in 2000) Revenue ($ Million) Annual Expenditure ($ Million) Sales ($ million) Employment Small, all nonprofits included 468 73 IWI JOHN M GANDY ELEMENTARY SCHOOL 5 86,320 $ 60.7 0 501 69 IWI CICERO EAST SCHOOL DIST 99 5 86,096 $ 36.8 0 6 29 IWI GRAYSLAKE COMMUNITY HIGH SCHOOL 127 5 35,065 $ 6.1 1 45 30 IWI GROSS SCHOOL DIST 95 5 10,930 $ 3.2 1 57 31 IWI DIEKMAN SCHOOL  DISTRICT 149 5 31,001 $ 12.2 1 58 32 IWI BERGER VANDENBERG SCHOOL 5 31,001 $ 12.2 1 66 33 IWI MARQUARDT SCHOOL DISTRICT 15 5 24,839 $ 10.7 1 69 34 IWI JACKSON JUNIOR HIGH SCHOOL 5 37,838 $ 17.3 1 72 35 IWI PIONEER SCHOOL 5 29,744 $ 16.0 1 79 36 IWI TRIOPIA HIGH SCHOOL  DISTRICT 27 5 2,514 $ 1.9 1 89 37 IWI FREEPORT SCHOOL DISTRICT 145  EMPIRE SCHOOL 5 31,705 $ 17.0 1 90 38 IWI CARL SANDBURG SCHOOL  DISTRICT 145 5 31,705 $ 17.0 1 91 39 IWI ROCK FALLS TOWNSHIP HIGH SCHOOL 5 15,074 $ 3.5 1 165 40 IWI ATHENS AREA SCHOOL DISTRICT 5 14,633 $ 12.3 1 184 41 IWI BURRELL SCHOOL DISTRICT 5 14,848 $ 8.9 1 195 42 IWI CHATTERTON JR HIGH SCHOOL 5 17,748 $ 13.3 1 234 117 IWI FITZGERALD HIGH SCHOOL 5 17,748 $ 13.3 1 437 43 IWI WALDRON AREA SCHOOLS 5 2,319 $ 1.8 1 469 43 IWI POWHATAN HIGH SCHOOL 5 22,377 $ 13.8 1 476 44 IWI HOLIDAYSBURG AREA SCHOOL DISTRICT 5 27,238 $ 18.2 1 477 45 IWI FOREST HILLS SCHOOL DISTRICT ( HI) HIGH SCHOOL 5 13,606 $ 9.2 1 479 46 IWI NORTHERN CAMBRIA SCHOOL DISTRICT ( ELE/ MI) 5 8,572 $ 6.1 1 480 45 IWI FOREST HILLS SCHOOL DISTRICT ( ELE) 5 13,606 $ 9.2 1 481 47 IWI CARMICHAELS AREA SCHOOL DISTRICT 5 7,120 $ 5.5 1 482 47 IWI CARMICHAELS AREA SCHOOL DISTRICT 5 7,120 $ 5.5 1 Nickerson Memorandum 1 August 15, 2005 Page 10 turning knowledge into practice Table 2. Characterization of OSWI Owners ( continued) Government Commercial RTI ID Owner Entity OSWI Type Facility Name Ownership Flag a Population Served ( in 2000) Revenue ($ Million) Annual Expenditure ($ Million) Sales ($ million) Employment Small, all nonprofits included 483 48 IWI PURCHASE LINE SCHOOL DISTRICT ( JR/ SR/ ELE) 5 7,687 $ 6.1 1 485 49 IWI TRINITY AREA SCHOOL DISTRICT 5 25,591 $ 18.0 1 486 50 IWI BURRELL SCHOOL DISTRICT ( ELE) 5 14,848 $ 8.9 1 487 51 IWI HEMPFIELD AREA SCHOOL DISTRICT ( SR.

HIGH) 5 48,464 $ 32.1 1 488 51 IWI HEMPFIELD AREA SCHOOL DISTRICT ( SR.

HIGH) 5 48,464 $ 32.1 1 490 52 IWI ELIZABETH FORWARD SCHOOL DISTRICT

MIDDLE SCHOOL INCINERATOR 5 19,219 $ 13.2 1 491 53 IWI KEYSTONE OAKS SCHOOL DISTRICT  HIGH SCHOOL INCINERATOR 5 22,172 $ 14.4 1 274 67 IWI JEFFERS HIGH SCHOOL 5 2,927 2.1 1 116 74 VSMWC AMPACET CORPORATION 6 $ 609 1,400 0 118 75 VSMWC BFI WASTE SYSTEMS OF NORTH AMERICA

RESERVE 6 $ 5,362 2,600 0 495 76 IWI VINCENTIAN HOME INC. ( SENIOR RESIDENCE HOME) 6 $ 13 300 0 142 77 VSMWC ENVIRONMENTAL SOLUTIONS LLC 6 $ 516 3,496 0 39 54 VSMWC SEAGULL SANITATION 6 $ 2 10 1 497 56 IWI GRANT COUNTY NURSING HOME 6 $ 3 156 1 391 113 IWI STEEPMEADOW CLUB INC 6 $ 0.08 4 1 97 4 IWI WIS DOA / UW MADISON CHARTER ST HEATING PLANT 7 5,364,000 $ 1,905.8 1 98 4 IWI WIS DOA / UW MADISON CHARTER ST HEATING PLANT 7 5,364,000 $ 1,905.8 1 99 4 IWI WIS DOA / UW MADISON CHARTER ST HEATING PLANT 7 5,364,000 $ 1,905.8 1 100 4 IWI WIS DOA / UW MADISON CHARTER ST HEATING PLANT 7 5,364,000 $ 1,905.8 1 ( continued) Nickerson Memorandum 1 August 15, 2005 Page 11 turning knowledge into practice Table 2. Characterization of OSWI Owners ( continued) Government Commercial RTI ID Owner Entity OSWI Type Facility Name Ownership Flag a Population Served ( in 2000) Revenue ($ Million) Annual Expenditure ($ Million) Sales ($ million) Employment Small, all nonprofits included 101 4 IWI UNIVERSITY OF WISCONSIN ( MAD) SAFETY DEPT 7 5,364,000 $ 1,905.8 1 307 55 IWI MARIAN MANOR HEALTHCARE CENTER 7 $ 2 150 1 4 78 IWI UNIV CAL, RIVERSIDE 7 33,872,000 $ 15,121.0 1 8 79 IWI KANSAS UNIVERSITY MEDICAL CENTER 7 2,688,000 $ 529.6 1 200 80 IWI COLORADO STATE UNIV 7 4,327,020 $ 562.9 1 399 81 IWI TEXAS A & M UNIVERSITY 7 20,949,136 $ 394.1 1 409 82 IWI UC DAVIS 7 33,872,000 $ 15,121.0 1 410 83 IWI UCSD/ CAMPUS 7 33,872,000 $ 15,121.0 1 411 84 IWI UCSF/ PARNASSUS 7 33,872,000 $ 15,121.0 1 412 85 IWI UNIVERSITY OF NE SWINE RESEARCH 7 1,713,239 $ 1,336.3 1 414 86 IWI UNIVERSITY 0F HOUSTON 7 20,949,136 $ 398.0 1 418 87 IWI UNIVERSITY OF ALABAMA AT BIRMINGHAM ( INCINERATOR) 7 4,452,307 $ 461.9 1 419 87 IWI UNIVERSITY OF ALABAMA AT BIRMINGHAM ( INCINERATOR) 7 4,452,307 $ 461.9 1 428 88 IWI UNL MANTER HALL 7 1,713,239 $ 1,336.3 1 436 89 IWI VPI & STATE UNIVERSITY 7 7,104,033 $ 564.6 1 462 90 IWI UNIVERSITY OF VIRGINIA  MEDICAL CENTER 7 7,104,033 $ 564.6 1 463 90 IWI UNIVERSITY OF VIRGINIA  MEDICAL CENTER 7 7,104,033 $ 564.6 1 464 90 IWI UNIVERSITY OF VIRGINIA  MEDICAL CENTER 7 7,104,033 $ 564.6 1 465 90 IWI UNIVERSITY OF VIRGINIA  MEDICAL CENTER 7 7,104,033 $ 564.6 1 472 91 IWI NORFOLK INTERNATIONAL AIRPORT 7 7,104,033 $ 564.6 1 42 92 VSMWC ORLANDO SANFORD INT'L AIRPORT 7 38,000 $ 242.6 650 1 61 57 IWI REGINA DOMINICAN HIGH SCHOOL 7 1 63 58 IWI MISERICORDIA SCHOOL  NORTH 7 1 Nickerson Memorandum 1 August 15, 2005 Page 12 turning knowledge into practice Table 2. Characterization of OSWI Owners ( continued) Government Commercial RTI ID Owner Entity OSWI Type Facility Name Ownership Flag a Population Served ( in 2000) Revenue ($ Million) Annual Expenditure ($ Million) Sales ($ million) Employment Small, all nonprofits included 178 93 IWI BOSTON UNIVERSITY # 2 7 $ 1,128.9 10400 1 179 94 IWI BOSTON UNIVERSITY ENGR & SCI CTR 7 $ 1,128.9 10400 1 217 95 IWI DUKE UNIVERSITY HEATING PLANT 7 $ 2,408 26,000 1 251 96 IWI HAMPTON UNIVERSITY 7 $ 171.0 1,050 1 302 97 IWI M. I. T. BLDG. # 56 ANIMAL CARE FACILITY 7 $ 1,832.3 7850 1 304 97 IWI M. I. T. COLLEGE OF HEALTH SCIENCE 7 $ 1,832.3 7850 1 344 98 IWI PURDUE UNIVERSITY WADE UTILITY PLANT 7 $ 688.8 1 374 99 IWI SOUTHERN RESEARCH INSTITUTE 7 $ 75.1 605 1 375 99 IWI SOUTHERN RESEARCH INSTITUTE 7 $ 75.1 605 1 379 59 IWI ST CLARE DE MONTEFALCO PARISH 7 $ 2.1 84 1 381 60 IWI ST GERARD PARISH 7 $ 165 1 390 100 IWI STANFORD UNIVERSITY 7 $ 3,743.9 15000 1 415 101 IWI UNIVERSITY OF ROCHESTER ( STRONG MEMORIAL HOSP.) 7 $ 1,808.9 13000 1 416 101 IWI UNIVERSITY OF ROCHESTER ( STRONG MEMORIAL HOSP.) 7 $ 1,808.9 13000 1 417 101 IWI UNIVERSITY OF ROCHESTER ( STRONG MEMORIAL HOSP.) 7 $ 1,808.9 13000 1 422 102 IWI UNIVERSITY OF IDAHO, HOLM RESEARCH CENTER 7 $ 160.9 1 426 103 IWI UNIVERSITY OF MARYLAND MEDICAL SCHOOL TEACHING FAC 7 $ 1,160.0 1 460 61 IWI PINEY FOREST HEALTHCARE DANVILLE 7 $ 9.3 180 1 461 104 IWI MARY WASHINGTON COLLEGE 7 $ 37.1 700 1 467 105 IWI RANDOPH MACON COLLEGE 7 $ 29.7 295 1 473 106 IWI LOUDOUN HOSPITAL CENTER  CORNWALL CAMPUS 7 $ 46.0 1000 1 474 107 IWI MWAA  WASHINGTON DULLES INTERNATIONAL AIRPORT 7 $ 442.2 1187 1 ( continued) Nickerson Memorandum 1 August 15, 2005 Page 13 turning knowledge into practice Table 2. Characterization of OSWI Owners ( continued) Government Commercial RTI ID Owner Entity OSWI Type Facility Name Ownership Flag a Population Served ( in 2000) Revenue ($ Million) Annual Expenditure ($ Million) Sales ($ million) Employment Small, all nonprofits included 475 108 IWI BRIDGEWATER COLLEGE 7 $ 25.3 270 1 489 62 IWI BISHOP MCCORT HIGH SCHOOL 7 1 492 63 IWI NORTH CATHOLIC HIGH SCHOOL

