WordPerfect Document Compare Summary Note to reader: This redline strikeout version of chapter 6 of 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 chapter 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 chapter. ( Note: Office of Management and Budget comments and questions on all other chapters and appendices of the Assessment document were minor and resulted in no substantive changes to any other parts of the Assessment document).

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The document was marked with 285 Deletions, 348 Insertions, 1 Move. FINAL DRAFT: March 2004 1 We did not include an analysis to assess the potential magnitude of property value benefits caused by the MACT standards due to limitations of the benefits transfer approach and because property value benefits likely overlap with some human health and ecological benefits;. As a result, including property value benefits may result in doublecounting The benefits assessment also does not examine how secondary impacts such as emissions from increased coal use at combustion sources that stop burning hazardous waste as fuel may result in human health and ecological damages.

6 2 NOTE: After this Assessment was prepared, the Agency modified its proposal for the HWC MACT replacement standards. The benefits analysis presented in this chapter does not reflect this change. Information on the costs, benefits, and other impacts of EPA's proposed HWC MACT replacement standards is available in EPA, " Addendum to the Assessment of the Costs, Benefits, and Other Impacts of the Hazardous Waste Combustion MACT Standards: Proposed Rule," March 2004. This document can be found in the docket.

NOTE: This chapter does not provide quantified or monetary estimates of the benefits associated with reduced dioxin emissions. However, estimates of the benefits associated with reduced dioxin emissions under the revised proposal for the HWC MACT replacement standards are available in EPA, " Addendum to the Assessment of the Costs, Benefits, and Other Impacts of the Hazardous Waste Combustion MACT Standards: Proposed Rule," March 2004. This document can be found in the docket.

BENEFITS ASSESSMENT CHAPTER 6 ______________________________________________________________________________

This chapter presents the benefits assessment for the proposed HWC MACT replacement standards. To evaluate incremental benefits to society of emission reductions at hazardous waste combustion facilities we use results from EPA's 1998 multiple pathway human health and ecological risk assessment updated to address incremental benefits of the replacement standards ( e. g., assuming that the 2002 interim standards are in place). 1 This chapter also briefly discusses how the proposed FINAL DRAFT: March 2004 6 3 MACT replacement standards may potentially lead to changes in the types and quantities of wastes generated and managed at combustion facilities through increased waste minimization. FINAL DRAFT: March 2004 6 4 The chapter is organized into eight sections:

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

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

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

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

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

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

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

Conclusions: Summarizes key findings from the benefits assessment. FINAL DRAFT: March 2004 6 5 FINAL DRAFT: March 2004 2 Although we extrapolate benefits from the estimates presented in the 1999 Assessment and the 1999 Addendum, the 2002 Interim Standards serve as the baseline of our analysis. The 2002 Interim Standards are generally similar to the standards examined in the 1999 Assessment and Addendum; therefore, these 1999 analyses serve as a reasonable approximation of the 2002 Interim Standards baseline.

6 6 This benefits analysis builds upon the results and discussions presented in the 1999 Assessment and the 1999 Addendum. These documents are cited as source material for the current analysis because they generally provide a reasonable approximation of the 2002 Interim Standards baseline. *** However, it is important to note that the 2002 Interim Standards, not the 1999 standards, represent the baseline for the HWC MACT replacement standards***. When the 1999 analyses are used to approximate the 2002 baseline, this Assessment identifies the necessary adjustments.

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

BENEFITS QUANTIFICATION OVERVIEW The basis for the quantitative benefits assessment is an extrapolation of particulate matter ( PM) benefits estimated for the 1999 standards in the 1999 Assessment. 2 This section provides an overview of the methods used to extrapolate the incremental benefits of the replacement standards from those estimated for the 1999 standards. Any comparison of the 2002 interim standards, currently in place, to the proposed HWC MACT replacement standards is complicated. No separate risk assessment was conducted for the interim standards. In general, because the interim standards involved only modest changes from the 1999 standards the benefits for the interim standards are likely to be similar in magnitude to the 1999 standards. Therefore, we assume that the benefits estimates in the 1999 Assessment are a reasonable proxy for benefits realized under the 2002 interim standards. FINAL DRAFT: March 2004 3 See " Human Health and Ecological Risk Assessment Support to the Development of Technical Standards for Emissions from Combustion Units Burning Hazardous Wastes: Background Document" JulyNovember 19998.

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

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

6 7 For the 1999 Assessment, EPAwe estimated the avoided incidence of mortality and morbidity associated with reductions in PM emissions. 3 The risk assessment developed estimated cases of mortality and morbidity avoided for children and the elderly, as well as the general population, using concentration response functions derived from human epidemiological studies available in 1998. Morbidity effects included respiratory and cardiovascular illnesses requiring hospitalization, as well as other illnesses not requiring hospitalization, such as acute and chronic bronchitis and acute upper and lower respiratory symptoms. The risk assessment also estimated decreases in PM related minor restricted activity days ( MRADs) and work loss days ( WLDs). Rates of avoided incidence, work days lost, and days of restricted activity were estimated for each of 16 sectors surrounding a facility using the concentration response functions and sector specific estimates of the corresponding population and model derived ambient air concentration, either annual mean PM 10 or PM 2.5 concentrations or distributions of daily PM 10 or PM 2.5 concentrations, depending on the concentration response function. The sectors were defined by four concentric rings out to a distance of 20 kilometers ( about 12 miles), each of which was divided into four quadrants. The sector specific rates were weighted by facility specific sampling weights and then summed to give the total incidence rates for a given source category. 4 To assess the benefits of the proposed HWC MACT replacement standards, EPAwe took the avoided incidence estimates from the 1999 Assessment and adjusted them to reflect both the PM emission reductions projected to occur under the replacement standards ***( incremental to the 2002 Interim Standards)***, and changes in the universe of facilities burning hazardous wastes since the 1999 Assessment. For cement kilns, lightweight aggregate kilns, and incinerators, the estimates were made by adjusting the respective estimates at the source category level by the ratio of emission reductions ( for the replacement standards vs. the 1999 standards) and the ratio of the number of facilities affected by the rules ( facilities currently burning hazardous wastes vs. facilities burning hazardous wastes in the 1999 Assessment). 5 For liquid and solid fuel fired boilers and hydrochloric acid production furnaces, EPAwe extrapolated the avoided incidence from the incinerator source FINAL DRAFT: March 2004 6 8 category using a similar approach, except that the ratios of the exposed populations were used ( corresponding to the concentration response functions from the 1999 Assessment), instead of the number of facilities. FINAL DRAFT: March 2004 6 OMB guidance recommends that federal agencies conduct probabilistic assessments of the benefits associated with new regulation. Office of Management and Budget. Informing Regulatory Decisions: 2003 Report to Congress on the Costs and Benefits of Federal Regulations and Unfunded Mandates on State, Local, and Tribal Entities. 2003.

