WordPerfect Document Compare Summary Note to reader: This redline strikeout version of the Addendum to the Assessment of Potential Costs, Benefits and Other Impacts of the Hazardous Waste Combustion MACT Replacement Standards, Proposed Rule, shows all changes made after the draft version of this Addendum was submitted to the Office of Management and Budget ( OMB) in December of 2003. Some of these changes were made as a result of discussions with OMB while many others were made by EPA in response to ongoing internal review. Changes made to this document specifically in response to OMB comments are identified in the following manner: *** xxxxx***. All other changes were made by EPA. OMB has reviewed and approved the final version of this Addendum.

Deletions are shown with the following attributes and color: Strikeout, Blue RGB( 0,0,255). Deleted text is shown as full text. Insertions are shown with the following attributes and color: Double Underline, Redline, Red RGB( 255,0,0). Moved blocks are marked in the new location, and only referenced in the old location. Moved block marks are shown in the following color: Orange RGB( 255,200,0).

The document was marked with 236 Deletions, 262 Insertions, 6 Moves. ADDENDUM TO THE ASSESSMENT OF THE POTENTIAL COSTS, BENEFITS, & AND OTHER IMPACTS OF THE HAZARDOUS WASTE COMBUSTION MACT REPLACEMENT STANDARDS: PROPOSED RULE Economics, Methods, and Risk Analysis Division Office of Solid Waste U. S. Environmental Protection Agency 1200 Pennsylvania Ave, N. W. Washington, DC 20460 December 2003 March 2004 TABLE OF CONTENTS INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 MAJOR CHANGES REFLECTED IN THE ADDENDUM . . . . . . . . . . . . . . . . . . . . . . . . . 1 Changes to the Proposed Replacement Standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 Changes to the Regulatory Baseline . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 Changes in Emissions Projections . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 REVISED COST AND BENEFIT ESTIMATES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 Revised Cost Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 Engineering Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 Social Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 Distribution of Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 Revised Economic Impact Estimates . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 Revised Benefits Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 EQUITY CONSIDERATIONS AND OTHER IMPACTS . . . . . . . . . . . . . . . . . . . . . . . . . 27 Assessment of Small Entity Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 Children's Health Protection Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 Energy Impact Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 Non air Environmental Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 COST EFFECTIVENESS ANALYSIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 APPENDICES *** Appendix A: Potential Benefits Associated with SO 2 Emissions Reductions Achieved Under Beyond The Floor Chlorine Standards for Solid Fuel Boilers and LWAKs*** ( added as an Appendix in response to OMB review)

Appendix B: Detailed Cost Model Results Appendix C: Emissions Reductions Achieved Under the Revised Agency Preferred Approach FINAL DRAFT: March 2004 1 All options include chlorine controls for HCl production furnaces. With or without chlorine controls pertains to § 112( d)( 4) of the Clean Air Act.

1 INTRODUCTION The purpose of this Addendum is to provide revised information on the costs and benefits of the Agency's proposed hazardous waste combustion ( HWC) MACT replacement standards. This aAddendum is necessary because the Agency revised the initialwe have revised the regulatory baseline as well as the *** total chlorine ( TCl)*** and particulate matter ( PM) standards, as evaluated in the 2004 Assessment of the Potential Costs, Benefits, and Other Impacts of the Hazardous Waste Combustion MACT Replacement Standards: Proposed Rule, November 2003 ( the 2004 Assessment). This aAddendum provides revised social cost and benefit estimates for six options: three floor options and three " beyond the floor" ( BTF) options ( including the Agency Preferred Approach). In addition, for each option cost estimates are estimated " with chlorine controls" and " without chlorine controls." 1 Note, however, that the changes in the PM and *** chlorine standards*** affect both the" with chlorine controls" and " without chlorine controls" versions of the standards. Finally, this Addendum includes a discussion of potential monetized benefits associated with reduced dioxin emissions under the proposed HWC MACT replacement standards.

The Addendum is organized into twofour sections. The first section discusses the changes we made to the proposed chlorine and PM replacement standards and the regulatory baseline, as well as the rationale behind these changes. The standards for other hazardous air pollutants remain unchangedThis section also provides revised estimates of the emissions reductions expected as a result of the replacement standards. The second section summarizes theprovides revised cost and benefit estimates. This section also highlights and summarizes major changes in our assessment of economic impacts.

CHANGES TO THE PROPOSED PM REPLACEMENT STANDARDS The Agency is modifying relative to estimates presented in the 2004 Assessment. The third section of the Addendum discusses equity impacts of the proposed replacement standards and other pertinent regulatory concerns. The Addendum concludes with a presentation of revised cost effectiveness estimates.

MAJOR CHANGES REFLECTED IN THE ADDENDUM This Addendum provides results that reflect Agency revisions to the proposed HWC MACT replacement standards, regulatory baseline, and the emissions reductions anticipated in response to the revised standards. We discuss the nature and rationale for these changes below. FINAL DRAFT: March 2004 2 The Agency also considered the likelihood that solid fuel boiler and LWAK facilities may qualify for risk based emission limits ( instead of technology based emissions limits) pursuant to § 112( d)( 4) of the Clean Air Act.

2 Changes to the Proposed Replacement Standards We have altered our proposed standards for PM *** and chlorine***. The modifications related to chlorine reflect the Agency's interpretation of beyond the floor cost effectiveness, and the changes associated with PM are consistent with updates to EPA methods for estimating emissions.

Revised Chlorine Standards *** As illustrated in Exhibit 1, we have revised the proposed chlorine replacement standards for solid fuel boilers and lightweight aggregate kilns ( LWAKs) under the Agency Preferred Approach. The revised chlorine standards under the Agency Preferred Approach do not require solid fuel boilers or LWAKs to meet a beyond the floor standard for chlorine. Therefore, the Agency Preferred Approach for solid fuel boilers is now 440 parts per million by volume ( ppmv), compared to the standard of 110 ppmv presented in the 2004 Assessment. Similarly, the chlorine standard for LWAKs under the revised Agency Preferred Approach is 600 ppmv instead of 150 ppmv as presented in the 2004 Assessment. These changes reflect the Agency's determination that the beyond the floor standards for TCl are not cost effective2***.

Revised PM Standards The Agency has modified the proposed PM MACT replacement standards to reflect updated methods of characterizing the technical features of individual combustion systems. In developing the PM MACT replacement standards presented in the 2004 Assessment, wethe Agency relied upon a database containing detailed information on the performance characteristics of individual combustion systems. This included, including the effectiveness of fabric filters installed at facilities that emit PM. Although several years' worth of data are available for several fabric filters, the PM standards analyzed in the 2004 Assessment reflect only the most recent performance data associated with each filter. To achieve a more representative assessment of the performance of each fabric filter, we decided to augment itsSince completing the analysis for the 2004 Assessment, we have determined that estimates of fabric filter performance that account for less recent data would better represent the variation in fabric filter performance over time. The Agency has therefore augmented the summary of each fabric filter's performance with less recent data reflecting system trial burns, risk burns, and certification and compliance testing. Since MACT standards are based on the technological characteristics of the lowest emitting sources in the regulated universe, we are now amendinghave amended the proposedpreviously established HWC PM MACT replacement standards for PM. FINAL DRAFT: March 2004 3 Exhibit 1 summarizes the updated PM replacement standards for the Agency Preferred Approach, as well as thosethe PM standards includedevaluated under the Agency Preferred Approach in the November 20034 Assessment. As the tableExhibit 1 indicates, the updated PM standards for allmost source categories under the Agency Preferred Approach are less stringent than the standards originally presentedanalyzed in the 2004 Assessment. FINAL DRAFT: March 2004 3 Design levels for the proposed HWC MACT replacement standards are estimated as the average performance of the top performing systems.

4 Design levels are usually represented as a percentage of the regulatory standard. For example, a firm with a design level of 70 percent would attempt to meet an emissions standard of 0.010 g/ dscf by targeting an emissions level of 0.007.

5 In this case, fabric filter performance in more recent years appears to have decreased from previous levels.

4 Exhibit 1 PARTICULATE MATTER ( PM) REPLACEMENT STANDARDS UPDATED AND PREVIOUS STANDARDS FOR PM AND CHLORINE REPLACEMENT MACT MACT Source Category Updated ProposalPM Standards ( gr/ dscf) Previous PM Standards ( gr/ dscf) *** Updated Cl Standards*** ( ppmv) Previous Cl Standards ( ppmv)

Agency Preferred Approach Incinerators 0.01985 0.010 1.5 ppmv 1.5 ppmv Cement Kilns 0.0280 0.014 110 ppmv 110 ppmv LWAKs 0.02915 0.017 *** 600 ppmv*** 150 ppmv Solid Fuel Boilers 0.0630 0.030 *** 440 ppmv*** 110 ppmv Liquid Fuel Boilers 0.03102 0.026 2.5E 2 lbs of Cl in HW per MMBtu in HW 2.5E 2 lbs of Cl in HW per MMBtu in HW HCl Production Furnaces TCl as surrogate TCl as surrogate 14 ppmv or 99.9927% SRE 14 ppmv or 99.9927% SRE Consistent with less stringent PM standards, the updatedwe have estimated new PM design levels for most source categories ( i. e., the self imposed PM emissions ceilings that systems try not to surpass to ensure that they do not violate the standards). 3,4 These revised design levels affect our cost analysis; lower design levels ( i. e., more stringent design levels) require facilities to install more expensive ( and more effective) abatement technologies. For most source categories, the revised design levels are also less stringent thanrelative to those associated with the previous PM replacement standards evaluated in the 2004 Assessment. However, because of methodological changes in estimating fabric filter effectiveness, as outlined above, the updated PM design level for liquid boilers is lower ( i. e., more stringent) than that estimated for the 2004 Assessment. 5 In the currentupdated analysis, we estimate a liquid boiler PM design level of 0.0127 gr/ dscfgrams per dry square cubic foot FINAL DRAFT: March 2004 5 ( g/ dscf) to meet the proposed standard of 0.032 g/ dscf, whereas we previously applied an estimateestimated a design level of 0.014 gr/ dscf. Because of this decline in the estimated liquid boiler PM design level, the estimates of liquid boiler compliance costs presented in the following section exceed those presented in the Assessment. The PM design level for coal boilers is also more stringent under the revised standards, but this change has no impact on estimates of coal boiler costs. PM design levels for all other source categories are no more stringent than those estimated for the Assessment.

REVISED COST AND BENEFIT ESTIMATES In addition to the modifications to the proposed PM2004 Assessment. FINAL DRAFT: March 2004 6 Design levels for the 2002 Interim Standards were estimated as the product of the 2002 Interim Standards and the ratio of the design level of the proposed replacement standards to the proposed replacement standards themselves. For example, the cement kiln design level for chlorine under the proposed replacement standards is 66 ppmv, and the proposed chlorine replacement standards for cement kilns is 110 ppmv. Since the 2002 Interim Standard for cement kiln emissions of chlorine is 130 ppmv, the corresponding design level associated with the 2002 Interim Standards is 130 ppmv*( 66 ppmv)/( 110 ppmv), or 78 ppmv.

6 Changes to the Regulatory Baseline In addition to revising the replacement standards, we have applied revised assumptions and methods to the regulatory baseline, which assumes full compliance with the 2002 Interim Standards. More specifically, the 2002 baseline has been altered to reflect both design level changes and improvements in data quality.

Typically, a regulatory baseline reflects data about the state of the regulated industry or industries prior to the regulation's development. However, development of the proposed HWC MACT replacement standards described above, the cost and benefit estimates presented in this section reflect changes in PM design levels estimatedoverlaps with the implementation of the 2002 Interim Standards. The Agency, therefore, developed baseline conditions ( e. g., baseline emissions) reflecting facilities' expected responses to the 2002 Interim Standards. To maintain consistency with the analysis of the proposed replacement standards, we have assumed that ratios of design levels to standards for the 2002 Interim Standards. Similar to are the same as those associated with the proposed replacement standards. 6 Since the ratios associated with the replacement standards have changed, EPA estimates ofwe re estimated design levels associated with the 2002 Interim Standards have changed because of the revised technological characterization of fabric filters. As a result, EPA's estimate of baseline PM emissions for the replacement standards ( i. e., PM emissions after implementation of. This modification changes estimates of both the reduction in PM emissions achieved in response to the 2002 Interim Standards) is now lower for some source categories and higher for others than was estimated for the Assessment.

Major findings of the current analysis are as follows:

$

Text Was Moved From Here: 1 $ Annualized market adjusted costs of the Agency Preferred Approach are now estimated to be approximately $ 55.6 million, which is approximately 3.6 percent lower than the $ 57.6 million estimate presented in the Assessment.

$ Boilers bear more than 80 percent ($ 45.2 million) of the market adjusted costs and the baseline PM emissions assumed for the analysis of the proposed HWC MACT replacement standards. This reflects the fact that these facilities are not subject to any emissions requirementsNote that boilers and HCl production furnaces are not affected by this methodological change because these systems are not regulated under the 2002 Interim FINAL DRAFT: March 2004 7 Non detect data points are those below the discernable limits of emission measurement tools. The level below which quantified measurements are not possible is referred to as the detection limit.

7 Standards. In addition, the $ 45.2 million estimate is 3 percent greater than the $ 43.9 million estimate in the Assessment because of the design level changes outlined above.

$ Our revised analysis indicates that economic impacts are largely unchanged from those in the Assessment. The only substantial change is a slight reduction in employment gains, which are now approximately 6 percent lower under the Agency Preferred Approach.

$ We estimate annual health benefits of approximately $ 4.5 million associated with the Agency Preferred Approach. This estimate is approximately 15 percent lower than that We have also modified estimates of baseline metals emissions from boilers and HCl production furnaces to reflect changes in the management of non detect data points for these emissions. 7 In developing the baseline metals emissions presented in the 2004 Assessment ($ 5.28 million). Reduced benefits associated with chronic bronchitis make up approximately 75 percent of the decline in estimated benefits.

$ Visibility benefits, we received several non detect data points from boilers and HCl production furnaces. When coding these data, the Agency assumed that the corresponding detection limits would reasonably approximate the non detected metals emissions of each combustion system. However, several boilers and HCl production furnaces employed rudimentary measurement techniques incapable of capturing small yet detectable metals emissions. If these facilities had used more advanced measurement techniques, they would have applied a smaller detection limit to their non detect data points. Therefore, the conservative assumption that non detected emissions were equal to the high detection limits associated with the revised Agency Preferred Approach of the replacement standards range from $ 115,000 per year to $ 5.8 million per year. This reflects a 14 percent and 27 percent decline, respectively from the monetized visibility benefits estimatesrudimentary measurement techniques likely overstated actual emissions associated with non detect data points. The Agency has therefore re coded boilers' non detect data points for metals emissions as half the detection limit, which represents the central tendency between zero emissions and the detection limit.

Exhibit 2 presents the revised baseline emissions estimates ( i. e., emissions expected in the presence of the 2002 Interim Standards) that reflect the changes to the design levels and the refined treatment of non detect emissions data. As Exhibit 2 shows, current estimates of baseline PM emissions from cement kilns and incinerators are lower than those presented in the 2004 Assessment. These two figures represent two different methodologies for estimating visibility benefits. FINAL DRAFT: March 2004 8 Cost Analysis Text Was Moved From Here: 2 Annualized engineering costs with chlorine controls rangereductions reflect the updated PM design levels for these systems; we now estimate more stringent cement kiln and incinerator PM design levels of 0.0115 g/ dscf and 0.00315 g/ dscf respectively for the 2002 Interim Standards, compared to the estimates of 0.0214 g/ dscf and 0.0033 g/ dscf prepared for the 2004 Assessment. In contrast, the increase in baseline PM emissions from $ 72.1 million per year underLWAKs reflects a less stringent LWAK PM baseline design level of 0.0105 g/ dscf compared to 0.0088 g/ dscf in the Option 1 Floor to approximately $ 135 million per year under the Option 3 " beyond the floor" ( BTF). Without controls on chlorine, annual engineering costs range from $ 52.7 million under the Option 1 Floor to $ 82.9 million under Option 3 BTF2004 Assessment. When chlorine controlsSince metals are included in the standards, costs of the BTF versions of Options 1, 2, and 3 are 14.8 percent, 8.9 percent, and 8.7 percent greater than costs associated with their corresponding floor options. 2 Without chlorine controls, these differentials are 9.5 percent, 6.4 percent, and 6.7 percent respectively.