INCINERATOR, PYRONICS 7 1 493 64 IWI SISTERS OF THE HOLY SPIRIT 7 $ 1.2 42 1 494 65 IWI ST. ANGELA MERICI PARISH 7 $ 0.2 6 1 496 109 IWI DUKE UNIVERSITY HEATING PLANT 7 $ 2,408 26,000 1 159 66 IWI ALPENA COMM COLLEGE 7 $ 42.0 1 17 68 IWI KIRKSVILLE COLLEGE OF OSTEOPATHIC MEDICI COLLEGE 7 1 424 114 IWI UNIVERSITY OF ILLINOIS 7 $ 2,406 26,000 1 209 115 IWI DARTMOUTH COLLEGE 7 $ 569 5,000 1 420 116 IWI UNIVERSITY OF ALASKA 7 $ 323 6,629 1 TO: William Nickerson, EPA THROUGH: Gayle Kline, ICF FROM: Jeff Coburn Jamie Cajka Katherine Heller DATE: August 30, 2005 SUBJECT: Memorandum 2. Location of Small Entities and Possible Landfill Alternatives Purpose The purpose of this memorandum is to document the results of the GIS analysis. The GIS analysis was used to identify rural institutional waste incinerators ( IWI) and to identify the nearest landfills for each other solid waste incinerator ( OSWI) unit.

Approach to Locating Small OSWI and Landfills As described in an earlier Memorandum, RTI compiled a list of potential OSWI units that are believed to be operating and covered by the proposed rule. The list of OSWI units, along with a file of solid waste landfills ( from the Chartwell Atlas database), were submitted for GIS processing so they could be mapped to the nearest two landfills using straightline distances. Attachment 1 provides a summary of the GIS processing steps used. The GIS analysis output results file was then combined with the OSWI and landfill databases to pull in tipping fees and other relevant information.

Discussion of Results Seven IWIs were identified that met the definition of a rural IWI by being more than 50 miles from the border of a metropolitan statistical area ( MSA). These 7 rural IWIs are listed in Table 1. Under the provisions of the final rule, these 7 rural IWIs may petition for exemption. These rural OSWI were flagged in the database.

The compiled results file that combines the GIS output file with the OSWI and landfill databases is provided below. Table 2 provides a description of the fields in the compiled results sheet. Table 3 shows OSWI specific findings. Nickerson Memorandum 2 August 30, 2005 Page 2 Table 1. Rural IWIs that may petition for exemption ( IWIs more than 50 miles from the border of an MSA)   flagged in database RTI ID State Facility Identifier Facility Name City State 17 0036 KIRKSVILLE COLLEGE OF OSTEOPATHIC MEDICINE KIRKSVILLE MO 159 26007E212 ALPENA COMM COLLEGE ALPENA MI 209 RTI13 DARTMOUTH COLLEGE HANOVER NH 274 26061E211 JEFFERS HIGH SCHOOL PAINESDALE MI 290 484650003 LAUGHLIN AIR FORCE BASE DEL RIO TX 420 RTI403 UNIVERSITY OF ALASKA FAIRBANKS AK 432 22900005 USAF CLEAR CLEAR USA AK Table 2. Description of Electronic Results File Summarized in Table 3 Column Heading Description RTI_ ID OSWI facility code in Task 1 database OSWI Name Facility name with OSWI unit City City location of OSWI unit State State location of OSWI unit LF_ CODE_ 1 Landfill facility code for nearest landfill TIP_ FEE_ 1 Tipping fee charged by nearest landfill ($/ ton) RoadDist1 ( miles) Road distance to nearest landfill ( miles) LF_ CODE_ 2 Landfill facility code for 2nd closest landfill TIP_ FEE_ 2 Tipping fee charged by 2nd closest landfill ($/ ton) RoadDist2 ( miles) Road distance to 2nd closest landfill ( miles) ATTACHMENT 1 Synopsis of OSWI Project GIS Processing Inputs Two Excel files were received on 08/ 24/ 05: OSWI_ open_ 2005. xls and LFdata. xls. The former contained two sheets: IWI ( institutional waste incinerators) and VSMWC ( very small municipal waste combustors). Although approximately 1/ 3 of the records had a longitude and latitude value, all records had an address.

Processing These two sheets were combined into a single dbase file and sent to TeleAtlas via ftp for geocoding. Geocoding is the process of matching an address to a database of street names and address ranges. Once an address has been located along a street, the location is converted to a latitude and longitude. Those IWI or VSMWC records that did not have a latitude and longitude were given one based on the geocoded address. The landfills all had latitude and longitude values so they did not need to be sent to TeleAtlas for geocoding. Addresses that could not be matched to a location were moved to the correct location by hand. The correct location was determined by a variety of internet mapping sites.

The two files containing latitude and longitude values were loaded into ArcGIS and converted into spatially referenced shapefiles. A layer of Metropolitan Statistical Areas ( MSAs) were also loaded into the GIS and buffered to a distance of 50 miles. All IWI facilities greater than 50 miles from an MSA ( 7 facilities) were identified and flagged, because they may petition for exemption.

All shapefiles ( remaining IWI merged with VSMWC, and landfills) were projected into equidistant conic projection that would allow the correct distances to be calculated between points. A pointdistance tool within ArcGIS was used to calculate the distance between all input IWI/ VSMWC facilities and land fills. The closest two landfill ids were recorded as well as their respective distances from the IWI/ VSMWC facilities.

Outputs A file called summary_ statistics_ by_ RTI_ ID. dbf was generated containing the RTI_ ID, the landfill codes, and the distances. Nickerson Memorandum 2 August 30, 2005 Page 4 turning knowledge into practice Table 3. Landfill Data for OSWI Units RTI_ ID Owner ID OSWI Name State > 50mi MSA LF_ CODE_ 1 TipFee_ 1 ($/ ton) RoadDist1 ( miles) LF_ CODE_ 2 TipFee_ 2 ($/ ton) RoadDist2 ( miles)

