 1 Hazardous Waste Combustor MACT Response to Issues Raised by OMB March 3, 2004 Issue Page #

1. Beyond the Floor Justification 2 2. Inclusion of Data From Sources That 8 May Have Upgraded to Comply With Interim Standards 3. Total Chlorine Standard  Method 26 Bias Issue 9 4. Stakeholder's Objection to Thermal Emission Limits 10 5. Stakeholder's Request for an Alternative to the 13 Particulate Matter Standard 6. Stakeholders Objection to Requiring Site 13 Specific Risk Assessments 7. Miscellaneous Issues ( Inclusion of Waste 14 Minimization in the Benefits Discussion, Discounting Benefits, Corrected RIA Background Document Language, SO 2 benefits)  2

Increm ental Total Annualized Cost Cost Effectiveness Incremental Annualilzed Capital Cost # Sources Incurring BTF Cost Total Annualilzed Cost, from Baseline Coal Fired Boilers ( Solid Fuel Boilers) Non discounted: $ 74,000 3% discount rate: $ 71,500 3 7% discount rate: $ 68,400 3 TCl 440 ppm v 110 ppm v 790 tpy $ 3.7 M $ 4,700/ ton $ 0.18 M 6/ 12 $ 4.2 M $ 2.60 $ 27$ 280 m illion in 1999 dollars4 Lightweight Aggregate K ilins TCl 600 ppm v 150 ppm v 280 tpy $ 1.9 M $ 6,800/ ton $ 0.10 M 7/ 7 $ 1.9 M $ 1.75 Benefits no t m onetized, bu t include a reduction in acidification of acid sensitive surface waters Non discounted: $ 154,000  $ 912,000 3% discount rate: $ 56,000  $ 495,000 5 7% discount rate: $ 15,000  $ 222,000 5 Liquid Fuel Boilers Non discounted: $ 5,000  $ 29,000 3% discount rate: $ 1,800  $ 16,000 5 7% discount rate: $ 500  $ 7,000 5 HCl Production Furnaces Non discounted: $ 180,000  $ 1,100,000 3% discount rate: $ 67,000  $ 594,000 5 7% discount rate: $ 18,000  $ 267,000 5 Market Adjusted Costs ( Millions) 2 Engineering Costs Floor Level BTF Stnd Emission Reductions Annualized Incremental Benefits Source/ HAP Summary o f Costs, Benefits, and Cost Effectiveness for P roposed Beyond the Floor ( BTF) S tandards for Existing Sources 2 To provide consistent cost estimates for each source category, we assume that the proportional distribution of m arket adjusted costs across pollutants is consistent with the proportional distribution of engineering costs across pollu tants. S ince specific facilities m ay send waste off s ite instead of upgrading to comply with the standards, this assumption m ay not reflect the actual distribution of m arketadjusted costs across po llutants.

1 Tons of m etal HAP Dioxin/ Furan 6.8 ng TEQ/ dscm 0.40 ng TEQ/ dscm 2.3 gpy $ 1.9 M 3 Our analysis of PM m or tality be nefits assumes that 25 pe rcent of prem ature m ortalities associated w ith PM exposure occur during the first year, 25 pe rcent occur during the second year, and 16.7 percent occur in each of the three subsequent years after exposure. W e assume no time lag is associated w ith PM m orbidity effects. This m ethodology is consistent w ith EPA's an alysis of the proposed C lear Skies Act of 2003. EPA, Technical Addendum: M ethodologies for the Benefit Analysis of the C lear S kies Act of 2003 , S eptember 2003.

4 This range reflects our lower bound estimate an d our average estimate based on results presented in U . S. EPA, 2 003 Technical A ddendum: Methodologies for the Benefit A nalysis of the Clear Skies Act of 2003 , Septem ber 2003 and U. S. EPA, Benefits o f the P roposed Inter State Air Q uality Rule , January 2004. A ssuming a discount rate of 3 percent, we estimate that annual benefits range from $ 29 million to $ 349 m illion. A t a discount rate of 7 percent, annual benefits fall in the range of $ 27 m illion to $ 340 m illion.

5 T he range of benefits associated with reduced dioxin/ furan emissions reflects a latency pe riod ranging from 21 to 34 years ( see: J. Neum ann and B. Unsworth, Addenda to M ortality Valuation Methodology, internal memorandum submitted to Jim DeMocker, September 28, 1993). In add ition, the low end of the ranges presented reflects a cancer risk factor of 1.5 x 10 5 [ mg/ kg/ day] 1. The upper end of each range represents a cancer risk factor of 9 .0 x 105 [ mg/ kg/ day] 1. This range reflects EPA's effort currently und erway to refine estimates of dioxin cancer risk factors.

6 Our econom ic m odel indicates that the single boiler system that would incur increm ental en gineering costs un der the A gency Preferred A pproach is predicted to close in both the Floor and BTF m arket adjusted scenarios; it therefore incurs no incremental m arket adjusted costs. $ 830,000/ gram $ 0.39 M 10/ 17 $ 1.90 $ 1.9 M Dioxin/ Furan 3.0 ng TEQ/ dscm 0.40 ng TEQ/ dscm 0.06 gpy $ 0.08 M $ 1,300,000/ gram $ 0.008 M 1/ 104 $ 0.13 M 0.00 6 Dioxin/ Furan 6.1 ng TEQ/ dscm 0.40 ng TEQ/ dscm 1.9 gpy $ 1.8 M $ 950,000/ gram $ 0.44 M 7/ 7 $ 1.3 M $ 87,000/ ton $ 0.85 M 11/ 12 $ 1.5 M $ 0.88 $ 1.8 M $ 1.68 PM 0.060 gr/ dscf 0.030 gr/ dscf 15 tpy 1 1. Beyond the Floor Justification. ( Issue raised by ACC and CRWI)

The table below provides a summary of the costs and benefits for each of the six proposed beyond the foor standards. Following this table, we provide our rationale as to why these beyond the floor standards are appropriate.  3 Beyond the Floor Justification ( continued)

A. Coal Fired ( Solid Fuel) Boilers 1. PM:

a. The BTF Standard Is Cost Effective ( CE) at $ 87,000/ ton HAP Metal.

Consideration of Agency CE Precedence:

EPA determined that $ 2,500/ ton is CE for metal HAP, HCl, and organic HAP combined. Pulp and Paper Combustion MACT NPRM ( Dec. 8, 1007).

EPA determined that $ 22,000/ ton is not CE for metal HAP, HCl, and HF combined. Clay Products MACT NPRM, 67 FR@ 47910 ( July 22, 2002). Rationale included the fact that the cost for BTF stnds would be substantially higher than the Floor$ 101 million vs $ 39 million. In addition, BTF costs to small businesses would be substantially higher$ 39 million vs $ 7 million.

EPA determined that $ 250,000/ ton is not CE for lead and manganese b/ c sources would be required to remove existing FFs and replace them with more efficient FFs to achieve a very low standard 0.001 gr/ dscf. Iron and Steel Foundry MACT NPRM, 67 FR@ 78287 ( Dec. 23, 2002).

BTF PM Standard for Coal Boilers Burning Hazardous Waste Is Cost Effective at $ 87,000/ ton HAP Metal b/ c:

Incremental total annualized cost would be only $ 1.3 million to improve the design, operation, and maintenance of existing ESPs and FFs to remove 15 tons/ yr of metal HAP several of which are highly toxic or carcinogenic.

The BTF standard would not pose a significant economic impact on a substantial number of potentially affected small entities.

b. The BTF Standard Is Comparable to the Floor Standard for Industrial Boilers.

The Floor is 0.060 gr/ dscf. The BTF standard of 0.030 gr/ dscf would be comparable to the Floor standard of 0.034 gr/ dscf for industrial coal fired boilers that do not burn hazardous waste.

No reason for MACT control to be different for coal boilers that burn hazardous waste b/ c hazardous waste does not affect PM emissions significantly.

c. Monetized Health and Environmental Benefits Are Significant: $ 74,000/ yr nondiscounted, $ 72,000 discounted at 3%, and $ 68,000 discounted at 7%.  4 2. TCl a. The BTF Standard Is Cost Effective ( CE) at $ 4,700/ ton Consideration of Agency CE Precedence:

EPA determined that $ 1,100/ ton is CE for HCl. Hazardous Waste Combustor MACT FRM, 68 FR@ 52900 ( Sept. 30, 1999).

EPA determined that $ 45,000/ ton is not CE for HCl. Industrial Boiler MACT NPRM, 68 FR@ 1677 ( Jan. 13, 2003).

BTF TCl Standard for Coal Boilers Burning Hazardous Waste Is Cost Effective at $ 4,700/ ton HCl b/ c:

Incremental total annualized cost would be only $ 3.7 million to install dry scrubbing ( i. e., lime injection) to remove 790 tons/ yr of TCl.

CE value of $ 4,700 is within the range of values that the Agency could reasonably determine is CE.

b. Monetized Health Benefits from Collateral Reductions in SO 2 Emissions Would Be Substantial: $ 27 280 million/ yr ( 1999 dollars)

B. Lightweight Aggregate Kilns 1. TCl a. The BTF Standard Is Cost Effective ( CE) at $ 6,800/ ton Consideration of Agency CE Precedence: See discussion above.

BTF TCl Standard Is CE at $ 6,800/ ton HCl b/ c:

Incremental total annualized cost would be only $ 1.9 million to install dry scrubbing to remove 280 tons/ yr of TCl.

CE value of $ 6,800 is within the range of values that the Agency could reasonably determine is CE.

b. HCl Reductions from the Floor ( 600 ppmv) Will Reduce Acidification of Acid Sensitive Surface Waters.

2. D/ F  5 a. The BTF Standard Is Cost Effective at $ 0.95 million/ gram TEQ.

Consideration of Agency CE Precedence:

EPA determined that a CE of $ 25,000/ gram is CE to control D/ F to an emission level of 0.4 ng TEQ/ dscm for lightweight aggregate kilns that burn hazardous waste. Hazardous Waste Combustor MACT FRM, 64 FR@ 52892 ( Sept. 30, 1999).

EPA determined that a CE of $ 370,000/ gram is CE to control D/ F to an emission level of 0.4 ng TEQ/ dscm for hazardous waste incinerators equipped with heat recovery boilers. Hazardous Waste Combustor MACT FRM, 64 FR@ 53861.

EPA determined that CE values of $ 530,000/ gram, $ 660,000/ gram, and $ 827,000/ gram were not CE to control D/ F to an emission level of 0.2 ng TEQ/ dscm for hazardous waste burning lightweight aggregate kilns, cement kilns, and incinerators. Hazardous Waste Combustor MACT FRM, 64 FR@ 52892, 52876, and 52961.

BTF D/ F Standard for Lightweight Aggregate Kilns Burning Hazardous Waste Is Cost Effective at $ 0.95 million/ gram TEQ b/ c:

D/ F are highly toxic. EPA has accepted relatively high CE values for HAP that are particularly problematic.

EPA determined that $ 18,000,000 is CE for mercury. Chlorine Production MACT NPRM, 67 FR@ 44682 3 ( July 3, 2002).

The incremental total annualized cost would be only $ 1.8 million to install activated carbon injection to achieve a BTF standard of 0.4 ng TEQ/ dscm to remove 1.9 grams TEQ/ yr.

The lower CE values that EPA determined were not CE were to establish a BTF standard 0.2 ng TEQ/ dscm that is generally considered to be below the level of health risk concern.

This BTF standard is consistent with the BTF standard EPA promulgated for hazardous waste incinerators with heat recovery boilers use of activated carbon injection to control D/ F to 0.4 ng TEQ/ dscm. 64 FR@ 53861.

D/ F emission levels at the Floor   6.1 ng TEQ/ dscm are very high and may expose individuals to substantial cancer risk Without a BTF standard, RCRA permit writers would likely require site specific risk assessments and associated RCRA permit conditions to control D/ F. Not only is this inconsistent w/ our preference to minimize risk assessments, it also would result in emission limits being retained in the RCRA permit, thus complicating implementation, compliance, and enforcement. 1 The D/ F potency slope factor used to support the lower benefit values is not supported by the current science. Rather, the upper bound on the lifetime risk of all cancers combined of 1E 03 risk/( pgTEQ/ kg/ day) is the value recommended in the draft dioxin reassessment as being an estimate representative for the general population ( September, 2000 SAB Review Draft). The reported range is actually 1E 03 to 9E 03, so individuals could have a lifetime excess cancer risk of considerably more than 1E 03 risk/( pgTEQ/ kg/ day). By comparison, the 1985 slope factor is 1.56E 04 risk/( pgTEQ/ kg/ day). In addition, D/ F cause many effects other than cancer. Current background exposures exceed any RfC/ RfD that could be estimated from the available data, which are substantial. These include developmental effects, reproductive effects, and metabolic effects ( e. g., increased incidence of diabetes). Therefore, any benefits based solely on avoided cancer incidence will underestimate the overall benefits of reducing D/ F emissions, particularly since the non cancer benefits would not be affected by the latency period typically associated with many forms of cancer.

 6 b. Monetized Health Benefits Are Significant: $ 150,000  $ 910,000 nondiscounted, $ 56,000  $ 500,000 discounted at 3%, and $ 15,000  $ 220,000 discounted at 7%. 1 C. Liquid Fuel Boilers: D/ F 1. The BTF Standard Is Cost Effective at $ 1.3 million/ gram TEQ.

Consideration of Agency CE Precedence: See discussion above.

BTF D/ F Standard for Liquid Fuel Boilers Burning Hazardous Waste Is Cost Effective at $ 1.3 million/ gram TEQ b/ c:

As discussed above, D/ F are highly toxic. EPA has accepted relatively high CE values for HAP that are particularly problematic.

The incremental total annualized cost would be only $ 0.08 million for one source to install activated carbon injection to achieve a BTF standard of 0.4 ng TEQ/ dscm.

As discussed above, the lower CE values that EPA determined were not CE were to establish a BTF standard 0.2 ng TEQ/ dscm that is generally considered to be below the level of health risk concern.

This BTF standard is consistent with the BTF standard EPA promulgated for hazardous waste incinerators with heat recovery boilers use of activated carbon injection to control D/ F to 0.4 ng TEQ/ dscm.