Under the Agency Preferred Approach, both with and without chlorine controls, liquid boilers bear the most significant portion of total engineering costs. With chlorine controls, liquid boiler engineering costs represent approximately 54 percent of total engineering costs. This figure increases to 70 percent of engineering costs when chlorine controls are not included in the standards.

Text Was Moved From Here: 3 .

PM, several of the revised baseline metals emissions estimates are lower than those presented in the 2004 Assessment. As illustrated in Exhibit 2, revised estimates of baseline semi volatile metals ( SVM), low volatile metals ( LVM), and mercury emissions for boilers are lower than those presented in the 2004 Assessment. Across most other source categories, estimates of baseline LVM emissions are also lower than estimates in the 2004 Assessment. FINAL DRAFT: March 2004 9 Exhibit 2 SUMMARY OF SOCIAL COST ESTIMATES  With Chlorine Controls ( millions of 2002 dollars) BASELINE EMISSIONS SUMMARY  PROPOSED HWC MACT REPLACEMENT STANDARDSa Cement KilnsaKil ns LWAKsaL WAKs Commercial Incinerators aIncinerator s On site Incinerators Liquid BoilersCoal Boilers and Process Heaters HCl Production Furnaces Generator s that currently send waste to commerci al facilitiesT OTALbOp tion 1 FloorMar ketadjusted Costs($ 2.7 )($ 0.1)($ 10 .6)$ 9.1$ 36 .7$ 1.5$ 1.5 $ 10.6$ 46.4 Engineeri ng Costs$ 6.5$

0.5$ 3.7$ 12 .8$ 44.7$ 1.

8$ 1.5NA$ 72.1TOTA L Dioxins/

Furans ( g/ yr) Revised Estimate 4.6 2.1 0.6 1.0 2.0 2.6 12.9 2004 Assessment Estimate 4.6 2.1 0.6 1.0 2.0 2.6 12.9 FINAL DRAFT: March 2004 10 Particulate Matter ( pounds/ year) Revised Estimate 1,700,000 44,000 63,000 151,000 6,800,000 80,000 8,800,000 2004 Assessment Estimate 2,700,000 36,000 69,000 158,000 6,800,000 80,000 9,800,000 Mercury ( pounds/ year) Revised Estimate 1,840 25 620 592 1,690 7 4,800 2004 Assessment Estimate 1,840 25 620 592 1,793 7 4,900 Semi Volatile Metals ( pounds/ year) Revised Estimate 8,100 112 580 726 6,100 36 15,600 2004 Assessment Estimate 8,400 108 579 736 7,700 36 17,500 Low Volatile Metals ( pounds/ year) Revised Estimate 513 67 331 565 29,100 150 30,700 2004 Assessment Estimate 712 66 335 581 31,000 150 32,700 Chlorine ( pounds/ year) Revised Estimate 3,800,000 835,000 106,000 485,000 10,700,000 306,000 16,200,000 2004 Assessment Estimate 3,800,000 835,000 106,000 485,000 10,700,000 306,000 16,200,000 Notes:

a. Emissions estimates are presented in pounds per year for all pollutants, except dioxins/ furans, which are presented in grams per year. FINAL DRAFT: March 2004 11 Changes in Emissions Projections We have changed projections of the emissions reductions achieved in response to the standards to reflect the changes to the regulatory baseline and the proposed HWC MACT replacement standards have been revised,. Exhibit 3 presents the updated projections of the percentage reduction in emissions, by pollutant and source category. In addition, Appendix C to this Addendum provides numerical estimates ( in tons) of the emissions reductions achieved under the revised HWC MACT replacement standards. For some pollutants, these revised projections represent a significant change from the projections presented in the 2004 Assessment. For example, under the Agency Preferred ApproachMarket adjusted Costs($ 5.4)$ 3.3($ 11.4)$ 9.1$ 36.8$ 5.0$ 3.4$ 14.2$ 55.6Engineering Costs$ 6.5$ 4.2$ 3.7$ 12.8$ 44.9$ 6.9$ 3.4NA$ 82.8Option 2 FloorMarket adjusted Costs$ 0($ 1.1)($ 14.9)$ 11.7$ 47.2$ 1.5$ 1.8$ 33.2$ 80.0Engineering Costs$ 28.0$ 0.8$ 4.7$ 16.6$ 60.4$ 1.8$ 1.8NA$ 114.7Option 2 BTFMarket adjusted Costs($ 2.4)$ 2.0($ 15.5)$ 11.7$ 47.4$ 5.0$ 3.4$ 36.6$ 88.6Engineering Costs$ 28.0$ 4.1$ 4.7$ 16.6$ 60.7$ 6.9$ 3.4NA$ 124.9 of the replacement standards, we no longer expect reductions in PM emissions from LWAKs or incinerators Text Was Moved From Here: 4 $ 1.9($ 15.9)$ 12.2$ 54.9$ 5.0$ 4.1$ 38.5$ 100.3Engineering Costs$ 29.7$ 4.2$ 4.8$ 17.0$ 67.8$ 6.9$ 4.1NA$ 135.0 Text Was Moved From Here: 5 b. Government administrative costs are included i ( commercial and on site). In the total social cost estimates. Government costs range from $ 4202004 Assessment, 000 to $ 447,000 per year across all six marker adjusted cost options. For the upper bound estimate, under which all systems upgrade and there is no market adjustment, annual government costsAgency projected that PM emissions would befall by at least 25 percent for each of these sources. Furthermore, the Agency now expects cement kiln PM emissions to fall by approximately $ 543,0005 percent, compared to the 40 45 percent reduction reported in the 2004 Assessment. In contrast, the reduction in boiler PM emissions will be slightly greater under the revised HWC MACT replacement standards than projected in the 2004 Assessment.

These changes in PM projections affect the Agency's SVM and LVM emissions projections. Since SVM and LVM are distributed within PM, metals emissions fluctuate with changes in PM emissions. Consequently, we now expect cement kiln SVM emissions to fall by 20 30 percent, compared to the 45 55 percent reduction presented in the 2004 Assessment. Similarly, the Agency's revised estimate of the reduction in cement kiln LVM emissions is approximately one third lower than the corresponding estimate in the 2004 Assessment. LVM emissions from LWAKs and incinerators are now expected to decline by less than 10 percent, instead of by 23 28 percent as previously estimated. The emissions reductions presented in Exhibit 3 do not capture the 5.4 tons of reduced FINAL DRAFT: March 2004 8 Non enumerated metals include manganese, cobalt, nickel, selenium, and antimony.

9 In addition to the emissions reductions presented in the 2004 Assessment, solid fuel boilers' compliance with the chlorine standards under the Agency Preferred Approach proposed in the 2004 Assessment would reduce SO2 emissions by approximately 22,000 tons per year as a result of the implementation of dry scrubber systems to control chlorine. Appendix A to this Addendum contains an analysis of the benefits associated with this reduction in SO2 emissions. Note, however, that these reductions are not anticipated under the updated Agency Preferred Approach that eliminates beyond the floor ( BTF) standards for coal fired boilers and LWAKs.

12 non enumerated metals emissions associated with the revised PM standards. 8 Projected emissions reductions for chlorine have also changed relative to those presented in the 2004 Assessment, reflecting EPA's decision to eliminate beyond the floor chlorine controls for solid fuel boilers and LWAKs. As Exhibit 3 indicates, the *** Agency now expects no reduction in LWAK's chlorine emissions under the Agency Preferred Approach***, compared to the reduction of nearly 70 percent associated with the LWAK chlorine standard presented in the 2004 Assessment. Similarly, *** we now expect a 20 percent reduction in boiler emissions of chlorine***; the 2004 Assessment reported an estimated 35 percent reduction. *** The analytical assumption supporting these modifications to projected chlorine emissions also eliminates the 22,000 ton per year reduction in SO 2 emissions that would have been achieved under the version of the Agency Preferred Approach*** analyzed in the 2004 Assessment. 9 Exhibit 3 Text Was Moved From Here: 6 TOTALbOption 1 FloorPERCENT CHANGE IN AGGREGATE EMISSIONS UNDER AGENCY PREFERRED APPROACH FINAL DRAFT: March 2004 13 0% 20% 40% 60% 80% 100% 120%

D/ F PM Hg SVM LVM TCl Percent Change Cement Kilns LWAKs Commercial Incinerators Onsite Incinerators Boilers and Process Heaters HCl Production Furnaces For on site and commercial incinerators, cement kilns, and LWAKs, percent change in emissions is relative to the 2002 Interim Standards. For boilers and HCl production furnaces, percent change is relative to the 1991 RCRA Boiler and Industrial Furnaces rule.

REVISED COST AND BENEFIT ESTIMATES The cost and benefit estimates presented in this document are consistent with the analytical framework described in Chapters 4, 5, and 6 of the 2004 Assessment. Detailed model results are included in Appendix B to this Addendum. Additional information on the economic model used to develop cost estimates is available in Appendix D of the 2004 Assessment.

Major findings of the current analysis are as follows:

Text Moved Here: 1 E ° The analysis now estimates upper bound engineering costs of ***$ 8277.89*** million per year are now estimated for the Agency Preferred Approach, with chlorine controls. This represents a 3n 8.29 percent reduction compared to the estimate of $ 85.5 million presented in the 2004 Assessment. FINAL DRAFT: March 2004 10 The avoided mortality benefits included in this estimate were calculated in 1999 dollars, in contrast to estimated morbidity benefits and estimated social costs, which were estimated in 2002 dollars. Therefore, estimated total benefits are not comparable to estimates of costs.

14 End Of Moved Text ° Market adjusted Costs($ 0. costs of the *** Agency Preferred Approach with chlorine controls are now estimated to be approximately $ 50.0 million, which is approximately 13.2 percent lower than the $ 57.6 million estimate presented in the 2004 Assessment***.

° Boilers and HCl production furnaces bear approximately 83 percent ($ 41.5 million) of the costs of the proposed replacement standards. This reflects the fact that these facilities are not subject to any emissions requirements under the 2002 Interim Standards. In addition, the $ 41.5 million estimate is 5.5 percent less than the $ 43.9 million estimate in the 2004 Assessment because of the elimination of beyond the floor chlorine standards for solid fuel boilers.

° Estimates of economic impacts are largely unchanged from those in the 2004 Assessment. Estimated employment gains are now approximately 6 percent lower under the Agency Preferred Approach. In addition, the analysis now projects an increase of 1.05 percent in combustion pricing, as opposed to the 1.4 percent increase presented in the 2004 Assessment.

° Monetized health benefits associated with the Agency Preferred Approach are approximately $ 4.50 million. 10 This estimate is approximately 8.2 percent greater than that presented in the 2004 Assessment.

° Visibility benefits associated with the revised Agency Preferred Approach of the replacement standards range from $ 106,300 per year to $ 5.78 million per year. These two figures represent two different methodologies for estimating visibility benefits. Estimates in the 2004 Assessment ranged from $ 105,800 to $ 7.41 million per year.

Revised Cost Analysis Text Moved Here: 2 Revised engineering and market adjusted cost estimates are presented in Exhibit 23 and Exhibit 34. The market adjusted costs included in these exhibits reflect a 100 percent cost passthrough consistent with the market adjusted costs presented in Exhibit 5 7 of the 2004 Assessment. WithUnder the revised PM replacement standards revised, total costs for each option included in the 2004 Assessment have decreased. The engineering costs of the Agency Preferred Approach with chlorine controls are now estimated at ***$ 8277.89*** million per year, compared to $ 85.5 million FINAL DRAFT: March 2004 11 As explained in the 2004 Assessment, the Agency Preferred Approach is the beyond the floor version of the Option 1 Floor.

15 in the 2004 Assessment. Similarly, the total social costs of the Agency Preferred Approach with chlorine controls are now approximately ***$ 550.60*** million per year, compared to $ 57.6 million per year in the 2004 Assessment. End Of Moved Text 7)$ 0.1($ 7.0)$ 1.0$ 32.6$ 1.0$ 1.5$ 7.4$ 36.2 Engineering Costs Annualized engineering costs with chlorine controls range from $ 572.91 million per year under the Option 1 Floor to approximately $ 130.5$ 1 million per year under the Option 3 " beyond the floor" ( BTF). 0$ 1.5$ 40.3$ 1.3$ 1.5NA Without controls on chlorine, annual engineering costs range from $ 52.7 million under the Option 1 Floor to $ 82.9 million under Option 3 BTF. When chlorine controls are included in the standards, costs of the BTF versions of Options 1, 2, and 3 are 8.0 percent, 5.0 percent, and 5.1 percent greater than costs associated with their corresponding floor options. 11 Without chlorine controls, these differentials are 9.5 percent, 6.4 percent, and 6.7 percent, respectively.

Average per system engineering costs associated with the revised Agency Preferred Approach with chlorine controls have changed for several source categories. *** Per system costs for coal boilers are now $ 286,400, which represents a 46 percent reduction*** compared to the estimate of $ 528,009 per system presented in the 2004 Assessment. In addition, revised per system cement kiln engineering costs, approximately $ 245,400 per system, are 24 percent lower than the estimate of $ 323,700 presented in the 2004 Assessment. Commercial and on site incinerator per system engineering costs, $ 239,400 and $ 135,800 respectively, are now approximately $ 20,000 lower than the corresponding estimates presented in the 2004 Assessment. *** Average LWAK engineering costs have fallen by $ 192,600 per system*** to $ 394,100. In contrast, per system engineering costs for liquid boilers, $ 378,300, have increased by approximately 3.3 percent relative to the estimate of $ 366,000 per system presented in the 2004 Assessment. Per system engineering costs for HCl production furnaces are unchanged.

Social Costs Text Moved Here: 3 W Market adjusted costs when the standards include chlorine controls, market adjusted costs range from $ 46.4 million under the Option 1 Floor to $ 100$ 94.37 million under Option 3 BTF. Without chlorine controls, this range is $ 36.2 $ 64.9 million. As mentioned above, annual social costs associated with the Agency Preferred Approach with chlorine controls are ***$ 550.60*** million. These costs are approximately 207.8 percent more than the costs of the Option 1 Floor and nearly 50approximately 36 percent lower than the engineering costs of the Agency Preferred Approach3. End Of Moved Text FINAL DRAFT: March 2004 16 M Compared to estimates presented in the 2004 Assessment, market adjusted costs for cement kilns and on site incinerators under the Agency Preferred Approach are now slightly lower. Similarly, estimates of coal boiler and LWAK costs are also lower, reflecting the elimination of beyond the floor chlorine controls for these sources. In contrast, current estimates of liquid boiler costs are higher than their corresponding estimates in the 2004 Assessment due to a lower ( i. e., more stringent) estimate of the PM design level for liquid boilers under the replacement standards. Our estimate of commercial incinerator savings is now slightly lower since combustion prices do not increase as much under the revised standards. Estimates of HCl production furnace costs are unchanged.

Distribution of Costs($ 2.0)$ 1.7($ 7.4)$ 1.0$ 32.7$ 2.2$ 3.4$ 9.2$ 41.1Engineering C Among source categories, boilers and HCl production furnaces bear the most significant portion of total engineering and market adjusted costs associated with the proposed HWC MACT replacement standards. This distribution of costs reflects the focus of past regulation on incinerators and commercial kilns. The 2002 Interim Standards did not regulate boilers and HCl production furnaces; the proposed replacement standards are the first hazardous waste combustion MACT regulations to address these systems.