1 1 NAVAL AIR WEAPONS STATION CA 0 CA0042 29 2.1 CA0037 29 3.78 9 1 NATIONAL SECURITY AGENCY MD 0 MD0119 66.25 7.28 MD0013 65 7.98 10 1 NATIONAL SECURITY AGENCY MD 0 MD0119 66.25 7.28 MD0013 65 7.98 11 1 NAVAL SURFACE WARFARE CNTR INDIAN HD MD 0 VA0187 45 14.14 VA0058 45 20.16 12 1 NAVAL SURFACE WARFARE CNTR INDIAN HD MD 0 VA0187 45 14.14 VA0058 45 20.16 18 1 MALMSTROM AFB MT 0 MT0004 24.86 9.94 MT0032 19.5 82.32 19 1 LOS ALAMOS NATIONAL LABORATORY NM 0 NM0009 12.5 1.54 NM0069 25 23.94 20 1 US DEPARTMENT OF THE ARMY NV 0 NV0126 18.85 7.84 NV0014 24 43.4 21 1 TINKER AFB US AIR FORCE LOGISTICS CTR OK 0 OK0093 40.45 6.86 OK0092 16.5 8.26 23 1 US NAVY: WEAPONS STATION SC 0 SC0114 29.25 10.92 SC0037 59.5 15.12 24 1 US AIRFORCE: CHARLESTON AFB SC 0 SC0114 29.25 1.68 SC0037 59.5 20.72 25 1 US AIRFORCE: SHAW AFB SC 0 SC0043 38 8.96 SC0020 33 25.2 26 1 MAIN BASE UT 0 UT0007 25 3.36 UT0005 29.5 9.94 93 1 US ARMY  FORT BELVOIR VA 0 VA0187 45 20.58 MD0067 61 21.7 122 1 NAVY SALVAGE FUEL BOILER PLANT VA 0 VA0314 20 7.42 VA0355 38.55 13.44 152 1 101ST AIRBORNE DIV./ FORT CAMPBELL TN 0 TN0049 33 27.02 TN0020 112.15 33.04 153 1 88 ABW/ EMP OH 0 OH0349 35.5 11.06 OH0102 29.88 11.06 290 1 LAUGHLIN AIR FORCE BASE TX 1 TX0184 24.83 3.64 TX0137 25.84 57.4 322 1 NAVAL SECURITY GRP ACTIVITY WINTER HBR ME 0 ME0029 59.57 67.9 ME0290 59.57 77.98 323 1 NAVAL SECURITY GRP ACTIVITY WINTER HBR ME 0 ME0029 59.57 67.9 ME0290 59.57 77.98 324 1 NAVAL SURFACE WARFARE CENTER CRANE IN 0 IN0170 23.5 22.82 IN0112 28 42.98 340 1 PETERSON AFB 21CES CEV CO 0 CO0043 26.25 7.84 CO0210 21 12.6 408 1 U. S. ARMY AIR DEFENSE ART TX 0 TX0563 24 7.28 NM0025 24.6 14.84 431 1 US MILITARY ACADEMY NY 0 NY0047 25.25 28.14 NY0025 60 29.26 432 1 USAF CLEAR AK 1 AK0044 54.31 58.8 AK0072 50 64.82 471 1 US DEPARTMENT OF JUSTICE FBI VA 0 VA0449 50 7.42 VA0490 41 7.84 498 1 NAVAL SECURITY GROUP ACTIVITY WV 0 VA0086 29 32.76 VA0106 40 33.6 2 2 CALIF. DEPT. OF FOOD & AG. CA 0 CA0506 24.84 34.02 NV0001 11.19 36.12 3 2 CALIF. DEPT. OF FOOD & AG. CA 0 CA0506 24.84 34.02 NV0001 11.19 36.12 186 2 CALIF CORRECTIONAL CENTER CA 0 CA0455 20.25 5.6 CA0045 27 28.28 ( continued) Nickerson Memorandum 2 August 30, 2005 Page 5 turning knowledge into practice Table 3. Landfill Data for OSWI Units ( continued)

RTI_ ID Owner ID OSWI Name State > 50mi MSA LF_ CODE_ 1 TipFee_ 1 ($/ ton) RoadDist1 ( miles) LF_ CODE_ 2 TipFee_ 2 ($/ ton) RoadDist2 ( miles)

22 3 PA DEPT OF CORR/ DALLAS SCI PA 0 PA0083 55 24.36 PA0088 72 31.78 97 4 WIS DOA / UW MADISON CHARTER ST HEATING PLANT WI 0 WI0007 36 7.84 WI0008 34.5 18.34 98 4 WIS DOA / UW MADISON CHARTER ST HEATING PLANT WI 0 WI0007 36 7.84 WI0008 34.5 18.34 99 4 WIS DOA / UW MADISON CHARTER ST HEATING PLANT WI 0 WI0007 36 7.84 WI0008 34.5 18.34 100 4 WIS DOA / UW MADISON CHARTER ST HEATING PLANT WI 0 WI0007 36 7.84 WI0008 34.5 18.34 101 4 UNIVERSITY OF WISCONSIN ( MAD) SAFETY DEPT WI 0 WI0007 36 8.4 WI0008 34.5 18.2 299 5 LOUISIANA STATE PENITENTIARY LA 0 LA0148 25.69 38.08 LA0042 25 38.5 309 6 MARYLAND DEPARTMENT OF HEARTH &

MENTAL HYGIENE PUB MD 0 MD0031 67.5 9.66 MD0119 66.25 15.26 325 7 NE GAME & PARKS COMMISSION NE 0 NE0026 17 2.52 NE0016 32 28.42 439 8 WASH STATE PARK & RECREATION COMM WA 0 WA0053 66.3 3.36 WA0482 92.45 42.7 499 9 WVDEP OFFICE OF WASTE MANAGEMENT WV 0 MD0087 30 30.8 PA0090 44.5 37.66 38 10 LA CO., SANITATION DIST CA 0 CA0485 39.56 11.06 CA0096 27 13.16 120 11 CARTER COUNTY AIR CURTAIN DESTRUCTION TN 0 TN0175 32.16 10.78 VA0263 26.5 25.62 285 12 KALAMAOO VALLEY COMM CO MI 0 MI0888 36.6 15.82 MI0039 37.5 30.94 293 13 ELGIN CUMMUNITY COLLEGE IL 0 IL0020 45 2.66 IL0062 45.15 16.38 470 14 HENRICO COUNTY POLICE VA 0 VA0449 50 6.02 VA0490 41 8.12 ( continued) Nickerson Memorandum 2 August 30, 2005 Page 6 turning knowledge into practice Table 3. Landfill Data for OSWI Units ( continued)

RTI_ ID Owner ID OSWI Name State > 50mi MSA LF_ CODE_ 1 TipFee_ 1 ($/ ton) RoadDist1 ( miles) LF_ CODE_ 2 TipFee_ 2 ($/ ton) RoadDist2 ( miles)

484 15 MERCER COUNTY VO TECH PA 0 OH0091 36 28.84 OH0092 22 39.62 500 16 HUNTINGTON SANITARY BOARD WV 0 KY0216 33.83 16.52 KY0005 35 17.08 121 17 CITY OF ALCOA INCINERATOR TN 0 TN0014 26 0.14 TN0039 33.57 27.72 129 18 CITY OF SOUTHSIDE PLACE INCINERATOR TX 0 TX0250 12.3 8.12 TX0236 30.3 8.12 130 19 TOWN OF READSBORO INCINERATOR VT 0 VT0050 26.04 MA0745 35.7 132 20 SILOAM SPRINGS AR 0 AR0074 36 23.1 OK0001 15.5 43.96 138 21 CITY OF LUFKIN TX 0 TX0002 17.25 11.9 TX0146 25.26 27.02 139 22 CITY OF NORFOLK WASTE FACILITY NE 0 NE0058 27.55 37.24 NE0018 26 69.44 140 23 CITY OF SULPHUR SPRINGS TX 0 TX0538 29.85 21.98 TX0175 22.5 47.6 143 24 OSSIPEE INCINERATOR FACILITY NH 0 NH0119 67 7.42 NH0060 67 11.06 144 25 TOWN OF CANDIA NH 0 NH0027 82 10.08 NH0131 82 29.96 145 26 TOWN OF LITCHFIELD INCINERATOR &

RECYCLING FACILITY NH 0 NH0131 107.6 12.04 NH0052 107.6 13.16 146 27 WILTON RECYCLING CENTER NH 0 NH0053 16.67 8.68 NH0131 16.67 10.08 149 28 HEBRON BRIDGEWATER REFUSE DISTRICT NH 0 NH0037 77.91 13.16 NH0077 77.91 25.9 6 29 GRAYSLAKE COMMUNITY HIGH SCHOOL 127 IL 0 IL0067 36 0.42 IL0065 38.5 13.72 45 30 GROSS SCHOOL DIST 95 IL 0 IL0030 45.5 5.6 IL0032 38 12.04 ( continued) Nickerson Memorandum 2 August 30, 2005 Page 7 turning knowledge into practice Table 3. Landfill Data for OSWI Units ( continued)

RTI_ ID Owner ID OSWI Name State > 50mi MSA LF_ CODE_ 1 TipFee_ 1 ($/ ton) RoadDist1 ( miles) LF_ CODE_ 2 TipFee_ 2 ($/ ton) RoadDist2 ( miles)

57 31 DIEKMAN SCHOOL  DISTRICT 149 IL 0 IL0236 37.5 2.66 IN0061 50 16.8 58 32 BERGER VANDENBERG SCHOOL IL 0 IL0236 37.5 2.94 IN0061 50 17.36 66 33 MARQUARDT SCHOOL DISTRICT 15 IL 0 IL0030 45.5 12.74 IL0020 45 18.2 69 34 JACKSON JUNIOR HIGH SCHOOL IL 0 IL0030 45.5 6.16 IL0208 37.5 17.08 72 35 PIONEER SCHOOL IL 0 IL0062 45.15 7.28 IL0020 45 13.16 79 36 TRIOPIA HIGH SCHOOL  DISTRICT 27 IL 0 IL0110 25.5 41.16 IL0120 41 55.02 89 37 FREEPORT SCHOOL DISTRICT 145  EMPIRE SCHOOL IL 0 IL0129 35 5.32 IL0297 47.5 42.84 90 38 CARL SANDBURG SCHOOL  DISTRICT 145 IL 0 IL0129 35 5.32 IL0297 47.5 43.26 91 39 ROCK FALLS TOWNSHIP HIGH SCHOOL IL 0 IL0296 36 21 IL0055 20.15 21.42 165 40 ATHENS AREA SCHOOL DISTRICT PA 0 NY0740 55 16.1 NY0296 55 16.1 184 41 BURRELL SCHOOL DISTRICT PA 0 PA0101 63 14.56 PA0073 63 24.36 195 42 CHATTERTON JR HIGH SCHOOL MI 0 MI1623 30.05 23.94 MI0074 39 24.92 234 117 FITGERALD HIGH SCHOOL MI 0 MI1623 30.05 23.8 MI0074 39 25.62 437 43 WALDRON AREA SCHOOLS MI 0 OH0142 43.5 27.3 MI0062 50.76 31.22 469 43 POWHATAN HIGH SCHOOL VA 0 VA0490 41 19.32 VA0083 50 19.6 476 44 HOLLIDAYSBURG AREA SCHOOL DISTRICT PA 0 PA0078 53.5 30.1 PA0072 42 39.76 ( continued) Nickerson Memorandum 2 August 30, 2005 Page 8 turning knowledge into practice Table 3. Landfill Data for OSWI Units ( continued)