D/ F emission levels at the Floor   3.0 ng TEQ/ dscm are very high and may expose individuals to substantial cancer risk. See discussion above regarding implications on RCRA permitting.  7 2. Monetized Health Benefits Are Significant: $ 5,000  $ 29,000 nondiscounted, $ 1,800  $ 16,000 discounted at 3%, and $ 500  $ 7,000 discounted at 7%.

D. HCl Production Furnaces: D/ F 1. The BTF Standard Is Cost Effective at $ 0.83 million/ gram TEQ.

Consideration of Agency CE Precedence: See discussion above.

BTF D/ F Standard for HCl Production Furnaces Burning Hazardous Waste Is Cost Effective at $ 0.83 million/ gram TEQ b/ c:

As discussed above, D/ F are highly toxic. EPA has accepted relatively high CE values for HAP that are particularly problematic.

The incremental total annualized cost would be only $ 1.9 million to install activated carbon injection to achieve the BTF standard of 0.4 ng TEQ/ dscm and remove 2.3 grams TEQ/ yr.

As discussed above, the lower CE values that EPA determined were not CE were to establish a BTF standard 0.2 ng TEQ/ dscm that is generally considered to be below the level of health risk concern.

This BTF standard is consistent with the BTF standard EPA promulgated for hazardous waste incinerators with heat recovery boilers use of activated carbon injection to control D/ F to 0.4 ng TEQ/ dscm.

D/ F emission levels at the Floor   6.8 ng TEQ/ dscm are very high and may expose individuals to substantial cancer risk. See discussion above regarding implications on RCRA permitting.

2. Monetized Health Benefits Are Substantial: $ 180,000  $ 1,100,000 nondiscounted, $ 67,000  $ 594,000 discounted at 3%, and $ 18,000  $ 270,000 discounted at 7%.  8 2. Inclusion of Data From Sources That May Have Upgraded to Comply With Interim Standards. ( Issue raised by ACC and CRWI)

The table below summarizes the estimated impacts to the MACT floors of removing data from sources that may have upgraded to comply with the 1999 standards. EPA and stakeholders identified six sources that may have upgraded. Four cement kiln standards and two incinerator standards would be impacted. The remainder of the standards would remain unchanged.

Category Pollutant EPA's Proposed Floor Level Projected MACT Floor Level Removing Sources Cement kilns PM 0.028 gr/ dscf 0.033 gr/ dscf Cement kilns Hg 64 ug/ dscm 48 ug/ dscm Cement kilns SVM 4.0 x 10 4 lb/ MMBtu 8.5 x 10 4 lb/ MMBtu Cement kilns LVM 1.4 x 10 5 lb/ MMBtu 1.9 x 10 5 lb/ MMBtu Incinerators SVM 59 ug/ dscm 230 ug/ dscm Incinerators TCl 1.5 ppmv 2.2 ppmv The projected SVM floor level for cement kilns could be less stringent than the interim standard for some sources. Thus, in order to avoid any backsliding from the current level of performance achieved by cement kilns, the projected floor level would be expressed as a dual standard: 8.5 x 10 4 lb/ MMBtu or 330 ug/ dscm. This would ensure that all sources are complying with a limit that is at least as stringent as the interim standard. Note that we believe we are obligated to consider the emissions data that was excluded from the above MACT floor analysis. Nonetheless, the proposal requests comment on two alternative approaches to calculate MACT floors ( see Part Two, Section III) because this is known to be a controversial issue, and we want input from all stakeholders. As a result, we believe it prudent discuss this issue ( and alternative options) openly in the preamble in order to give all parties the opportunity to comment.  9 3. Total Chlorine Standard  Method 26 Bias Issue ( Issue raised by ACC and CRWI)

Issue: CRWI raised the following issues/ concerns regarding the data used to calculate total chlorine standard.

1) Request that EPA provide a scientific justification as to why the database is suitable for use in a statistical calculation to develop a MACT standard given that the data was generated for a distinctly different measurement objective ( i. e., pass/ fail question at a much higher compliance point).

EPA Response: The same measurement method, the SW 846 version of the Air Method 26A, was used to obtain all results contained in the database. This method contains procedures to ensure data quality regardless of the measured level. The method does not, as CRWI infers, allow a less stringent data quality standard based on the measured level.

2) Given the known and suspected biases in the measurement system, method variability, and source variability, request that EPA provide a concrete rationale to justify that sources can realistically achieve compliance in a defensible manner with a standard of less than 20 ppm.

EPA Response: CRWI provided a report, authored by Joette Steger, et. al., to document the bias they believe appears in Method 26A. We further analyzed Steger's results, found on Table III of Steger's paper, and believe the negative bias Steger reports was brought about by using an overwhelming amount of water spiking during the test. Steger's data shows that a significant negative bias was observed whenever 38 to 50% of the water spiked into the sampling train were in form of water droplets. ( For the purposes of this discussion we define a " significant negative bias" as any recovery less than 93%.)

We also checked our HCl emissions data to see if water droplets could be present in the sample line. We found that water droplets could be present in three of our test conditions: 327C10 at 5% water droplets; 808C1 at 12.5% water droplets; and 3204C1 at 8% water droplets. None of these stack conditions approach the 38 to 50% observed to be a problem by Steger. These stack gas conditions most closely resemble Steger's run B 5, with 10% water droplets. No negative bias was observed for Steger's run B 5.

3) Request that EPA investigate whether the identified measurement system biases may change over time or be different from source to source, and how achievability of compliance may be affected.

EPA Response: As discussed above, we do not believe the method has a low measurement bias due to condensation.  10 4. Stakeholder's Objection to Thermal Emission Limits ( Issue raised by ACC)

Issue: American Chemistry Council objects to the inclusion of thermal emission limitations for liquid fuel fired boilers for the following four reasons:

1. ACC states emission standards that are expressed in the thermal emissions format are not needed for liquid fuel fired boilers because the " competitiveness issues" that exist for cement kilns do not apply to the boiler source category.

EPA Response: We are not proposing thermal emission limits for energy recovery units to address competitiveness issues. Rather, we believe thermal emissions are appropriate for energy recovery units because standards based either on a concentration basis ( or total thermal heat input basis) are biased against sources that feed more hazardous waste to recover more energy. We believe our approach to use hazardous waste thermal emissions as the baseline emissions format to assess best performers is appropriate because it supports the concept of promoting energy recovery from hazardous waste that has lower pollutant concentration levels per million BTUs.

2. ACC believes that demonstrating compliance for these units could present significant difficulties due to detection limit issues.

EPA Response: We believe the metal HAP emission concentration compliance level for some sources may be close to the method detection limit. Specifically, sources that feed hazardous waste to account for a small fraction of the total heat input may have difficulty measuring the low levels of metals necessary to demonstrate compliance with the standard. We are currently developing a mechanism ( that we would request comment on) that would provide relief to sources that have difficulty complying with the standard because of detection limit issues.

3. ACC believes it is arbitrary that liquid fuel fired boilers burning waste fuel with a higher heating value ( e. g., high BTU solvents with trace metals) would be allowed greater HAP mass emissions than liquid fuel fired boilers burning lower BTU waste with an identical metals feed concentration.

EPA Response: ACC is correct that sources burning waste fuel with a higher heating value ( e. g., high BTU solvents) would be allowed to emit HAP at higher concentration levels as compared to sources burning lower BTU waste with an identical metals feed concentration ( i. e., an identical metals feed concentration based on mg/ kg, as opposed to lb/ million BTUs). We believe this is appropriate because of the reasons discussed in # 1 above.

4. ACC believes that EPA should propose standards for liquid fuel fired boilers based on the approach the Agency finalized for nonhazardous waste industrial boilers because the affected sources are similar. They have communicated to EPA that they prefer the standards to be calculated using the industrial boiler MACT floor methodology, and that the standards be expressed in the same format ( i. e., using a " total thermal emissions format" instead of hazardous waste thermal emissions format).

EPA Response: The nonhazardous waste industrial boiler sources do not have the above discussed bias because they do not burn hazardous waste. If we were to use the industrial boiler MACT methodology, emission standards may be biased against sources that feed high BTU content  11 hazardous wastes. As a result, we believe it is appropriate to propose emission limitations that differ slightly in format when compared to the industrial boiler MACT. In addition, although the hazardous waste burning boilers are functionally similar to nonhazardous waste boilers, their method of controlling emissions are not. Hazardous waste boilers control metal HAP and chlorine both by front end hazardous waste feed control, and back end air pollution control. Nonhazardous boilers control these emissions only by back end control technologies. We therefore do not believe that the MACT methodology used in Industrial Boiler MACT is appropriate for hazardous waste boilers because the methodology does not assess hazardous waste feed control as a floor control technology. [ Note that we do use the Industrial Boiler MACT methodology to calculate floor levels for the particulate matter standard for all source categories because we believe particulate matter emissions are primarily controlled via back end control technologies. Nonetheless, we have calculated emission standards using the approaches recommended by ACC. Results of the analysis indicate that our proposed approach generally results in lower retrofit costs. The table below summarizes these results.  12

LIQUID FUEL FIRED BOILERS: COMPARISON OF FLOOR LEVELS AND COSTS FOR MACT FLOOR APPROACHES FOR EXISTING SOURCES MACT Approach Proposed Approach.

SRE Feed/ Emissions:

HW Thermal Emissions1 SRE Feed/ Emissions:

Stack Gas Concentration2 Control Technology:

HW Thermal Emissions3 Control Technology:

Stack Gas Concentration2 Floor Levels D/ F 3.0 ng TEQ/ dscm 3.0 ng TEQ/ dscm 3.0 ng TEQ/ dscm 3.0 ng TEQ/ dscm PM4 0.032 gr/ dscf 0.032 gr/ dscf 0.032 gr/ dscf 0.032 gr/ dscf Hg 3.7 lb/ 1012 Btu 0.47 ug/ dscm 9.5 lb/ 1012 Btu 11 ug/ dscm SVM 11 lb/ 1012 Btu 8.7 ug/ dscm 5.4 lb/ 1012 Btu 4.1 ug/ dscm Cr 110 lb/ 1012 Btu 27 ug/ dscm 29 lb/ 1012 Btu 20 ug/ dscm TCl 24 lb/ 109 Btu 25 ppmv 29 lb/ 109 Btu 15 ppmv Total Annualized Cost w/ TCl $ 39 million $ 55 million $ 49 million $ 42 million w/ o TCl $ 35 million $ 47 million $ 34 million $ 37 million 1 SRE Feed Approach used for Cr and TCl identifies best performing sources based on the aggregate ranking for hazardous waste feedrate of the HAP and SRE of the control device. Emissions Approach used for D/ F, Hg, and SVM identifies best performing sources based on stack gas concentrations. HW Thermal Emissions are pounds of HAP from hazardous waste per 1012 or 109 Btu from hazardous waste.

2 Stack gas concentrations can be converted to lb/ MM Btu assuming 9000 dscf/ MM Btu at 0% O2 3 Control Technology Approach identifies best performers based on nominal control efficiency ( i. e., based on generic engineering information) of the air pollution control device. This approach is not appropriate for HAP where control of the HAP hazardous waste feedrate relates to control of emissions.

4 Control Technology Approach is used for PM universally because hazardous waste feedrate control of ash does not relate to emissions of nonenumerated metal HAP for which the PM standard is a surrogate.  13 5. Stakeholder's Request for an Alternative to the Particulate Matter Standard ( Issue raised by ACC)

Issue: American Chemistry Council supports inclusion of an alternative to the particulate matter standards for incinerators and boilers.

EPA Response: We agree. We are proposing a simplified version of the alternative to the particulate matter standard that was promulgated in the 1999 rule. This alternative to the particulate matter standard would apply to liquid and solid fuel fired boilers and incinerators. We are also requesting comment another alternative to the particulate matter that would be applicable to all source categories that would be subject to a particulate matter standard.

6. Stakeholder Objection to Requiring Site Specific Risk Assessments ( Issue raised by ACC and CRWI)

Issue: ACC and CRWI group stated that, " EPA should not require site specific risk assessments ( SSRAs) as part of the permanent replacement standards rulemaking."

Individually, ACC stated that " OMB should ensure that EPA does not require SSRAs as part of the permanent replacement standards rulemaking." CRWI feels that " If EPA does not propose to require SSRAs, but keeps the status the same as it currently is, no action by OMB is needed. If EPA proposes to require SSRAs, we suggest that you ask EPA to address all the issues raised under the previous question and especially to justify requiring an untested method to set site specific operating parameters to show compliance."

EPA Response: We agree with CRWI and ACC that we should not require SSRAs. We also agree with CRWI that SSRAs should not be required, for many of the same reasons that CRWI described under its potential ramifications question. Thus, in the rulemaking, we have only proposed to make explicit an authority that has been and remains available under the omnibus authority ( RCRA statutory authority or " omnibus" authority as provided under Section 3005( c)( 3)) and its implementing regulations ( see 40 CFR 270.10( k)). Although we believe that the RCRA omnibus authority provides sufficient authority to conduct SSRAs where they are determined to be necessary, we also believe it appropriate to explicitly codify the omnibus authority for the sake of regulatory clarity and transparency.  14 7. Miscellaneous Issues ( Inclusion of Waste Minimization in the Benefits Discussion, Discounting Benefits, Corrected RIA Background Document Language, SO2 benefits)

1. Issue: Should waste minimization be included and discussed as a benefit?

Response: OSW plans to maintain the waste minimization discussion as part of the benefits section. We believe that waste minimization resulting from the proposed standards would be a benefit for the following key reasons: 1) Emissions reductions resulting from waste minimization at the generator level would occur beyond those necessary for compliance with the replacement standards. These benefits would not be captured in the benefits assessment, 2) Waste minimization is also likely to result in benefits such as reduced waste handling costs and reduced risks associated with waste spills and waste management.

We plan to incorporate the following discussion into the waste minimization section of the Preamble and RIA:

A quantitative assessment of the benefits associated with waste minimization may result in double counting of some of the benefits described earlier in this chapter. For example, waste minimization may reduce emissions of hazardous air pollutants and therefore have a positive effect on public health. A portion of these health impacts are captured in the analysis of health related benefits presented above. However, emissions reductions beyond those necessary for compliance with the replacement standards are not addressed in this benefits assessment. In addition, waste minimization is likely to result in specific types of benefits not captured in this Assessment. For example, waste generators that engage in waste minimization will experience a reduction in their waste handling costs and could also reduce the risk related to waste spills and waste management. These impacts are not captured in the quantitative analysis of costs and benefits presented in this Assessment.