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

6 9 EPAWe estimated the exposed populations for hazardous waste burning boilers and HCl production furnaces using the same GIS methods as the 1999 Assessment ( e. g., a 16 sector overlay). Nonetheless, the extrapolated estimates are subject to additional uncertainty, especially for solid fuelfired boilers and HCl production furnaces because these two source categories have only a small number of facilities and may be poorly represented by the incinerator facilities analyzed in the 1999 Assessment.

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

The benefits estimates in this assessment are presented as point estimates instead of in probabilistic terms. 6 Although probabilistic estimates would provide valuable information about the uncertainty associated with the benefits of the proposed HWC MACT replacement standards, probabilistic analysis was not amenable to our methodology of adjusting the benefits estimates presented in the 1999 Assessment, which were not expressed in probabilistic terms.*** In certain cases, however, we present monetized estimates as a range to reflect uncertainty in valuation techniques.***

RISK ASSESSMENT OVERVIEW The basis for the 1999 benefits Assessment was a multiple pathway risk assessment developed by the Economics, Methods and Risk Analysis Division in EPA's Office of Solid Waste. This risk assessment was designed to estimate baseline risks from hazardous waste combustion emissions, as well as expected risks after the 1999 MACT standards were implemented. 7 This section provides an FINAL DRAFT: March 2004 8 EPA The Agency expects that hazardous waste burning kilns that are able to use feed control to achieve emissions reductions will also generate cement kiln dust ( CKD) with a lower toxicity than prior to feed control ( in particular, lower SVM content) ( USEPA " Selection of MACT Standards and Technology," Chapter 12 of Volume 3 Technical Support Document for HWC MACT Standards, July 1999.) The risk assessment did not address the potential human health and ecological benefits associated with reduced toxicity CKD.

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

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

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

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

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

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

6 10 overview of the risk assessment, which analyzed both human health and ecological risks that result from direct and indirect exposure to emissions from facilities that burn hazardous waste. 8 A multiple pathway analysis that models both inhalation and ingestion pathways was used to estimate human health risks. 9 The Assessment used a statistically based stratified random sampling approach in which 76 hazardous waste combustion facilities and their site specific land uses and environmental settings were characterized. 10 The randomly selected facilities in the study included: 43 on site incinerators, 13 commercial incinerators, 15 cement kilns, and five lightweight aggregate kilns. 11 The current Assessment adjusts the estimates from the 1999 Assessment to project the human health benefits of the replacement standards.

The pollutants analyzed in the risk assessment included dioxins and furans, selected metals, and PM. 12 The metals modeled in the Assessment include the following: antimony, arsenic, barium, beryllium, cadmium, chromium copper, cobalt, lead, manganese, mercury, nickel, selenium, silver, and thallium. 13 The risk assessment modeled fate and transport of the emissions of these pollutants FINAL DRAFT: March 2004 6 11 to arrive at concentrations in air, soil, surface water, and sediments. To assess human health risks, these concentrations can be converted to estimated doses to the exposed populations using exposure factors such as inhalation and ingestion rates. These risk assessment calculated cancer and noncancer risks using these doses, if the appropriate health benchmarks were available. FINAL DRAFT: March 2004 14 The methodology used to develop the eco toxicological criteria is largely a product of the ecological risk assessment work conducted to support the proposed HWIR for process waste.

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

6 12 This Assessment provides a discussion of the ecological benefits that may be associated with the replacement standards by comparing emissions reductions to the reductions from the 1999 standards. In the 1999 Assessment, soil, surface water and sediment concentrations were compared with eco toxicological criteria representing protective screening values for ecological risks to assess potential ecological risks. 14 Because these criteria were based on de minimis ecological effects and thus represented conservative values, an exceedence of the eco toxicological criteria did not necessarily indicate ecological damage; it simply suggested that potential damages could not be ruled out.

To characterize the non cancer risks to the populations listed above, the 1999 risk assessment broke down the area surrounding each modeled combustion facility into 16 polar grid sectors, as illustrated in Exhibit 6 1. For each polar grid sector, risk estimates were developed for different age groups and receptor populations ( e. g., 0 5 year old children of subsistence fishers). This approach was used because geographic and demographic differences across polar grid sectors lead to sectoral variation in individual risks. Thus, individual risk results are aggregated across sectors and weighted by population in each sector to generate the distribution of risk to individuals in the affected area. 15 An additional Monte Carlo analysis was conducted to incorporate variability in other exposure factors such as inhalation and ingestion rates.