RTI_ ID Owner ID OSWI Name State > 50mi MSA LF_ CODE_ 1 TipFee_ 1 ($/ ton) RoadDist1 ( miles) LF_ CODE_ 2 TipFee_ 2 ($/ ton) RoadDist2 ( miles)

477 45 FOREST HILLS SCHOOL DISTRICT ( ELE/ HI) PA 0 PA0193 48.54 17.08 PA0072 42 20.3 480 45 FOREST HILLS SCHOOL DISTRICT ( ELE) PA 0 PA0193 48.54 17.08 PA0072 42 20.3 479 46 NORTHERN CAMBRIA SCHOOL DISTRICT ( ELE/ MI) PA 0 PA0072 42 19.04 PA0110 44.76 31.5 481 47 CARMICHAELS AREA SCHOOL DISTRICT PA 0 PA0090 44.5 9.24 PA0108 35 25.48 482 47 CARMICHAELS AREA SCHOOL DISTRICT PA 0 PA0090 44.5 9.24 PA0108 35 25.48 483 48 PURCHASE LINE SCHOOL DISTRICT ( JR/ SR/ ELE) PA 0 PA0072 42 23.38 PA0110 44.76 27.58 485 49 TRINITY AREA SCHOOL DISTRICT PA 0 PA0077 50 0.56 PA0087 52 24.92 486 50 BURRELL SCHOOL DISTRICT ( ELE) PA 0 PA0101 63 14.56 PA0073 63 24.36 487 51 HEMPFIELD AREA SCHOOL DISTRICT ( SR. HIGH) PA 0 PA0114 50.54 3.64 PA0073 63 15.4 488 51 HEMPFIELD AREA SCHOOL DISTRICT ( SR. HIGH) PA 0 PA0114 50.54 3.64 PA0073 63 15.4 490 52 ELIZABETH FORWARD SCHOOL DISTRICT

MIDDLE SCHOOL INCINERATOR PA 0 PA0096 52.38 2.24 PA0073 63 8.82 491 53 KEYSTONE OAKS SCHOOL DISTRICT  HIGH SCHOOL INCINERATOR PA 0 PA0087 52 4.34 PA0099 67.64 4.48 39 54 SEAGULL SANITATION CA 0 CA0058 9.94 CA1613 40.88 307 55 MARIAN MANOR HEALTHCARE CENTER ND 0 ND0036 26.05 0.14 ND0042 21 55.44 497 56 GRANT COUNTY NURSING HOME WV 0 WV0020 37 29.54 VA0089 36 46.06 61 57 REGINA DOMINICAN HIGH SCHOOL IL 0 IL0208 37.5 9.38 IL0033 34.5 13.3 ( continued) Nickerson Memorandum 2 August 30, 2005 Page 9 turning knowledge into practice Table 3. Landfill Data for OSWI Units ( continued)

RTI_ ID Owner ID OSWI Name State > 50mi MSA LF_ CODE_ 1 TipFee_ 1 ($/ ton) RoadDist1 ( miles) LF_ CODE_ 2 TipFee_ 2 ($/ ton) RoadDist2 ( miles)

63 58 MISERICORDIA SCHOOL  NORTH IL 0 IL0208 37.5 12.04 IL0032 38 17.78 379 59 ST CLARE DE MONTEFALCO PARISH MI 0 MI0084 26 26.04 MI1623 30.05 31.64 381 60 ST GERARD PARISH MI 0 MI1623 30.05 11.62 MI0070 42 17.22 460 61 PINEY FOREST HEALTHCARE DANVILLE VA 0 VA0072 30 15.12 VA0038 15 21.7 489 62 BISHOP MCCORT HIGH SCHOOL PA 0 PA0193 48.54 7.98 PA0072 42 18.2 492 63 NORTH CATHOLIC HIGH SCHOOL

INCINERATOR, PYRONICS PA 0 PA0099 67.64 3.78 PA0087 52 9.38 493 64 SISTERS OF THE HOLY SPIRIT PA 0 PA0099 67.64 7 PA0087 52 11.06 494 65 ST. ANGELA MERICI PARISH PA 0 PA0073 63 7.14 PA0096 52.38 8.26 159 66 ALPENA COMM COLLEGE MI 1 MI0289 36.6 5.74 MI0108 33 40.18 274 67 JEFFERS HIGH SCHOOL MI 1 MI0012 60 39.06 MI0010 60 83.02 17 68 KIRKSVILLE COLLEGE OF OSTEOPATHIC MEDICI COLLEGE MO 1 MO0009 19.5 0.28 MO0042 38.27 42.56 46 69 GOODWIN ELEM SCHOOL IL 0 IL0032 38 6.86 IL0030 45.5 9.66 48 69 WOODBINE SCHOOL DISTRICT 99 IL 0 IL0032 38 5.18 IL0030 45.5 11.34 49 69 SHERLOCK SCHOOL IL 0 IL0032 38 6.3 IL0030 45.5 10.5 52 69 DREXEL SCHOOL DISTRICT 99 IL 0 IL0032 38 5.32 IL0030 45.5 11.2 53 69 COLUMBUS SCHOOL DISTRICT 99 IL 0 IL0032 38 5.6 IL0030 45.5 10.78 55 69 MCKINLEY SCHOOL IL 0 IL0032 38 7.84 IL0030 45.5 9.38 56 69 LINCOLN SCHOOL  DISTRICT 99 IL 0 IL0032 38 6.58 IL0030 45.5 10.08 501 69 CICERO EAST SCHOOL DIST 99 IL 0 IL0032 38 6.16 IL0030 45.5 10.5 ( continued) Nickerson Memorandum 2 August 30, 2005 Page 10 turning knowledge into practice Table 3. Landfill Data for OSWI Units ( continued)

RTI_ ID Owner ID OSWI Name State > 50mi MSA LF_ CODE_ 1 TipFee_ 1 ($/ ton) RoadDist1 ( miles) LF_ CODE_ 2 TipFee_ 2 ($/ ton) RoadDist2 ( miles)

81 70 SPRINGFIELD PUBLIC SCHOOLS DISTRICT 186 IL 0 IL0120 41 3.08 IL0013 27 35.56 82 70 SPRINGFIELD HIGH SCHOOL  DISTRICT 186 IL 0 IL0120 41 2.66 IL0013 27 35.14 83 70 WASHINGTON MIDDLE SCHOOL  DISTRICT 186 IL 0 IL0120 41 3.64 IL0013 27 35.84 84 70 SOUTHEAST HIGH SCHOOL  DISTRICT 186 IL 0 IL0120 41 0.98 IL0013 27 31.5 85 70 LANPHIER HIGH SCHOOL  DISTRICT 186 IL 0 IL0120 41 3.08 IL0013 27 35.14 87 70 FRANKLIN MIDDLE SCHOOL  DISTRICT 186 IL 0 IL0120 41 3.22 IL0013 27 34.16 65 71 ADDISON TRAIL HIGH SCHOOL DISTRICT 88 IL 0 IL0030 45.5 10.36 IL0208 37.5 15.12 459 72 CONCORD ELEMENTARY SCHOOL VA 0 VA0064 48 11.34 VA0060 39 14 468 73 JOHN M GANDY ELEMENTARY SCHOOL VA 0 VA0054 50 10.92 VA0449 50 11.06 116 74 AMPACET CORPORATION LA 0 TX0523 23 45.36 TX0829 21 48.72 118 75 BFI WASTE SYSTEMS OF NORTH AMERICA

RESERVE LA 0 LA0076 25.69 8.4 LA0137 25.69 11.48 495 76 VINCENTIAN HOME INC. ( SENIOR RESIDENCE HOME) PA 0 PA0099 67.64 11.9 PA0087 52 15.26 142 77 ENVIRONMENTAL SOLUTIONS LLC MN 0 MN0196 48 23.1 MN0130 60 24.36 4 78 UNIV CAL, RIVERSIDE CA 0 CA0102 30.54 8.54 CA0133 36.34 9.38 8 79 KANSAS UNIVERSITY MEDICAL CENTER KS 0 KS0120 43 5.88 KS0049 39 13.72 200 80 COLORADO STATE UNIV CO 0 CO0081 15.12 7 CO0162 27.75 25.9 399 81 TEXAS A & M UNIVERSITY TX 0 TX0018 23.5 9.1 TX0597 25.84 79.24 409 82 UC DAVIS CA 0 CA0209 0 0.7 CA0208 36 0.7 ( continue) Nickerson Memorandum 2 August 30, 2005 Page 11 turning knowledge into practice Table 3. Landfill Data for OSWI Units ( continued)

RTI_ ID Owner ID OSWI Name State > 50mi MSA LF_ CODE_ 1 TipFee_ 1 ($/ ton) RoadDist1 ( miles) LF_ CODE_ 2 TipFee_ 2 ($/ ton) RoadDist2 ( miles)