Under the Agency Preferred Approach, boiler and HCl production furnace engineering costs represent approximately two thirds of total engineering costs. This figure increases to 80 percent of engineering costs when chlorine controls are not included in the Agency Preferred Approach. Similarly, boilers and HCl production furnaces incur 83 percent of total social costs under the Agency Preferred Approach and more than 92 percent of social costs when chlorine controls are excluded from these standards. Boilers and HCl production furnaces represent a higher percentage of marketadjusted costs than engineering costs because these systems, unlike commercial incinerators and commercial kilns, are unable to offset engineering costs by managing waste commercially. FINAL DRAFT: March 2004 17 Exhibit 4 SUMMARY OF SOCIAL COST ESTIMATES  With Chlorine Controls ( millions of 2002 dollars)

Cement Kilnsa $ 5.9LW AKsa $ 2.3Commer cial Incinerators b $ 1.0On site Incinerators $ 1.5Liqui d Boilers $ 40.4Coa l Boilers $ 2.6HCl Production Furnaces $ 3.4Generators that currently send waste to commercial facilities NA$ 57.7 TOTALc Option 21 Floor Market adjusted Costs ($ 12.37) ($ 0.41) ($ 10.6) $ 9.1) $ 36.4$ 33.

27 $ 1.05 $ 1.85 $ 210.46 $ 5246.34 Engineering Costs $ 17$ 6.5 $ 0.5 $ 3.7 $ 0.8$ 2$ 12.0$

4.8 $ 414.1$ 1.

37 $ 1.8 $ 1.5 NA $ 702.21 Option 2 BTFAgen cy Preferred Approach Market adjusted Costs ($ 05.24) ***$ 1.05 ($ 911.4) $ 9.1 $ 36.8 ***$ 1.3 $ 3.4 $ 33.14$ 2.2 $ 350.4$ 2 1.9$ 56.60 Engineering CostsCostsd $ 17$ 6.5 $ 2.8*** $ 3.7 $ 12.3$ 2.0$ 4.

8 $ 414.39 $ 23.64**

* $ 3.4 NA $ 747.79 Option 32 Floor Market adjusted Costs $ 1.20 ($ 01.41) ($ 9.4$ 14.9) $ 411.07 $ 3947.2 $ 1.05 $ 1.8 $ 22.4$ 33.2 $ 680.10 Engineering Costs $ 1928.50 $ 0.9$ 2.1$

5.58 $ 46$ 4.7 $ 16.06 $ 60.4 $ 1.38 $ 1.8 NA $ 77$ 114.

7 Option 32 BTF Market adjusted Costs ($ 02.14) $ 0.92 ($ 915.75) $ 411.07 $ 39$ 47.4 $ 1.3 $ 23.24 $ 436.16 $ 283.8$ 6 4.90 Engineering CostsCostsd $ 19.5$ 2.3 $ 2.1$ 5.5$

46.2$ 28.0 $ 3.0 $ 4.7 $ 16.6 $ 60.7 $ 3.4 $ 3.4 NA $ 120.4 Text Moved Here: 4 Option 3 Floor Market adjusted Costs $ 1.7 ($ 1.1) ($ 15.2) $ 12.2 $ 54.7 $ 1.5 $ 1.8 $ 35.3 $ 91.3 Engineering Costs $ 29.7 $ 0.9 $ 4.8 $ 17.0 $ 67.6 $ 1.8 $ 1.8 NA $ 124.2 Option 3 BTF Market adjusted Costs ($ 0.9) End Of Moved Text $ 0.1 ($ 15.9) $ 12.2 $ 54.9 $ 1.3 $ 4.1 $ 38.5 $ 94.7 FINAL DRAFT: March 2004 18 Engineering Costsd $ 29.67 $ 3.1 $ 4.8 $ 17.0 $ 67.8 $ 3.4 $ 4.1 NA $ 82$ 130.

95 NOTES:

a. *** Social cost estimates presented here are adapted from estimates that reflect the change in the proposed PM standards but not the change in the proposed chlorine standards for coal boilers and LWAKs. To generate our estimate, we subtracted the incremental, floor to beyond the floor LWAK and coal boiler chlorine control costs estimated in the 2004 Assessment from social cost estimates that reflected the updated PM proposal but not the updated chlorine proposal.***

ab. Social cost estimates for commercial systems reflect simplifying assumptions that all commercial facilities are able to charge the same prices for each waste type ( e. g.,

" halogenated waste") and are able to increase prices in order to offset cost increases. These estimates may understate social costs to commercial kilns if these systems are unable to increase prices and charge lower prices for waste with lower halogen content. However, while commercial kiln costs reflect some uncertainty, total social costs estimates are not significantly affected, because changes in assumptions about commercial kiln combustion pricing generally reflect a transfer from waste generators to kilns. The Economic Assessment developed for this rule describes a sensitivity analysis that addresses the uncertainty associated with cement kiln costs.

bc. GTotals will not add due to rounding. In addition, government administrative costs are included in the total social cost estimates. Government costs range from $ 4270,000 to $ 45547,000 per year across all six market adjusted cost options. For the upper bound estimate, under which all systems upgrade and there is no market adjustment,

annual government costs are approximately $ 543,000. Compared to estimates presented in the Assessment ( Exhibit 5 7), market adjusted costs ( with chlorine  Exhibit 2) are now slightly lower for cement kilns and marginally higher for commercial incinerators, under d. Updated estimates of beyond the floor engineering costs are available in U. S. EPA, " Technical Support Document for the HWC MACT Standards, Volume V:

Emission Estimates and Engineering Costs," February 2004. The updated results in the technical support document reflect co control cost savings associated with beyond the floor dioxin controls for LWAKs and beyond the floor PM controls for coal boilers. Under the Agency Preferred Approach. In contrast, current estimates of liquid boiler costs are higher than their corresponding estimates in the Assessment because we have reduced our estimate of the PM design level for liquid boilers under the replacement standards . Similarly, estimates of LWAK costs are also higher because the PM design level for the 2002 Interim Standards is now higher. This higher design level for the 2002 Interim Standards implies that updated estimates, updated engineering costs are approximately $ 77.2 million. FINAL DRAFT: March 2004 19 Exhibit 5 Text Moved Here: 6 SUMMARY OF SOCIAL COST ESTIMATES  No Chlorine Controls ( millions of 2002 dollars)

Cement Kilnsa LWAKsa Commercial Incinerators a On site Incinerators Liquid Boilers Coal Boilers HCl Production Furnaces Generators that currently send waste to commercial facilities End Of Moved Text of LWAK emissions in the baseline exceed estimates used for the Assessment.

TOTALb Option 1 Floor Market adjusted costs for on site incinerators are reduced by about 11 percent from the estimate presented in the Assessment.

Estimates of coal boiler and HCl production furnace costs remain unchanged from those in the Assessment.

Costs ($ 0.7) $ 0.1 ($ 7.0) $ 1.0 $ 32.6 $ 1.0 $ 1.5 $ 7.4 $ 36.2 Engineering Costs $ 5.9 $ 0.5 $ 1.0 $ 1.5 $ 40.3 $ 1.3 $ 1.5 NA $ 52.7 Agency Preferred Approach Market adjusted Costs ($ 2.0) $ 1.7 ($ 7.4) $ 1.0 $ 32.7 $ 2.2 $ 3.4 $ 9.2 $ 41.1 Engineering Costs $ 5.9 $ 2.3 $ 1.0 $ 1.5 $ 40.4 $ 2.6 $ 3.4 NA $ 57.7 Option 2 Floor Market adjusted Costs $ 1.3 ($ 0.4) ($ 9.1) $ 3.4 $ 33.2 $ 1.0 $ 1.8 $ 20.4 $ 52.3 Engineering Costs $ 17.7 $ 0.8 $ 2.0 $ 4.8 $ 41.1 $ 1.3 $ 1.8 NA $ 70.2 FINAL DRAFT: March 2004 20 Option 2 BTF Market adjusted Costs $ 0.2 $ 1.0 ($ 9.4) $ 3.4 $ 33.4 $ 2.2 $ 3.4 $ 21.9 $ 56.6 Engineering Costs $ 17.7 $ 2.3 $ 2.0 $ 4.8 $ 41.3 $ 2.6 $ 3.4 NA $ 74.7 Option 3 Floor Market adjusted Costs $ 1.2 ($ 0.4) ($ 9.4) $ 4.0 $ 39.2 $ 1.0 $ 1.8 $ 22.4 $ 60.1 Engineering Costs $ 19.5 $ 0.9 $ 2.1 $ 5.5 $ 46.0 $ 1.3 $ 1.8 NA $ 77.7 Option 3 BTF Market adjusted Costs ($ 0.1) $ 0.9 ($ 9.7) $ 4.0 $ 39.3 $ 2.2 $ 4.1 $ 23.8 $ 64.9 Engineering Costs $ 19.5 $ 2.3 $ 2.1 $ 5.5 $ 46.2 $ 2.6 $ 4.1 NA $ 82.9 Text Moved Here: 5 NOTES:

a. Social cost estimates for commercial systems reflect simplifying assumptions that all commercial facilities are able to charge the same prices for each waste type e. g.,

" halogenated waste") and are able to increase prices in order to offset cost increases. These estimates may understate social costs to commercial kilns if these systems are unable to increase prices and charge lower prices for waste with lower halogen content. However, while commercial kiln costs reflect some uncertainty, total social costs estimates are not significantly affected, because changes in assumptions about commercial kiln combustion pricing generally reflect a transfer from waste generators to kilns. The Economic Assessment developed for this rule describes a sensitivity analysis that addresses the uncertainty associated with cement kiln costs.

End Of Moved Text b. Totals will not add due to rounding. In addition, government administrative costs are included in the total social cost estimates. Government costs range from $ 427,000 to $ 455,000 per year across all six options. For the upper bound estimate, under which all systems upgrade, annual government costs are approximately $ 543,000. FINAL DRAFT: March 2004 12 This estimate reflects beyond the floor chlorine controls for LWAKs and coal boilers. Since the Agency has eliminated beyond the floor chlorine standards for these systems, estimated job gains may be lower than the estimate presented in this Addendum.

13 This estimated price increase reflects the beyond the floor standard that the Agency considered for LWAKs. Since LWAKs are not required to meet beyond the floor chlorine controls under the revised Agency Preferred Approach, the estimated increase in commercial combustion prices may be lower than presented in this Addendum.

21 Major Revisions toRevised Economic Impact Estimates Estimates of economic impacts change very little from those included in the 2004 Assessment. The only notable changes are inEstimated employment gains, which decrease by approximately 6 percent in the current analysis. With3 percent to 559 full time equivalents under the revised Agency Preferred Approach. 12 This reflects the fact that with less stringent PM standards for several facilities, fewer labor resources will be required to comply with the standards. In addition, we now estimate that combustion prices may increase by approximately 1.05 percent as a result of the replacement standards, compared to the projected 1.4 percent increase reported in the 2004 Assessment. 13 Market exits are virtually unchanged from exits reported in the 2004 Assessment. Since market exits do not change considerably, no major changes occur in the estimated quantity of hazardous waste reallocated.

Benefits Analysis Monetized health benefits of approximately $ 4.5 million per year are estimated for the revised version of the Agency Preferred Approach. This is a decline of about 15 percent from the $ 5.28 million/ yr estimate presented in the Assessment. This revised estimate reflects changes in the proposed PM standards as well as an adjustment to the inflation factor EPA used to estimate benefits. 4 Across other options, monetized health benefits were found to range from $ 4.4 million to $ 8.3 million. Overall, monetized health benefits were found to be approximately 15 19 percent lower than those presented in the Assessment. For ( e. g., 120,855 tons under the Agency Preferred Approach, reduced chronic bronchitis benefits represent approximately 75 percent of this decline. Reduced benefits associated with premature deaths and minor restricted activity represent most of the remaining 25 percent.

Under the revised PM replacement standards, we estimated annual visibility benefits associated with the Agency Preferred Approach ranging from $ 115,000 to $ 5.8 million. The low end of this range, which is a decline of about 14 percent from the low end estimate ($ 134,000) in the Assessment, assumes a linear relationship between health benefits and visibility benefits. In contrast, the higher FINAL DRAFT: March 2004 14 The revised estimates of SVM and LVM emissions reductions described above have no effect on monetized benefits estimates, which are based completely on estimated PM emission reductions.

22 of the two estimates assumes a linear relationship between PM emissions reductions and visibility improvements. This figure is approximately 27 percent lower than the high end estimate ($ 8 million)) does not change as a result of the changes to the proposed standards.

Most of the revised estimates of other industry impacts ( e. g., changes in the profitability and cost structure of the combustion industry) are similar to estimates presented in the 2004 Assessment. Similar to the current estimates of health benefits, changes in the low end and high end visibility estimates reflect less stringent PM standards and an adjustment to the inflation factor EPA applied in the analysis. Both estimates are based on results presented in The Benefits and Costs of the Clean Air Act 1990 to 2010.5However, we now estimate that cement kiln and commercial incinerator waste burning costs may increase by 10.3 percent and 1.3 percent respectively, compared to the potential increases of 14 percent and 3.9 percent reported in the 2004 Assessment. In addition, the Agency now estimates a possible 9 percent increase in cement kiln pollution control costs. This is nearly 3 percentage points lower than the 11.9 percent increase that we had previously estimated in the 2004 Assessment.

Revised Benefits Analysis This section provides updated estimates of the health and visibility benefits associated with the revised replacement standards. The benefits analysis has been revised to include the following:

* ** Monetized benefits associated with reduced dioxin emissions,***

Revised estimates of benefits associated with reduced PM emissions, reflecting changes to the baseline and the proposed standards as outlined above,

* ** Discounted estimates of benefits that are not immediately realized after emissions are reduced***.

The results presented below include only those benefits associated with reduced PM *** and dioxin. 14*** Although little information is available on the potential magnitude of benefits associated with reduced emissions of the other pollutants included in the standards, reductions in the emissions of these pollutants are likely to improve human health. For example, adverse health effects associated with hydrogen chloride exposure are well documented. These include eye, nose, and respiratory tract irritation; pulmonary edema; gastritis; bronchitis; and dermatitis. Prolonged exposure to low concentrations of hydrogen chloride may also lead to dental discoloration and erosion. The benefits FINAL DRAFT: March 2004 15 The " with chlorine controls" version of the standards analyzed in the 2004 Assessment may have reduced coal boiler emissions of SO2. The benefits associated with this emissions reduction are not included in the 2004 Assessment or in the primary results of this Addendum but are provided in Appendix A of this Addendum.

23 associated with reducing the incidence of these ailments are likely to be lower under the " without chlorine controls" version of each option than the corresponding " with chlorine controls" option.

Our estimates of the physical effects associated with the revised PM replacement standards are presented in Exhibit 6. The exhibit does not differentiate between " with chlorine controls" and " without chlorine controls" versions of the standards because *** none of the quantified benefits presented in Exhibit 6 are associated with reduced chlorine emissions. 15***

Most of the quantified reductions in physical effects reported in Exhibit 6 are slightly lower than the corresponding results presented in the 2004 Assessment, although the number of premature deaths is largely unchanged across all regulatory options. Differences between current and previous results are least pronounced under the Agency Preferred Approach. Compared to results presented in the 2004 Assessment, 0.1 fewer cases of chronic bronchitis and upper respiratory illness are avoided each year under the Agency Preferred Approach. In addition, 0.4 fewer work loss days and lower respiratory illness cases are avoided each year under the revised Agency Preferred Approach. Under the Option 1 Floor and the Option 2 Floor, annual reductions in lower respiratory illness, work loss days, and minor restricted activity are 0.8, 3.4, and 28 cases less respectively than estimates presented in the 2004 Assessment. Similarly, 0.1 fewer cases of acute and chronic bronchitis and upper respiratory illness are avoided under the revised Option 1 and 2 Floors. Results associated with the revised Option 3 Floor differ most significantly from the corresponding estimates presented in the 2004 Assessment. Our current estimate of 6,848.6 avoided minor restricted activity cases represents a decline of 438.6 avoided cases compared to the annual reductions presented in the 2004 Assessment. In addition, we now anticipate the avoidance of 52.6 fewer work loss days per year and of 5.1 fewer lower respiratory cases per year under the revised Option 3 Floor. Our current estimates of chronic and acute bronchitis cases avoided under this option are 0.7 and 0.6 annual cases less respectively than the estimates presented in the 2004 Assessment. FINAL DRAFT: March 2004 16 USEPA, 1985. Health Assessment Document for Polychlorinated Dibenzo p Dioxins. EPA/ 600/ 8 84/ 014F. Final Report. Office of Health and Environmental Assessment. Washington, DC. September, 1985.