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

Human Health Benefits Methodology FINAL DRAFT: March 2004 6 13 Exhibit 6 1 DIAGRAM OF 16 SECTOR POLAR BASED GRID USED IN THE RISK ASSESSMENT Waterbody ( lake)

One of 16 sectors U. S. Census Block Group 0 2 km ring 2 5 km ring 5 10 km ring 10 20 km ring The approach for assessing human health benefits is divided into two components   benefits from cancer risk reductions and benefits from non cancer risk reductions. We separate the discussion in this way because the interpretation of risk reductions for carcinogenic pollutants is very different than that for non carcinogens. As explained above, for both cancer and non cancer benefits, we focus on population risks because these results form the basis for assessing total benefits of the proposed HWC MACT replacement standards. In general, these results concern the population overall with regards to different age groups, though risk reductions associated with certain pollutants, such as lead, specifically affect children within the population. In these cases, we focus on the benefits to a subset population, ages 0 19.

In addition to population results, we also describe individual risk results for the hypothetical worst case scenarios for both cancer and non cancer risks. Because we do not have population data for the most sensitive sub populations, we can only describe individual risk results for subsistence farmers and fishermen and cannot make statements concerning the total number of people that may experience health benefits associated with the proposed HWC MACT replacement standards. FINAL DRAFT: March 2004 16 Cancer incidence estimates used direct and indirect exposure pathways for all non subsistence receptors, excluding recreational anglers. Population risks could not be calculated for recreational anglers because detailed population data were not available for this receptor population.

17 In a December 30, 1997 benefits methodology memorandum, we noted that summing these estimates may pose the potential for double counting, considering that dioxin contaminated food ingestion is also evaluated on the local level ( Industrial Economics, Incorporated, Social Science Discussion Group. Handbook for Non Cancer Valuation: Draft. Prepared for U. S. EPA, 1997, as cited in U. S. EPA, Assessment of the Potential Costs, Benefits, and Other Impacts of the Hazardous Waste Combustion MACT Standards: Final Rule, Office of Solid Waste, July 1999). However, if we make the assumption that most of the agriculture products produced within 20 kilometers of the facility are consumed outside the local area, then we minimize the double counting potential. A follow up phone call with EPA and Research Triangle Institute, the contractor that prepared the Combustion Risk Assessment, confirmed that this in fact is a reasonable assumption.

6 14 Approach for Assessing Benefits from Cancer Risk Reductions In this analysis we discuss the potential cancer risk reductions by comparing the replacement standards to the results of the 1999 Assessment. The basic approach for assessing benefits from cancer risk reductions in the 1999 Assessment relied on two analytic components. First, the risk assessment estimated cancer risk reductions for all non subsistence receptors in the vicinity of combustion facilities. These risk reduction estimates were derived from the median individual risk values and population data for non subsistence population. 16 Carcinogens included in the risk assessment were dioxins/ furans, arsenic, beryllium, cadmium, chromium ( VI), and nickel. Second, the risk assessment estimated cancer risk reductions associated with the ingestion of dioxin contaminated foods grown or raised near combustion facilities but distributed nationwide. We then calculated total cancer risk reductions by summing the avoided cases in communities near combustion facilities with the number of cases avoided due to reduced dioxin in the national food supply. 17 That is,

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

The 1999Addendum to the1999 Assessment estimated 0.376 cancer deaths would be avoided annually with a reduction of 28.7 grams of dioxins/ furans emissions per year. The replacement standards will reduce dioxins/ furans emissions by 0.4 grams annually for each of the Floor options and 24.47 grams annually for the Agency Preferred Approach ( Exhibit 6 53). Thus, the replacement standards are expected to avoid less than 0.376 cancer deaths annually.

To assign monetary values to cancer risk reduction estimates, we apply the value of a statistical life ( VSL) to the risk reduction expected to result from the replacement MACT standards. FINAL DRAFT: March 2004 18 Viscusi, W. Kip. Fatal Tradeoffs: Public and Private Responsibilities for Risk. New York: Oxford University Press, 1992.

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

20 U. S. EPA Benefits of the Proposed Inter State Air Quality Rule, January 2004. Pg. 4 65.

21 This mean value and range are consistent with estimates presented in U. S. EPA, Benefits of the Proposed Inter State Air Quality Rule, January 2004, inflation adjusted.

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

6 15 The VSL is based on an individual's willingness to pay ( WTP) to reduce a risk of premature death or their willingness to accept ( WTA) increases in mortality risk. 17 Because t There are many different estimates of VSL in the economic literature, we would estimate the reduced mortality benefits using a range of VSL estimates from. Viscusi18 presents 26 policy relevant value of life studies. *** As shown in Exhibit 6 2, the estimated VSL figures from*** tThese studies range from $ 0.860 million to $ 198.5623 million, with an average value of $ 6.8842 million ( in 2002 dollars). 19 *** For this analysis we are altering the value of a statistical life ( VSL) to reflect new information in the ongoing academic debate over the appropriate characterization of the value of reducing the risk of premature mortality. We are characterizing the VSL distribution in a more general fashion, based on two recent meta analyses of the wage risk based VSL literature. The new distribution is assumed to be normal, with a mean of $ 5.5 million ( in 1999 dollars) and a 95 percent confidence interval between $ 1 and $ 10 million. 20,21 *** To value the mortality risk reductions, we would multiply the expected number of annual premature statistical deaths avoided by the high end, low end, and mean value of the VSL estimates. The Agency welcomes public comment on the appropriate methodology for valuing reductions in the risk of premature death.