410 83 UCSD/ CAMPUS CA 0 CA0147 41 16.8 CA0148 49.75 22.12 411 84 UCSF/ PARNASSUS CA 0 CA0162 49.5 7.7 CA0008 58 19.6 412 85 UNIVERSITY OF NE SWINE RESEARCH NE 0 NE0035 27.81 28.28 NE0026 17 33.32 414 86 UNIVERSITY 0F HOUSTON TX 0 TX0250 12.3 3.78 TX0236 30.3 3.78 418 87 UNIVERSITY OF ALABAMA AT BIRMINGHAM ( INCINERATOR) AL 0 AL0116 29 2.1 AL0050 45 8.96 419 87 UNIVERSITY OF ALABAMA AT BIRMINGHAM ( INCINERATOR) AL 0 AL0116 29 2.1 AL0050 45 8.96 428 88 UNL MANTER HALL NE 0 NE0026 17 0.56 NE0016 32 26.46 436 89 VPI & STATE UNIVERSITY VA 0 VA0448 31.5 24.92 VA0029 38.55 33.18 462 90 UNIVERSITY OF VIRGINIA  MEDICAL CENTER VA 0 VA0021 43 10.64 VA0352 52 25.2 463 90 UNIVERSITY OF VIRGINIA  MEDICAL CENTER VA 0 VA0021 43 10.64 VA0352 52 25.2 464 90 UNIVERSITY OF VIRGINIA  MEDICAL CENTER VA 0 VA0021 43 10.64 VA0352 52 25.2 465 90 UNIVERSITY OF VIRGINIA  MEDICAL CENTER VA 0 VA0021 43 10.64 VA0352 52 25.2 472 91 NORFOLK INTERNATIONAL AIRPORT VA 0 VA0314 20 11.9 VA0104 20 14.28 42 92 ORLANDO SANFORD INT'L AIRPORT FL 0 FL0223 33.17 14 FL0250 30.65 27.16 178 93 BOSTON UNIVERSITY # 2 MA 0 MA0650 43.5 15.96 MA0055 69.94 19.32 179 94 BOSTON UNIVERSITY ENGR & SCI CTR MA 0 MA0650 43.5 15.96 MA0055 69.94 19.32 217 95 DUKE UNIVERSITY HEATING PLANT NC 0 NC0083 45 16.94 NC0115 29.5 23.94 ( continued) Nickerson Memorandum 2 August 30, 2005 Page 12 turning knowledge into practice Table 3. Landfill Data for OSWI Units ( continued)

RTI_ ID Owner ID OSWI Name State > 50mi MSA LF_ CODE_ 1 TipFee_ 1 ($/ ton) RoadDist1 ( miles) LF_ CODE_ 2 TipFee_ 2 ($/ ton) RoadDist2 ( miles)

251 96 HAMPTON UNIVERSITY VA 0 VA0418 27.5 10.5 VA0314 20 13.3 302 97 M. I. T. BLDG. # 56 ANIMAL CARE FACILITY MA 0 MA0650 43.5 15.54 MA0055 69.94 19.32 304 97 M. I. T. COLLEGE OF HEALTH SCIENCE MA 0 MA0650 43.5 15.54 MA0055 69.94 19.32 344 98 PURDUE UNIVERSITY WADE UTILITY PLANT IN 0 IN0017 32 32.62 IN0139 30.65 34.44 374 99 SOUTHERN RESEARCH INSTITUTE AL 0 AL0116 29 2.1 AL0050 45 8.82 375 99 SOUTHERN RESEARCH INSTITUTE AL 0 AL0116 29 2.1 AL0050 45 8.82 390 100 STANFORD UNIVERSITY CA 0 CA0170 75 3.22 CA0001 55.77 18.2 415 101 UNIVERSITY OF ROCHESTER ( STRONG MEMORIAL HOSP.) NY 0 NY0310 48 15.26 NY0317 45 17.92 416 101 UNIVERSITY OF ROCHESTER ( STRONG MEMORIAL HOSP.) NY 0 NY0310 48 15.26 NY0317 45 17.92 417 101 UNIVERSITY OF ROCHESTER ( STRONG MEMORIAL HOSP.) NY 0 NY0310 48 15.26 NY0317 45 17.92 422 102 UNIVERSITY OF IDAHO, HOLM RESEARCH CENTER ID 0 ID0011 55 9.52 WA0058 69 10.64 426 103 UNIVERSITY OF MARYLAND MEDICAL SCHOOL TEACHING FAC MD 0 MD0031 67.5 8.68 MD0119 66.25 13.86 461 104 MARY WASHINGTON COLLEGE VA 0 VA0271 42 7.84 VA0101 36 9.1 467 105 RANDOPH MACON COLLEGE VA 0 VA0449 50 10.5 VA0054 50 10.78 473 106 LOUDOUN HOSPITAL CENTER  CORNWALL CAMPUS VA 0 VA0062 55 6.02 VA0489 55 7.42 474 107 MWAA  WASHINGTON DULLES INTERNATIONAL AIRPORT VA 0 VA0489 55 14.84 VA0062 55 16.52 ( continued) Nickerson Memorandum 2 August 30, 2005 Page 13 turning knowledge into practice Table 3. Landfill Data for OSWI Units ( continued)

RTI_ ID Owner ID OSWI Name State > 50mi MSA LF_ CODE_ 1 TipFee_ 1 ($/ ton) RoadDist1 ( miles) LF_ CODE_ 2 TipFee_ 2 ($/ ton) RoadDist2 ( miles)

475 108 BRIDGEWATER COLLEGE VA 0 VA0086 29 8.4 VA0106 40 19.6 496 109 DUKE UNIVERSITY HEATING PLANT NC 0 NC0083 45 15.4 NC0115 29.5 25.48 124 110 SMITH ISLAND INCINERATOR MD 0 MD0091 52 24.08 MD0073 35 28.28 134 111 CITY OF AURORA IL 0 IL0062 45.2 9.7 IL0020 45.0 24.1 150 112 SHELBY COUNTY COMMUNITY SERVICES IL 0 IL0191 33.6 IL0013 40.3 391 113 STEEPMEADOW CLUB INC IL 0 IL0118 24.0 6.6 IL0117 36.0 9.9 424 114 UNIVERSITY OF ILLINOIS IL 0 IL0136 28.0 45.9 IL0176 31.0 53.3 209 115 DARTMOUTH COLLEGE NH 1 NH0037 69.26 27.02 NH0045 60.6 38.92 420 116 UNIVERSITY OF ALASKA AK 1 AK0044 54.31 11.34 AK0072 50 23.94 TO: William Nickerson, EPA THROUGH: Gayle Kline, ICF FROM: Jeff Coburn Tom Holloway Katherine Heller DATE: September 12, 2005 SUBJECT: Memorandum 3. Selection of Small Entities for Detailed Cost Analysis Background RTI is supporting EPA in evaluating potential small entity impacts associated with EPA's proposed rule regulating emissions from Other Solid Waste Incinerators ( OSWI), to address concerns voiced by the Small Business Administration and other commenters on the proposed rule. The model plant analysis conducted for the proposal indicated that most OSWI would incur no additional cost or perhaps a slight savings by shutting down their waste combustion unit and sending the waste to a landfill. This memorandum describes the methods used in this supplemental analysis to estimate the costs of compliance with the proposed rule and the costs of switching to landfilling, and the criteria used to identify small entities for detailed cost analysis.

Previous memoranda have described RTI's process for identification of OSWI units that are currently operating and in scope for the regulation, characterizing their ownership by type, size and location, and identifying the two landfills located closest to each OSWI.

RTI identified 173 OSWI units still operating and in scope. Of these, 7 were identified as being located farther than 50 miles from the border of an MSA. Because these " rural" OSWI have the option of petition for exemption from the rule, these units were flagged in the database.

Of the 173 OSWI, RTI identified 48 units that are owned by small entities, as defined by the Regulatory Flexibility Act as amended by the Small Business Regulatory Enforcement Fairness Act ( RFA/ SBREFA). These include 45 units owned by small governments and 3 units owned by small businesses. These units are assigned a small business flag of " 1" in the database. The RFA/ SBREFA criteria for small nonprofit organizations is somewhat ambiguous (" independently owned" and " not dominant"). To avoid arbitrarily identifying nonprofit organizations as dominant or not dominant, RTI classified all nonprofit organizations as potentially small and treats them, at least for tabulation purposes, as small entities. These units are assigned a small business flag of " 2" in the database. Thus, there are a total of 108 OSWI units owned by small or potentially small entities. For all of the small or potentially small OSWI units, RTI identified the two nearest landfills, and compiled data on distance to the landfills and tipping fees at the landfills. Nickerson Memorandum 3 September 12, 2005 Page 2 Estimating Costs for Compliance or Switching to Landfilling Estimating landfill switching costs ( Option 1)

RTI first estimated the cost of landfilling waste currently being incinerated, for each OSWI. RTI computed landfill costs based on actual throughput data where available, and based on incinerator capacity when actual throughput data was not reported. Missing data were filled based on reported capacities and operating days. We developed separate statistics for Very Small Municipal Waste Combustors ( VSMWCs) and Institutional Waste Incinerators ( IWIs). Using the units that reported throughput data, we calculated a lower end capacity estimate using the 10th percentile throughput for each class of incinerator ( VSMWCs and IWIs), a midrange capacity estimate using the arithmetic average throughput, and an upper end capacity estimate using the 90th percentile throughput.

We assumed a hauling fee of $ 0.50/ ton/ mile. Using these data, we calculated the estimated disposal cost for the closest and second closest landfills. Landfill distances and tipping fees were based on site specific data for each OSWI. We selected the lower of these land disposal costs as the landfill cost.

EPA had estimated at proposal that landfilling would often represent absolute cost savings relative to baseline incinerator costs. To test this assertion, we estimated baseline incineration costs using site specific incinerator throughput data as described above and a regression of the incinerator operating costs that were developed for the proposal. We excluded capital recovery because this cost will be incurred whether the incinerator is operating or not. We conducted separate regressions for the incinerator operation and maintenance ( O& M) cost and the property tax, insurance, and administration cost, because O& M cost tends to behave more linearly than other costs. We tried various types of regressions ( linear, power, logarithmic, etc.) on each cost, and chose the regression equation with the best R2 value. We found the best results when the batch OSWI units were considered separately from the intermittent OSWI units in the regression. Consequently, we developed separate equations for batch and intermittent OSWI units, assuming zero cost at zero throughput for the batch units. The switch point between the batch and intermittent OSWI equations was identified by determining where the two equations intersect ( i. e., are equal to one another). Tables 1 and 2 below show the cost data we used in the regression, as well as the regression equations we chose to determine the incinerator operation costs. The x and y coordinates for the equations are also identified.