Note that a revised Chapter Six of the RIA that includes this revised waste minimization benefits discussion is attached.

2. Issue: OMB requested that monetized human health benefits associated with avoided premature Deaths be discounted in order to be consistent with Agency and OMB guidance.

Response: OSW is preparing discounted figures for all BTF levels, where possible. OSW will also prepare an aggregated discounted figure that includes all monetized benefits ( morbidity and visibility). These figures will be presented to OMB. The aggregated figure, along with the non discounted figure will be incorporated into the Addendum.

3. Issue: RIA background document appears to have errors ( e. g., page 6 3 and exhibit 6 5).

Response: We have corrected this language. A revised Chapter Six of the RIA is attached.

4. Issue: SO 2 benefits associated with total chlorine beyond the floor standard for solid fuel fired boilers.  15 Response: OSW has prepared a stand alone assessment document that describes the methodology, data sources, findings, and limitations associated with these newly monetized benefits. This document is attached. These findings will also be incorporated into the Addendum to the RIA, and the benefits section in part four of the Preamble. OMB REVIEW DRAFT: November 2003 2 We did not include an analysis to assess the potential magnitude of property value benefits caused by the MACT standards due to limitations of the benefits transfer approach and because property value benefits likely overlap with human health and ecological benefits; including property value benefits may result in double counting. The benefits assessment also does not examine how secondary impacts such as emissions from increased coal use at combustion sources that stop burning hazardous waste as fuel may result in human health and ecological damages.

6 16 BENEFITS ASSESSMENT CHAPTER 6 ______________________________________________________________________________

This chapter presents the benefits assessment for the proposed HWC MACT replacement standards. To evaluate incremental benefits to society of emission reductions at hazardous waste combustion facilities we use results from EPA's 1998 multiple pathway human health and ecological risk assessment updated to address incremental benefits of the replacement standards ( e. g., assuming that the 2002 interim standards are in place). 2 This chapter also briefly discusses how the proposed MACT replacement standards may potentially lead to changes in the types and quantities of wastes generated and managed at combustion facilities through increased waste minimization.

The chapter is organized into eight sections:

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

Human Health Benefits Analysis: Describes the approach and presents results for characterizing human health benefits from the risk results. Where possible, we assign monetary values to these risk reductions using different economic valuation techniques. We also describe benefits to sensitive sub populations in quantitative, non monetary terms. OMB REVIEW DRAFT: November 2003 6 17

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

Ecological Benefits Analysis: Describes the methodology and results from the 1999 standards ecological benefits assessment and provides a comparison to the expected ecological benefits of the replacement standards.

Forest Health and Aesthetics: Describes the impacts of HAPs on forest ecosystems and provides examples of forest health and aesthetics benefit assessments. Forest health and aesthetics benefits results are described in qualitative terms due to the lack of research linking measurable effects of HAPs on forest ecosystems.

Agricultural Productivity: Describes the potential effects of emissions on agricultural productivity. Agricultural productivity benefits are described in qualitative terms as little research has been done on the effects of the compounds of concern in this analysis.

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

Conclusions: Summarizes key findings from the benefits assessment.

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

It is also important to note that the benefits analysis assumes a baseline scenario with constant future capacity and with combustion facilities operating at levels corresponding to trial burn performance. As explained in the " Regulatory Baseline" chapter, the characteristics of waste fed during normal operations may differ significantly from that fed during trial burns. In particular, facilities often " spike" the waste feed at the trial burns with high levels of metals, chlorine, and mercury. This situation results in emission estimates that likely exceed " typical" emissions. Therefore, the risk reductions and benefits estimates may overstate true benefits. Conversely, if significant numbers of facilities cease burning waste altogether, then risk reductions at those facilities may in some cases be greater than this analysis assumes.

BENEFITS QUANTIFICATION OVERVIEW The basis for the quantitative benefits assessment is an extrapolation of particulate matter ( PM) OMB REVIEW DRAFT: November 2003 3 Although we extrapolate benefits from the estimates presented in the 1999 Assessment and the 1999 Addendum, the 2002 Interim Standards serve as the baseline of our analysis. The 2002 Interim Standards are generally similar to the standards examined in the 1999 Assessment and Addendum; therefore, these 1999 analyses serve as a reasonable approximation of the 2002 Interim Standards baseline.

4 See " Human Health and Ecological Risk Assessment Support to the Development of Technical Standards for Emissions from Combustion Units Burning Hazardous Wastes: Background Document" July 1999.

5 It should be noted that the avoided incidence estimates were based entirely on the incremental decrease in ambient air concentrations associated with emission controls on the hazardous waste sources subject to the 1999 rule. Background levels of PM were assumed to be sufficiently high to exceed any possible threshold of effect but ambient background levels of PM were not otherwise considered in the analysis.

6 18 benefits estimated for the 1999 standards in the 1999 Assessment. 3 This section provides an overview of the methods used to extrapolate the incremental benefits of the replacement standards from those estimated for the 1999 standards. Any comparison of the 2002 interim standards, currently in place, to the proposed HWC MACT replacement standards is complicated. No separate risk assessment was conducted for the interim standards. In general, because the interim standards involved only modest changes from the 1999 standards the benefits for the interim standards are likely to be similar in magnitude to the 1999 standards.

For the 1999 Assessment, EPA estimated the avoided incidence of mortality and morbidity associated with reductions in PM emissions. 4 The risk assessment developed estimated cases of mortality and morbidity avoided for children and the elderly, as well as the general population, using concentrationresponse functions derived from human epidemiological studies available in 1998. Morbidity effects included respiratory and cardiovascular illnesses requiring hospitalization, as well as other illnesses not requiring hospitalization, such as acute and chronic bronchitis and acute upper and lower respiratory symptoms. The risk assessment also estimated decreases in PM related minor restricted activity days ( MRADs) and work loss days ( WLDs). Rates of avoided incidence, work days lost, and days of restricted activity were estimated for each of 16 sectors surrounding a facility using the concentration response functions and sector specific estimates of the corresponding population and model derived ambient air concentration, either annual mean PM 10 or PM 2.5 concentrations or distributions of daily PM 10 or PM 2.5 concentrations, depending on the concentration response function. The sectors were defined by four concentric rings out to a distance of 20 kilometers ( about 12 miles), each of which was divided into four quadrants. The sector specific rates were weighted by facility specific sampling weights and then summed to give the total incidence rates for a given source category. 5 To assess the benefits of the proposed HWC MACT replacement standards, EPA took the avoided incidence estimates from the 1999 Assessment and adjusted them to reflect both the PM emission reductions projected to occur under the replacement standards ( incremental to the 2002 Interim Standards), and changes in the universe of facilities burning hazardous wastes since the 1999 Assessment. OMB REVIEW DRAFT: November 2003 6 To account for the increase in population since the 1990 census was taken, we also adjusted the avoided incidence estimates by the ratio of the population at the national level ( corresponding to the concentration response function) for the year 2000 census vs. the 1990 census.

7 OMB guidance recommends that federal agencies conduct probabilistic assessments of the benefits associated with new regulation. Office of Management and Budge. Informing Regulatory Decisions: 2003 Report to Congress on the Costs and Benefits of Federal Regulations and Unfunded Mandates on State, Local, and Tribal Entities. 2003.

6 19 For cement kilns, lightweight aggregate kilns, and incinerators, the estimates were made by adjusting the respective estimates at the source category level by the ratio of emission reductions ( for the replacement standards vs. the 1999 standards) and the ratio of the number of facilities affected by the rules ( facilities currently burning hazardous wastes vs. facilities burning hazardous wastes in the 1999 Assessment). 6 For liquid and solid fuel fired boilers and hydrochloric acid production furnaces, EPA extrapolated the avoided incidence from the incinerator source category using a similar approach, except that the ratios of the exposed populations were used ( corresponding to the concentration response functions from the 1999 Assessment), instead of the number of facilities.

EPA estimated the exposed populations for hazardous waste burning boilers and HCl production furnaces using the same GIS methods as the 1999 Assessment ( e. g., a 16 sector overlay). Nonetheless, the extrapolated estimates are subject to additional uncertainty, especially for solid fuel fired boilers and HCl production furnaces because these two source categories have only a small number of facilities and may be poorly represented by the incinerator facilities analyzed in the 1999 Assessment.

It is important to note that the proposed HWC MACT replacement standards are incremental to the previous ( 2002 interim) rule. Therefore, benefits are more modest than the 1999 estimates because the baseline reflects the implementation of the rule similar to the 1999 rule, and assumes that a significant portion of the benefits estimated in the 1999 Assessment have already been captured. Although the benefits estimated in this analysis are expected to be more modest than those estimated in the 1999 Assessment the benefits captured by both analyses represent only a portion of the benefits associated with this rule. Specific ecological and human health benefits are not captured because of lack of research linking measurable effects of HAPs on human and ecosystem health and ecosystems.

The benefits estimates in this assessment are presented as point estimates instead of in probabilistic terms. 7 Although probabilistic estimates would provide valuable information about the uncertainty associated with the benefits of the proposed HWC MACT replacement standards, probabilistic analysis was not amenable to our methodology of adjusting the benefits estimates presented in the 1999 Assessment, which were not expressed in probabilistic terms. OMB REVIEW DRAFT: November 2003 8 " Human Health and Ecological Risk Assessment Support to the Development of Technical Standards for Emissions from Combustion Units Burning Hazardous Wastes: Background Document  Final Report," November 1998.

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

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

11 For a more detailed discussion of the land use characterization, see: Zachary Pekar and Tony Marimpietri, " Description of Methodologies and Data Sources Used in Characterizing Land Use ( including Human/ Livestock Populations), Air Modeling Impacts, and Waterbody/ Watershed Characteristics for HWC Study Areas," Memorandum, Prepared for David Layland, U. S. Environmental Protection Agency, 27 January 1998.

12 According to the risk assessment, the random sample of 65 facilities ensures that the probability of modeling at least one high risk facility is 90 percent. The other 11 combustion facilities were selected for the risk assessment at Proposal. Because these 11 facilities were not selected at random, they are handled differently from the 65 randomly selected facilities in extrapolating risks to reflect the universe of facilities.

6 20 RISK ASSESSMENT OVERVIEW The basis for the 1999 benefits Assessment was a multiple pathway risk assessment developed by the Economics, Methods and Risk Analysis Division in EPA's Office of Solid Waste. This risk assessment was designed to estimate baseline risks from hazardous waste combustion emissions, as well as expected risks after the 1999 MACT standards were implemented. 8 This section provides an overview of the risk assessment, which analyzed both human health and ecological risks that result from direct and indirect exposure to emissions from facilities that burn hazardous waste. 9 A multiple pathway analysis that models both inhalation and ingestion pathways was used to estimate human health risks. 10 The Assessment used a statistically based stratified random sampling approach in which 76 hazardous waste combustion facilities and their site specific land uses and environmental settings were characterized. 11 The randomly selected facilities in the study included: 43 on site incinerators, 13 commercial incinerators, 15 cement kilns, and five lightweight aggregate kilns. 12 The current Assessment adjusts the estimates from the 1999 Assessment to project the human health benefits of the replacement standards. OMB REVIEW DRAFT: November 2003 13 PM is not evaluated in the screening for ecological risks. Also, the national risk assessment did not include an assessment of the risk posed by nondioxin products of incomplete combustion ( PICs) due to the lack of sufficient emission measurements.

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

15 The methodology used to develop the eco toxicological criteria is largely a product of the ecological risk assessment work conducted to support the proposed HWIR for process waste.

16 Some of the exposure levels will not be sector specific ( e. g., exposure to dioxin in dairy products is based on an average concentration at dairies throughout the entire study area.)

6 21 The pollutants analyzed in the risk assessment included dioxins and furans, selected metals, and PM. 13 The metals modeled in the Assessment include the following: antimony, arsenic, barium, beryllium, cadmium, chromium copper, cobalt, lead, manganese, mercury, nickel, selenium, silver, and thallium. 14 The risk assessment modeled fate and transport of the emissions of these pollutants to arrive at concentrations in air, soil, surface water, and sediments. To assess human health risks, these concentrations can be converted to estimated doses to the exposed populations using exposure factors such as inhalation and ingestion rates. These risk assessment calculated cancer and non cancer risks using these doses, if the appropriate health benchmarks were available.

This Assessment provides a discussion of the ecological benefits that may be associated with the replacement standards by comparing emissions reductions to the reductions from the 1999 standards. In the 1999 Assessment, soil, surface water and sediment concentrations were compared with ecotoxicological criteria representing protective screening values for ecological risks to assess potential ecological risks. 15 Because these criteria were based on de minimis ecological effects and thus represented conservative values, an exceedence of the eco toxicological criteria did not necessarily indicate ecological damage; it simply suggested that potential damages could not be ruled out.

To characterize the non cancer risks to the populations listed above, the 1999 risk assessment broke down the area surrounding each modeled combustion facility into 16 polar grid sectors, as illustrated in Exhibit 6 1. For each polar grid sector, risk estimates were developed for different age groups and receptor populations ( e. g., 0 5 year old children of subsistence fishers). This approach was used because geographic and demographic differences across polar grid sectors lead to sectoral variation in individual risks. Thus, individual risk results are aggregated across sectors and weighted by population in each sector to generate the distribution of risk to individuals in the affected area. 16 An additional Monte Carlo analysis was conducted to incorporate variability in other exposure factors such as inhalation and OMB REVIEW DRAFT: November 2003 6 22 Exhibit 6 1 DIAGRAM OF 16 SECTOR POLAR BASED GRID USED IN THE RISK ASSESSMENT Waterbody ( lake)

One of 16 sectors U. S. Census Block Group 0 2 km ring 2 5 km ring 5 10 km ring 10 20 km ring ingestion rates.

HUMAN HEALTH BENEFITS This section describes in greater detail the approaches for characterizing human health benefits. The starting point for assessing benefits is identifying those pollutants for which emission reductions are expected to result in improvements to human health or the environment. We then summarize the relevant results from the risk assessment for the pollutants of concern, focusing on population risk results based on central tendency exposure parameters so that benefits can be appropriately compared with total costs. We express the risk assessment data as indicators of potential benefits, such as reduced potential for developing particular illnesses. Where possible, we assign monetary values to these benefits using a benefits transfer approach.