Approach for Assessing Benefits from Non Cancer Risk Reductions A variety of approaches are used to evaluate the benefits of reducing particulate matter, for which we estimate both morbidity and mortality benefits. 22 For lead and mercury, we compare the replacement standards to the results of the 1999 Assessment. In the 1999 Assessment we used upper bound estimates of the population at risk because we only had information on the potential of an adverse effect and we could not say anything about the likelihood of the effects.

We assign monetary values to non cancer benefits using a direct cost approach which focuses on the expenditures averted by decreasing the occurrence of an illness or other health effects. While the WTP approach used for valuing the cancer risk reductions is conceptually superior to the direct FINAL DRAFT: March 2004 6 16 cost approach, measurement difficulties, such as estimating the severity of various illnesses, preclude us from using this approach here. Direct cost measures are expected to understate true benefits because they do not include cost of pain, suffering, and time lost. On the other hand, because we use upper bound estimates of the population at risk, we cannot conclude that the results are biased in one direction or the other. FINAL DRAFT: March 2004 23 The benefits discussion that follows in the rest of this paragraph is adapted from EPA, Regulatory Impact Analysis of the Final Industrial Boilers and Process Heaters NESHAP: Final Report, February 2004.

24 U. S. EPA, Regulatory Impact Analysis of The Final Industrial Boilers and Process Heaters NESHAP: Final Report, February 2004.

25 U. S. EPA, Benefits of the Proposed Inter State Air Quality Rule, January 2004.

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

6 17 Benefits from Reduced Exposure to Particulate Matter Epidemiological studies have linked PM ( alone or in combination with other air pollutants) with a series of health effects. 23 PM can accumulate in the respiratory system and aggravate health problems such as asthma, or it can penetrate deep into the lungs and lead to even more serious health problems. These health effects include premature death, respiratory symptoms and disease, diminished lung function, and weakened respiratory tract defense mechanisms. Children, the elderly, and people with cardiopulmonary disease, such as asthma, are most at risk from these health effects.

*** Since performing the risk assessment for the 1999 Assessment, EPA has updated its benefits methodology to reflect recent advances in air quality modeling and human health benefits modeling. To estimate PM exposure for the 1999 risk assessment, the Agency used the Industrial Source Complex Model Short Term Version 3 ( ISCST3). More recent EPA benefits analyses have used more advanced air quality models. For example, the Agency's assessment of the industrial boilers and process heaters NESHAP used the Climatological Regional Dispersion Model ( CRDM), which uses a national source receptor matrix to estimate exposure associated with PM emissions. 24 Similarly, the Agency's analysis of the proposed Inter state Air Quality Rule used the Regional Modeling System for Aerosols and Deposition ( REMSAD), which also accounts for the long range transport of particles. 25 In contrast, ISCST3 modeled exposure within a 20 kilometer radius of each emissions source for the 1999 risk assessment. 26 To the extent that PM is transported further than 20 km from each emissions source, the 1999 risk assessment may underestimate PM exposure. In addition, to estimate exposure in the 1999 risk assessment, EPA used block group level data from the 1990 Census. More recent studies use data from the 2000 Census.

More recent EPA benefits analyses also apply a different concentration response function for PM mortality than that used for the 1999 risk assessment. In 1999, EPA used the concentration FINAL DRAFT: March 2004 27Pope, C. A., III, M. J. Thun, M. M. Namboodiri, D. W. Dockery, J. S. Evans, F. E. Speizer, and C. W. Heath, Jr. 1995. Particulate air pollution as a predictor of mortality in a prospective study of U. S. adults. American Journal of Respiratory and Critical Care Medicine151: 669 674, as cited in Research Triangle Institute, op. cit.

28 Krewski D, Burnett RT, Goldbert MS, Hoover K, Siemiatycki J, Jerrett M, Abrahamowicz M, White WH. 2000. Reanalysis of the Harvard Six Cities Study and the American Cancer Society Study of Particulate Air Pollution and Mortality. Special Report to the Health Effects Institute, Cambridge MA, July 2000.

6 18 response function published by Pope, et al. in 1995.27 Since that time, health scientists have refined estimates of the concentration response relationship, and EPA has updated its methodology for estimating benefits to reflect these more recent estimates. In its regulatory impact analysis of the nonhazardous boiler MACT standards, EPA used the Krewski, et al. re analysis of the 1995 Pope study to estimate avoided premature mortality. 28 Since the relative risk estimated in the Krewski study ( 1.18) is nearly the same as that presented in Pope et al.( 1.17), the Agency assumes that updating the 1999 risk assessment to reflect the results of the 2000 Krewski study would have minimal impact on the estimated benefits associated with the proposed HWC MACT replacement standards.***

To assess benefits from reduced exposure to particulate matter in 1999, EPAwe first estimated the number of excess mortality and hospital admissions in the baseline and under various 1999 MACT standard scenarios. EPAWe then subtracted the number of cases post MACT from the number of cases in the baseline to determine potential avoided deaths and hospital admissions. Hospital admissions are associated with respiratory illness and cardiovascular disease. For the current assessment EPAwe scaled the cases found in the 1999 Assessment to reflect current conditions and emission reductions achieved by the proposed HWC MACT replacement standards. FINAL DRAFT: March 2004 29 Work loss days and mild restricted activity days do not necessarily affect a worker's income and do not generally require hospitalization. It does, however, result in lost economic productivity and consequently, a loss to society.