After we determined the incinerator operation costs, we calculated net switching costs as landfill cost minus incinerator operating costs. Negative switching costs indicated OSWI for which landfilling represents an absolute cost savings. Of the 173 OSWI believed to be in scope and operating, 161 are estimated to experience cost savings if they switch to landfilling their waste; only 12 are projected to incur any positive costs by switching to landfilling at baseline, based on these calculations. Nickerson Memorandum 3 September 12, 2005 Page 3 Table 1. Regression Results for O& M Costs Capacity, tpd 1 5 15 30 Waste flow, tpy ( x) 121 290 870 1740 Electricity $ 71 $ 587 $ 1,426 $ 2,684 Natural gas $ 3,905 $ 4,764 $ 10,490 $ 19,078 Water $ 0 $ 20 $ 60 $ 121 Operating labor $ 2,182 $ 11,947 $ 11,947 $ 11,947 Supervisory labor $ 327 $ 1,792 $ 1,792 $ 1,792 Maintenance labor $ 2,143 $ 1,837 $ 1,837 $ 1,837 Maintenance materials $ 1,285 $ 2,736 $ 4,504 $ 6,169 Ash disposal $ 436 $ 1,044 $ 3,132 $ 6,263 PC refractory replacement $ 1,065 $ 1,769 $ 3,260 $ 4,959 SC refractory replacement $ 561 $ 1,443 $ 2,851 $ 4,416 Overhead $ 3,563 $ 10,988 $ 12,049 $ 13,047 Total O& M 3rd qtr 1998 $ 15,538 $ 38,927 $ 53,348 $ 72,313 Total O& M Sept 2003 ( y) $ 17,061 $ 42,742 $ 58,576 $ 79,400 Equation, x > 310 y = 25.175x + 35,903, R2 = 0.9987 Equation, x   310 y = 141x, R2 = 1.0 Table 2. Regression Results for Property Taxes, Insurance, and Administration Costs Capacity, tpd 1 5 15 30 Waste flow, tpy ( x) 121 290 870 1740 Property tax, insurance, and administration 3rd qtr 1998 $ 2,569 $ 5,473 $ 9,009 $ 12,338 Property tax, insurance, and administration Sept 2003 ( y) $ 2,821 $ 6,009 $ 9,892 $ 13,547 Equation, x > 234 y = 458.91x0.4537, R2 = 1.0 Equation, x   234 y = 23.312x, R2 = 1.0 Estimating costs of complying with OSWI Rule ( Option 2)

To estimate the costs of complying with the OSWI rule, RTI calculated compliance costs for each OSWI using a regression of the OSWI compliance costs that were developed for the proposal. We tried various types of regressions ( linear, power, logarithmic, etc.) on the OSWI compliance costs, and the linear regression equation had the best R2 value. Because the type of OSWI unit ( batch or intermittent) was not a significant factor in compliance costs ( an excellent R2 value was obtained with batch and intermittent units together), we decided to use a single compliance cost equation for all OSWI units ( batch and intermittent). Table 3 below shows the cost data we used in the regression, as well as the regression equation we chose to determine the compliance costs. The x and y coordinates for the equation are also identified. Nickerson Memorandum 3 September 12, 2005 Page 4 Table 3. Regression Results for Compliance Costs Capacity, tpd 1 5 15 30 Waste flow, tpy ( x) 121 290 870 1740 WS Annualized capital $ 18,355 $ 23,674 $ 34,310 $ 50,265 WS Annual ( direct and indirect) $ 23,609 $ 32,381 $ 52,352 $ 82,309 CEMS Annualized capital $ 10,825 $ 10,825 $ 10,825 $ 10,825 CEMS Annual ( direct and indirect) $ 23,125 $ 23,125 $ 23,125 $ 23,125 CEMS Quarterly audits $ 30,835 $ 30,835 $ 30,835 $ 30,835 Performance test and report $ 30,926 $ 30,926 $ 30,926 $ 30,926 Recordkeeping and Reporting $ 22,698 $ 22,698 $ 22,698 $ 22,698 Title V $ 1,966 $ 2,008 $ 2,112 $ 2,269 Total cost of control ( y) $ 162,339 $ 176,470 $ 207,183 $ 253,251 Equation y = 55.005x + 158,269, R2 = 0.9972 Identifying each OSWI's cost minimizing compliance option RTI assumed that each OSWI would choose to comply using its lowest cost option ( Option 1: Switch to Landfill or Option 2: Comply with OSWI Rule). We compared the estimated costs for each option for each OSWI. Option 1 ( Landfilling) was found to be the lower cost option for all OSWI. See Table 4.

Comparing high throughput estimated compliance costs to owner revenue The severity of impacts on small entities is usually defined in terms of the ratio of costs of compliance to owner entity revenues. To be conservative, RTI estimated compliance costs under the lower cost option, but based on upper end incinerator throughput. This approach provides upper bound estimated compliance cost for each OSWI unit, to identify those small entities that appear most likely to incur significant impacts due to the rule. For all 108 OSWI owned by small or potentially small entities, we summed the cost per unit to calculate estimated upper bound cost per owner entity. We then compared the summed costs for each owner entity to the owner's revenue ( see Table 5). We refer to this criterion as the cost to revenue ratio or CRR. The analysis showed the following results: o Twelve small governments owning twelve OSWI units, one small business owning one OSWI unit, and six nonprofits owning 8 OSWI units have positive costs, assuming high end throughput. o No non profits had a CRR exceeding 0.1%. o 8 small entities had a CRR exceeding 1.0%. o 1 additional small entity had a CRR just under 1.0% Nickerson Memorandum 3 September 12, 2005 Page 5 Units recommended for detailed cost analysis RTI recommends conducting a detailed cost analysis for the nine small entities having projected high throughput CRRs of approximately 1 percent or greater. o Of the 9 small entities, 8 are small government jurisdictions and one is a small business. o The OSWI units at the 9 small entities are unit numbers: 39, 130, 143, 144, 145, 146, 149, 150, and 274. o 8 of the 9 units are VSMWC; 1 of the 9 units is an IWI.

References Holloway, T. and J. Coburn. 2005. Confirmation of Potential Impacts on Small Entities. Memorandum submitted by RTI to W. Nickerson, U. S. Environmental Protection Agency, Office of Policy, Economics, and Innovation, through G. Kline, ICF. October 16.

Dijkgraaf, E. and H. Vollebergh. 2003. Burn or Bury? A Social Cost Comparison of Final Waste Disposal Methods. April.

Burning Garbage and Land Disposal in Rural Alaska. 2004. Alaska Energy Authority and Alaska Department of Environmental Conservation. May.

Shrager, B. 2004. OSWI  Documentation of Teleconference with Representatives of the State of Alaska. Memorandum submitted by EPA to project files. July 21.

Rutz, C. 2005. Comments on the Proposed Standards of Performance for New Stationary Sources and Emission Guidelines for Existing Sources: Other Solid Waste Incineration Units; Proposed Rule. Letter and attachment from Alyeska Pipeline Service Co. to EPA. February 7. Nickerson Memorandum 3 September 12, 2005 Page 6 turning knowledge into practice Table 4. Estimated Compliance Costs Based on Medium Throughput, and Cost to Revenue Ratio ( CRR)

Compliance Costs RTI_

ID Owner ID Owner Type OSWI Name Small Entity Medium Annual Q ( tpy) LF Disposal Costs ($/ yr) Incinerator Oper. Costs ($/ yr) Option 1 Landfill ($/ yr) Option 2 Comply OSWI ($/ yr) Low Cost Option ($/ yr) Revenue ( MM$) CRR 1 1 1 NAVAL AIR WEAPONS STATION 0 41.00 $ 1,232 $ 6,737 $ ( 5,505) $ 160,524 $ ( 5,505) 1853000 0.00%