24 Exhibit 6 REDUCTION IN ANNUAL INCIDENCE OF PHYSICAL EFFECTS ASSOCIATED WITH PM Agency Preferred Approach Option 1 Floor Option 2 Floor Option 2 BTF D Option 3 Floor Option 3 BTF D Premature deaths avoided 0.3 0.3 0.3 0.3 0.6 0.6 Respiratory illness 0.9 0.9 0.9 0.9 1.6 1.6 Cardiovascular disease 0.4 0.4 0.4 0.4 0.7 0.7 Chronic bronchitis 5.6 5.5 5.5 5.6 10.3 10.4 Acute bronchitis 4.3 4.2 4.2 4.3 7.8 7.9 Lower respiratory symptoms 38.0 37.3 37.3 38.0 69.1 69.8 Upper respiratory symptoms 4.4 4.3 4.3 4.4 8.0 8.1 Work loss days 450.7 443.9 443.9 450.7 822.1 829.2 Minor restricted activity days 3,754.4 3,698.1 3,698.1 3,754.4 6,848.6 6,907.4 Restricted Activity days 1,236.4 1,217.9 1,217.9 1,236.4 2,255.4 2,274.8 The proposed replacement standards are also likely to reduce the number of cancer deaths associated with dioxin/ furans emissions. The Addendum to the 1999 Assessment estimated that 0.36 premature cancer deaths would be avoided annually due to the annual emissions reduction of 28.7 grams of mass doxin/ furans, associated with the 1999 dioxin/ furan standards. *** Assuming that the proportional relationship between dioxin/ furans emissions and premature cancer deaths is constant, we estimate that approximately 0.058 premature cancer deaths will be avoided on an annual basis under the Agency Preferred Approach because of reduced dioxin/ furans emissions. This estimate reflects a cancer risk slope factor of 1.56 x 105 [ mg/ kg/ day] 1. This cancer slope factor is derived from the Agency's 1985 health assessment document for polychlorinated dibenzo p dioxins16 and represents an upper bound 95th percentile confidence limit of the excess cancer risk from a lifetime exposure.*** FINAL DRAFT: March 2004 17 U. S. EPA, Exposure and Human Health Reassessment of 2,3,7,8 Tetrachlorodibenzo p Dioxin ( TCDD) and Related Compounds, September 2000. Note: Toxicity risk factors presented in this document should not be considered EPA's official estimate of dioxin toxicity, but rather reflect EPA's ongoing effort to reevaluate dioxin toxicity.

25 *** For the past 12 years the Agency has been conducting a reassessment of the human health risks associated with dioxin and dioxin like compounds. This reassessment17 will soon be under review at the National Academy of Sciences ( NAS), as specified by Congress in the Conference Report accompanying EPA's fiscal year 2003 appropriation ( Title IV of Division K of the Conference Report for the Consolidated Appropriations Resolution of 2003). Evidence compiled from this draft reassessment indicates that the carcinogenic effects of dioxin/ furans may be as much as six times as great as believed in 1985, reflecting an upper bound cancer risk slope factor of 1 x 106 [ mg/ kg/ day] 1 for some individuals. Agency scientists' more likely ( central tendency) estimates ( derived from the ED 01 rather than the LED 01) result in slope factors and risk estimates that are within 2 3 times of the upper bound estimates ( i. e., between 3 x 105 [ mg/ kg/ day] 1 and 5 x 105 [ mg/ kg/ day] 1) based on the available epidemiological and animal cancer data. Risks could be as low as zero for some individuals. Use of the alternative upper bound cancer risk slope factor would result in up to 0.35 premature cancer deaths avoided in response to the proposed replacement standards for dioxin/ furans. The assessment of upper bound cancer risk using this alternative slope factor should not be considered Agency policy. The proposed standards for dioxin in today's rule were not based on this draft reassessment***.

*** Our estimates of avoided premature cancer deaths associated with the proposed replacement standards for dioxin and various options are presented in Exhibit 7. However, since dioxin causes several other health effects, such as impaired development and reduced fertility, the values in Exhibit 7 are believed to underestimate the actual benefits associated with reduced dioxin/ furans emissions.*** FINAL DRAFT: March 2004 18 U. S. EPA, Exposure and Human Health Reassessment of 2,3,7,8 Tetrachlorodibenzo p Dioxin ( TCDD) and Related Compounds, September 2000. Note: Toxicity risk factors presented in this document should not be considered EPA's official estimate of dioxin toxicity, but rather reflect EPA's ongoing effort to reevaluate dioxin toxicity.

26 *** Exhibit 7***

REDUCTION IN ANNUAL INCIDENCE OF PREMATURE CANCER DEATHS ASSOCIATED WITH DIOXIN/ FURANSa, b Agency Preferred Approach Option 1 Floor Option 2 Floor Option 2 BTF D Option 3 Floor Option 3 BTF D 0.058 0.005 0.005 0.058 0.005 0.058 Notes:

a. The primary estimates assume that the proportional relationship between cancer deaths and dioxin/ furans emissions is constant. All estimates rely on results of the risk analysis prepared for EPA, Assessment of The Potential Costs, Benefits & Other Impacts of The Hazardous Waste Combustion MACT Standards: Final Rule, July 1999. b. As discussed in the text above, the Agency has been conducting a reassessment of the human health risks associated with dioxin and dioxin like compounds. This reassessment will soon be under review at the National Academy of Sciences ( NAS), as specified by Congress in the Conference Report accompanying EPA's fiscal year 2003 appropriation ( Title IV of Division K of the Conference Report for the Consolidated Appropriations Resolution of 2003). Evidence compiled from this draft reassessment indicates that the carcinogenic effects of dioxin/ furans may be as much as six times as great as believed in 1985, reflecting an upper bound cancer risk slope factor of 1 x 106 [ mg/ kg/ day] 1 for some individuals. Use of the alternative upper bound cancer risk slope factor would result in up to 0.35 premature cancer deaths avoided in response to the proposed replacement standards for dioxin/ furans. The assessment of upper bound cancer risk using this alternative slope factor should not be considered Agency policy.

*** A detailed accounting of the monetized, non discounted benefits of the revised replacement standards is presented in Exhibit 8. Our central estimate of the annual health benefits associated with the revised version of the Agency Preferred Approach is approximately $ 4.50 million, reflecting a range of $ 2.73 million to $ 6.27 million. The central estimate of $ 4.50 million represents an 8.2 percent increase over the annual benefits of $ 4.16 million reported in the 2004 Assessment. This increase in benefits reflects the monetization of avoided cancer deaths associated with reduced dioxin/ furans exposure; these benefits were not monetized in the 2004 Assessment. Across all three beyond the floor options, our primary estimate of benefits associated with reduced dioxin emissions is $ 0.06 million to $ 0.58 million. Recent evidence suggests, however, that the toxicity of dioxin may be as much as six times greater than reflected in these estimates. 18*** As explained above, we have FINAL DRAFT: March 2004 27 also made minor modifications to baseline PM emissions and the proposed PM replacement standards, but these changes have little impact on monetized benefits estimates since the current estimate of avoided mortalities is nearly the same as that presented in the 2004 Assessment.

Across the three floor options, we estimate health benefits ranging from approximately $ 2.64 million to $ 11.04 million, compared to the range of $ 4.12 million to $ 8.08 million presented in the 2004 Assessment. This range of benefits associated with the revised version of the proposed replacement standards reflects a VSL range of $ 1.0 million to $ 10.0 million. Benefits are greater under the beyond the floor versions of the replacement standards because the PM standards for solid fuel boilers and the dioxin/ furans standards for LWAKs, liquid fuel boilers, and HCl production furnaces are more stringent under the BTF options. FINAL DRAFT: March 2004 28 Exhibit 8 MONETIZED NON DISCOUNTED VALUE OF BENEFITS ASSOCIATED WITH THE PROPOSED HWC MACT REPLACEMENT STANDARDS ( 2002 Dollars in Millions) a Type of Benefit Agency Preferred Approach Option 1 Floor Option 2 Floor Option 2 BTF D Option 3 Floor Option 3 BTF D Human Health Benefits  Particulate Matterb Premature deaths avoidedc $ 1.84 ($ 0.34  $ 3.35) $ 1.81 ($ 0.33  $ 3.30) $ 1.81 ($ 0.33  $ 3.30) $ 1.84 ($ 0.34  $ 3.36) $ 3.36 ($ 0.61  $ 6.10) $ 3.39 ($ 0.62  $ 6.16)

Respiratory illness $ 0.01 $ 0.01 $ 0.01 $ 0.01 $ 0.01 $ 0.01 Cardiovascular disease $ 0.01 $ 0.01 $ 0.01 $ 0.01 $ 0.01 $ 0.01 Chronic bronchitis $ 2.12 $ 2.09 $ 2.09 $ 2.12 $ 3.87 $ 3.91 Acute bronchitis $ 0 $ 0 $ 0 $ 0 $ 0 $ 0 Lower respiratory symptoms $ 0 $ 0 $ 0 $ 0 $ 0 $ 0.01 Upper respiratory symptoms $ 0 $ 0 $ 0 $ 0 $ 0 $ 0 Work loss days $ 0.05 $ 0.05 $ 0.05 $ 0.05 $ 0.09 $ 0.09 Minor restricted activity $ 0.15 $ 0.15 $ 0.15 $ 0.15 $ 0.27 $ 0.27 *** Human Health Benefits  Dioxin/ Furans***

Premature cancer deaths avoided ( primary estimate) d $ 0.32 ($ 0.06  $ 0.58) $ 0.03 ($ 0.01  $ 0.05) $ 0.03 ($ 0.01  $ 0.05) $ 0.32 ($ 0.06  $ 0.58) $ 0.03 ($ 0.01  $ 0.05) $ 0.32 ($ 0.06  $ 0.58)

Annual Monetized Health Benefitse, f, g $ 4.50 ($ 2.73  $ 6.27) $ 4.14 ($ 2.64  $ 5.65) $ 4.14 ($ 2.64  $ 5.65) $ 4.50 ( 2.73  $ 6.27) $ 7.65 ($ 4.88  $ 10.42) $ 8.01 ($ 4.97  $ 11.04)

Visibilityh Total Visibility Benefits  PM emissions $ 0.11  $ 5.78 $ 0.10  $ 4.43 $ 0.10  $ 4.43 $ 0.11  $ 5.88 $ 0.19  $ 8.03 $ 0.20  $ 9.44 Total Annual Monetary Benefitsf $ 2.84  $ 12.05 $ 2.74  $ 10.08 $ 2.74  $ 10.08 $ 2.84  $ 12.15 $ 5.07  $ 18.45 $ 5.17  $ 20.48 FINAL DRAFT: March 2004 Exhibit 8 MONETIZED NON DISCOUNTED VALUE OF BENEFITS ASSOCIATED WITH THE PROPOSED HWC MACT REPLACEMENT STANDARDS ( 2002 Dollars in Millions) a 29 Notes: a. *** Benefits associated with avoided mortality are presented in 1999 dollars and benefits associated with avoided morbidity are presented in 2002 dollars***. b. To avoid potential double counting with benefits related to minor restricted activity days, we do not provide monetized estimates associated with restricted activity days. c. *** Monetized benefits associated with avoided premature mortality reflect a VSL range of $ 1.0 million to $ 10.0 million, with a central VSL estimate of $ 5.5 million. These values are consistent with those presented in U. S. EPA, Benefits of the Proposed Inter State Air Quality Rule, January 2004. However, these VSL values are in 1999 dollars and are therefore inconsistent with morbidity and cost estimates, which are presented in 2002 dollars***. d. *** The primary estimate of dioxin benefits presented here reflects EPA's current guidance on the cancer risk ( 1.5 x 105 [ mg/ kg/ day] 1) associated with dioxin/ furans. These values reflect a VSL range of $ 1.0 million to $ 10.0 million. As discussed in the text above, the Agency has been conducting a reassessment of the human health risks associated with dioxin and dioxin like compounds. This reassessment will soon be under review at the National Academy of Sciences ( NAS), as specified by Congress in the Conference Report accompanying EPA's fiscal year 2003 appropriation ( Title IV of Division K of the Conference Report for the Consolidated Appropriations Resolution of 2003). Evidence compiled from this draft reassessment indicates that the carcinogenic effects of dioxin/ furans may be as much as six times as great as believed in 1985, reflecting an upper bound cancer risk slope factor of 1 x 106 [ mg/ kg/ day] 1 for some individuals. Use of the alternative upper bound cancer risk slope factor would result in up to 0.35 premature cancer deaths avoided in response to the proposed replacement standards for dioxin/ furans. The assessment of upper bound cancer risk using this alternative slope factor should not be considered Agency policy***. e. *** This estimate differs from benefits associated with the standards presented in the 2004 Assessment in that it does not include benefits associated with beyond the floor chlorine standards for solid fuel boilers or LWAKs. As explained in Appendix A of this Addendum, the solid fuel boiler beyond the floor standard for chlorine analyzed in the 2004 Assessment ( 110 ppmv) would have reduced emissions of SO2, a PM precursor, by approximately 22,000 tons per year. Adapting from benefits estimates presented in U. S. EPA, 2003 Technical Addendum: Methodologies for the Benefit Analysis of the Clear Skies Act of 2003, September 2003 and U. S. EPA, Benefits of the Proposed Inter State Air Quality Rule, January 2004, we estimate that the benefits associated with the solid fuel boiler beyond the floor standard for chlorine would yield annual health benefits of approximately $ 288.5 million ( in 2002 dollars) under the Agency Preferred Approach*** f. Totals may not add due to rounding. g. *** Because of the uncertainty associated with the " high cancer risk" estimate of dioxin benefits, this estimate is not included in the total benefits estimates presented in this exhibit.*** h. *** This estimate differs from benefits associated with the standards presented in the 2004 Assessment in that it does not include benefits associated with beyond the floor chlorine standards for solid fuel boilers or LWAKs ( see note b). As illustrated in Appendix B of this Addendum, the benefits associated with the solid fuel boiler beyond the floor standard for chlorine analyzed in the 2004 Assessment could yield annual visibility benefits of approximately $ 6.06 million ( in 2002 dollars) under the Agency Preferred Approach. ***

In addition to benefits resulting from reduced PM emissions, the 2004 Assessment also provided general estimates of the health benefits associated with reduced metals emissions. The Addendum to the 1999 Assessment estimated that the reduction in lead emissions associated with the 1999 standards would reduce lead exposure below levels of concern ( i. e., a blood level of at least 10 µ g/ dl) for seven children annually. However, the relatively modest reduction in lead emissions expected under the proposed HWC MACT replacement standards suggests that the replacement standards will reduce lead exposure below levels of concern for fewer than seven children annually. FINAL DRAFT: March 2004 19 U. S. EPA, The Benefits and Costs of the Clean Air Act 1990 to 2010, November 1999. 20 Jim Neumann and Bob Unsworth, Addenda to Mortality Valuation Methodology, internal memorandum submitted to Jim DeMocker, September 28, 1993. 21 U. S. EPA, 2003 Technical Addendum: Methodologies for the Benefit Analysis of the Clear Skies Act of 2003, September 2003 30 Under the revised PM replacement standards, we estimate annual visibility benefits associated with the Agency Preferred Approach ranging from $ 106,300 to $ 5.78 million. The low end of this range, which is approximately 0.5 percent greater than the low end estimate in the 2004 Assessment, assumes a linear relationship between health benefits and visibility benefits. In contrast, the higher of the two estimates assumes a linear relationship between PM emissions reductions and visibility improvements and is approximately 22 percent lower than the high end estimate presented in the 2004 Assessment. Across other regulatory options, the lower estimate ranges from $ 104,600 to $ 195,500 per year, which represents a 0.3 to 4.9 percent decline compared to the low end estimates presented in the 2004 Assessment. Varying between $ 4.43 and $ 9.44 million annually, the high end estimates for these options are approximately 25 percent less than the corresponding results in the 2004 Assessment. Similar to the current estimates of health benefits, changes in the low end and high end visibility estimates reflect less stringent PM standards and an adjustment to the inflation factor applied in the analysis. Both estimates are based on results presented in The Benefits and Costs of the Clean Air Act 1990 to 2010.1919 Chapter 6 of the 2004 Assessment contains additional information on the methodologies associated with both estimates.