6 19 *** Exhibit 6 2***

*** SUMMARY OF MORTALITY VALUATION ESTIMATESStudyType of EstimateValuation ( millions 2002$) Kneisner and Leeth ( 1991) ( US) Labor Market0.86Smith and Gilbert ( 1984) Labor Market0.98Dillingham ( 1985) Labor Market1.35Butler ( 1983) Labor Market1.60Miller and Guria ( 1991) Contingent Value1.72Moore and Viscusi ( 1988a) Labor Market3.57Viscusi, Magat, and Huber ( 1991b) Contingent Value3.94Marin and Psacharopoulos ( 1982) Labor Market4.06Gegax et al. ( 1985) Contingent Value4.80Kneisner and Leeth ( 1991) ( Australia) Labor Market4.80Gerking, de Haan, and Schulze ( 1988) Contingent Value4.92Cousineau, Lacroix, and Girard ( 1988) Labor Market5.17Jones Lee ( 1989) Contingent Value5.54Dillingham ( 1985) Labor Market5.66Viscusi ( 1978, 1979) Labor Market5.90R. S. Smith ( 1976) Labor Market6.64V. K. Smith ( 1976) Labor Market6.77Olson ( 1981) Labor Market7.50Viscusi ( 1981) Labor Market9.47R. S. Smith ( 1974) Labor Market10.46Moore and Viscusi ( 1988a) Labor Market10.58Kneisner and Leeth ( 1991) ( Japan) Labor Market10.95Herzog and Schlottman ( 1987) Labor Market13.16Leigh and Folson ( 1984) Labor Market14.02Leigh ( 1987) Labor Market15.01Gaten ( 1988) Labor Market19.56Source: Viscusi, W. Kip. Fatal Tradeoffs: Public and Private Responsibilities for Risk. New York: Oxford University Press, 1992 *** In addition to avoided illnesses and deaths, benefits of reduced PM emissions include valuation of work loss days and mild restricted activity days ( MRAD). To assess benefits from reduced particulate matter exposure, EPAwe first estimated the number of excess mortality cases, cases of illnesses, restricted activity days, and work loss days in the baseline. We then estimate the number of cases under four MACT standards: Option 1 Floor, Option 2 Floor, Option 3 Floor, and Agency Preferred Approach. To determine potential benefits for each option, we then subtract the number of post MACT cases from the number of baseline cases. We estimated benefits based on the dollar value associated with the following health conditions:

respiratory illness,

upper respiratory symptoms,

lower respiratory symptoms,

chronic bronchitis,

acute bronchitis,

cardiovascular disease,

work loss days, and

mild restricted activity days ( MRAD). 29 For avoided deaths, we assign monetary values in the same way as for avoided cancer cases, FINAL DRAFT: March 2004 30 These estimates come from the following source: U. S. Environmental Protection Agency, The Benefits and Costs of the Clean Air Act, 1970 to 1990, October 1997, I11 I12. Estimates for COPD and physician charges for the remaining four illnesses come from Abt Associates, Incorporated, The Medical Costs of Five Illnesses Related to Exposure to Pollutants, Prepared for U. S. EPA, Office of Pollution Prevention and Toxics, Washington, DC, 1992, as cited in U. S. EPA, Assessment of the Potential Costs, Benefits, and Other Impacts of the Hazardous Waste Combustion MACT Standards: Final Rule, Office of Solid Waste, July 1999. Hospital charge estimates for the remaining illnesses are from A. Elixhauser, R. M. Andrews, and S. Fox, Agency for Health Care Policy and Research ( AHCPR), Center for General Health Services Intramural Research, U. S. Department of Health and Human Services, Clinical Classifications for Health Policy Research: Discharge Statistics by Principal Diagnosis and Procedure, 1993, as cited in U. S. EPA, Assessment of the Potential Costs, Benefits, and Other Impacts of the Hazardous Waste Combustion MACT Standards: Final Rule, Office of Solid Waste, July 1999; Pope, C. A., III, D. W. Dockery, J. D. Spengler, and M. E. Raizenne. 1991. Respiratory Health and PM10 pollution: a Daily Time Series Analysis. American Review of Respiratory Diseases. 144: 668 674, as cited in U. S. EPA, Draft Regulatory Impact Analysis: Control of Emission from Nonroad Diesel Engines, Assessment and Standards Division, April 2003; Schwartz J., and Nease L. M., 2000. Fine Particles are more strongly associated than coarse particles with acute respiratory health effects in schoolchildren. Epidemiology. 11L 6 10, as cited in U. S. EPA, Draft Regulatory Impact Analysis: Control of Emission from Nonroad Diesel Engines, Assessment and Standards Division, April 2003; Schwartz J., Dockery, D. W., Nease, L. M., Wypij, D., Ware, J. H., Spengler, J. D., Koutrakis, P., Speizer, F. E., and Ferris, Jr., B. G. 1994. Acute Effects of Summer Air Pollution on Respiratory Symptom Reporting in Children. American Journal of Respiratory Critical Care Medicine. 150. 1234 1242, as cited in U. S. EPA, Draft Regulatory Impact Analysis: Control of Emission from Nonroad Diesel Engines, Assessment and Standards Division, April 2003; and Dockery, D. W., J. Cunningham, A. I. Damokosh, L. M. Neas, J. D. Spengler, P. Koutrakis, J. H. Ware, M. Raizenne, and F. R. Speizer. 1996. Health Effects of Acid Aerosols on North American Children Respiratory Symptoms. Enviromental Health Perspectives. 104( 5)" 500 505.