9 1 1 NATIONAL SECURITY AGENCY 0 265.58 $ 18,323 $ 43,223 $ ( 24,900) $ 172,877 $ ( 24,900) 1853000 0.00%

10 1 1 NATIONAL SECURITY AGENCY 0 249.96 $ 17,245 $ 40,863 $ ( 23,618) $ 172,018 $ ( 23,618) 1853000 0.00%

11 1 1 NAVAL SURFACE WARFARE CNTR INDIAN HD 0 58.58 $ 3,050 $ 9,626 $ ( 6,576) $ 161,491 $ ( 6,576) 1853000 0.00%

12 1 1 NAVAL SURFACE WARFARE CNTR INDIAN HD 0 58.58 $ 3,050 $ 9,626 $ ( 6,576) $ 161,491 $ ( 6,576) 1853000 0.00%

18 1 1 MALMSTROM AFB 0 1,900.08 $ 56,679 $ 97,840 $ ( 41,161) $ 262,783 $ ( 41,161) 1853000 0.00%

19 1 1 LOS ALAMOS NATIONAL LABORATORY 0 444.64 $ 5,900 $ 54,394 $ ( 48,493) $ 182,727 $ ( 48,493) 1853000 0.00%

20 1 1 US DEPARTMENT OF THE ARMY 0 444.64 $ 10,125 $ 54,394 $ ( 44,269) $ 182,727 $ ( 44,269) 1853000 0.00%

21 1 1 TINKER AFB US AIR FORCE LOGISTICS CTR 0 44.10 $ 910 $ 7,246 $ ( 6,336) $ 160,695 $ ( 6,336) 1853000 0.00%

23 1 1 US NAVY: WEAPONS STATION 0 16.40 $ 569 $ 2,695 $ ( 2,125) $ 159,171 $ ( 2,125) 1853000 0.00%

24 1 1 US AIRFORCE: CHARLESTON AFB 0 8.52 $ 256 $ 1,400 $ ( 1,144) $ 158,738 $ ( 1,144) 1853000 0.00%

25 1 1 US AIRFORCE: SHAW AFB 0 0.47 $ 20 $ 76 $ ( 57) $ 158,295 $ ( 57) 1853000 0.00%

26 1 1 MAIN BASE 0 444.64 $ 11,863 $ 54,394 $ ( 42,531) $ 182,727 $ ( 42,531) 1853000 0.00%

93 1 1 US ARMY  FORT BELVOIR 0 127.00 $ 7,022 $ 20,868 $ ( 13,846) $ 165,255 $ ( 13,846) 1853000 0.00%

122 1 1 NAVY SALVAGE FUEL BOILER PLANT 0 3,288.07 $ 77,960 $ 136,767 $ ( 58,807) $ 339,130 $ ( 58,807) 1853000 0.00%

152 1 1 101ST AIRBORNE DIV./ FORT CAMPBELL 0 245.91 $ 11,437 $ 40,250 $ ( 28,813) $ 171,795 $ ( 28,813) 1853000 0.00%

153 1 1 88 ABW/ EMP 0 956.31 $ 33,863 $ 70,306 $ ( 36,443) $ 210,871 $ ( 36,443) 1853000 0.00%

290 1 1 LAUGHLIN AIR FORCE BASE 0 273.23 $ 7,282 $ 44,376 $ ( 37,094) $ 173,298 $ ( 37,094) 1853000 0.00%

322 1 1 NAVAL SECURITY GRP ACTIVITY WINTER HBR 0 254.11 $ 23,764 $ 41,490 $ ( 17,726) $ 172,246 $ ( 17,726) 1853000 0.00%

323 1 1 NAVAL SECURITY GRP ACTIVITY WINTER HBR 0 254.11 $ 23,764 $ 41,490 $ ( 17,726) $ 172,246 $ ( 17,726) 1853000 0.00%

324 1 1 NAVAL SURFACE WARFARE CENTER CRANE 0 444.64 $ 15,522 $ 54,394 $ ( 38,871) $ 182,727 $ ( 38,871) 1853000 0.00%

340 1 1 PETERSON AFB 21CES CEV 0 819.70 $ 22,378 $ 66,169 $ ( 43,792) $ 203,356 $ ( 43,792) 1853000 0.00%

408 1 1 U. S. ARMY AIR DEFENSE ART 0 204.92 $ 5,664 $ 33,672 $ ( 28,007) $ 169,541 $ ( 28,007) 1853000 0.00%

431 1 1 US MILITARY ACADEMY 0 444.64 $ 17,483 $ 54,394 $ ( 36,910) $ 182,727 $ ( 36,910) 1853000 0.00%

432 1 1 USAF CLEAR 0 444.64 $ 36,643 $ 54,394 $ ( 17,751) $ 182,727 $ ( 17,751) 1853000 0.00%

471 1 1 US DEPARTMENT OF JUSTICE FBI 0 54.65 $ 2,455 $ 8,979 $ ( 6,524) $ 161,275 $ ( 6,524) 1853000 0.00%

( continued) Nickerson Memorandum 3 September 12, 2005 Page 7 turning knowledge into practice Table 4. Estimated Compliance Costs Based on Medium Throughput, and Cost to Revenue Ratio ( CRR) ( continued)

Compliance Costs RTI_

ID Owner ID Owner Type OSWI Name Small Entity Medium Annual Q ( tpy) LF Disposal Costs ($/ yr) Incinerator Oper. Costs ($/ yr) Option 1 Landfill ($/ yr) Option 2 Comply OSWI ($/ yr) Low Cost Option ($/ yr) Revenue ( MM$) CRR 498 1 1 NAVAL SECURITY GROUP ACTIVITY 0 173.05 $ 7,853 $ 28,434 $ ( 20,581) $ 167,787 $ ( 20,581) 1853000 0.00%

1 z 0 1853000 0.00%

2 2 2 CALIF. DEPT. OF FOOD & AG. 0 203.09 $ 5,940 $ 33,371 $ ( 27,430) $ 169,440 $ ( 27,430) 151245 0.00%

3 2 2 CALIF. DEPT. OF FOOD & AG. 0 710.82 $ 20,792 $ 62,826 $ ( 42,034) $ 197,368 $ ( 42,034) 151245 0.00%

186 2 2 CALIF CORRECTIONAL CENTER 0 436.80 $ 10,068 $ 54,138 $ ( 44,069) $ 182,295 $ ( 44,069) 151245 0.00%

2 z 0 151245  0.0001%

22 3 2 PA DEPT OF CORR/ DALLAS SCI 0 200.94 $ 13,499 $ 33,017 $ ( 19,518) $ 169,322 $ ( 19,518) 46.1645  0.04%

2 z 0 46.1645  0.04%

97 4 7 WIS DOA / UW MADISON CHARTER ST HEATING PLANT 2 444.64 $ 17,750 $ 54,394 $ ( 36,644) $ 182,727 $ ( 36,644) 1905.8 0.00%

98 4 7 WIS DOA / UW MADISON CHARTER ST HEATING PLANT 2 444.64 $ 17,750 $ 54,394 $ ( 36,644) $ 182,727 $ ( 36,644) 1905.8 0.00%

99 4 7 WIS DOA / UW MADISON CHARTER ST HEATING PLANT 2 444.64 $ 17,750 $ 54,394 $ ( 36,644) $ 182,727 $ ( 36,644) 1905.8 0.00%

100 4 7 WIS DOA / UW MADISON CHARTER ST HEATING PLANT 2 444.64 $ 17,750 $ 54,394 $ ( 36,644) $ 182,727 $ ( 36,644) 1905.8 0.00%

101 4 7 UNIVERSITY OF WISCONSIN ( MAD) SAFETY DEPT 2 1,606.61 $ 64,586 $ 89,418 $ ( 24,833) $ 246,640 $ ( 24,833) 1905.8 0.00%

7 z 2 1905.8  0.01%

299 5 2 LOUISIANA STATE PENITENTIARY 0 4,098.48 $ 181,358 $ 159,071 $ 22,287 $ 383,706 $ 22,287 18078.5 0.00%

2 z 0 18078.5 0.0001%

309 6 2 MARYLAND DEPARTMENT OF HEARTH &

MENTAL HYGIENE PUB 0 273.23 $ 19,763 $ 44,376 $ ( 24,613) $ 173,298 $ ( 24,613) 20787.9 0.00%

2 z 0 20787.9  0.0001%

325 7 2 NE GAME & PARKS COMMISSION 0 444.64 $ 8,119 $ 54,394 $ ( 46,274) $ 182,727 $ ( 46,274) 6001.93 0.00%

2 z 0 6001.93  0.0008%

439 8 2 WASH STATE PARK & RECREATION COMM 0 444.64 $ 30,227 $ 54,394 $ ( 24,167) $ 182,727 $ ( 24,167) 23.8131  0.10%

2 z 0 23.8131  0.1015%

499 9 2 WVDEP OFFICE OF WASTE MANAGEMENT 0 444.64 $ 20,187 $ 54,394 $ ( 34,207) $ 182,727 $ ( 34,207) 9130.22 0.00%

2 z 0 9130.22  0.0004%

( continued) Nickerson Memorandum 3 September 12, 2005 Page 8 turning knowledge into practice Table 4. Estimated Compliance Costs Based on Medium Throughput, and Cost to Revenue Ratio ( CRR) ( continued)

Compliance Costs RTI_

ID Owner ID Owner Type OSWI Name Small Entity Medium Annual Q ( tpy) LF Disposal Costs ($/ yr) Incinerator Oper. Costs ($/ yr) Option 1 Landfill ($/ yr) Option 2 Comply OSWI ($/ yr) Low Cost Option ($/ yr) Revenue ( MM$) CRR 38 10 3 LA CO., SANITATION DIST 0 3,818.41 $ 128,222 $ 151,388 $ ( 23,166) $ 368,301 $ ( 23,166) 14788.2 0.00%

2 z 0 14788.2  0.0002%

120 11 3 CARTER COUNTY AIR CURTAIN DESTRUCTION 0 3,288.07 $ 123,467 $ 136,767 $ ( 13,300) $ 339,130 $ ( 13,300) 50.3  0.03%

3 z 0 50.3  0.0264%

285 12 3 KALAMAZOO VALLEY COMM CO 0 1,639.39 $ 72,969 $ 90,364 $ ( 17,395) $ 248,444 $ ( 17,395) 128.219  0.01%

3 z 0 128.219  0.0136%

293 13 3 ELGIN CUMMUNITY COLLEGE 0 873.60 $ 40,474 $ 67,809 $ ( 27,335) $ 206,321 $ ( 27,335) 162.049  0.02%

3 z 0 162.049  0.0169%

470 14 3 HENRICO COUNTY POLICE 0 444.64 $ 20,036 $ 54,394 $ ( 34,358) $ 182,727 $ ( 34,358) 694.602 0.00%

3 z 0 694.602  0.0049%

484 15 3 MERCER COUNTY VO TECH 0 444.64 $ 18,591 $ 54,394 $ ( 35,803) $ 182,727 $ ( 35,803) 47.2  0.08%

3 z 0 47.2  0.0759%

500 16 4 HUNTINGTON SANITARY BOARD 0 444.64 $ 18,715 $ 54,394 $ ( 35,679) $ 182,727 $ ( 35,679) 50.196  0.07%

4 z 0 50.196  0.0711%

121 17 4 CITY OF ALCOA INCINERATOR 1 3,288.07 $ 85,720 $ 136,767 $ ( 51,047) $ 339,130 $ ( 51,047) 18.2283  0.28%

4 z 1 18.2283  0.2800%

129 18 4 CITY OF SOUTHSIDE PLACE INCINERATOR 1 3,358.33 $ 54,942 $ 138,710 $ ( 83,768) $ 342,994 $ ( 83,768) 1.3142  6.37%