Human Health Benefits Methodology The approach for assessing human health benefits is divided into two components   benefits from cancer risk reductions and benefits from non cancer risk reductions. We separate the discussion in this way because the interpretation of risk reductions for carcinogenic pollutants is very different than that for non carcinogens. As explained above, for both cancer and non cancer benefits, we focus on population risks because these results form the basis for assessing total benefits of the proposed HWC MACT replacement standards. In general, these results concern the population overall with regards to different age groups, though risk reductions associated with certain pollutants, such as lead, specifically OMB REVIEW DRAFT: November 2003 17 Cancer incidence estimates used direct and indirect exposure pathways for all nonsubsistence receptors, excluding recreational anglers. Population risks could not be calculated for recreational anglers because detailed population data were not available for this receptor population.

18 In a December 30, 1997 benefits methodology memorandum, we noted that summing these estimates may pose the potential for double counting, considering that dioxin contaminated food ingestion is also evaluated on the local level ( Industrial Economics, Incorporated, Social Science Discussion Group. Handbook for Non Cancer Valuation: Draft. Prepared for U. S. EPA, 1997). However, if we make the assumption that most of the agriculture products produced within 20 kilometers of the facility are consumed outside the local area, then we minimize the double counting potential. A follow up phone call with EPA and Research Triangle Institute, the contractor that prepared the Combustion Risk Assessment, confirmed that this in fact is a reasonable assumption.

6 23 affect children within the population. In these cases, we focus on the benefits to a subset population, ages 0 19.

In addition to population results, we also describe individual risk results for the hypothetical worst case scenarios for both cancer and non cancer risks. Because we do not have population data for the most sensitive sub populations, we can only describe individual risk results for subsistence farmers and fishermen and cannot make statements concerning the total number of people that may experience health benefits associated with the proposed HWC MACT replacement standards.

Approach for Assessing Benefits from Cancer Risk Reductions In this analysis we discuss the potential cancer risk reductions by comparing the replacement standards to the results of the 1999 Assessment. The basic approach for assessing benefits from cancer risk reductions in the 1999 Assessment relied on two analytic components. First, the risk assessment estimated cancer risk reductions for all non subsistence receptors in the vicinity of combustion facilities. These risk reduction estimates were derived from the median individual risk values and population data for non subsistence population. 17 Carcinogens included in the risk assessment were dioxins/ furans, arsenic, beryllium, cadmium, chromium ( VI), and nickel. Second, the risk assessment estimated cancer risk reductions associated with the ingestion of dioxin contaminated foods grown or raised near combustion facilities but distributed nationwide. We then calculated total cancer risk reductions by summing the avoided cases in communities near combustion facilities with the number of cases avoided due to reduced dioxin in the national food supply. 18 That is,

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

The Addendum to the1999 Assessment estimated 0.36 cancer deaths would be avoided annually with a OMB REVIEW DRAFT: November 2003 19 We use the VSL approach for the MACT benefits assessment instead of applying estimates of the Value of a Statistical Life Year ( which values the number of life years lost as the result of premature mortality) because, while we have age stratified cancer incidence data for the local populations near incinerators, we do not have such data for cancer incidence from nationwide consumption of dioxin contaminated foods.

20 VSL was converted to 2002 dollars using the Consumer Price Index for all goods. WTP estimates are converted using the Consumer Price Index for all goods, while cost of illness estimates are converted using the Consumer Price Index for medical expenditures only.

21 Particulate matter is the only non carcinogen in the risk assessment for which there is sufficient dose response information to estimate numbers of cases of disease and deaths from exposures.

6 24 reduction of 28.7 grams of dioxins/ furans emissions per year. The replacement standards will reduce dioxins/ furans emissions by 0.4 grams annually for each of the Floor options and 4.7 grams annually for the Agency Preferred Approach ( Exhibit 6 5). Thus, the replacement standards are expected to avoid less than 0.36 cancer deaths annually.

To assign monetary values to cancer risk reduction estimates, we apply the value of a statistical life ( VSL) to the risk reduction expected to result from the replacement MACT standards. The VSL is based on an individual's willingness to pay ( WTP) to reduce a risk of premature death or their willingness to accept ( WTA) increases in mortality risk. 19 Because there are many different estimates of VSL in the economic literature, we would estimate the reduced mortality benefits using a range of VSL estimates from 26 policy relevant value of life studies. As shown in Exhibit 6 2, the estimated VSL figures from these studies range from $ 0.80 million to $ 18.23 million, with an average value of $ 6.42 million ( in 2002 dollars). 20 To value the mortality risk reductions, we would multiply the expected number of annual premature statistical deaths avoided by the high end, low end, and mean value of the VSL estimates.

Approach for Assessing Benefits from Non Cancer Risk Reductions A variety of approaches are used to evaluate the benefits of reducing particulate matter, for which we estimate both morbidity and mortality benefits. 21 For lead and mercury, we compare the replacement standards to the results of the 1999 Assessment. In the 1999 Assessment we used upper bound estimates of the population at risk because we only had information on the potential of an adverse effect and we could not say anything about the likelihood of the effects.

We assign monetary values to non cancer benefits using a direct cost approach which focuses on the expenditures averted by decreasing the occurrence of an illness or other health effects. While the WTP approach used for valuing the cancer risk reductions is conceptually superior to the direct cost approach, measurement difficulties, such as estimating the severity of various illnesses, preclude us from using this approach here. Direct cost measures are expected to understate true benefits because they do not include cost of pain, suffering, and time lost. On the other hand, because we use upper bound estimates of the OMB REVIEW DRAFT: November 2003 6 25 population at risk, we cannot conclude that the results are biased in one direction or the other.

Benefits from Reduced Exposure to Particulate Matter To assess benefits from reduced exposure to particulate matter in 1999, EPA first estimated the number of excess mortality and hospital admissions in the baseline and under various 1999 MACT standard scenarios. EPA then subtracted the number of cases post MACT from the number of cases in the baseline to determine potential avoided deaths and hospital admissions. Hospital admissions are associated with respiratory illness and cardiovascular disease. For the current assessment EPA scaled the cases found in the 1999 Assessment to reflect current conditions and emission reductions achieved by the proposed HWC MACT replacement standards.

Exhibit 6 2 SUMMARY OF MORTALITY VALUATION ESTIMATES Study Type of Estimate Valuation ( millions 2002$)

Kneisner and Leeth ( 1991) ( US) Labor Market 0.80 Smith and Gilbert ( 1984) Labor Market 0.92 Dillingham ( 1985) Labor Market 1.26 Butler ( 1983) Labor Market 1.49 Miller and Guria ( 1991) Contingent Value 1.61 Moore and Viscusi ( 1988a) Labor Market 3.33 Viscusi, Magat, and Huber ( 1991b) Contingent Value 3.67 Marin and Psacharopoulos ( 1982) Labor Market 3.78 Gegax et al. ( 1985) Contingent Value 4.47 Kneisner and Leeth ( 1991) ( Australia) Labor Market 4.47 Gerking, de Haan, and Schulze ( 1988) Contingent Value 4.59 Cousineau, Lacroix, and Girard ( 1988) Labor Market 4.82 Jones Lee ( 1989) Contingent Value 5.16 Dillingham ( 1985) Labor Market 5.27 Viscusi ( 1978, 1979) Labor Market 5.50 R. S. Smith ( 1976) Labor Market 6.19 V. K. Smith ( 1976) Labor Market 6.31 Olson ( 1981) Labor Market 6.99 Viscusi ( 1981) Labor Market 8.83 R. S. Smith ( 1974) Labor Market 9.75 Moore and Viscusi ( 1988a) Labor Market 9.86 Kneisner and Leeth ( 1991) ( Japan) Labor Market 10.20 OMB REVIEW DRAFT: November 2003 Exhibit 6 2 SUMMARY OF MORTALITY VALUATION ESTIMATES Study Type of Estimate Valuation ( millions 2002$)

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

6 26 Herzog and Schlottman ( 1987) Labor Market 12.27 Leigh and Folson ( 1984) Labor Market 13.07 Leigh ( 1987) Labor Market 13.99 Gaten ( 1988) Labor Market 18.23 Source: Viscusi, W. Kip. Fatal Tradeoffs: Public and Private Responsibilities for Risk. New York: Oxford University Press, 1992 In addition to avoided illnesses and deaths, benefits of reduced PM emissions include valuation of work loss days and mild restricted activity days ( MRAD). To assess benefits from reduced particulate matter exposure, EPA first estimated the number of excess mortality cases, cases of illnesses, restricted activity days, and work loss days in the baseline. We then estimate the number of cases under four MACT standards: Option 1 Floor, Option 2 Floor, Option 3 Floor, and Agency Preferred Approach. To determine potential benefits for each option, we then subtract the number of post MACT cases from the number of baseline cases. We estimated benefits based on the dollar value associated with the following health conditions:

respiratory illness,

upper respiratory symptoms,

lower respiratory symptoms,

chronic bronchitis,

acute bronchitis,

cardiovascular disease,

work loss days, and

mild restricted activity days ( MRAD). 22 For avoided deaths, we assign monetary values in the same way as for avoided cancer cases, using a range of estimates for the statistical value of a life ( see discussion above). For the avoided illnesses listed above, we estimate the avoided costs of hospital admissions for each of the health effects associated with exposure to particulate matter. To value the morbidity risk reductions, we multiply the expected number of annual reductions in hospital admissions for each ailment by the cost of illness for that condition, as shown in Exhibit 6 3. The estimated cost of each illness includes the hospital charge, the costs of associated physician care, and the opportunity cost of time OMB REVIEW DRAFT: November 2003 23 These estimates come from the following source: U. S. Environmental Protection Agency, The Benefits and Costs of the Clean Air Act, 1970 to 1990, October 1997, I11 I12. Estimates for COPD and physician charges for the remaining four illnesses come from Abt Associates, Incorporated, The Medical Costs of Five Illnesses Related to Exposure to Pollutants, Prepared for U. S. EPA, Office of Pollution Prevention and Toxics, Washington, DC, 1992. Hospital charge estimates for the remaining illnesses are from A. Elixhauser, R. M. Andrews, and S. Fox, Agency for Health Care Policy and Research ( AHCPR), Center for General Health Services Intramural Research, U. S. Department of Health and Human Services, Clinical Classifications for Health Policy Research: Discharge Statistics by Principal Diagnosis and Procedure, 1993., Pope, C. A., III, D. W. Dockery, J. D. Spengler, and M. E. Raizenne. 1991. Respiratory Health and PM10 pollution: a Daily Time Series Analysis. American Review of Respiratory Diseases. 144: 668 674., Schwartz J., and Nease L. M., 2000. Fine Particles are more strongly associated than coarse particles with acute respiratory health effects in schoolchildren. Epidemiology. 11L 6 10. Schwartz J., Dockery, D. W., Nease, L. M., Wypij, D., Ware, J. H., Spengler, J. D., Koutrakis, P., Speizer, F. E., and Ferris, Jr., B. G. 1994. Acute Effects of Summer Air Pollution on Respiratory Symptom Reporting in Children. American Journal of Respiratory Critical Care Medicine. 150. 1234 1242., and Dockery, D. W., J. Cunningham, A. I. Damokosh, L. M. Neas, J. D. Spengler, P. Koutrakis, J. H. Ware, M. Raizenne, and F. R. Speizer. 1996. Health Effects of Acid Aerosols on North American Children Respiratory Symptoms. Enviromental Health Perspectives. 104( 5)" 500 505.

6 27 spent in the hospital. 23 Since these estimates do not include post hospital costs or pain and suffering of the afflicted individuals, the cost of illness estimates may understate benefits. OMB REVIEW DRAFT: November 2003 6 28 Exhibit 6 3 AVOIDED COST OF CASES ASSOCIATED WITH PM Illness Estimated Cost Per Incidence ( 2002 $)

Respiratory Illness1 $ 9,011 Upper respiratory symptoms2 $ 27 Lower respiratory symptoms3 $ 18 Chronic bronchitis1 $ 382,969 Acute bronchitis4 $ 55 Cardiovascular disease1 $ 15,018 Work loss days ( cost per day) 1 $ 112 Minor restricted activity days ( cost per day) 1 $ 39 Sources: 1 U. S. Environmental Protection Agency, The Benefits and Costs of the Clean Air Act, 1970 to 1990, October 1997, I11 I12 2 Pope, C. A., III, D. W. Dockery, J. D. Spengler, and M. E. Raizenne. 1991. Respiratory Health and PM10 pollution: a Daily Time Series Analysis. American Review of Respiratory Diseases. 144: 668 674. 3 Average of Schwartz J., and Nease L. M., 2000. Fine Particles are more strongly associated than coarse particles with acute respiratory health effects in schoolchildren. Epidemiology. 11L 6 10. and Schwartz J., Dockery, D. W., Nease, L. M., Wypij, D., Ware, J. H., Spengler, J. D., Koutrakis, P., Speizer, F. E., and Ferris, Jr., B. G. 1994. Acute Effects of Summer Air Pollution on Respiratory Symptom Reporting in Children. American Journal of Respiratory Critical Care Medicine. 150. 1234 1242. 4 Neumann, J. E., M. T. Dickie, and R. E. Unsworth. 1994. Industrial Economics, Incorporated. Memorandum to Jim DeMocker, U. S. EPA, Office of Air and Radiation. Linkage Between Health Effects Estimation and Morbidity Valuation in the Section 812 Analysis  Draft Valuation Document. March 31. Note: Cardiovascular disease is assumed to be Ischemic heart disease.

Benefits from Reduced Exposure to Lead The primary effect from chronic exposure to lead is to the central nervous system. Children are particularly sensitive to the effects of lead and excess exposure can affect a child's nervous system and cognitive development. The proposed HWC MACT replacement standards will reduce lead emissions by approximately five to seven tons per year for the Floor and Agency Preferred Approach options, or OMB REVIEW DRAFT: November 2003 24 Based on the population estimated in the 1999 Assessment.

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

26 Benefits estimate was converted to 2002 dollars using the Consumer Price Index for all goods. WTP estimates are converted using the Consumer Price Index for all goods, while cost of illness estimates are converted using the Consumer Price Index for medical expenditures only.