This analysis does not quantify The annual emissions reductions achieved under the HWC MACT replacement standards may not have an immediate impact on public health. *** Specifically, avoided mortalities resulting from annual reductions in PM and dioxin/ furans emissions may occur over a period of several years. For example, the epidemiological literature suggests that premature mortality associated with dioxin/ furans emissions may not occur until 21 to 34 years following exposure. 20 Similarly, the premature mortalities resulting from PM emissions may be distributed over the five years subsequent to exposure. 21 Since a portion of the benefits associated with reduced chlorine emissions under the proposed HWC MACT replacement standards because little information is available on the potential magnitude of these benefits. However, adverse health effectsmay materialize over a period of several years, we estimated discounted benefits as a sensitivity analysis***. The results of this analysis are presented in Exhibit 9. For comparison, Exhibit 9 also includes non discounted benefits. FINAL DRAFT: March 2004 31 *** Exhibit 9***

Comparison of Discounted And Non discounted Benefits of the Hazardous Waste Combustion MACT Replacement Standards Benefit Category and Pollutant Monetized Valuea, b ( million 2002 dollars per year)

Non discounted Three Percent Discount Rate Seven Percent Discount Rate Human Health Benefits Dioxin/ Furansc: Baseline to Floor  Floor to Beyond the Floor

Baseline to Beyond the Floor: $ 0.03 $ 0.29 $ 0.32 $ 0.01  $ 0.02 $ 0.11  $ 0.16 $ 0.12  $ 0.17 $ 0.003  $ 0.01 $ 0.03  $ 0.07 $ 0.03  $ 0.08 Particulate Matterd: Mortality  Morbidity

Baseline to Beyond the Floor: $ 1.84 $ 2.34 $ 4.18 $ 1.70 $ 2.34 $ 4.04 $ 1.54 $ 2.34 $ 3.87 TCle: Not monetized Not monetized Not monetized Mercury: Not monetized Not monetized Not monetized Lead: Not monetized Not monetized Not monetized Human Health Sub Total: f $ 4.50 $ 4.15  $ 4.21 $ 3.91  $ 3.95 Visibility Benefits:

Visibility Sub total Particulate Matter: $ 0.11  $ 5.78 $ 0.11  $ 5.78 $ 0.11  $ 5.78 Grand Total f $ 4.61  $ 10.28 $ 4.26  $ 9.99 $ 4.02  $ 9.73 FINAL DRAFT: March 2004 *** Exhibit 9***

Comparison of Discounted And Non discounted Benefits of the Hazardous Waste Combustion MACT Replacement Standards 32 Notes:

a. Estimates of monetized benefits presented in this exhibit reflect a central VSL estimate of $ 5.5 million. This value reflects the mean of the estimated VSL 95 percent confidence interval estimated for U. S. EPA, Benefits of the Proposed Inter State Air Quality Rule, January 2004. In contrast, estimates in Exhibit 8 reflect this central value and the $ 1 million to $ 10 million range. b. Benefits associated with chlorine exposure are well documented. These include eye, nose, and respiratory tract irritation; pulmonary edema; gastritis; bronchitis, asthma and swelling of the lungs; headaches; heart disease; meningitis; and death. The avoided mortality are expressed in 1999 dollars, unlike compliance costs and benefits associated with reducing the incidence of these ailments are likely to be significantly lower under the " without chlorine controls" version of each option than the corresponding " with chlorine controls" option.

reduced morbidity, which are expressed in 2002 dollars. Since a portion of benefits are in 1999 dollars instead of 2002 dollars, the estimate of total benefits presented here is not comparable with cost estimates. c. Total dioxin/ furans emissions reductions are 4.68 grams per year, represented by 0.42 grams interim baseline to floor and 4.26 grams floor to BTF. The range of monetized benefits reflects a latency period ranging from 21 years to 34 years. In addition, this range reflects a cancer risk factor of 1.5 x 105 [ mg/ kg/ day] 1. As discussed in the text above, the Agency has been conducting a reassessment of the human health risks associated with dioxin and dioxin like compounds. This reassessment will soon be under review at the National Academy of Sciences ( NAS), as specified by Congress in the Conference Report accompanying EPA's fiscal year 2003 appropriation ( Title IV of Division K of the Conference Report for the Consolidated Appropriations Resolution of 2003). Evidence compiled from this draft reassessment indicates that the carcinogenic effects of dioxin/ furans may be as much as six times as great as believed in 1985, reflecting an upper bound cancer risk slope factor of 1 x 106 [ mg/ kg/ day] 1 for some individuals. Use of the alternative upper bound cancer risk slope factor would result in up to 0.35 premature cancer deaths avoided in response to the proposed replacement standards for dioxin/ furans. The assessment of upper bound cancer risk using this alternative slope factor should not be considered Agency policy. d. Monetized PM mortality benefits assume that 25 percent of premature mortalities occur during the first year, 25 percent occur during the second year, and 16.7 percent occur in each of the three subsequent years after exposure. We assume no time lag is associated with PM morbidity effects. This methodology is consistent with EPA's analysis of the proposed Clear Skies Act of 2003. EPA, Technical Addendum: Methodologies for the Benefit Analysis of the Clear Skies Act of 2003, September 2003. e. The beyond the floor version of the chlorine standards analyzed in the 2004 Assessment would yield ancillary benefits associated with reduced emissions of SO2. These benefits are not presented in the 2004 Assessment, but Appendix A to this Addendum presents information on these benefits. f. Totals may not add due to rounding. Totals do not include dioxin benefits associated with the high end dioxin toxicity estimate.

*** As Exhibit 9 shows, monetized benefits of the proposed HWC MACT replacement standards range from $ 4.02 million to $ 10.28 million, depending on which discount rate is used. For example, the high end estimate of total non discounted benefits is $ 10.28 million, whereas our highend estimates discounted at 3 percent and 7 percent are $ 9.99 million and $ 9.73 million respectively. Although our estimates of total benefits are sensitive to discounting assumptions, discounting has no effect on our estimates of morbidity and visibility benefits because we assume that there is no latency associated with these benefits. ***

It is important to emphasize that the monetized benefits presented in this Addendum represent only a portion of the benefits associated with the proposed replacement standards. Specifically, ecological benefits and health benefits associated with reduced emissions of chlorine, mercury, lead, FINAL DRAFT: March 2004 33 and several other hazardous air pollutants are not monetized. FINAL DRAFT: March 2004 22 Total compliance costs represent engineering costs, the upper bound estimate of costs. This conservative approach generally overestimates compliance costs as a percentage of total sales. 23 This estimate does not reflect the elimination of the beyond the floor chlorine standards for LWAKs under the Agency Preferred Approach. This facility's compliance costs as a percent of total sales are likely to be lower than estimated in this Addendum.

34 EQUITY CONSIDERATIONS AND OTHER IMPACTS Changes to the PM replacement standards and design levels have no impact on most of the equity considerations and other regulatory concerns addressed under relevant Executive Orders. The costs associated with the proposed PM replacement standards under the Agency Preferred Approach range from $ 55.6 to $ 82.8 million. Since these costs total less than $ 100 million, the proposed replacement standards do not represent a significant unfunded mandate and are consequently exempt from requirements associated with the Unfunded Mandates Reform Act. Because the changes to the proposed standards do not reflect changes in locations or operating status of regulated facilities, the proposed replacement standards may still result in significant health and environmental benefits to minority and low income populations living in proximity to hazardous waste combustion facilities. For the same reasons described in the 2004 Assessment, the proposed PM replacement standards will not be likely to have a significant joint impact on the actions of facilities controlled by other regulations. Likewise, the revised replacement standards do not have implications as defined in Executive Order 13175, " Consultation With Indian Tribal Governments;" Executive Order 13132, " Federalism;" and Executive Order 12630, " Government Actions and Interference with Constitutionally Protected Property Rights." The remainder of this section discusses the impacts of the proposed PM replacement standards on small entities, children's health protection, and energy use, as well as non air environmental impacts.

Assessment of Small Entity Impacts According to the Small Business Administration, the same six facilities as those identified in the 2004 Assessment are small businesses. The total compliance costs per facility, however, vary due to the proposed PM replacement standards. 22 As Exhibit 10 demonstrates, under the revised replacement standards, estimated costs decline for most facilities classified as small businesses. Costs at the one facility where compliance costs exceed 1 percent of total annual sales increase marginally from 2.21 percent of annual sales to 2.23 percent. 23 Under the market adjusted scenario, we expect that this facility will continue to operate. Therefore, the new proposed PM replacement standards are not likely to result in a significant economic impact on a substantial number of small hazardous waste combustion facilities. FINAL DRAFT: March 2004 35 Exhibit 10 SMALL ENTITY ANALYSIS RESULTS Facility Name/

Parent Companya EPA ID Combustor Type Corporate Entity Annual Sales ( dollars) b Total Compliance Costs in the 2004 Assessment ( Agency Preferred Approach) c ( dollars) Revised Total Compliance Costs ( Agency Preferred Approach) d ( dollars) Revised Costs As a Percentage of Sales ( CPS)

Reilly Industries,

Inc. IND000807107 Liquid Boiler $ 329,600,000 $ 715,900 $ 704,600 0.21%

Rubicon, Inc. LAD008213191 Liquid Boiler $ 465,000,000 $ 848,800 $ 844,800 0.18%

Continental Cement Company MOD054018288 Cement Kiln $ 52,400,000 $ 238,900 $ 87,300 0.17%

Thermalkem ( Norlite); subsidiary of United Oil Recovery NYD080469935 LWAK $ 49,100,000 $ 1,077,600 $ 1,092,500e 2.23%

3V, Inc. f SCD980500052 Liquid Boiler $ 62,600,000 $ 45,100 $ 44,100 0.07%

Velsicol Chemical Corporation TND007024664 On Site Incinerator $ 150,000,000 $ 5,200 $ 6,800 < 0.01% FINAL DRAFT: March 2004 Exhibit 10 SMALL ENTITY ANALYSIS RESULTS 36 Notes:

a Except in the case of Norlite, the name of each facility's parent company is the same as the name of the facility itself.

b Corporate entity data obtained from ReferenceUSA, Dun and Bradstreet, company websites, and company financial documents.

c Total compliance costs represent the upper bound engineering costs under the proposed HWC MACT replacement standards described in the 2004 Assessment, assuming facilities upgrade to comply with proposed standards.

d Revised total compliance costs represent the upper bound engineering costs under the proposed PM replacement standards, assuming facilities upgrade to comply with proposed standards.

e Estimated compliance costs for this facility do not reflect the elimination of the beyond the floor chlorine controls for LWAKs. The compliance cost value presented here for this facility may overestimate the facility's actual compliance costs under the Agency Preferred Approach.

f 3V, Incorporated is an Italian owned company with facilities in the United States, Italy, and several other countries. Employment in the U. S. is at least 270 people, and overall employment worldwide is likely over 500 people ( the small business size threshold). However, we included this facility as a small business because it is an internationally owned company and we were unable to confirm total employment. Sales data are for the single facility in South Carolina. FINAL DRAFT: March 2004 24 U. S. EPA, Environmental Health Threats to Children, EPA 175 F 96 001, September 1996, 4.

25 Note that lead related benefits, while modest, may be higher than those reported in the 2004 Assessment. These benefits are expected to be less than the seven cases estimated in the July 23, 1999 Addendum and under the 2002 Interim Standards.

37 Children's Health Protection Analysis Most health benefits associated with the proposed replacement standards result from reduced PM emissions. The revision to the proposed PM replacement standards, however, does not change the number of avoided premature deaths and illnesses in children, relative to results presented in the 2004 Assessment. The standards should still prevent less than one premature death and approximately 54 illness cases per year. As described in the 2004 Assessment, separate results are not available for children. We assume, however, that children would experience significant health benefits since they are particularly vulnerable to the effects of PM exposure. 24 Benefits associated with mercury and lead controls will also remain the same since the mercury and lead standards have not changed. 25 If the Agency implements chlorine controls, the effect on children's health will be positive. We do not quantify the exact magnitude of these benefits given available data, but reduced chlorine emissions may prevent eye, nose, and respiratory tract irritations; pulmonary edema; gastritis; bronchitis; asthma and swelling of the lungs; headaches; heart disease; meningitis; and death. We assume that children would experience some of these health benefits as their exposure to chlorine declines.

Energy Impact Analysis In order to comply with the proposed PM replacement standards, regulated hazardous waste combustion facilities may upgrade their pollution abatement systems, consolidate hazardous waste into fewer systems located on site, or stop burning hazardous waste. Under the market adjusted scenario, we expect that hazardous waste combustion systems will comply as described in the 2004 Assessment. Of the 276 systems in the regulatory universe, 218 will upgrade, 45 will close and ship their waste off site, and 13 will consolidate. Consequently, compared to results presented in the 2004 Assessment, energy use impacts are unchanged under the revised PM replacement standards. The standards will result in the use of an additional 1,0172,722 million Btus of energy per year, costing at least $ 1,377,396. This increase represents less than 0.0032 percent of the energy consumed in 2002, and consequently, the rule does not represent a " significant energy action" as defined in Executive Order 12311, " Actions Concerning Regulations That Significantly Affect Energy Supply, Distribution, or Use." As in the 2004 Assessment, these estimates do not include energy and costs associated with system upgrades and thus underestimate the total energy impact of the proposed PM replacement standards. FINAL DRAFT: March 2004 38 Non air Environmental Impacts Most of our estimates of the non air environmental impacts associated with the revised standards are similar to those presented in the 2004 Assessment. Differences between current and previous estimates reflect changes in the standards and slight modifications to the technologies we assume different systems will implement to comply with the standards.

The Agency now estimates that systems using wet scrubbers to control chlorine emissions will generate an additional 4.6 billion gallons of wastewater per year, compared to the 4.0 billion gallons estimated in the Assessment. In addition, we estimate that systems installing dry scrubbers to limit chlorine emissions will generate approximately 33,000 tons of spent sorbent per year, just 1,000 tons less than estimated in the 2004 Assessment. We also project that facilities using activated carbon to control emissions of dioxins/ furans and mercury will generate approximately 8,000 tons of carbon on an annual basis, which represents a 3,000 ton reduction relative to the estimate presented in the 2004 Assessment. Controls for other pollutants will likely increase annual water consumption by 500 million gallons and generate an additional 5,000 tons of solid waste per year. The former estimate is 50 percent less than the corresponding estimate presented in the 2004 Assessment.

COST EFFECTIVENESS ANALYSIS The revised proposal for the HWC MACT replacement standards does not significantly change most of the cost effectiveness estimates reported in the 2004 Assessment. Exhibits 11 and 12 present the updated cost effectiveness results. These exhibits do not present separate estimates for versions of the standards that exclude controls on chlorine emissions. With the exception of estimates associated with chlorine, the cost effectiveness for such versions of the standards are the same as the corresponding versions of the replacement standards that include chlorine controls. Key findings from these updated results include the following:

° Cost effectiveness per ton of reduced PM emissions from LWAKs and incinerators are not calculated because the revised standards do not require PM controls at these systems.

° The LWAK and coal boiler chlorine standards under the Agency Preferred Approach are now more cost effective than the corresponding standards presented in the 2004 Assessment. This change reflects the elimination of beyond the floor chlorine standards for these sources.