4 z 1 1.3142  6.3741%

130 19 4 TOWN OF READSBORO INCINERATOR 1 3,358.33 $ 194,851 $ 138,710 $ 56,140 $ 342,994 $ 56,140 1.02381 5.48%

4 z 1 1.02381 5.4834%

132 20 4 SILOAM SPRINGS 1 5,910.67 $ 221,532 $ 208,304 $ 13,227 $ 483,385 $ 13,227 15.9424 0.08%

4 z 1 15.9424 0.0830%

138 21 4 CITY OF LUFKIN 1 3,288.07 $ 76,283 $ 136,767 $ ( 60,484) $ 339,130 $ ( 60,484) 40.987  0.15%

4 z 1 40.987  0.1476%

( continued) Nickerson Memorandum 3 September 12, 2005 Page 9 turning knowledge into practice Table 4. Estimated Compliance Costs Based on Medium Throughput, and Cost to Revenue Ratio ( CRR) ( continued)

Compliance Costs RTI_

ID Owner ID Owner Type OSWI Name Small Entity Medium Annual Q ( tpy) LF Disposal Costs ($/ yr) Incinerator Oper. Costs ($/ yr) Option 1 Landfill ($/ yr) Option 2 Comply OSWI ($/ yr) Low Cost Option ($/ yr) Revenue ( MM$) CRR 139 22 4 CITY OF NORFOLK WASTE FACILITY 1 6.61 $ 305 $ 1,086 $ ( 781) $ 158,633 $ ( 781) 35.1298 0.00%

4 z 1 35.1298  0.0022%

140 23 4 CITY OF SULPHUR SPRINGS 1 3,288.07 $ 134,285 $ 136,767 $ ( 2,482) $ 339,130 $ ( 2,482) 14.2315  0.02%

4 z 1 14.2315  0.0174%

143 24 3 OSSIPEE INCINERATOR FACILITY 1 4,030.00 $ 240,430 $ 157,194 $ 83,236 $ 379,939 $ 83,236 9.28023 0.90%

3 z 1 9.28023 0.8969%

144 25 4 TOWN OF CANDIA 1 4,030.00 $ 245,790 $ 157,194 $ 88,595 $ 379,939 $ 88,595 8.63771 1.03%

4 z 1 8.63771 1.0257%

145 26 4 TOWN OF LITCHFIELD INCINERATOR &

RECYCLING FACILITY 1 6,179.33 $ 531,546 $ 215,549 $ 315,997 $ 498,163 $ 315,997 16.2777 1.94%

4 z 1 16.2777 1.9413%

146 27 4 WILTON RECYCLING CENTER 1 8,060.00 $ 679,780 $ 265,980 $ 413,801 $ 601,609 $ 413,801 8.22984 5.03%

4 z 1 8.22984 5.0280%

149 28 3 HEBRON BRIDGEWATER REFUSE DISTRICT 1 3,868.80 $ 206,787 $ 152,772 $ 54,015 $ 371,072 $ 54,015 2.14682 2.52%

3 z 1 2.14682 2.5161%

6 29 5 GRAYSLAKE COMMUNITY HIGH SCHOOL 127 1 488.20 $ 17,678 $ 55,806 $ ( 38,128) $ 185,123 $ ( 38,128) 6.1  0.63%

5 z 1 6.1  0.6251%

45 30 5 GROSS SCHOOL DIST 95 1 390.56 $ 17,193 $ 52,615 $ ( 35,423) $ 179,752 $ ( 35,423) 3.2  1.11%

5 z 1 3.2  1.1070%

57 31 5 DIEKMAN SCHOOL  DISTRICT 149 1 390.56 $ 15,166 $ 52,615 $ ( 37,450) $ 179,752 $ ( 37,450) 12.2  0.31%

5 z 1 12.2  0.3070%

58 32 5 BERGER VANDENBERG SCHOOL 1 468.68 $ 18,264 $ 55,175 $ ( 36,911) $ 184,048 $ ( 36,911) 12.2  0.30%

5 z 1 12.2  0.3025%

66 33 5 MARQUARDT SCHOOL DISTRICT 15 1 449.15 $ 23,297 $ 54,540 $ ( 31,243) $ 182,974 $ ( 31,243) 10.7  0.29%

5 z 1 10.7  0.2920%

69 34 5 JACKSON JUNIOR HIGH SCHOOL 1 507.73 $ 23,376 $ 56,435 $ ( 33,059) $ 186,197 $ ( 33,059) 17.3  0.19%

( continued) Nickerson Memorandum 3 September 12, 2005 Page 10 turning knowledge into practice Table 4. Estimated Compliance Costs Based on Medium Throughput, and Cost to Revenue Ratio ( CRR) ( continued)

Compliance Costs RTI_

ID Owner ID Owner Type OSWI Name Small Entity Medium Annual Q ( tpy) LF Disposal Costs ($/ yr) Incinerator Oper. Costs ($/ yr) Option 1 Landfill ($/ yr) Option 2 Comply OSWI ($/ yr) Low Cost Option ($/ yr) Revenue ( MM$) CRR 5 z 1 17.3  0.1911%

72 35 5 PIONEER SCHOOL 1 488.20 $ 23,819 $ 55,806 $ ( 31,987) $ 185,123 $ ( 31,987) 16  0.20%

5 z 1 16  0.1999%

79 36 5 TRIOPIA HIGH SCHOOL  DISTRICT 27 1 507.73 $ 23,396 $ 56,435 $ ( 33,038) $ 186,197 $ ( 33,038) 1.9  1.74%

5 z 1 1.9  1.7389%

89 37 5 FREEPORT SCHOOL DISTRICT 145  EMPIRE SCHOOL 1 488.20 $ 18,386 $ 55,806 $ ( 37,421) $ 185,123 $ ( 37,421) 17  0.22%

5 z 1 17  0.2201%

90 38 5 CARL SANDBURG SCHOOL  DISTRICT 145 1 361.27 $ 13,605 $ 51,639 $ ( 38,033) $ 178,141 $ ( 38,033) 17  0.22%

5 z 1 17  0.2237%

91 39 5 ROCK FALLS TOWNSHIP HIGH SCHOOL 1 390.56 $ 12,053 $ 52,615 $ ( 40,562) $ 179,752 $ ( 40,562) 3.5  1.16%

5 z 1 3.5  1.1589%

165 40 5 ATHENS AREA SCHOOL DISTRICT 1 546.46 $ 34,455 $ 57,673 $ ( 23,218) $ 188,327 $ ( 23,218) 12.3  0.19%

5 z 1 12.3  0.1888%

184 41 5 BURRELL SCHOOL DISTRICT 1 888.00 $ 62,409 $ 68,245 $ ( 5,836) $ 207,114 $ ( 5,836) 8.9  0.07%

5 z 1 8.9  0.0656%

195 42 5 CHATTERTON JR HIGH SCHOOL 1 1,092.93 $ 45,925 $ 74,391 $ ( 28,466) $ 218,386 $ ( 28,466) 13.3  0.21%

5 z 1 13.3  0.2140%

234 117 5 FITZGERALD HIGH SCHOOL 1 218.59 $ 9,170 $ 35,916 $ ( 26,747) $ 170,292 $ ( 26,747) 13.3  0.20%

5 z 1 13.3  0.2011%

437 43 5 WALDRON AREA SCHOOLS 1 227.69 $ 13,013 $ 37,413 $ ( 24,400) $ 170,793 $ ( 24,400) 1.8  1.36%

469 43 5 POWHATAN HIGH SCHOOL 1 444.64 $ 22,526 $ 54,394 $ ( 31,868) $ 182,727 $ ( 31,868) 13.8  0.23%

5 z 1 15.6  1.59%

476 44 5 HOLLIDAYSBURG AREA SCHOOL DISTRICT 1 91.08 $ 5,636 $ 14,965 $ ( 9,329) $ 163,279 $ ( 9,329) 18.2  0.05%

5 z 1 18.2  0.05%

( continued) Nickerson Memorandum 3 September 12, 2005 Page 11 turning knowledge into practice Table 4. Estimated Compliance Costs Based on Medium Throughput, and Cost to Revenue Ratio ( CRR) ( continued)

Compliance Costs RTI_

ID Owner ID Owner Type OSWI Name Small Entity Medium Annual Q ( tpy) LF Disposal Costs ($/ yr) Incinerator Oper. Costs ($/ yr) Option 1 Landfill ($/ yr) Option 2 Comply OSWI ($/ yr) Low Cost Option ($/ yr) Revenue ( MM$) CRR 477 45 5 FOREST HILLS SCHOOL DISTRICT ( ELE/ HI) 1 500.93 $ 26,123 $ 56,216 $ ( 30,093) $ 185,822 $ ( 30,093) 9.2  0.33%

480 45 5 FOREST HILLS SCHOOL DISTRICT ( ELE) 1 45.54 $ 2,375 $ 7,483 $ ( 5,108) $ 160,774 $ ( 5,108) 9.2  0.06%

5 z 1 9.2  0.38%

479 46 5 NORTHERN CAMBRIA SCHOOL DISTRICT ( ELE/ MI) 1 455.39 $ 23,462 $ 54,744 $ ( 31,282) $ 183,318 $ ( 31,282) 6.1  0.51%

5 z 1 6.1  0.51%

481 47 5 CARMICHAELS AREA SCHOOL DISTRICT 1 200.37 $ 9,566 $ 32,923 $ ( 23,358) $ 169,290 $ ( 23,358) 5.5  0.42%

482 47 5 CARMICHAELS AREA SCHOOL DISTRICT 1 182.15 $ 8,696 $ 29,930 $ ( 21,234) $ 168,288 $ ( 21,234) 5.5  0.39%

5 z 1 5.5  0.81%