27 It is important to note that OSW is currently working to obtain ORD review of the risk assessment for mercury. Given the current state of scientific knowledge, there is controversy regarding modeling mercury concentrations in fish.

28 N. J. Waitzman, R. M Scheffler, and P. S. Romano, The Costs of Birth Defects, Lanham, Maryland: University Press of America, Inc., 1996. This study provides estimates of the costs of birth defects involving major structural anomalies, and includes both direct and indirect costs. The direct costs include medical, developmental, and special education outlays. Indirect costs consist of the foregone earnings and fringe benefits from premature mortality, excess morbidity, lower 6 29 less than 0.01 pounds per person ( see below, Exhibit 6 5). 24 The 1999 standards were expected to reduce lead emissions by 89 tons per year, or 0.17 pounds per person, and were expected to reduce cumulative lead exposures for seven children age 0 5 to less than 10 µ g/ dL. The benefits associated with the replacement standards are expected to be more modest per year, reducing the cumulative lead exposures for fewer than seven children age 0 5, to less than 10 µ g/ dL annually.

The Benefits and Costs of the Clean Air Act, 1970 to 1990 monetizes benefits of reduced lead emissions by associating high blood lead levels with reduction in IQ. 25 The analysis estimates annual benefits of about $ 49 million associated with reductions ranging from 5,000 to 13,000 tons of lead, depending on the year. 26 The reduction of lead emissions and increase in IQ does not display a linear relationship and cannot be transferred to this analysis so we do not attempt to monetize them.

Benefits from Reduced Exposure to Mercury The 1999 Assessment considered benefits from reduced exposure to mercury. The 1999 standards were expected to reduce mercury emissions by four tons per year, the replacement standards are expected to reduce mercury emissions by about one ton per year ( Exhibit 6 5). This Assessment provides no quantification of health benefits associated with the reduction of mercury emission resulting from the replacement standards but does provide a discussion of the benefits estimated in the 1999 Assessment. The Assessment noted that recreational anglers exposed to mercury above levels of concern are potentially at risk for bearing children with developmental abnormalities. 27 To project the benefits of reduced exposure, the 1999 risk assessment estimated the median cost of developmental abnormalities using a range of estimates for various birth defects provided in the Waitzman et al. study ( see Exhibit 6 4). 28 In a survey of the non cancer economic literature, this study was found to provide reasonable OMB REVIEW DRAFT: November 2003 wages, and lower labor force participation rates. In addition, indirect costs include foregone nonmarket production, based on the cost of hiring people for household work.

29 U. S. Environmental Protection Agency, Social Science Discussion Group, Handbook for Non Cancer Valuation: Draft, Prepared for U. S. EPA by Industrial Economics, Incorporated, September 30, 1997.

30 U. S. Department of Commerce, Bureau of the Census, Statistical Abstract of the United States 1995, 115th ed., 73.

6 30 benefit measures. 29 The birth rate of the general population indicates that 1.67 percent of recreational anglers potentially at risk will have children in a given year. 30 This estimate also may understate benefits because it does not include avoided pain and suffering.

It is important to note that the approach used in the 1999 Assessment uses upper bound estimates of the population at risk to compute benefits for mercury. For the 1999 Assessment the cost of developmental abnormalities was applied to all recreational anglers potentially at risk ( e. g., those exposed to mercury above levels of concern ( HQ> 1)) ( Exhibit 6 4). This approach did not allow us to say anything about the likelihood of an adverse effect for the anglers at risk; we could only say that we could not rule out adverse impacts for these individuals. Subsistence fishermen, those individuals who obtain a significant portion of their dietary fish intake from their own fishing activities, potentially faced even greater risk for bearing children with developmental abnormalities as a result of higher mercury exposure levels in their daily fish consumption.

Benefits from Reduced Exposure to Chlorine This analysis does not quantify the benefits associated with reductions in chlorine emissions. The replacement standards are expected to reduce total chlorine emissions, a combination of hydrogen chloride ( HCl) and chlorine gas ( Cl 2) emissions, by approximately 1,426 to 4,806 tons per year for the Floor options and 2,490 tons per year for the Agency Preferred Approach ( Exhibit 6 5). Hydrogen chloride is corrosive to the eyes, skin, and mucous membranes. Acute inhalation can cause eye, nose, and respiratory tract irritation and inflamation, and pulmonary edema. Chronic occupational inhalation has been reported to cause gastritis, bronchitis, and dermatitis in workers. Long term exposure can also cause dental discoloration and erosion. No information is available on the reproductive or developmental effects in humans. Chlorine gas inhalation can cause bronchitis, asthma and swelling of the lungs, headaches, heart disease, and meningitis. Acute exposure causes more severe respiratory and lung effects, and can result in fatalities. No information is available on the reproductive or developmental effects in humans. The proposed HWC MACT replacement standards are expected to reduce chlorine exposure for people in close proximity to hazardous waste combustion facilities, and are therefore likely to reduce the risk of all of these health effect among those populations. However, without detailed exposure modeling it is not possible to quantify the impact of the proposed HWC MACT replacement standards. OMB REVIEW DRAFT: November 2003 6 31 Exhibit 6 4 COSTS OF ILLNESS ASSOCIATED WITH VARIOUS BIRTH DEFECTS Health Condition Cost per Case ( thousands)

Spina bifida $ 405 Truncus arteriosus $ 697 Transposition of great arteries/ Double Outlet Right Ventricle $ 368 Single ventricle $ 474 Tetralogy of Fallot $ 360 Cleft lip or palate $ 140 Tracheoesophageal fistula $ 200 Atresia of the small intestine $ 103 Colorectal atresia $ 169 Renal agenesis $ 345 Urinary tract obstruction $ 116 Upper limb reduction $ 138 Lower limb reduction $ 274 Diaphragmatic hernia $ 345 Gastroschisis $ 149 Omphalocele $ 243 Down syndrome $ 622 Median $ 274 Source: Waitzman et al. ( 1996). Note: Figures are in 2002 dollars.

Human Health Benefit Results This Assessment provides quantified human health benefits from both cancer and non cancer risk reductions related to PM emissions reductions for each of the Floor options and the Agency Preferred Approach. In addition, benefits from reduced exposure to lead and mercury are discussed and compared to the 1999 standards benefits estimates. Finally, we are not able to quantify benefits to reduced exposure to chlorine but we discuss potential effects of hydrogen chloride and chlorine gas.

In general, the 1999 standards resulted in greater incremental emissions reductions than are expected OMB REVIEW DRAFT: November 2003 6 32 under the proposed HWC MACT replacement standards ( Exhibit 6 5). This is reasonable given that the proposed HWC MACT replacement standards address only emissions reductions not already captured by the 2002 interim standards. One notable exception is that Option 3 Floor is associated with a greater PM emissions reduction than the options considered for the 1999 standards. Among the proposed HWC MACT replacement standards options Option 3 Floor is expected to result in the most human health benefits. The Agency Preferred Approach is expected to result in more human health benefits than Option 1 Floor and Option 2 Floor.

Exhibit 6 5 ANNUAL EMISSIONS REDUCTIONS FOR THE PROPOSED HWC MACT REPLACEMENT STANDARDS Standard Particulate Matter ( tons/ yr) Mercury ( tons/ yr) Lead ( tons/ yr) Dioxins/ Furans ( grams/ yr) Chlorine ( tons/ yr)

Agency Preferred Approach 2,215 0.9 5.4 4.7 2,635 Option 1 Floor 1,829 0.9 5.1 0.4 1,570 Option 2 Floor 1,829 1.3 5.8 0.4 3,106 Option 3 Floor 3,254 1.3 6.6 0.4 4,955 1999 Standard 2,449 3.9 89 28.7 5,132 A summary of the quantified benefits for the Agency Preferred Approach are provided in Exhibit 6 6, and the summary of quantified benefits of the Floor options are presented in Exhibit 6 7. Below, we describe the results in more detail.

Benefits from Cancer Risk Reductions Less than 0.36 cancer cases per year are expected to be avoided due to the proposed HWC MACT replacement standards. Based on the 1999 Assessment the majority of the cancer risk reductions are linked to consumption of dioxin contaminated agricultural products exported beyond the boundaries of the study area ( e. g., within 20 km). Less than one third of the cancer risk reductions occurred in local populations living near combustion facilities. Cancer risks for local populations were attributed primarily to reductions in arsenic and chromium emissions; these pollutants accounted for almost 85 percent of total local cancer incidence in the baseline.

In 1999, across all receptor populations, individual cancer risks were greatest for subsistence farmers, individuals who obtain the majority of their dietary intake of all agricultural commodities from home OMB REVIEW DRAFT: November 2003 31 The following pathways pertain to this subsistence receptor: ingestion of homeproduced beef, pork, chicken, eggs, milk, root vegetables, exposed fruit, exposed vegetables, and fish caught on farm ponds.

32 The hypothetical scenario with the greatest individual cancer risk is that for children ( ages 0 5 and 6 11) of subsistence farmers resulting from dioxin associated with commercial incinerator emissions.

33 Baseline cancer risk for subsistence farmers ages 0 5 and 6 11 associated with cement kiln emissions was 2E 05; it remained 2E 05 following the implementation of the 1999 standards. It is important to emphasize that because of the absence of subsistence farmer population estimates, these hypothetical scenarios represent only the upper bound, worst case risks possible. No conclusions can be made as to the incidence rates associated with these hypothetical worst case individual risks.

34 Other pollutants were found to pose negligible individual risks and so are not included in the results.

6 33 production. 31 Dioxin and arsenic were the primary pollutants that drive the cancer risks for this sensitive receptor population. Lack of population data prevented the quantification of benefits for this hypothetical sub population, but the reduction in risk from baseline to implementation of the 1999 standards was characterized. Subsistence farmers exposed to the highest individual risks faced getting cancer with a probability of five in 100,000.32 With the exception of one particular scenario, the cancer risk for all subsistence farmers was reduced to below levels of concern after implementation of the 1999 standards. 33 The 1999 Assessment found that in addition to the cancer risk reductions for the overall population, the 1999 standards would result in lower cancer risks for the children of especially sensitive sub populations. Children of subsistence farmers, who potentially face the greatest individual risk of any receptor population, were expected to experience a reduction in individual cancer risk by a factor as high as 0.005. Risk reductions may be associated with the proposed HWC MACT replacement standards, particularly near facilities with boilers and industrial furnaces that are not subject to regulation under the 2002 interim standards.

Benefits from Non Cancer Risk Reductions Most of the human health benefits from the proposed HWC MACT replacement standards come from reductions in particulate matter. Some additional benefits which are not quantified in this analysis, may come from reductions in exposure to lead, mercury, chlorine, and dioxin for people living near combustion facilities. 34 Total annual health benefits are valued at about $ 4.5 million for Option 1 Floor and Option 2 Floor and the Agency Preferred Approach, and $ 8.7 million for Option 3 Floor.

Particulate Matter. The proposed HWC MACT replacement standards are expected to avoid less OMB REVIEW DRAFT: November 2003 35 U. S. EPA, Environmental Health Threats to Children, EPA 175 F 96 001, September 1996, page 4.

36The primary form of lead exposure to children is via ingestion of contaminated soil.

6 34 than one premature death for each of the regulatory options, 54 illnesses annually for Option 1 Floor and Option 2 Floor and Agency Preferred Approach, and 105 illnesses annually for Option 3 Floor; all illnesses are associated with exposure to PM. These and other human health benefits related to reduced PM exposure are valued at $ 4.5 million to $ 8.7 million per year. Benefits from reduced exposure to PM come primarily from liquid boilers. Reductions in the number of respiratory diseases account for over half of the morbidity benefits. While separate results are not available for children, it is safe to assume that many of the respiratory health benefits will be experienced by children, who are thought to be especially vulnerable to the effects of PM exposure. 35 Mercury. The 1999 standards were expected to reduce mercury emission by four tons per year. The proposed HWC MACT replacement standards are expected to reduce mercury emissions by an additional one ton per year ( Exhibit 6 5). The benefits associated with the reduction under the proposed HWC MACT replacement standards are not quantified in this analysis.

The 1999 Assessment found risk reductions in recreational anglers potentially exposed to mercurycontaminated fish could be significant, with fewer anglers at risk for having offspring with developmental abnormalities. Baseline mercury risks are greatest for subsistence fishermen, individuals who obtain a significant portion of their dietary fish intake from self caught fish. Subsistence fishermen face an overall non cancer risk with a hazard index as high as 10 for some individuals that is driven primarily by methyl mercury. The 1999 Assessment found the baseline risks for mercury to be less than one for methyl mercury intake from fish for recreational anglers and subsistence fishers. Following the implementation of the proposed HWC MACT replacement standards, the hazard index for subsistence fishermen may be further reduced, suggesting that subsistence fishermen will potentially experience reduced risks of having children with developmental abnormalities. This reduction is likely to be less than the reductions described in the 1999 Assessment, but relying on past analyses may also underestimate the benefits of reduced mercury exposure, as mercury health science is continuing to evolve.

Lead. The proposed HWC MACT replacement standards will reduce lead emissions by approximately five to seven tons per year for the Floor and Agency Preferred Approach options ( Exhibit 6 5). In comparison, the 1999 standards were expected to reduce lead emissions by 89 tons per year, and were expected to reduce cumulative lead exposures for seven children age 0 5 to less than 10 µ g/ dL. The benefits associated with the proposed HWC MACT replacement standards are therefore expected to be modest, reducing the cumulative lead exposures for less than seven children age 0 5 less than 10 µ g/ dL annually. 36 The proposed HWC MACT replacement standards will also result in reduced lead levels for children of sub populations with especially high levels of exposure. Children of subsistence fishermen, commercial beef farmers, and commercial dairy farmers who face the greatest levels of cumulative lead exposure will also experience comparable reductions in overall exposure as a result of the MACT OMB REVIEW DRAFT: November 2003 6 35 standards. The small number of cases identified in the 1999 Assessment suggests that these benefits may be modest. OMB REVIEW DRAFT: November 2003 6 36 Human Health Benefits Summary The measurable annual human health benefits associated with emission reductions from Option 1 Floor and Option 2 Floor of the HWC MACT replacement standards include less than one avoided premature death, reductions of 1.3 hospital admission ( respiratory illness and cardiovascular disease involve hospital admissions), ten cases of bronchitis, 52 cases of respiratory symptoms, and about 4,200 days of work loss or MRAD. For Option 3 Floor annual human health benefits include less than one avoided premature death, reductions of three hospital admission, 19 cases of bronchitis, 102 cases of respiratory symptoms, and about 8,200 days of work loss or MRAD. Additional ecological and human health benefits are possible but not quantified in this analysis due to lack of data. Exhibit 6 8 summarizes the quanitifiable human health benefits across combustion sources for the Agency Preferred Approach and Floor options 1 through 3. Overall, the majority of the human health benefits are due to reductions in liquid boiler emissions. This is primarily due to the fact that liquid boilers comprise the largest portion of the total number of hazardous waste combustion systems, roughly 40 percent.