° Across all source categories, cost effectiveness estimates associated with SVM and LVM have changed relative to the estimates reported in the 2004 Assessment. These changes are consistent with the revised PM standards FINAL DRAFT: March 2004 39 since emissions of SVM and LVM are influenced by controls on PM.

° Per unit health improvement, the revised proposal for the HWC MACT PM replacement standards is more cost effective than the previous proposal. Under the Agency Preferred Approach, the cost effectiveness of the revised PM standards is approximately $ 47.9 million per life saved and $ 2,617 per avoided morbidity case, both of which represent an 18 percent improvement compared to the corresponding estimates of $ 58.4 million per life saved and $ 3,187 per avoided illness presented in the 2004 Assessment. These revised estimates reveal that the revised PM standards are more cost effective than the previous standards because estimated reductions in premature death and morbidity have changed little from estimates presented in the 2004 Assessment, while estimated engineering costs have fallen.

Exhibit 11 COST EFFECTIVENESS RESULTSa Pollutant Source Options TEQ, $ 1,000/ gram Hg, $ 1,000/ ton SVM, $ 1,000/ ton LVM, $ 1,000/ ton PM, $ 1,000/ ton TCl, $ 1,000/ ton LWAKs Baseline to Floor Option 1  $ 120,054 $ 1,861 $ 6,283

Baseline to Agency Preferred Approach ***$ 91 5 $ 120,054 $ 1,861 $ 6,283  $ 6.82 Option 1 Floor to Agency Preferred Approach $ 915** *     $ 6.82 Baseline to Floor Option 2  $ 119,961 $ 1,794 $ 5,172

Baseline to Option 2 BTF D $ 724 $ 119,961 $ 1,794 $ 5,172  $ 6.59 Option 2 Floor to Option 2 BTF D $ 724     $ 6.59 Baseline to Floor Option 3  $ 119,960 $ 2,985 $ 8,127

Baseline to Option 3 BTF D $ 767 $ 119,960 $ 2,985 $ 8,127  $ 5.45 Option 3 Floor to Option 3 BTF D $ 767     $ 5.45 Incinerator s Baseline to Floor Option 1 $ 2,627  $ 2,965 $ 3,607  $ 44.34 Baseline to Agency Preferred Approach $ 2,627  $ 2,965 $ 3,607  $ 44.34 Option 1 Floor to Agency Preferred Approach       FINAL DRAFT: March 2004 Exhibit 11 COST EFFECTIVENESS RESULTSa Pollutant Source Options TEQ, $ 1,000/ gram Hg, $ 1,000/ ton SVM, $ 1,000/ ton LVM, $ 1,000/ ton PM, $ 1,000/ ton TCl, $ 1,000/ ton 40 Baseline to Floor Option 2 $ 2,627  $ 4,402 $ 7,724  $ 39.38 Baseline to Option 2 BTF D $ 2,627  $ 4,402 $ 7,724  $ 39.38 Option 2 Floor to Option 2 BTF D

Baseline to Floor Option 3 $ 2,627  $ 4,339 $ 6,806  $ 38.74 Baseline to Option 3 BTF D $ 2,627  $ 4,339 $ 6,806  $ 38.74 Option 3 Floor to Option 3 BTF D

Cement Kilns Baseline to Floor Option 1  $ 16,567 $ 405 $ 10,458 $ 13.17 $ 8.62 Baseline to Agency Preferred Approach  $ 16,567 $ 405 $ 10,458 $ 13.17 $ 8.62 Option 1 Floor to Agency Preferred Approach

Baseline to Floor Option 2  $ 22,501 $ 1,319 $ 20,535 $ 13.95 $ 13.14 Baseline to Option 2 BTF D  $ 22,501 $ 1,319 $ 20,535 $ 13.95 $ 13.14 Option 2 Floor to Option 2 BTF D

Baseline to Floor Option 3  $ 22,501 $ 1,489 $ 13,189 $ 7.85 $ 13.14 Baseline to Option 3 BTF D  $ 22,501 $ 1,489 $ 13,189 $ 7.85 $ 13.14 Option 3 Floor to Option 3 BTF D

Liquid Boilers Baseline to Floor Option 1 $ 373 $ 13,072 $ 4,172 $ 733 $ 9.67 $ 6.40 Baseline to Agency Preferred Approach $ 662 $ 13,072 $ 4,172 $ 733 $ 9.67 $ 6.40 Option 1 Floor to Agency Preferred Approach $ 1,313

Baseline to Floor Option 2 $ 373 $ 14,191 $ 4,161 $ 738 $ 9.39 $ 13.52 Baseline to Option 2 BTF D $ 662 $ 14,191 $ 4,161 $ 738 $ 9.39 $ 13.52 Option 2 Floor to Option 2 BTF D $ 1,916

Baseline to Floor Option 3 $ 373 $ 17,209 $ 1,215 $ 262 $ 9.60 $ 6.51 FINAL DRAFT: March 2004 Exhibit 11 COST EFFECTIVENESS RESULTSa Pollutant Source Options TEQ, $ 1,000/ gram Hg, $ 1,000/ ton SVM, $ 1,000/ ton LVM, $ 1,000/ ton PM, $ 1,000/ ton TCl, $ 1,000/ ton 41 Baseline to Option 3 BTF D $ 662 $ 17,209 $ 1,215 $ 262 $ 9.60 $ 6.51 Option 3 Floor to Option 3 BTF D $ 1,313

Coal Boilers Baseline to Floor Option 1  $ 23,274 $ 687 $ 343 $ 4.68 $ 1.16 Baseline to Agency Preferred Approach *** $ 23,274 $ 687b $ 343b $ 3.32 $ 1.16c Option 1 Floor to Agency Preferred Approach ***    $ 3.97  c Baseline to Floor Option 2  $ 23,274 $ 687 $ 343 $ 4.68 $ 1.16 Baseline to Option 2 BTF D  $ 23,274 $ 687b $ 343b $ 3.76 $ 1.16 Option 2 Floor to Option 2 BTF D     $ 3.69

Baseline to Floor Option 3  $ 23,274 $ 683 $ 339 $ 4.43 $ 1.16 Baseline to Option 3 BTF D  $ 23,274 $ 683b $ 339b $ 3.21 $ 1.16 Option 3 Floor to Option 3 BTF D     $ 3.82

HCl Production Furnaces Baseline to Floor Option 1      $ 4.99 Baseline to Agency Preferred Approach $ 823     $ 4.99 Option 1 Floor to Agency Preferred Approach $ 823

Baseline to Floor Option 2      $ 7.32 Baseline to Option 2 BTF D $ 698     $ 7.32 Option 2 Floor to Option 2 BTF D $ 698

Baseline to Floor Option 3      $ 7.21 Baseline to Option 3 BTF D $ 987     $ 7.21 Option 3 Floor to Option 3 BTF D $ 987      FINAL DRAFT: March 2004 Exhibit 11 COST EFFECTIVENESS RESULTSa Pollutant Source Options TEQ, $ 1,000/ gram Hg, $ 1,000/ ton SVM, $ 1,000/ ton LVM, $ 1,000/ ton PM, $ 1,000/ ton TCl, $ 1,000/ ton 42 Notes: a. This table includes pollutants where more than one option was under consideration. b. Despite higher SVM and LVM emission reductions under the beyond the floor option, cost effectiveness for coal boiler SVM and LVM under the beyond the floor option are equal to cost effectiveness estimates under the corresponding Floor. Since the incremental reductions under the beyond the floor option are due to tighter PM restrictions, we do not incorporate them into our estimate of the cost effectiveness of beyond the floor SVM and LVM standards. c. The chlorine standards under the Agency Preferred Approach evaluated in the 2004 Assessment included a beyond thefloor standard for coal boilers. The cost effectiveness of this beyond the floor standard, incremental to the floor standard, was $ 473,000 per ton. Incremental to the baseline, the cost effectiveness of the standard was $ 349,000 per ton. FINAL DRAFT: March 2004 43 Exhibit 12 COST EFFECTIVENESS PER UNIT HEALTH IMPROVEMENTa, b, c, d ( using unadjusted, maximum cost of control, 2002$)

Benefit Type Pollutant( s) Option 1 Floor Agency Preferred Approach Option 2 Floor Option 2 BTF D Option 3 Floor Option 3 BTF D Health Benefits Avoided Premature Mortality Cases e PM $ 42.6 million per life saved $ 47.9 million per life saved $ 41.5 million per life saved $ 46.9 million per life saved $ 38.0 million per life saved $ 40.6 million per life saved Avoided Premature Mortality Cases Dioxins/ Furans $ 159.5 million per life saved $ 85.9 million per life saved $ 159.5 million per life saved $ 81.0 million per life saved $ 159.5 million per life saved $ 92.4 million per life saved Avoided Morbidity ( PM) f PM $ 2,361 per case $ 2,617 per case $ 2,303 per case $ 2,560 per case $ 2,273 per case $ 2,412 per case Avoided Morbidity ( lead) g SVM Unknown Unknown Unknown Unknown Unknown Unknown Ecological Benefits Reduction in area of Land and Water Impacted dioxin, mercury, lead Unknown Unknown Unknown Unknown Unknown Unknown Notes: a Engineering costs. b Dollar per unit benefit. c These cost effectiveness per unit benefit measures are upper bound estimates that apply the full costs of control ( by pollutant) to a single type of benefit ( e. g., lives saved). The cost per unit benefit measures should not be reported in isolation from other benefit estimates; they should only be used as relative measures to compare across MACT standards. d All figures are incremental from the baseline to the HWC MACT standards. e Mortality cases comprise fatal cancers and fatalities from exposure to particulate matter. f PM morbidity cases comprise hospital admissions from respiratory diseases, cases of chronic bronchitis and asthma, work loss days, and mild restricted activity days. g SO 2 morbidity cases comprise reduced incidence of chronic bronchitis, acute bronchitis, non fatal myocardial infarctions, hospital admissions ( respiratory and cardiological), emergency room visits, respiratory symptoms, g Morbidity cases associated with exposure to lead are cases in which children have blood lead levels above 10

g/ dL. FINAL DRAFT: March 2004 44 Appendix A Hazardous Waste Combustion MACT Replacement Standards: Proposed Rule FINAL DRAFT: March 2004 26 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.

45 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 that may occur under *** one option*** considered for the Hazardous Waste Combustion ( HWC) MACT replacement standards. This option would require coal fired ( i. e., solid fuel) hazardous waste burning boilers and LWAKs to meet a beyond the floor standard for chlorine. Under this option, facilities with coal fired hazardous waste burning boilers would need to install flue gas desulfurization ( i. e., " dry scrubber") technology26 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. 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 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). FINAL DRAFT: March 2004 46 Our engineers have determined that the installation of dry scrubbers for required control of HCl ( beyond the floor standard) 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 Beyond the Floor Standard for TCl  Solid Fuel Boilers Facility Sulfur Content of Coal Baseline SO2 Emissions SO2 Emission Reductions SO2 Emissions Under TCl BTF Option 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 FINAL DRAFT: March 2004 27 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 Q u a l i t y Ru l e , a c c e s s e d Fe b r u a r y 17 , 2 0 0 4 , a t < http:// www. epa. gov/ interstateairquality/ tsd0175. pdf>. In addition, we examined an unpublished draft report by Carrothers et al. ( 2002), which estimates national 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.

47 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). 27 As detailed in these documents and other literature, a significant percentage of the benefits associated with the control of SO 2 results from avoided health effects associated with the development of fine particulate matter ( PM) formed by SO 2 in the atmosphere. The Clear Skies Initiative and the IAQR both examine benefits associated with reduction in PM resulting from both SO 2 and nitrogen ( NOx) releases.

Our preliminary benefit estimate assumes a linear relationship between quantity of sulfur dioxide controlled and monetary benefits. In addition, we assume:

The facilities in the HWC MACT universe are similar to the national average addressed in the Clear Skies and IAQR analyses in terms of affected populations and avoided health impacts.

The relationship between benefits and quantity of SO 2 emissions reduced is linear even at relatively small quantities ( i. e., 22,000 tons).

Where benefits related to particulate matter associated with SO 2 emissions reductions and NOx reductions are not reported separately, the relationship between benefits is proportional to the quantity of pollutants ( i. e., if SO 2 emissions represent 50 percent of the per weight pollutant reductions, then they FINAL DRAFT: March 2004 28 Note that this is a conservative assumption because in general, SO 2 is a more efficient precursor of particulate matter than nitrous oxides. 29 These estimates reflect the average of a range of discount rates and scenarios. Low end estimates reflect IAQR study near term benefits using a seven percent discount rate; High end estimates reflect Clear Skies study longer term benefits using a three percent discount rate. The estimates also exclude ozone related benefits; IAQR study estimated total benefits ( including ozone related benefits) at $ 54 to $ 84 billion; the Clear Skies study estimated total benefits ( including ozone related benefits) at $ 52 to $ 113 billion. 30 The Clear Skies and IAQR total predictions ( SO 2 plus NO x) of approximately 5.0 million tons/ yr emissions reductions ( 3.5/ 5.0 = 70 percent).

48 represent 50 percent of the benefits). 28 The Clear Skies and IAQR analyses each predicted a total reduction in SO 2 emissions of roughly 3.5 million tons and NOx reductions of 1.5 million tons. The total benefits associated with particulate matter reductions were estimated at $ 51.5 to $ 109.3 billion ( 1999 dollars) in the Clear Skies analysis and $ 54.5 to $ 83.6 billion ( 1999 dollars) in the IAQR analysis. 29 Assuming that SO 2 emissions reductions represent roughly 70 percent30 of total particulate matter benefits, we estimate that a reduction of 22,000 tons of SO 2 emissions under the HWC MACT standards would incur total monetized benefits ranging from $ 212 million to $ 350 million per year. This result reflects a " dollar per ton" range of $ 9,700 to $ 15,900 for benefits per ton of SO 2 removed. If only mortality is included, annual monetized benefits would range from $ 193 million to $ 320 million, reflecting a " dollar per ton" range of approximately $ 8,800 to 14,600 for benefits per ton of SO 2 removed.

Exhibit 2 provides a more detailed summary of the range of potential benefits based on both studies. FINAL DRAFT: March 2004 49 Exhibit 2 SUMMARY OF BENEFITS ASSOCIATED WITH SO2 EMISSION REDUCTIONS Benefit Category IAQR Analysis ( million 1999$) Clear Skies Analysis ( million 1999$)

Total Mortality 50,000  72,000 47,000  100,000 Total Infant Mortality Benefits 130  180   Total Other Benefits 4,902  5,019 4,518  9,184 Total Benefits 54,532  83,599 51,518  109,284 Total SO2 Benefits 39,911  57,812a 34,478  73,255b Total Benefits of HWC MACT SO2 Reductions: BTF Option ( based on 22,000 tons/ yr) c Total Benefits ( millions) $ 247.4  $ 332.9 $ 212.4  $ 350.0 Average of Total Benefits ( millions) $ 281.7 $ 281.9 Total Benefits, per Ton ( dollars) $ 10,642  $ 15,133 $ 9,655  $ 15,908 Average of Total Benefits, per Ton ( dollars) $ 12,808 $ 12,814 Mortality Benefits Only ( millions) $ 215.2  $ 307.4 $ 193.8  $ 320.3 Average of Mortality Benefits Only ( millions) $ 259.5 $ 257.7 Mortality Benefits Only, per Ton ( dollars) $ 9,783  $ 13,971 $ 8,808  $ 14,557 Average of Mortality Benefits Only, per Ton ( dollars) $ 11,797 $ 11,714 Notes: a Based on 3.7  3.8 million tons SO2 avoided, adjusted to exclude 28 31% NOx contribution. b Based on 3.6  4.6 million tons SO2 avoided, adjusted to exclude 33% NOx contribution. c These ranges reflect the use of different discount rates, time frames, and assumptions about non mortality benefits. Low end estimates reflect near term mortality benefits only, using a seven percent discount rate; highend estimates reflect longer term total benefits using a three percent discount rate. FINAL DRAFT: March 2004 50 FINAL DRAFT: March 2004 31 Note that this assumption is very conservative and is designed solely to develop a lower bound estimate. Because boilers are designed to provide power for other facility processes, it would be unusual for them to operate at levels as low as 50 percent. In addition, trial burn data ( collected as part of the RCRA permitting process) were used to identify total coal requirements for boilers. Trial burns are typically designed to reflect maximum hazardous waste combustion. Because SO 2 is associated with the supplemental fuel coal ( and not with hazardous waste), it is possible that trial burn data may understate baseline SO 2 emissions if normal operations involve less hazardous waste and more coal.