6 20 using a range of estimates for the statistical value of a life ( see discussion above). For the avoided illnesses listed above, we estimate the avoided costs of hospital admissions for each of the health effects associated with exposure to particulate matter. To value the morbidity risk reductions, we multiply the expected number of annual reductions in hospital admissions for each ailment by the cost of illness for that condition, as shown in Exhibit 6 32. The estimated cost of each illness includes the hospital charge, the costs of associated physician care, and the opportunity cost of time spent in the hospital. 30 Since these estimates do not include post hospital costs or pain and suffering of the afflicted individuals, the cost of illness estimates may understate benefits. FINAL DRAFT: March 2004 6 21 Exhibit 6 2 AVOIDED COST OF CASES ASSOCIATED WITH PM Illness Estimated Cost Per Incidence ( 2002 $)

Respiratory Illness1 $ 9,011 Upper respiratory symptoms2 $ 27 Lower respiratory symptoms3 $ 18 Chronic bronchitis4 $ 377,229 Acute bronchitis5 $ 55 Cardiovascular disease1 $ 15,018 Work loss days ( cost per day) 1 $ 112 Minor restricted activity days ( cost per day) 1 $ 39 Sources: 1 U. S. Environmental Protection Agency, The Benefits and Costs of the Clean Air Act, 1970 to 1990, October 1997, I11 I12 2 Pope, C. A., III, D. W. Dockery, J. D. Spengler, and M. E. Raizenne. 1991. Respiratory Health and PM10 pollution: a Daily Time Series Analysis. American Review of Respiratory Diseases. 144: 668 674, as cited in U. S. EPA, Draft Regulatory Impact Analysis: Control of Emission from Nonroad Diesel Engines, Assessment and Standards Division, April 2003. 3 Average of Schwartz J., and Nease L. M., 2000. Fine Particles are more strongly associated than coarse particles with acute respiratory health effects in schoolchildren. Epidemiology. 11L 6 10, as cited in U. S. EPA, Draft Regulatory Impact Analysis: Control of Emission from Nonroad Diesel Engines, Assessment and Standards Division, April 2003; and Schwartz J., Dockery, D. W., Nease, L. M., Wypij, D., Ware, J. H., Spengler, J. D., Koutrakis, P., Speizer, F. E., and Ferris, Jr., B. G. 1994. Acute Effects of Summer Air Pollution on Respiratory Symptom Reporting in Children. American Journal of Respiratory Critical Care Medicine. 150. 1234 1242, as cited in U. S. EPA, Draft Regulatory Impact Analysis: Control of Emission from Nonroad Diesel Engines, Assessment and Standards Division, April 2003. 4 U. S. EPA, Benefits of the Proposed Inter State Air Quality Rule, January 2004. 5 Neumann, J. E., M. T. Dickie, and R. E. Unsworth. 1994. Industrial Economics, Incorporated. Memorandum to Jim DeMocker, U. S. EPA, Office of Air and Radiation. Linkage Between Health Effects Estimation and Morbidity Valuation in the Section 812 Analysis  Draft Valuation Document. March 31. Note: Cardiovascular disease is assumed to be Ischemic heart disease. FINAL DRAFT: March 2004 31 Based on the population estimated in the 1999 Assessment.

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

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

34 The benefits discussion that follows in the rest of this paragraph is adapted from EPA, Regulatory Impact Analysis of the Final Industrial Boilers and Process Heaters NESHAP: Final Report, February 2004. Additional information related to the health effects associated with mercury are provided in chapter 9 of this report.

6 22 Benefits from Reduced Exposure to Lead The primary effect from chronic exposure to lead is to the central nervous system. Children are particularly sensitive to the effects of lead and excess exposure can affect a child's nervous system and cognitive development. The proposed HWC MACT replacement standards will reduce lead emissions by approximately five to seven tons per year for the Floor and Agency Preferred Approach options, or less than 0.01 pounds per person. 31 The 1999 standards were expected to reduce lead emissions by 89 tons per year, or 0.17 pounds per person, and were expected to reduce cumulative lead exposures for seven children age 0 5 to less than 10 µ g/ dL. The benefits associated with the replacement standards are expected to be more modest per year, reducing the cumulative lead exposures for fewer than seven children age 0 5, to less than 10 µ g/ dL annually.

The Benefits and Costs of the Clean Air Act, 1970 to 1990 monetizes benefits of reduced lead emissions by associating high blood lead levels with reduction in IQ. 32 The analysis estimates annual benefits of about $ 42 million associated with reductions ranging from 5,000 to 13,000 tons of lead, depending on the year. 33 The reduction of lead emissions and increase in IQ does not display a linear relationship and cannot be transferred to this analysis so we do not attempt to monetize them.

Benefits from Reduced Exposure to Mercury Reduced mercury emissions under the proposed replacement standards may generate a range of human health benefits. 34 A reduction in mercury emissions is likely to reduce the deposition of mercury in lakes, rivers, and streams, which will subsequently reduce bioaccumulation of methylmercury in fish. Since consumption of fish containing methylmercury may cause adverse health effects, reductions in the bioaccumulation of methylmercury in fish could lead to human health benefits.

When humans consume fish containing methylmercury, the ingested methylmercury is FINAL DRAFT: March 2004 35 EPA, Regulatory Impact Analysis of the Final Industrial Boilers and Process Heaters NESHAP: Final Report, February 2004.

6 23 absorbed into the blood and distributed to tissue throughout the body. In pregnant women, methylmercury can be passed on to the developing fetus, leading to a number of neurological disorders in children. These disorders can lead to learning disabilities and developmental problems, which may lead to later adverse economic consequences. The effects of prenatal exposure can occur at doses that do not affect the mother. In addition, children who consume fish containing methylmercury may develop neurological disorders, which may lead to other adverse economic effects. A more detailed description of the benefits associated with reduced mercury exposure is presented in EPA's regulatory impact analysis of the non hazardous boiler MACT standards. 35 Since the numerical relationship between mercury exposure and the health effects described above is highly uncertain, we do not quantify the benefits associated with reduced mercury emissions. Instead, we present a qualitative discussions of the benefits that might result from the proposed HWC MACT replacement standards for mercury.