Annual human health benefits associated with emission reductions from the Agency Preferred Approach include less than one avoided premature death, reductions of 1.3 hospital admission, ten cases of bronchitis, 53 cases of respiratory symptoms, and about 5,000 days of work loss or MRAD. The Agency Preferred Approach does have additional health benefits that are not quantified including Cl, dioxin, etc. This analysis quantifies only the human health benefits associated with reduction in PM emissions. Thus, the quantified Agency Preferred Approach benefits do not differ greatly from Option 1 Floor and Option 2 Floor and are less than Option 3 Floor ( Exhibit 6 5).

However, one of the greatest differences between the HWC MACT Standards Floor options and the Agency Preferred Approach; is the increased reduction in dioxin emissions with the Agency Preferred Approach; a six fold increase in emissions reduced is expected under the Agency Preference Approach. The primary concern associated with dioxin is increased cancer risk. In the 1999 Assessment cancer risk reductions linked to consumption of dioxin contaminated agricultural products exported beyond 20 km of the facility accounted for the majority of the 0.36 cancer cases per year that were expected to be avoided due to the 1999 standards. Although the incremental reduction in dioxin emissions from the Agency Preferred Approach are expected to be about 12 times less than the 1999 standards, recent studies have shown a substantial increase in cancer risk estimates for exposure to dioxin. ( See, for example, Steenland et al. ( 1999), Fingerhut et al. ( 1991), Becher et al. ( 1996), Flesch Janys et al. ( 1995, 1 9 9 8 , 1 9 9 9 ) , Ma n z et al . ( 1 9 9 1 ) , O t t e t a l. ( 1 9 9 6 ) , OMB REVIEW DRAFT: November 2003 37 Steenland, K; Piacitelli, L; Deddens, J; et al. ( 1999) Cancer, heart disease, and diabetes in workers exposed to 2,3,7,8 Tetrachlorodibenzo p dioxin. J Nat Cancer Ins 91( 9): 779 786; Fingerhut, MA; Halperin, WE; Marlow, DA; et al. ( 1991) Cancer mortality in workers exposed to 2,3,7,8 tetrachlorodibenzo p dioxin. N Engl J Med 324: 212 218; Becher, H; Flesch Janys, D; Kauppinen, T; et al. ( 1996) Cancer mortality in German male workers exposed to phenoxy herbicides and dioxins. Cancer Causes Control 7: 312 321; Flesch Janys, D. ( 1997) Letters to the editor: the first author replies. Am J Epidemiol 146( 4): 362 363; Flesch Janys, D; Berger, J; Gurn, P; et al. ( 1995) Exposure to polychlorinated dioxins and furans ( PCDD/ F) and mortality in a cohort of workers from a herbicide producing plant in Hamburg, Federal Republic of Germany. Am J Epidemiol 142( 11): 1165 1175; Flesch Janys, D; Steindorf, K; Gurn, P; et al. ( 1998) Estimation of the cumulated exposure to polychlorinated dibenzo p dioxins/ furans and standardized mortality ratio analysis of cancer mortality by dose in an occupationally exposed cohort. Environ Health Perspect 106( supplement 2): 655 662; Flesch Janys, D.; Becher, J.; Berger, J.; et al. ( 1999) Epidemiological investigation of breast cancer incidence in a cohort of female workers with high exposure to PCDD/ F and HCH. Organohalogen Compounds 44: 379 382; Manz, A; Berger, J; Dwyer, JH; et al. ( 1991) Cancer mortality among workers in chemical plant contaminated with dioxin. Lancet 338: 959 964; Ott, MG; Zober, A. ( 1996) Cause specific mortality and cancer incidence among employees exposed to 2,3,7,8 TCDD after a 1953 reactor accident. Occup Environ Med 53: 606 612; Zober, A; Messerer, P; Huber, P. ( 1990) Thirty fouryear mortality follow up of BASF employees exposed to 2,3,7,8 TCDD after the 1953 accident. Int Arch Occup Environ Health 62: 138 157; Kogevinas, M; Becher, H; Benn, T; et al. ( 1997) Cancer mortality in workers exposed to phenoxy herbicides, chlorophenols, and dioxin. An expanded and updated international cohort study. Am J Epidemiol 145 ( 12): 1061 1075; Saracci, R; Kogevinas, M; Bertazzi, P; et al. ( 1991) Cancer mortality in workers exposed to chlorophenoxy herbicides and chlorophenols. Lancet 38( 3774): 1027 1032; Hooiveld, M; Heederik, D. ( 1996) Preliminary results of the second follow up of a Dutch cohort occupationally exposed to phenoxy herbicides, chlorophenols, and contaminants. Organohalogen Compounds 30: 185 189; and Hooiveld, M; Heederik, DJ J; Kogevinas, M; et al. ( 1998) Second follow up of a Dutch cohort occupationally exposed to phenoxy herbicides, chlorophenols, and contaminants. Am J Epidemiol 147( 9): 891 901.

6 37 Zober et al. ( 1990), Kogevinas et al. ( 1997), Saracci et al. ( 1991), and Hooiveld et al. ( 1996, 1998)). 37 As a result, benefits associated with reductions in dioxin may be significantly higher than the quantified estimates provided here ( e. g. because the estimates here are based on older studies).

Reduced dioxin emissions may result in additional cancer risk reductions for the most sensitive subpopulations subsistence fishermen and farmers, and their children. Because we do not have population data for the most sensitive sub populations, we can only describe individual risk results for subsistence farmers and fishermen and cannot make statements concerning the total number of people that may experience health benefits associated with the Agency Preferred Approach. In 1999, across all receptor populations, individual cancer risks were greatest for subsistence farmers. These cancer risks were driven primarily by dioxin and arsenic. Subsistence farmers exposed to the highest individual risks faced getting OMB REVIEW DRAFT: November 2003 38 The hypothetical scenario with the greatest individual cancer risk is that for children ( ages 0 5 and 6 11) of subsistence farmers resulting from dioxin associated with commercial incinerator emissions.

39 Baseline cancer risk for subsistence farmers ages 0 5 and 6 11 associated with cement kiln emissions was 2E 05; it remained 2E 05 following the implementation of the 1999 standards. It is important to emphasize that because of the absence of subsistence farmer population estimates, these hypothetical scenarios represent only the upper bound, worst case risks possible. No conclusions can be made as to the incidence rates associated with these hypothetical worst case individual risks.

6 38 cancer with a probability of five in 100,000.38 With the exception of one particular scenario, the cancer risk for all subsistence farmers was reduced to below levels of concern after implementation of the 1999 standards, based on risk data available at the time. However the 1999 standards did not address boilers and industrial furnaces. 39 Children of subsistence farmers, who potentially face the greatest individual risk of any receptor population, were expected to experience a reduction in individual cancer risk by a factor as high as 0.005.

Exhibit 6 6 HUMAN HEALTH BENEFITS SUMMARY: BASELINE TO AGENCY PREFERRED APPROACH Type of Benefit Reduction in Number of Cases per Year Annual Undiscounted Value ( 2002$) ( millions)

Human Health Benefits Premature deaths avoided 0.3 $ 2.11 Respiratory illness 0.9 $ 0.01 Cardiovascular disease 0.4 $ 0.01 Chronic bronchitis 5.7 $ 2.17 Acute bronchitis 4.3 $ 0 Lower respiratory symptoms 38.4 $ 0 Upper respiratory symptoms 4.5 $ 0 Work loss days 451.1 $ 0.05 Minor restricted activity 3757.8 $ 0.15 Total Annual Monetary Benefits $ 4.50 OMB REVIEW DRAFT: November 2003 6 39 OMB REVIEW DRAFT: November 2003 6 40 Exhibit 6 7 HUMAN HEALTH BENEFITS SUMMARY: BASELINE TO PROPOSED HWC MACT REPLACEMENT STANDARDS FLOOR OPTIONS Option Option 1 Floor Option 2 Floor Option 3 Floor Type of Benefit Reduction in Number of Cases per Year Annual Undiscounted Value ( 2002$)

( millions) Reduction in Number of Cases per Year Annual Undiscounted Value ( 2002$)

( millions) Reduction in Number of Cases per Year Annual Undiscounted Value ( 2002$)

( millions)

Human Health Benefits Premature deaths avoided 0.3 $ 2.09 0.3 $ 2.09 0.6 $ 4.12 Respiratory illness 0.9 $ 0.01 0.9 $ 0.01 1.7 $ 0.02 Cardiovascular disease 0.4 $ 0.01 0.4 $ 0.01 0.8 $ 0.01 Chronic bronchitis 5.6 $ 2.15 5.6 $ 2.15 11.0 $ 4.20 Acute bronchitis 4.3 $ 0 4.3 $ 0 8.4 $ 0 Lower respiratory symptoms 38.1 $ 0 38.1 $ 0 74.2 $ 0 Upper respiratory symptoms 4.4 $ 0 4.4 $ 0 8.6 $ 0 Work loss days 447.3 $ 0.05 447.3 $ 0.05 874.7 $ 0.10 Minor restricted activity 3726.1 $ 0.15 3726.1 $ 0.15 7287.2 $ 0.29 Total Annual Monetary Benefits $ 4.46 $ 4.46 $ 8.73 OMB REVIEW D 6 41 OMB REVIEW DRAFT: November 2003 6 42 Exhibit 6 8 BENEFITS SUMMARY: CASES AVOIDED BY SOURCE, BASELINE TO PROPOSED HWC MACT REPLACEMENT STANDARDS Agency Recommended Approach Option 1 Floor Option 2 Floor Option 3 Floor Type of Benefit Reduction in Number of Cases per Year Annual Undiscounted Value ( 2002$ millions) Reduction in Number of Cases per Year Annual Undiscounted Value ( 2002$ millions) Reduction in Number of Cases per Year Annual Undiscounted Value ( 2002$ millions) Reduction in Number of Cases per Year Annual Undiscounted Value ( 2002$ millions)

LWAK/ Human Health Benefits Premature deaths avoided 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Respiratory illness 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Cardiovascular disease 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Chronic bronchitis 0.1 $ 0.03 0.1 $ 0.03 0.1 $ 0.03 0.1 $ 0.03 Acute bronchitis 0.1 $ 0.00 0.1 $ 0.00 0.1 $ 0.00 0.1 $ 0.00 Lower respiratory symptoms 0.5 $ 0.00 0.5 $ 0.00 0.5 $ 0.00 0.5 $ 0.00 Upper respiratory symptoms 0.1 $ 0.00 0.1 $ 0.00 0.1 $ 0.00 0.1 $ 0.00 Work loss days 4.2 $ 0.00 4.2 $ 0.00 4.2 $ 0.00 4.2 $ 0.00 Minor restricted activity 35.0 $ 0.00 35.0 $ 0.00 35.0 $ 0.00 35.0 $ 0.00 Subtotal $ 0.03 $ 0.03 $ 0.03 $ 0.03 Cement Kilns/ Human Health Benefits Premature deaths avoided 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Respiratory illness 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Cardiovascular disease 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Chronic bronchitis 0.1 $ 0.03 0.1 $ 0.03 0.1 $ 0.03 0.1 $ 0.04 Acute bronchitis 0.1 $ 0.00 0.1 $ 0.00 0.1 $ 0.00 0.1 $ 0.00 Lower respiratory symptoms 0.6 $ 0.00 0.6 $ 0.00 0.6 $ 0.00 0.9 $ 0.00 OMB REVIEW DRAFT: November 2003 Exhibit 6 8 BENEFITS SUMMARY: CASES AVOIDED BY SOURCE, BASELINE TO PROPOSED HWC MACT REPLACEMENT STANDARDS Agency Recommended Approach Option 1 Floor Option 2 Floor Option 3 Floor Type of Benefit Reduction in Number of Cases per Year Annual Undiscounted Value ( 2002$ millions) Reduction in Number of Cases per Year Annual Undiscounted Value ( 2002$ millions) Reduction in Number of Cases per Year Annual Undiscounted Value ( 2002$ millions) Reduction in Number of Cases per Year Annual Undiscounted Value ( 2002$ millions)

6 43 Upper respiratory symptoms 0.1 $ 0.00 0.1 $ 0.00 0.1 $ 0.00 0.1 $ 0.00 Work loss days 4.1 $ 0.00 4.1 $ 0.00 4.1 $ 0.00 5.9 $ 0.00 Minor restricted activity 34.4 $ 0.00 34.4 $ 0.00 34.4 $ 0.00 48.9 $ 0.00 Subtotal $ 0.03 $ 0.03 $ 0.03 $ 0.05 All Incinerators/ Human Health Benefits Premature deaths avoided 0.0 $ 0.13 0.0 $ 0.13 0.0 $ 0.13 0.0 $ 0.24 Respiratory illness 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.1 $ 0.00 Cardiovascular disease 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Chronic bronchitis 0.3 $ 0.12 0.3 $ 0.12 0.3 $ 0.12 0.6 $ 0.23 Acute bronchitis 0.3 $ 0.00 0.3 $ 0.00 0.3 $ 0.00 0.5 $ 0.00 Lower respiratory symptoms 2.4 $ 0.00 2.4 $ 0.00 2.4 $ 0.00 4.4 $ 0.00 Upper respiratory symptoms 0.3 $ 0.00 0.3 $ 0.00 0.3 $ 0.00 0.5 $ 0.00 Work loss days 27.5 $ 0.00 27.5 $ 0.00 27.5 $ 0.00 50.4 $ 0.01 Minor restricted activity 229.1 $ 0.01 229.1 $ 0.01 229.1 $ 0.01 419.9 $ 0.02 Subtotal $ 0.27 $ 0.27 $ 0.27 $ 0.49 OMB REVIEW DRAFT: November 2003 Exhibit 6 8 BENEFITS SUMMARY: CASES AVOIDED BY SOURCE, BASELINE TO PROPOSED HWC MACT REPLACEMENT STANDARDS Agency Recommended Approach Option 1 Floor Option 2 Floor Option 3 Floor Type of Benefit Reduction in Number of Cases per Year Annual Undiscounted Value ( 2002$ millions) Reduction in Number of Cases per Year Annual Undiscounted Value ( 2002$ millions) Reduction in Number of Cases per Year Annual Undiscounted Value ( 2002$ millions) Reduction in Number of Cases per Year Annual Undiscounted Value ( 2002$ millions)