51 Lower Bound Estimate of Benefits In addition to the estimates based on a simple extrapolation of Clear Skies and IAQR analyses, we have developed a conservative lower bound estimate of potential benefits ( mortality only) associated with SO 2 emissions reductions resulting from the BTF TCl level for solid fuel boilers. This estimate includes only emissions reductions from the Tennessee Eastman facility and makes the following conservative assumptions:

The facility uses only coal with a low sulfur content of one percent ( initial estimate is based on sulfur content of 2.5 percent);

The facility operates boilers at 50 percent of the intensity reflected in the trial burn data ( initial estimate assumes that boilers operate as continuous process equipment at 90 percent of annual trial burn capacity); and 31

The low end benefit estimate of $ 8,808 per ton of SO 2 eliminated accurately reflects regional benefits in northeastern Tennessee.

The resulting reductions in SO 2 emissions from the facility are therefore 3,100 tons per year rather than 15,680 tons per year. Under these lower bound assumptions, we estimate annual benefits of roughly $ 27 million associated with SO 2 emission reductions. This reflects only the Eastman Tennessee facility and does not consider any benefits associated with the remaining three facilities with coal fired hazardous waste boilers. FINAL DRAFT: March 2004 52 Key Limitations:

This assessment incorporates various key assumptions and limitations. These include:

the affected populations for each of the facilities of concern are assumed to be generally consistent with populations affected by facilities examined in the Clear Skies and IAQR analyses,

* ** The specific technology required to meet the TCl BTF standard is simple direct duct injection dry scrubbing. This technology is also expected to result in the SO 2 emission reductions. [ Note: The EPA Floor option regulatory scenarios would not require dry scrubbers and would therefore incur no potential benefits associated with SO 2 reductions.***

the boiler operation and stack heights of the facilities of concern are generally representative of the boilers and stack heights at the facilities examined in the Clear Skies and IAQR analyses,

the linear extrapolation of national level SO 2 reduction benefits is reasonable for quantities of roughly 20,000 tons; and

baseline emissions estimates used in this analysis reflect current emissions for each of the facilities of concern. FINAL DRAFT: March 2004 32 See note above.

53 Appendix B DETAILED COST MODEL RESULTS NOTE: After the cost model was run to generate the results presented in this Appendix, EPA eliminated beyond the floor chlorine standards for LWAKs and solid fuel boilers. The results presented in this Appendix do not reflect this change.

This appendix contains model results for the twelve versions of the HWC MACT replacement standards analyzed in the Addendum to the Assessment of the Potential Costs, Benefits, & Other Impacts of the Hazardous Waste Combustion MACT Replacement Standards: Proposed Rule. Results associated with Option 1 BTF D represent the costs and other impacts of the Agency Preferred Approach. 32 The results for all options reflect potential price increases for hazardous waste incineration services in response to the HWC MACT replacement standards, as well as the most recent estimates of waste quantities, government costs, and monitoring/ performance testing costs. The results presented in this appendix assume that commercial kilns and incinerators charge the same premium for treating halogenated waste and that commercial facilities pass 100 percent of their compliance costs on to their customers. The total cost estimates presented in this appendix do not include government costs, which are presented separately for each regulatory option. FINAL DRAFT: March 2004 54 SDL Option 1 Floor, w/

Cl Controls SDL Option 1 Floor,

w/ o Cl Controls SDL Option 1 BTF D,

w/ Cl Controls SDL Option 1 BTF D,

w/ o Cl Controls $ 10,632,036.21 $ 7,044,493.23 $ 11,388,208.31 $ 7,408,633.54 $ 2,688,983.11 $ 721,165.72 $ 5,387,442.55 $ 2,023,205.48 $ 93,980.33 $ 88,125.70 $ 3,329,093.48 $ 1,740,084.93 $ 9,141,869.51 $ 978,411.78 $ 9,143,982.97 $ 978,679.18 Phase 1 Subtotal $ 4,273,130.15 $ 6,699,121.48 $ 4,302,574.41 $ 6,713,074.92 $ 10,562,921.73 $ 7,412,957.36 $ 14,187,412.95 $ 9,161,964.85 $ 36,710,295.36 $ 32,586,162.22 $ 36,846,275.87 $ 32,660,129.66 $ 1,511,207.10 $ 1,023,168.32 $ 5,023,990.34 $ 2,221,088.88 $ 1,470,615.58 $ 1,470,615.58 $ 3,359,766.69 $ 3,359,766.69 Phase 2 Subtotal $ 39,692,118.04 $ 35,079,946.13 $ 45,230,032.90 $ 38,240,985.24 $ 45,981,909.62 $ 35,793,782.01 $ 55,114,871.43 $ 40,689,875.16 Onsite Incinerators Liquid Boilers Commercial Incinerators Cement Kilns LWAKs Pre existing customers of commercial combustion facilities Net Private Costs, by Unit Type: SDL Option 1 Coal Boilers HCl Production Furnaces Total OPTION 1 FINAL DRAFT: March 2004 55 SDL Option 1 Floor, w/

Cl Controls SDL Option 1 Floor,

w/ o Cl Controls SDL Option 1 BTF D,

w/ Cl Controls SDL Option 1 BTF D,

w/ o Cl Controls $ 3,165,323.58 $ 1,034,979.26 $ 3,165,323.58 $ 1,034,979.26 $ 6,489,684.46 $ 5,940,214.96 $ 6,489,421.16 $ 5,939,951.66 $ 541,887.94 $ 541,887.94 $ 4,166,642.46 $ 2,291,158.72 $ 9,038,854.68 $ 968,809.83 $ 9,038,854.68 $ 968,809.83 Phase 1 Subtotal $ 19,235,750.66 $ 8,485,891.98 $ 22,860,241.88 $ 10,234,899.47 $ 34,600,145.55 $ 30,819,781.39 $ 34,732,671.87 $ 30,892,336.96 $ 1,381,306.23 $ 893,522.89 $ 4,893,793.90 $ 2,091,300.82 $ 1,470,615.58 $ 1,470,615.58 $ 3,359,766.69 $ 3,359,766.69 Phase 2 Subtotal $ 37,452,067.37 $ 33,183,919.87 $ 42,986,232.46 $ 36,343,404.48 $ 56,687,818.03 $ 41,669,811.85 $ 65,846,474.34 $ 46,578,303.95 Onsite Incinerators Liquid Boilers Commercial Incinerators Cement Kilns HCl Production Furnaces Total Coal Boilers Upgrade Expenditures, by Unit Type: SDL Option 1 LWAKs FINAL DRAFT: March 2004 56 SDL Option 1 Floor, w/

Cl Controls SDL Option 1 Floor,

w/ o Cl Controls SDL Option 1 BTF D,

w/ Cl Controls SDL Option 1 BTF D,

w/ o Cl Controls $ 3,653,499.14 $ 1,034,979.26 $ 3,653,499.14 $ 1,034,979.26 $ 6,489,684.46 $ 5,940,214.96 $ 6,489,421.16 $ 5,939,951.66 $ 541,887.94 $ 541,887.94 $ 4,166,642.46 $ 2,291,158.72 $ 12,807,392.58 $ 1,517,236.48 $ 12,807,392.58 $ 1,517,236.48 Phase 1 Subtotal $ 23,492,464.12 $ 9,034,318.63 $ 27,116,955.34 $ 10,783,326.12 $ 44,736,319.42 $ 40,304,055.83 $ 44,890,789.55 $ 40,376,611.41 $ 1,834,543.61 $ 1,346,760.27 $ 6,864,742.06 $ 2,641,019.14 $ 1,470,615.58 $ 1,470,615.58 $ 3,359,766.69 $ 3,359,766.69 Phase 2 Subtotal $ 48,041,478.61 $ 43,121,431.68 $ 55,115,298.30 $ 46,377,397.24 $ 71,533,942.73 $ 52,155,750.31 $ 82,232,253.65 $ 57,160,723.36 Liquid Boilers Coal Boilers Onsite Incinerators HCl Production Furnaces Commercial Incinerators Cement Kilns Private Engineering Costs: SDL Option 1 Total LWAKs SDL Option 1 Floor,

w/ Cl Controls SDL Option 1 Floor,

w/ o Cl Controls SDL Option 1 BTF D,

w/ Cl Controls SDL Option 1 BTF D,

w/ o Cl Controls Baseline Total Commercial Incinerators 2 0 2 0 15 Cement Kilns 0 0 0 0 26 LWAKs 0 0 0 0 7 Onsite Incinerators 32 29 32 29 92 Liquid Boilers 22 20 22 20 107 Coal Boilers 2 2 2 2 12 HCl Production Furnaces 0 0 0 0 17 Total 58 51 58 51 276 Number of Closed Systems, by Unit Type: Option 1 FINAL DRAFT: March 2004 57 SDL Option 1 Floor,

w/ Cl Controls SDL Option 1 Floor,

w/ o Cl Controls SDL Option 1 BTF D,

w/ Cl Controls SDL Option 1 BTF D,

w/ o Cl Controls To Commercial Incinerators 44,548 23,085 44,548 23,085 To Cement Kilns or LWAKs 9,041 7,698 9,041 7,698 Non commercial Consolidation 67,266 56,732 67,266 56,732 Total 120,855 87,515 120,855 87,515 Quantity of Waste Sent Offsite or Rerouted ( tons): Option 1 Annual Cost SDL Option 1 Floor, w/ Cl controls $ 447,479.75 SDL Option 1 Floor, w/ o Cl controls $ 455,470.46 SDL Option 1 BTF D, w/ Cl controls $ 447,479.75 SDL Option 1 BTF D, w/ o Cl controls $ 455,470.46 Government Costs: Option 1 SDL Option 1 Floor, w/ Cl controls SDL Option 1 Floor, w/ o Cl controls SDL Option 1 BTF D, w/ Cl controls SDL Option 1 BTF D, w/ o Cl controls Commercial Incinerators 188,193.00 504,875.53 Pre MACT Capacity ( tons) 495,834.52 165,107.76 116,547.89 165,107.76 497,177.63 Available Capacity at Commercial Facilities: Option 1 Cement Kilns/ LWAKs Post MACT ( tons) 116,547.89 497,177.63 495,834.52 FINAL DRAFT: March 2004 58 Lost Gained Lost Gained Lost Gained Lost Gained Commercial Incinerators 47.8 13.6 0.0 5.3 47.8 13.6 0.0 5.3 Cement Kilns 0.0 32.9 0.0 30.1 0.0 32.9 0.0 30.1 LWAKs 0.0 3.5 0.0 3.5 0.0 29.1 0.0 14.8 Onsite Incinerators 237.2 39.4 215.4 5.2 237.2 39.4 215.4 5.2 Liquid Boilers 92.0 208.7 82.9 191.1 92.0 208.7 82.9 191.3 Coal Boilers 9.5 10.7 9.5 7.0 9.5 32.7 9.5 11.2 HCl Production Furnaces 0.0 11.7 0.0 11.7 0.0 23.8 0.0 23.8 APCD Industry  162.3  110.7  178.8  125.0 Total 386.5 482.8 307.8 364.7 386.5 559.0 307.8 406.8 Number of Jobs Lost and Gained, by Unit Type: Option 1 SDL Option 1 BTF D, w/

Cl controls SDL Option 1 BTF D,

w/ o Cl controls SDL Option 1 Floor, w/

Cl controls SDL Option 1 Floor, w/ o Cl controls Baseline Prices SDL Option 1 Floor,

w/ Cl Controls SDL Option 1 Floor,

w/ o Cl Controls SDL Option 1 BTF D,

w/ Cl Controls SDL Option 1 BTFD w/ o Cl Controls $ 1,080.54 $ 1,090.25 $ 1,087.36 $ 1,093.60 $ 1,088.97 $ 127.05 $ 128.19 $ 127.85 $ 128.59 $ 128.04 $ 560.14 $ 565.17 $ 563.68 $ 566.91 $ 564.51 $ 557.14 $ 562.15 $ 560.66 $ 563.87 $ 561.49 $ 2,820.00 $ 2,845.34 $ 2,837.80 $ 2,854.07 $ 2,842.01 $ 940.00 $ 948.45 $ 945.93 $ 951.36 $ 947.34 $ 1,080.54 $ 1,090.25 $ 1,087.36 $ 1,093.60 $ 1,088.97 $ 127.05 $ 128.19 $ 127.85 $ 128.59 $ 128.04 $ 1,010.14 $ 1,019.22 $ 1,016.52 $ 1,022.34 $ 1,018.02 $ 560.14 $ 565.17 $ 563.68 $ 566.91 $ 564.51 $ 1,067.14 $ 1,076.73 $ 1,073.88 $ 1,080.03 $ 1,075.47 $ 557.14 $ 562.15 $ 560.66 $ 563.87 $ 561.49 Combustion Prices ($ per ton): SDL Option 1 Waste Form Organic Liquids ( NonHal)

Inorganic Liquid ( Nonhalogenated)

Inorganic Liquid ( Halogenated)

Organic Liquids ( Halogenated)

Gases Inorganic Sludge ( Nonhalogenated)

Inorganic Solids ( NonHal)

Lab Packs Organic Sludges ( Halogenated)

Organic Sludges ( NonHal)

Organic Solids ( Halogenated)

Organic Solids ( NonHal) FINAL DRAFT: March 2004 59 SDL Option 2 Floor, w/

Cl Controls SDL Option 2 Floor,

w/ o Cl Controls SDL Option 2 BTF D,

w/ Cl Controls SDL Option 2 BTF D,

w/ o Cl Controls $ 14,853,559.44 $ 9,091,171.81 $ 15,549,719.33 $ 9,391,107.51 $ 30,109.86 $ 1,349,763.14 $ 2,449,616.16 $ 154,312.84 $ 1,102,743.58 $ 362,052.10 $ 2,036,645.82 $ 1,007,040.17 $ 11,734,629.27 $ 3,394,237.55 $ 11,739,156.66 $ 3,395,574.68 Phase 1 Subtotal $ 4,191,563.89 $ 4,709,223.22 $ 4,223,533.01 $ 4,834,179.83 $ 33,249,151.48 $ 20,442,700.24 $ 36,573,582.53 $ 21,877,957.21 $ 47,162,524.41 $ 33,242,337.01 $ 47,353,184.07 $ 33,415,151.29 $ 1,513,054.10 $ 1,024,229.18 $ 5,025,812.88 $ 2,222,124.15 $ 1,842,814.77 $ 1,842,814.77 $ 3,444,134.59 $ 3,444,134.59 Phase 2 Subtotal $ 50,518,393.28 $ 36,109,380.95 $ 55,823,131.53 $ 39,081,410.03 $ 79,575,980.86 $ 51,842,857.97 $ 88,173,181.05 $ 56,125,187.40 Onsite Incinerators Liquid Boilers Commercial Incinerators Cement Kilns LWAKs Pre existing customers of commercial combustion facilities Net Private Costs, by Unit Type: SDL Option 2 Coal Boilers HCl Production Furnaces Total OPTION 2 FINAL DRAFT: March 2004 60 SDL Option 2 Floor, w/