Text Moved Here: 1 Benefits from Reduced Exposure to Chlorine This analysis does not quantify the benefits associated with reductions in chlorine emissions. The replacement standards are expected to reduce total chlorine emissions, a combination of hydrogen chloride ( HCl) and chlorine gas ( Cl 2) emissions, by approximately 1,426 to 4,806 tons per year for the Floor options and 2,490 tons per year for the Agency Preferred Approach ( Exhibit 6 53). Hydrogen chloride is corrosive to the eyes, skin, and mucous membranes. Acute inhalation can cause eye, nose, and respiratory tract irritation and inflamation, and pulmonary edema. Chronic occupational inhalation has been reported to cause gastritis, bronchitis, and dermatitis in workers. Long term exposure can also cause dental discoloration and erosion. No information is available on the reproductive or developmental effects in humans. Chlorine gas inhalation can cause bronchitis, asthma and swelling of the lungs, headaches, heart disease, and meningitis. Acute exposure causes more severe respiratory and lung effects, and can result in fatalities. No information is available on the reproductive or developmental effects in humans. The proposed HWC MACT replacement standards are expected to reduce chlorine exposure for people in close proximity to hazardous waste combustion facilities, and are therefore likely to reduce the risk of all of these health effect among those populations. However, without detailed exposure modeling it is not possible to quantify the impact of the proposed HWC MACT replacement standards. FINAL DRAFT: March 2004 6 24 End Of Moved Text Benefits from Reduced Exposure to Lead The primary effect from chronic exposure to lead is to the central nervous system. Children are particularly sensitive to the effects of lead and excess exposure can affect a child's nervous system and cognitive development. The proposed HWC MACT replacement standards will reduce lead emissions by approximately five to seven tons per year for the Floor and Agency Preferred Approach options, or less than 0.01 pounds per person ( see below, Exhibit 6 5). 22 The 1999 standards were expected to reduce lead emissions by 89 tons per year, or 0.17 pounds per person, and were expected to reduce cumulative lead exposures for two children age 0 5 to less than 10 µ g/ dL. The benefits associated with the replacement standards are expected to be more modest per year, reducing the cumulative lead exposures for fewer than two children age 0 5, to less than 10 µ g/ dL annually.

The Benefits and Costs of the Clean Air Act, 1970 to 1990 monetizes benefits of reduced lead emissions by associating high blood lead levels with reduction in IQ. 23 The analysis estimates annual benefits of about $ 49 million associated with reductions ranging from 5,000 to 13,000 tons of lead, depending on the year. 24 The reduction of lead emissions and increase in IQ does not display a linear relationship and cannot be transferred to this analysis so we do not attempt to monetize them.

Benefits from Reduced Exposure to Mercury The 1999 Assessment considered benefits from reduced exposure to mercury. The 1999 standards were expected to reduce mercury emissions by four tons per year, the replacement standards are expected to reduce mercury emissions by about one ton per year ( Exhibit 6 5). This Assessment provides no quantification of health benefits associated with the reduction of mercury emission resulting from the replacement standards but does provide a discussion of the benefits estimated in the 1999 Assessment. The Assessment noted that recreational anglers exposed to mercury above levels of concern are potentially at risk for bearing children with developmental abnormalities. 25 To project the benefits of reduced exposure, the 1999 risk assessment estimated the median cost of developmental abnormalities using a range of estimates for various birth defects provided in the Waitzman et al. study ( see Exhibit 6 4). 26 In a survey of the non cancer economic literature, this study was found to provide reasonable benefit measures. 27 The birth rate of the general population indicates that 1.67 percent of recreational anglers potentially at risk will have children in a given year. 28 This estimate also may understate benefits because it does not include avoided pain and suffering.

It is important to note that the approach used in the 1999 Assessment uses upper bound estimates of the population at risk to compute benefits for mercury. For the 1999 Assessment the cost of developmental abnormalities was applied to all recreational anglers potentially at risk ( e. g., those exposed to mercury above FINAL DRAFT: March 2004 6 25 levels of concern ( HQ> 1)) ( Exhibit 6 4). This approach did not allow us to say anything about the likelihood of an adverse effect for the anglers at risk; we could only say that we could not rule out adverse impacts for these individuals. Subsistence fishermen, those individuals who obtain a significant portion of their dietary fish intake from their own fishing activities, potentially faced even greater risk for bearing children with developmental abnormalities as a result of higher mercury exposure levels in their daily fish consumption.

Text Was Moved From Here: 1 *** Exhibit 6 4***

COSTS OF ILLNESS ASSOCIATED WITH VARIOUS BIRTH DEFECTSHealth ConditionCost per Case ( thousands) Spina bifida$ 510Truncus arteriosus$ 877Transposition of great arteries/ Double Outlet Right Ventricle $ 463Single ventricle$ 597Tetralogy of Fallot $ 453Cleft lip or palate$ 176Tracheoesophageal fistula$ 252Atresia of the small intestine$ 129Colorectal atresia$ 212Renal agenesis$ 434Urinary tract obstruction$ 146Upper l imb reduction $ 173Lower limb reduction $ 345Diaphragmatic hernia$ 434Gastroschisis$ 187Omphalocele$ 305Down syndrome$ 782Median$ 345Source: Waitzman et al. ( 1996). Note: Figures are in 2002 dollars.