6 44 Coal Boilers/ Human Health Benefits Premature deaths avoided 0.0 $ 0.02 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Respiratory illness 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Cardiovascular disease 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Chronic bronchitis 0.1 $ 0.02 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Acute bronchitis 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Lower respiratory symptoms 0.4 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Upper respiratory symptoms 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Work loss days 4.2 $ 0.00 0.4 $ 0.00 0.4 $ 0.00 0.4 $ 0.00 Minor restricted activity 34.9 $ 0.00 3.2 $ 0.00 3.2 $ 0.00 3.2 $ 0.00 Subtotal $ 0.04 $ 0.00 $ 0.00 $ 0.00 HCl Production Furnaces/ Human Health Benefits Premature deaths avoided 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Respiratory illness 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Cardiovascular disease 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Chronic bronchitis 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Acute bronchitis 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 OMB REVIEW DRAFT: November 2003 Exhibit 6 8 BENEFITS SUMMARY: CASES AVOIDED BY SOURCE, BASELINE TO PROPOSED HWC MACT REPLACEMENT STANDARDS Agency Recommended Approach Option 1 Floor Option 2 Floor Option 3 Floor Type of Benefit Reduction in Number of Cases per Year Annual Undiscounted Value ( 2002$ millions) Reduction in Number of Cases per Year Annual Undiscounted Value ( 2002$ millions) Reduction in Number of Cases per Year Annual Undiscounted Value ( 2002$ millions) Reduction in Number of Cases per Year Annual Undiscounted Value ( 2002$ millions)

6 45 Lower respiratory symptoms 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Upper respiratory symptoms 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Work loss days 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Minor restricted activity 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Subtotal $ 0.00 $ 0.00 $ 0.00 $ 0.00 Liquid Boilers/ Human Health Benefits Premature deaths avoided 0.3 $ 1.96 0.3 $ 1.96 0.3 $ 1.96 0.6 $ 3.88 Respiratory illness 0.8 $ 0.01 0.8 $ 0.01 0.8 $ 0.01 1.6 $ 0.01 Cardiovascular disease 0.4 $ 0.01 0.4 $ 0.01 0.4 $ 0.01 0.7 $ 0.01 Chronic bronchitis 5.1 $ 1.97 5.1 $ 1.97 5.1 $ 1.97 10.2 $ 3.89 Acute bronchitis 3.9 $ 0.00 3.9 $ 0.00 3.9 $ 0.00 7.7 $ 0.00 Lower respiratory symptoms 34.5 $ 0.00 34.5 $ 0.00 34.5 $ 0.00 68.4 $ 0.00 Upper respiratory symptoms 4.0 $ 0.00 4.0 $ 0.00 4.0 $ 0.00 7.9 $ 0.00 Work loss days 411.1 $ 0.05 411.1 $ 0.05 411.1 $ 0.05 813.9 $ 0.09 Minor restricted activity 3,424.3 $ 0.13 3,424.3 $ 0.13 3,424.3 $ 0.13 6,780.1 $ 0.27 Subtotal $ 4.12 $ 4.12 $ 4.12 $ 8.16 Total $ 4.50 $ 4.46 $ 4.46 $ 8.73 VISIBILITY BENEFITS OMB REVIEW D 40 Chestnut, L. and R. Rowe. 1989. " Economic Valuation of Changes in Visibility: A State of the Science Assessment for NAPAP," as cited in National Acid Preparation Assessment Program, Methods for Valuing Acidic Deposition and Air Pollution Effects. NAPAP State of Science and State of Technology Report No. 27, Part B. December.

41 Chestnut, L. and R. Dennis. 1997. " Economic Benefits of Improvements in Visibility: Acid Rain Provisions of the 1990 Clean Air Act Amendments" Journal of Air and Waste Management Association 47: 395 402.

42 McClelland, G. et al. 1991. Valuing Eastern Visibility: A field test of the Contingent Valuation Method. Prepared for Office of Policy, Planning and Evaluation, USEPA, June.

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

44 U. S. EPA, Draft Regulatory Impact Analysis: Control of Emission from Nonroad Diesel Engines, Assessment and Standards Division, April 2003.

6 46 Particulate matter emissions are a primary cause of reduced visibility. Changes in the level of ambient PM caused by the reduction in emissions from the proposed HWC MACT replacement standards will increase the level of visibility in some parts of the U. S. Visibility directly affects people's enjoyment of a variety of daily activities. Individuals value visibility both in the places they live and work, in the places they travel to for recreational purposes. For example, Chestnut and Row ( 1989) examined WTP for improved visibility in recreational settings. 40 In addition, Chestnut and Dennis ( 1997) used data representative of the Eastern United States from McClelland et al. ( 1990) to measure WTP in residential areas. 41,42 EPA has incorporated these methods in The Benefits and Costs of the Clean Air Act 1990 to 2010. We can estimate the upper bound and lower bound benefits associated with PM emissions reductions with the proposed HWC MACT replacement standards using two different methodologies, each comparing reductions to those associated with the Clean Air Act.

The first approach assumes a linear relationship between PM reductions and visibility improvements. A national decrease of PM emissions of two percent ( 823,000 tons annually) is associated with annual visibility benefits of roughly $ 2 billion. 43 Assuming a linear relationship, reduced PM associated with the proposed HWC MACT replacement standards could result in a visibility benefit from approximately $ 6.1 million for Option 1 Floor and Option 2 Floor, $ 7.4 million for the Agency Preferred Approach, and $ 10.9 million for Option 3 Floor, proportional to national reductions. This comparative approach of linear extrapolation produces similar results ($ 6.1 million to $ 10.9 million) when comparing benefits of emissions reductions of the Draft Regulatory Impact Analysis: Control of Emission from Nonroad Diesel Engines. 44 The Draft Regulatory Impact Analysis: Control of Emission from Nonroad Diesel Engines used a similar approach to the The Benefits and Costs of the Clean Air Act 1990 to 2010. This approach has several limitations. In The Benefits and Costs of the Clean Air Act 1990 to 2010 and Draft OMB REVIEW D 45 Although no quantified analysis of the proximity of facilities to Class 1 areas has been performed, facilities are distributed over a wide area including Gulf of Mexico Coast, Great Lakes, and the Mississippi which include numerous recreation areas. Also, the WTP of households for increases in residential visibility is higher than their WTP for recreational visibility. The EPA, in The Benefits and Costs of the Clean Air Act 1990 to 2010, estimated the WTP per household for residential visibility changes to be $ 141, and $ 65 to $ 137 for recreational visibility changes in National Parks ( depending on household and park location). Thus, visibility benefits are likely.

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

47 U. S. EPA, Draft Regulatory Impact Analysis: Control of Emission from Nonroad Diesel Engines, Assessment and Standards Division, April 2003.

6 47 Regulatory Impact Analysis: Control of Emission from Nonroad Diesel Engines EPA valued recreational visibility ( e. g., realized through visits to Class 1 areas, most of which are National Parks). 45 In this Assessment no quantified analysis of the proximity of facilities to Class I areas has been performed. Another limitation of this method is that it assumes that visibility improvements are related to direct PM emissions only. In both The Benefits and Costs of the Clean Air Act 1990 to 2010 and Draft Regulatory Impact Analysis: Control of Emission from Nonroad Diesel Engines EPA valued both direct PM emissions and gaseous PM precursors. No reductions in gaseous precursors are quantified for the proposed HWC MACT replacement standards, thus, this method may overestimate visibility benefits and represents the upper bound of potential visibility benefits.

The second approach is to assume a linear relationship between health benefits and visibility benefits associated with reduction in PM emissions. In The Benefits and Costs of the Clean Air Act 1990 to 2010 annual human health benefits of roughly $ 68 to $ 108 billion and visibility benefits of $ 2 to $ 3 billion are estimated for reductions in PM emissions. 46 In the Draft Regulatory Impact Analysis: Control of Emission from Nonroad Diesel Engines EPA estimates human health benefits of $ 58 to $ 104 billion and visibility benefits of $ 1 to $ 2 billion associated with reductions in PM emissions. 47 Assuming a linear relationship between human health benefits and visibility benefits the proposed HWC MACT replacement standards could result in a visibility benefit of approximately $ 113,000 for Option 1 Floor and Option 2 Floor, $ 114,000 for the Agency Preferred Approach, and $ 222,000 for Option 3 Floor. This approach also has several limitations as it still does not take into account Class I areas, or any reductions in PM precursors. This method represents the lower bound of visibility benefits.

ECOLOGICAL BENEFITS This section provides a comparison of the ecological benefits derived in the 1999 Assessment and the potential benefits associated with the proposed HWC MACT replacement standards. Ecological benefits derived in the 1999 Assessment were based on a screening analysis for ecological risks that compared soil, OMB REVIEW D 48 Threatened and endangered species and/ or habitats were not included in the analysis.

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

6 48 surface water, and sediment concentrations with eco toxicological criteria based on de minimis thresholds for ecological effects. Because these criteria represented conservative values, an exceedence of the ecotoxicological criteria only indicates the potential for adverse ecological effects and does not necessarily indicate ecological damages. For this reason, the benefits of avoiding adverse ecological impacts were discussed qualitatively.

The basic approach for determining whether ecosystems and/ or biota are potentially at risk consisted of five steps:

First, the risk assessment identified susceptible ecological receptors. Because combustion facilities are located across the country, ecological receptors for the screening analysis were chosen to represent relatively common species and communities of wildlife. 48

Second, the risk assessment developed eco toxicological criteria for receptors that represent acceptable pollutant concentrations ( e. g., at these levels, there is a low potential for adverse ecological effects). 49

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

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

Finally, to estimate the potential for adverse ecological effects in the study areas the risk assessment totaled the number of polar grid sectors ( for terrestrial ecosystems) and water bodies ( from aquatic ecosystems) with hazard quotients exceeding one.

To assess potential ecological benefits from the risk assessment results, the number of sectors or water bodies potentially at risk in the baseline with the number post 1999 standards were compared. The reduction in the number of sectors or water bodies potentially at risk indicated a potential for avoiding adverse ecological impacts. Monetary values were not assigned to these potential benefits because the surface area of land or water affected corresponding to the number of grid sectors or water bodies potentially at risk could not be calculated, and no clear link exists between an exceedance in the eco OMB REVIEW DRAFT: November 2003 6 49 toxicological criteria and a real benefit measure, such as increased fish populations, for which a benefits transfer approach could assign monetary values. OMB REVIEW D 50 The low end estimate assumed the same waterbodies or land areas are affected by different pollutants. That is, under the six square kilometers of land nearby incinerators that experienced ecological improvements associated with lead emission reductions are captured in the 87 square kilometers of land nearby incinerators associated with mercury reductions.

51 Although the primary pollutants which are detrimental to vegetation aesthetics and growth are tropospheric ozone, sulfur dioxide, and hydrogen fluoride, three pollutants which are not regulated in the MACT standards, some literature exists on the relationship between metal deposition and vegetation health. ( Mercury Study Report to Congress Volume VI, 1997)

6 50 Ecological Benefit Results Ecological benefits were assessed in the 1999 Assessment based on reductions of approximately 100 tons per year in dioxin/ furans and selected metals. Lead was the only pollutant of concern for aquatic ecosystems. Mercury appeared to be of greatest concern for terrestrial ecosystems. Dioxin and lead emission reductions also provided some potential benefits for terrestrial ecosystems. Under the 1999 standards, the eco toxicological hazard quotient was reduced to below the level of concern for 38 square kilometers of water surface area. For terrestrial ecosystems, the land area that experienced reductions in ecological risk criteria below levels of concern ranged from 115 square kilometers to 147 square kilometers under the 1999 standards. 50 The proposed HWC MACT replacement standards will reduce dioxin/ furans and selected metals from 17 tons annually for Option 1 Floor and Agency Preferred Approach, Option 2 Floor 18 tons annually, and 22 tons annually for Option 3 Floor. In general the proposed HWC MACT replacement standards will produce fewer incremental benefits than those estimated for the 1999 Assessment ( and later, for the 2002 Interim standards). However, the 1999 Assessment did not estimate the ecological benefits of MACT standards for boilers and industrial furnaces. These systems were excluded from the universe in 1999 but are part of the universe addressed by the proposed HWC MACT repayment standards. As a result, while the total ecological benefits of the proposed rule are likely to be modest, areas near facilities with boilers may enjoy more significant ecological benefits under the proposed HWC MACT replacement standards than areas near facilities that have already complied with the 2002 Interim standards.

It is important to note that these reductions of ecological risk criteria below levels of concern only indicate the potential for an ecological improvement. It is not clear that a MACT standard would necessarily provide ecological benefits to areas around combustion facilities. Also, because the screeninglevel nature of the ecological risk assessment did not allow us to predict the type or magnitude of benefits, we could not assign monetary values to these potential ecological benefits.

Forest Health and Aesthetics Mercury, lead, and chlorides are among the HAPs that can cause damage to the health and visual appearance of plants. 51 While the total value of forest health is difficult to estimate, visible deterioration OMB REVIEW D ( Several studies are cited in this report.)

52 See, for example, Brown, T. C. et al. 1989, Scenic Beauty and Recreation Value: Assessing the Relationship, In J. Vining, ed., Social Science and Natural Resources Recreation Management, Westview Press, Boulder, Colorado; this work studies the relationship between forest characteristics and the value of recreational participation. Also see Peterson, D. G. et al. 1987, Improving Accuracy and Reducing Cost of Environmental Benefit Assessments. Draft Report to the US EPA, by Energy and Resource Consultants, Boulder, Colorado; Walsh et al. 1990, Estimating the public benefits of protecting forest quality, Journal of Forest Management, 30: 175 189., and Homes et al. 1992, Economic Valuation of Spruce Fir Decline in the Southern Appalachian Mountains: A comparison of Value Elicitation Methods. Presented at the Forestry and the Environment: Economic Perspectives Conference, March 9 1, 1992 Jasper, Alberta, Canada for estimates of the WTP of visitors and residents to avoid forest damage.