Cl Controls SDL Option 2 Floor,

w/ o Cl Controls SDL Option 2 BTF D,

w/ Cl Controls SDL Option 2 BTF D,

w/ o Cl Controls $ 4,165,271.17 $ 2,037,899.93 $ 4,165,271.17 $ 2,037,899.93 $ 27,965,218.06 $ 17,693,435.65 $ 27,965,218.06 $ 17,693,435.65 $ 815,489.45 $ 815,489.45 $ 4,139,920.51 $ 2,264,436.78 $ 11,533,002.81 $ 3,307,188.20 $ 11,533,002.81 $ 3,307,188.20 Phase 1 Subtotal $ 44,478,981.49 $ 23,854,013.23 $ 47,803,412.54 $ 25,302,960.55 $ 42,064,030.21 $ 31,465,455.05 $ 42,246,559.19 $ 31,395,773.63 $ 1,381,306.23 $ 893,522.89 $ 4,893,793.90 $ 2,091,300.82 $ 1,842,814.77 $ 1,842,814.77 $ 3,444,134.59 $ 3,444,134.59 Phase 2 Subtotal $ 45,288,151.21 $ 34,201,792.71 $ 50,584,487.67 $ 36,931,209.04 $ 89,767,132.70 $ 58,055,805.94 $ 98,387,900.22 $ 62,234,169.59 Onsite Incinerators Liquid Boilers Commercial Incinerators Cement Kilns HCl Production Furnaces Total Coal Boilers Upgrade Expenditures, by Unit Type: SDL Option 2 LWAKs FINAL DRAFT: March 2004 61 SDL Option 2 Floor, w/

Cl Controls SDL Option 2 Floor,

w/ o Cl Controls SDL Option 2 BTF D,

w/ Cl Controls SDL Option 2 BTF D,

w/ o Cl Controls $ 4,698,190.92 $ 2,037,899.93 $ 4,698,190.92 $ 2,037,899.93 $ 27,965,218.06 $ 17,693,435.65 $ 27,965,218.06 $ 17,693,435.65 $ 815,489.45 $ 815,489.45 $ 4,139,920.51 $ 2,264,436.78 $ 16,550,359.22 $ 4,792,531.87 $ 16,550,359.22 $ 4,792,531.87 Phase 1 Subtotal $ 50,029,257.65 $ 25,339,356.91 $ 53,353,688.71 $ 26,788,304.23 $ 60,449,413.61 $ 41,095,380.54 $ 60,711,650.14 $ 41,278,175.21 $ 1,834,543.61 $ 1,346,760.27 $ 6,864,742.06 $ 2,641,019.14 $ 1,842,814.77 $ 1,842,814.77 $ 3,444,134.59 $ 3,444,134.59 Phase 2 Subtotal $ 64,126,771.98 $ 44,284,955.58 $ 71,020,526.79 $ 47,363,328.93 $ 114,156,029.64 $ 69,624,312.48 $ 124,374,215.50 $ 74,151,633.16 Liquid Boilers Coal Boilers Onsite Incinerators HCl Production Furnaces Commercial Incinerators Cement Kilns Private Engineering Costs: SDL Option 2 Total LWAKs SDL Option 2 Floor,

w/ Cl Controls SDL Option 2 Floor,

w/ o Cl Controls SDL Option 2 BTF D,

w/ Cl Controls SDL Option 2 BTF D,

w/ o Cl Controls Baseline Total Commercial Incinerators 2 0 2 0 15 Cement Kilns 0 0 0 0 26 LWAKs 0 0 0 0 7 Onsite Incinerators 33 30 33 30 92 Liquid Boilers 29 20 29 21 107 Coal Boilers 2 2 2 2 12 HCl Production Furnaces 0 0 0 0 17 Total 66 52 66 53 276 Number of Closed Systems, by Unit Type: Option 2 FINAL DRAFT: March 2004 62 SDL Option 2 Floor,

w/ Cl Controls SDL Option 2 Floor,

w/ o Cl Controls SDL Option 2 BTF D,

w/ Cl Controls SDL Option 2 BTF D,

w/ o Cl Controls To Commercial Incinerators 48,230 26,766 48,230 26,766 To Cement Kilns or LWAKs 16,087 7,698 16,087 8,564 Non commercial Consolidation 67,266 56,732 67,266 56,732 Total 131,582 91,196 131,582 92,062 Quantity of Waste Sent Offsite or Rerouted ( tons): Option 2 SDL Option 2 Floor, w/ Cl controls SDL Option 2 Floor, w/ o Cl controls SDL Option 2 BTF D, w/ Cl controls SDL Option 2 BTF D, w/ o Cl controls Commercial Incinerators 188,193.00 504,875.53 Pre MACT Capacity ( tons) 488,788.88 161,426.70 112,866.84 161,426.70 497,177.63 Available Capacity at Commercial Facilities: Option 2 Cement Kilns/ LWAKs Post MACT ( tons) 112,866.84 496,311.83 488,788.88 Annual Cost SDL Option 2 Floor, w/ Cl controls $ 419,512.27 SDL Option 2 Floor, w/ o Cl controls $ 455,470.46 SDL Option 2 BTF D, w/ Cl controls $ 419,512.27 SDL Option 2 BTF D, w/ o Cl controls $ 451,475.11 Government Costs: Option 2 FINAL DRAFT: March 2004 63 Lost Gained Lost Gained Lost Gained Lost Gained Commercial Incinerators 47.8 18.4 0.0 10.6 47.8 18.4 0.0 10.6 Cement Kilns 0.0 145.8 0.0 96.9 0.0 145.8 0.0 96.9 LWAKs 0.0 5.4 0.0 5.4 0.0 29.0 0.0 14.7 Onsite Incinerators 245.2 51.0 223.4 15.7 245.2 51.0 223.4 15.7 Liquid Boilers 119.3 241.5 82.9 195.5 119.3 241.5 86.3 194.3 Coal Boilers 9.5 10.7 9.5 7.0 9.5 32.7 9.5 11.2 HCl Production Furnaces 0.0 13.8 0.0 13.8 0.0 24.1 0.0 24.1 APCD Industry  283.7  157.6  299.0  170.4 Total 421.8 770.3 315.8 502.5 421.8 841.5 319.2 537.9 Number of Jobs Lost and Gained, by Unit Type: Option 2 SDL Option 2 BTF D, w/

Cl controls SDL Option 2 BTF D,

w/ o Cl controls SDL Option 2 Floor, w/

Cl controls SDL Option 2 Floor, w/ o Cl controls Baseline Prices SDL Option 2 Floor,

w/ Cl Controls SDL Option 2 Floor,

w/ o Cl Controls SDL Option 2 BTF D,

w/ Cl Controls SDL Option 2 BTFD w/ o Cl Controls $ 1,080.54 $ 1,111.15 $ 1,099.36 $ 1,114.22 $ 1,100.69 $ 127.05 $ 130.65 $ 129.26 $ 131.01 $ 129.42 $ 560.14 $ 576.01 $ 569.90 $ 577.60 $ 570.59 $ 557.14 $ 572.92 $ 566.85 $ 574.51 $ 567.53 $ 2,820.00 $ 2,899.89 $ 2,869.13 $ 2,907.89 $ 2,872.58 $ 940.00 $ 966.63 $ 956.38 $ 969.30 $ 957.53 $ 1,080.54 $ 1,111.15 $ 1,099.36 $ 1,114.22 $ 1,100.69 $ 127.05 $ 130.65 $ 129.26 $ 131.01 $ 129.42 $ 1,010.14 $ 1,038.76 $ 1,027.74 $ 1,041.62 $ 1,028.98 $ 560.14 $ 576.01 $ 569.90 $ 577.60 $ 570.59 $ 1,067.14 $ 1,097.37 $ 1,085.73 $ 1,100.40 $ 1,087.04 $ 557.14 $ 572.92 $ 566.85 $ 574.51 $ 567.53 Combustion Prices ($ per ton): SDL Option 2 Waste Form Organic Liquids ( NonHal)

Inorganic Liquid ( Nonhalogenated)

Inorganic Liquid ( Halogenated)

Organic Liquids ( Halogenated)

Gases Inorganic Sludge ( Nonhalogenated)

Inorganic Solids ( NonHal)

Lab Packs Organic Sludges ( Halogenated)

Organic Sludges ( NonHal)

Organic Solids ( Halogenated)

Organic Solids ( NonHal) FINAL DRAFT: March 2004 64 SDL Option 3 Floor, w/

Cl Controls SDL Option 3 Floor,

w/ o Cl Controls SDL Option 3 BTF D,

w/ Cl Controls SDL Option 3 BTF D,

w/ o Cl Controls $ 15,216,727.09 $ 9,382,100.40 $ 15,897,834.01 $ 9,682,618.40 $ 1,736,297.03 $ 1,177,655.95 $ 886,739.70 $ 91,535.02 $ 1,143,437.54 $ 427,109.79 $ 1,938,973.22 $ 941,794.39 $ 12,236,289.96 $ 3,951,805.13 $ 12,240,719.45 $ 3,953,144.86 Phase 1 Subtotal $ 2,387,577.64 $ 4,679,749.11 $ 2,604,881.04 $ 4,879,214.18 $ 35,266,378.27 $ 22,362,839.41 $ 38,518,925.61 $ 23,800,882.78 $ 54,662,219.58 $ 39,170,275.21 $ 54,857,663.51 $ 39,278,217.96 $ 1,511,485.56 $ 1,022,652.72 $ 5,025,971.52 $ 2,222,280.96 $ 1,825,249.10 $ 1,825,249.10 $ 4,063,291.11 $ 4,061,001.70 Phase 2 Subtotal $ 57,998,954.24 $ 42,018,177.02 $ 63,946,926.13 $ 45,561,500.62 $ 90,877,754.87 $ 59,701,267.32 $ 99,860,970.70 $ 64,483,169.22 Net Private Costs, by Unit Type: SDL Option 3 Coal Boilers HCl Production Furnaces Total Onsite Incinerators Liquid Boilers Commercial Incinerators Cement Kilns LWAKs Pre existing customers of commercial combustion facilities OPTION 3 FINAL DRAFT: March 2004 65 SDL Option 3 Floor, w/

Cl Controls SDL Option 3 Floor,

w/ o Cl Controls SDL Option 3 BTF D,

w/ Cl Controls SDL Option 3 BTF D,

w/ o Cl Controls $ 4,224,525.39 $ 2,148,236.27 $ 4,224,525.39 $ 2,148,236.27 $ 29,743,955.17 $ 19,472,172.77 $ 29,743,955.17 $ 19,472,172.77 $ 887,076.65 $ 887,076.65 $ 4,150,527.94 $ 2,336,023.97 $ 12,031,916.34 $ 3,862,966.92 $ 12,031,916.34 $ 3,862,966.92 Phase 1 Subtotal $ 46,887,473.55 $ 26,370,452.61 $ 50,150,924.84 $ 27,819,399.93 $ 51,734,745.94 $ 36,499,149.67 $ 51,925,884.96 $ 36,605,325.20 $ 1,379,573.19 $ 891,789.85 $ 4,893,793.90 $ 2,091,300.82 $ 1,825,249.10 $ 1,825,249.10 $ 3,780,695.19 $ 3,780,695.19 Phase 2 Subtotal $ 54,939,568.22 $ 39,216,188.61 $ 60,600,374.04 $ 42,477,321.21 $ 101,827,041.77 $ 65,586,641.23 $ 110,751,298.88 $ 70,296,721.14 Upgrade Expenditures, by Unit Type: SDL Option 3 LWAKs Cement Kilns HCl Production Furnaces Total Coal Boilers Commercial Incinerators Onsite Incinerators Liquid Boilers FINAL DRAFT: March 2004 66 SDL Option 3 Floor, w/

Cl Controls SDL Option 3 Floor,

w/ o Cl Controls SDL Option 3 BTF D,

w/ Cl Controls SDL Option 3 BTF D,

w/ o Cl Controls $ 4,793,785.11 $ 2,148,236.27 $ 4,793,785.11 $ 2,148,236.27 $ 29,743,955.17 $ 19,472,172.77 $ 29,743,955.17 $ 19,472,172.77 $ 887,076.65 $ 887,076.65 $ 4,150,527.94 $ 2,336,023.97 $ 17,012,345.65 $ 5,474,939.65 $ 17,012,345.65 $ 5,474,939.65 Phase 1 Subtotal $ 52,437,162.59 $ 27,982,425.34 $ 55,700,613.88 $ 29,431,372.66 $ 67,595,056.06 $ 46,048,070.44 $ 67,793,126.46 $ 46,161,177.35 $ 1,832,155.84 $ 1,344,372.50 $ 6,864,742.06 $ 2,641,019.14 $ 1,825,249.10 $ 1,825,249.10 $ 4,090,382.62 $ 4,090,382.62 Phase 2 Subtotal $ 71,252,461.00 $ 49,217,692.04 $ 78,748,251.14 $ 52,892,579.11 $ 123,689,623.59 $ 77,200,117.38 $ 134,448,865.02 $ 82,323,951.77 Private Engineering Costs: SDL Option 3 Total LWAKs HCl Production Furnaces Commercial Incinerators Cement Kilns Onsite Incinerators Liquid Boilers Coal Boilers SDL Option 3 Floor,

w/ Cl Controls SDL Option 3 Floor,

w/ o Cl Controls SDL Option 3 BTF D,

w/ Cl Controls SDL Option 3 BTF D,

w/ o Cl Controls Baseline Total Commercial Incinerators 2 0 2 0 15 Cement Kilns 0 0 0 0 26 LWAKs 0 0 0 0 7 Onsite Incinerators 33 30 33 30 92 Liquid Boilers 27 26 27 26 107 Coal Boilers 2 2 2 2 12 HCl Production Furnaces 0 0 1 1 17 Total 64 58 65 59 276 Number of Closed Systems, by Unit Type: Option 3 FINAL DRAFT: March 2004 67 SDL Option 3 Floor,

w/ Cl Controls SDL Option 3 Floor,

w/ o Cl Controls SDL Option 3 BTF D,

w/ Cl Controls SDL Option 3 BTF D,

w/ o Cl Controls To Commercial Incinerators 48,230 26,766 48,230 26,766 To Cement Kilns or LWAKs 11,577 10,705 12,267 11,394 Non commercial Consolidation 67,266 56,732 67,266 56,732 Total 127,072 94,203 127,762 94,892 Quantity of Waste Sent Offsite or Rerouted ( tons): Option 3 Annual Cost SDL Option 3 Floor, w/ Cl controls $ 427,502.98 SDL Option 3 Floor, w/ o Cl controls $ 431,498.33 SDL Option 3 BTF D, w/ Cl controls $ 423,507.62 SDL Option 3 BTF D, w/ o Cl controls $ 427,502.98 Government Costs: Option3 SDL Option 3 Floor, w/ Cl controls SDL Option 3 Floor, w/ o Cl controls SDL Option 3 BTF D, w/ Cl controls SDL Option 3 BTF D, w/ o Cl controls 161,426.70 494,170.81 Available Capacity at Commercial Facilities: Option 3 Cement Kilns/ LWAKs Post MACT ( tons) 112,866.84 493,481.22 492,608.96 504,875.53 Pre MACT Capacity ( tons) 493,298.55 161,426.70 112,866.84 Commercial Incinerators 188,193.00 FINAL DRAFT: March 2004 68 Lost Gained Lost Gained Lost Gained Lost Gained Commercial Incinerators 47.8 18.7 0.0 11.3 47.8 18.7 0.0 11.3 Cement Kilns 0.0 154.2 0.0 105.3 0.0 154.2 0.0 105.3 LWAKs 0.0 5.7 0.0 5.7 0.0 29.0 0.0 15.0 Onsite Incinerators 245.2 53.6 223.4 18.5 245.2 53.6 223.4 18.5 Liquid Boilers 113.3 303.8 109.0 229.2 113.3 303.8 109.0 229.2 Coal Boilers 9.5 10.7 9.5 7.0 9.5 32.7 9.5 11.2 HCl Production Furnaces 0.0 13.6 0.0 13.6 3.4 26.0 3.4 26.0 APCD Industry  310.5  173.2  326.2  187.0 Total 415.8 870.7 341.9 563.7 419.2 944.2 345.2 603.5 Number of Jobs Lost and Gained, by Unit Type: Option 3 SDL Option 3 BTF D, w/