53 MacKenzie, James J., and Mohamed T. El Ashry, Air Pollution's Toll on Forests and Crops ( New Haven, Yale University Press, 1989).

6 51 in the health of forests and plants can cause a measurable change in recreation behavior. Several studies that measure the change in outdoor recreation behavior according to forest health are available to place a value on aesthetic degradation of forests. 52 Although these studies are available, additional research is needed to fully understand the effects of these HAPs on the forest ecosystem. Thus, these benefits are not quantified in this analysis.

Productivity to Agricultural Land Emissions that are sufficient to cause structural and aesthetic damage to vegetation are likely to affect growth as well. Little research has been done on the effects of compounds such as chlorine, heavy metals ( as air pollutants), and PM on agricultural productivity. 53 Even though the potential for visible damage and production decline from metals and other pollutants suggests the proposed HWC MACT replacement standards could increase agricultural productivity these changes cannot be quantified.

WASTE MINIMIZATION BENEFITS As discussed in Chapter 5, all commercial combustion facilities that remain in operation will experience increased costs under the MACT standards. To protect their profits, combustion facilities will have an incentive to pass these increased costs on to their customers in the form of higher combustion prices. In 1999 we conducted a waste minimization analysis to inform the expected price change under the 1999 ( and later the 2002 interim) standards. Based on the results of this analysis, we estimated that as much as 240,000 tons of waste might be reallocated to waste minimization alternatives in response to OMB REVIEW D 54 U. S. Environmental Protection Agency, Addendum to the Assessment of the Potential Costs, Benefits, and Other Impacts of the Hazardous Waste Combustion MACT Standards: Final Rule, July 23, 1999.

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

6 52 higher combustion prices. 54 Since the publication of the 1999 Assessment, however, approximately 100,000 tons of waste have already been reallocated. In addition, given the current pricing structure of the hazardous waste combustion market, the costs of waste minimization alternatives in the short term generally exceed the cost of combustion. 55 When the additional costs of compliance with the MACT standards are taken into account, waste minimization alternatives still tend to exceed the higher combustion costs. This inelasticity in the demand for combustion suggests that in the short term large reductions in waste quantities are not likely.

While, short tern options for waste minimization may be limited it is likely that over the longer term ( e. g. as production systems are updated) companies will continue to seek alternatives to expensive waste management ( e. g., source reduction). To the extent that increases in combustion prices provide additional incentive to adopt more efficient processes, the proposed HWC MACT replacement standard may contribute to the longer term process based waste minimization efforts. However, we are not able to isolate and quantify the specific impact of the proposed HWC MACT replacement standards on source reduction decisions.

A quantitative assessment of the benefits associated with waste minimization may result in doublecounting of some of the benefits described earlier in this chapter. For example, waste minimization may reduce emissions of hazardous air pollutants and therefore have a positive effect on public health. A portion of these health impacts are captured in the analysis of health related benefits presented above. However, emissions reductions beyond those necessary for compliance with the replacement standards are not addressed in this benefits assessment. In addition, waste minimization is likely to result in specific types of benefits not captured in this Assessment. For example, waste generators that engage in waste minimization will experience a reduction in their waste handling costs and could also reduce the risk related to waste spills and waste management. These impacts are not captured in the quantitative analysis of costs and benefits presented in this Assessment. OMB REVIEW DRAFT: November 2003 6 53 Exhibit 6 9 BENEFITS SUMMARY: BASELINE TO PROPOSED HWC MACT REPLACEMENT STANDARDS ( 2002 Dollars in Millions)

Option Agency Preferred Approach Option 1 Floor Option 2 Floor Option 3 Floor Type of Benefit Reduction in Number of Cases per Year Annual Undiscounted Value Reduction in Number of Cases per Year Annual Undiscounted Value Reduction in Number of Cases per Year Annual Undiscounted Value Reduction in Number of Cases per Year Annual Undiscounted Value Human Health Benefits Premature deaths avoided 0.3 $ 2.11 0.3 $ 2.09 0.3 $ 2.09 0.6 $ 4.12 Respiratory illness 0.9 $ 0.01 0.9 $ 0.01 0.9 $ 0.01 1.7 $ 0.02 Cardiovascular disease 0.4 $ 0.01 0.4 $ 0.01 0.4 $ 0.01 0.8 $ 0.01 Chronic bronchitis 5.7 $ 2.17 5.6 $ 2.15 5.6 $ 2.15 11.0 $ 4.20 Acute bronchitis 4.3 $ 0 4.3 $ 0 4.3 $ 0 8.4 $ 0 Lower respiratory symptoms 38.4 $ 0 38.1 $ 0 38.1 $ 0 74.2 $ 0 Upper respiratory symptoms 4.5 $ 0 4.4 $ 0 4.4 $ 0 8.6 $ 0 Work loss days 451.1 $ 0.05 447.3 $ 0.05 447.3 $ 0.05 874.7 $ 0.09 Minor restricted activity 3757.8 $ 0.15 3726.1 $ 0.15 3726.1 $ 0.15 7287.2 $ 0.29 Annual Monetary Health Benefits $ 4.50 $ 4.46 $ 4.46 $ 8.73 Visibility Annual Monetary Visibility Benefits $ 0.11 to $ 7.41 $ 0.11 to $ 6.12 $ 0.11 to $ 6.12 $ 0.22 to $ 10.89 Total Annual Monetary Benefits $ 4.61 to $ 11.91 $ 4.57 to $ 10.58 $ 4.57 to $ 10.58 $ 8.95 to$ 19.62 OMB REVIEW DRAFT: November 2003 6 54 CONCLUSIONS Overall, the Agency Preferred Approach is expected to result annually in approximately $ 4.5 in human health benefits beyond the baseline. In addition, the proposed Agency Preferred Approach is expected to result in $ 100,000 to $ 7.4 million in visibility benefits beyond the baseline ( see Exhibit 6 8 for a summary of the quantified annual monetary benefits of the proposed HWC MACT replacement standards). In particular, the Agency Preferred Approach is expected to result in:

Reductions in premature deaths. Risk reductions associated with the Agency Preferred Approach is expected to result in less than one fewer premature deaths annually. Particulate matter accounts for most of the human health benefits.

Cancer risk reductions. The Agency Preferred Approach is expected to avoid less than 0.36 cancer deaths annually when compared to the 1999 standards. The value of this avoided cancer case is not quantified in this Assessment.

Reductions in diseases associated with particulate matter exposure. Hospital admissions for diseases associated with particulate matter are expected to be reduced by approximately 1.3 cases per year. Respiratory illnesses account for almost 70 percent of the hospital admissions. In addition, approximately 53 occurrences of acute respiratory conditions will be avoided annually due to the Agency Preferred Approach.

Reduced risk for subsistence fishermen associated with mercury. The hazard index for subsistence fishermen may be reduced, suggesting that subsistence fishermen will potentially experience reduced risks of having children with developmental abnormalities, but this reduction is likely to be small based on the 1999 Assessment.

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

Potential improvement in visibility. An upper bound estimate of visibility benefits, assuming a linear relationship with WTP for improved visibility and particulate matter concentration visibility improvements associated with particulate matter, could result in benefits of $ 7.4 million annually for a 30 percent change in particulate matter concentration from baseline. A lower bound estimate of visibility benefits, assuming a linear relationship between human health benefits and visibility benefits reductions in PM emissions, could result in $ 100,000 in visibility benefits.

Potential ecological improvements. The Agency Preferred Approach is likely to result in some ecological benefits. In comparison with the 1999 standards the Agency Preferred Approach is likely to produce less ecological benefits than estimated in the 1999 Assessment. That is, less than 38 square kilometers of water, and 147 square kilometers OMB REVIEW DRAFT: November 2003 6 55 of terrestrial areas may experience a decrease in potential risks to ecosystems.

Increased forest health and aesthetics. Mercury, lead, and chlorides are among the HAPs that can cause damage to the health and visual appearance of plants. While the total value of forest health is difficult to estimate, visible deterioration in the health of forests and plants can cause a measurable change in recreation behavior. These benefits are not quantified in this analysis.

Increased productivity to agricultural land. Emissions that are sufficient to cause structural and aesthetic damage to vegetation are likely to affect growth as well. The Agency Preferred Approach could increase agricultural productivity but are not quantified in this analysis.

Waste minimization benefits. The Agency Preferred Approach is likely to produce a small reduction, if any, in short term generation waste combusted because the demand for combustion is relatively inelastic. However, impacts fo this rule on long term process decisions are unknown.

It is important to emphasize that the monetized portion of the benefits represent only a portion of the benefits associated with this rule. Specifically ecological benefits, chlorine, dioxin, mercury, lead, etc. health benefits are not quantified or monetized. In some locations these benefits may be significant. In addition, specific sub populations near combustion facilities, including children and minority populations, may be disproportionately affected by environmental risks and may therefore enjoy more significant benefits. Chapter 7 provides a more detail discussion of the environmental justice and childrens health implications of this proposed rule. OMB REVIEW DRAFT: November 2003 56 The specific technology is simple direct duct injection dry scrubbing. EPA Floor option regulatory scenarios ( i. e., Floor Option 1, Floor Option 2, and Floor Option 3) would not require dry scrubbers and would therefore incur no benefits associated with SO 2 reductions.

6 56 February 25, 2004 Hazardous Waste Combustion MACT Replacement Standards: Proposed Rule Assessment of Benefits Associated with the Beyond the Floor Standard for TCl from Solid Fuel Boilers Burning Hazardous Waste We have identified expected reductions in sulfur dioxide ( SO 2) emissions from coal fired boilers as a result of the Hazardous Waste Combustion ( HWC) MACT replacement standards. The HWC MACT standard for chlorine under the " Agency Preferred Approach" regulatory scenario will require facilities with coal fired ( i. e., solid fuel) hazardous waste burning boilers to install flue gas desulfurization ( i. e., " dry scrubber") technology. 56 In addition to controlling releases of chlorine, dry scrubbers will reduce emissions of sulfur dioxide from these facilities.

This Assessment examines anticipated benefits associated with SO 2 emissions reductions under the HWC MACT replacement standards, Agency preferred approach. To develop a range of potential benefits estimates of SO 2 reductions, we adjusted published national estimates of SO 2 control benefits to reflect our estimate of the total SO 2 emissions ( tons/ year) avoided in response to the beyond the floor ( BTF) standard for chlorine in solid fuel boilers. We first provide two estimates of benefits based on extrapolation from available literature. We then incorporate a number of very conservative assumptions to provide a " lower bound" estimate of benefits. Finally, we discuss the primary limitations associated with our analysis.

Sulfur Dioxide Emission Reductions Four facilities in the HWC MACT regulated universe have solid fuel boilers. These facilities are: 1) Eastman Chemical Company in Tennessee ( seven boilers), 2) Union Carbide in West Virginia ( one boiler), 3) Celanese Chemicals in Texas ( two boilers), and, 4) Eastman Chemical Company facility in Arkansas ( two boilers). None of the boilers at these facilities are currently equipped with dry scrubbers.

We estimate baseline ( SO 2) emissions from these facilities at 37,000 tons per year, reflecting operating requirements under test conditions. The Texas and Arkansas facilities are assumed to use OMB REVIEW DRAFT: November 2003 57 U. S. EPA, 2003, Technical Addendum: Methodologies for the Benefit Analysis of the Clear Skies Act of 2003, accessed February 17, 2004, at < http:// www. epa. gov/ clearskies/ tech_ addendum. pdf>; U. S. EPA, 2003, Technical Support Document for the Clear Skies Act 2003 Air Quality Modeling Analysis, accessed February 17, 2002, at < http:// www. epa. gov/ air/ clearskies/ aq_ modeling_ tsd_ csa2003. pdf>; U. S. EPA, Benefits of the Proposed Inter State Air Quality Rule, accessed February 17, 2004, at < http:// www. epa. gov/ interstateairquality/ tsd0175. pdf>. In addition, we examined an unpublished draft report by Carrothers et al. ( 2002), which estimates national 6 57 low sulfur coal ( sulfur content of 0.6 percent), and the West Virginia and Tennessee facilities are believed to use eastern coal ( sulfur content ranging from one to five percent, with an average value of 2.5 percent).

Our engineers have determined that the installation of dry scrubbers for required control of HCl ( beyond the floor standard of the agency preferred approach) will reduce SO 2 emissions by 60 percent, or 22,000 tons per year. Exhibit 1 summarizes the SO 2 emissions reductions.

Exhibit 1 SUMMARY OF ESTIMATED SO2 EMISSION REDUCTIONS Associated with the AGENCY PREFERRED APPROACH Beyond the Floor Standard for TCl  Solid Fuel Boilers Facility Sulfur Content of Coal Baseline SO2 Emissions SO2 Emission Reductions SO2 Emissions Under Agency Preferred Approach Eastman Chemical Co., Kingsport, Tennessee 2.5% 26,130 15,680 10,450 Celanese Chemicals, Pampa, Texas 0.6% 6,280 3,770 2,510 Union Carbide, South Charleston, West Virginia 2.5% 4,000 2,400 1,600 Eastman Chemical Co., Batesville, Arkansas 0.6% 550 330 220 TOTAL 36,960 22,180 14,780 Evaluation of Benefits To develop initial estimates of potential benefits associated with SO 2 emissions reductions, we scale existing published national benefits assessments associated with SO 2 emissions reductions under the Clear Skies Initiative and the Inter State Air Quality Rule ( IAQR). 57 As detailed in these OMB REVIEW DRAFT: November 2003 exposure to PM 2.5 and gaseous precursors from coal fired power plants and mobile sources. The report then estimates benefits associated with reduced mortality due to decreases in emissions. Carrothers, Timothy J., Scott K. Wolff, Jouni Tuomisto, Andrew M. Wilson, Jonathan I. Levy, John D. Graham, John D. Graham, John S. Evans, 2002, Assessing the Economic Value of Further Research about Fine Particle Air Pollution: Model Framework and Preliminary Findings, final review draft.