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

In general, the 1999 standards resulted in greater incremental emissions reductions than are expected under the proposed HWC MACT replacement standards ( Exhibit 6 5). This is reasonable given that the proposed HWC MACT replacement standards address only emissions reductions not already captured by the 2002 interim standards. One notable exception is that Option 3 Floor is associated with a greater PM emissions reduction than the options considered for the 1999 standards. Among the proposed HWC MACT replacement standards options Option 3 Floor is expected to result in the most human health benefits. The Agency Preferred Approach is expected to result in more human health benefits than Option 1 Floor and Option 2 Floor. FINAL DRAFT: March 2004 6 26 Human Health Benefit Results This section discusses quantified human health benefits from risk reductions related to PM emissions reductions for each of the Floor options and the Agency Preferred Approach. Cancer risk reductions associated with dioxin emissions reductions are also discussed. In addition, benefits from reduced exposure to lead and mercury are discussed and compared to the 1999 standards benefits estimates. Finally, we are not able to quantify benefits to reduced exposure to chlorine but we discuss potential effects of hydrogen chloride and chlorine gas.

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

Exhibit 6 3 AVOIDED COST OF CASES ASSOCIATED WITH PMIllnessEstimated Cost Per Incidence ( 2002 $) Respiratory Illness1 $ 11,333Upper respiratory symptoms2 $ 31Lower respiratory symptoms3 $ 20Chronic bronchitis1 $ 482,256Acute bronchitis4 $ 59Cardiovascular disease1 $ 18,888Work loss days ( cost per day) 1 $ 121Minor restricted activity days ( cost per day) 1 $ 55Sources: 1 U. S. Environmental Protection Agency, The Benefits and Costs of the Clean Air Act, 1970 to 1990, October 1997, I11 I12 2 Pope, C. A., III, D. W. Dockery, J. D. Spengler, and M. E. Raizenne. 1991. Respiratory Health and PM10 pollution: a Daily Time Series Analysis. American Review of Respiratory Diseases. 144: 668 674. 3 Average of Schwartz J., and Nease L. M., 2000. Fine Particles are more strongly associated than coarse particles with acute respiratory health effects in schoolchildren. Epidemiology. 11L 6 10. and Schwartz J., Dockery, D. W., Nease, L. M., Wypij, D., Ware, J. H., Spengler, J. D., Koutrakis, P., Speizer, F. E., and Ferris, Jr., B. G. 1994. Acute Effects of Summer Air Pollution on Respiratory Symptom Reporting in Children. American Journal of Respiratory Critical Care Medicine. 150. 1234 1242. 4 Neumann, J. E., M. T. Dickie, and R. E. Unsworth. 1994. Industrial Economics, Incorporated. Memorandum to Jim DeMocker, U. S. EPA, Office of Air and Radiation. Linkage Between Health Effects Estimation and Morbidity Valuation in the Section 812 Analysis  Draft Valuation Document. March 31. Note: Cardiovascular disease is assumed to be Ischemic heart disease. FINAL DRAFT: March 2004 6 27 Exhibit 6 5 ANNUAL EMISSIONS REDUCTION FOR THE PROPOSED HWC MACT NNUAL EMISSIONS REDUCTIONS FOR THE PROPOSED HWC MACT REPLACEMENT STANDARD OPTIONS AND THE 1999 STANDARDSTANDARDS Standard Particulate Matter ( tons/ yr) a Mercury ( tons/ yr) LeadSVM/ LVM ( tons/ yr) Dioxins/ Furans ( grams/ yr) Chlorine ( tons/ yr)

Agency Preferred Approach 2,215 ( 9.7) 0.9 15216.4 4.7 2,490638 Option 1 Floor 1,829 ( 4.7) 0.9 1515.8 0.4 1,426570 Option 2 Floor 1,829 ( 4.7) 1.3 616.7 0.4 23,957106 Option 3 Floor 3,254 ( 15.5) 1.3 720.4 0.4 4,806955 1999 Standard 2,449 ( 6.2) 43.9 8997.1 28.7 5,132 Notes a. Values in parentheses following the PM emissions reductions estimates represent emissions reductions of nonenumerated metals ( i. e., antimony, cobalt, nickel, selenium, and manganese) attributable to the PM replacement standards.

A summary of the quantified benefits for the Agency Preferred Approach are provided in Exhibit 6 64, and the summary of quantified benefits of the Floor options are presented in Exhibit 6 75. Below, we describe the results in more detail.

Benefits from Cancer Risk Reductions Dioxin  Less than 0.376 cancer cases per year are expected to be avoided due to the proposed HWC MACT replacement standards. Based on the 1999 Assessment the majority of the cancer risk reductions are linked to consumption of dioxin contaminated agricultural products exported beyond the boundaries of the study area ( e. g., within 20 km). Less than one third of the cancer risk reductions occurred in local populations living near combustion facilities. Cancer risks for local populations were attributed primarily to reductions in arsenic and chromium emissions; these pollutants accounted for almost 85 percent of total local cancer incidence in the baseline.

In 1999, across all receptor populations, individual cancer risks were greatest for subsistence farmers, individuals who obtain the majority of their dietary intake of all agricultural commodities FINAL DRAFT: March 2004 36 The following pathways pertain to this subsistence receptor: ingestion of home produced beef, pork, chicken, eggs, milk, root vegetables, exposed fruit, exposed vegetables, and fish caught on farm ponds.

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

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

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

6 28 from home production. 36 Dioxin and arsenic were the primary pollutants that drive the cancer risks for this sensitive receptor population. Lack of population data prevented the quantification of benefits for this hypothetical sub population, but the reduction in risk from baseline to implementation of the 1999 standards was characterized. Subsistence farmers exposed to the highest individual risks faced getting cancer with a probability of five in 100,000.37 With the exception of one particular scenario, the cancer risk for all subsistence farmers was reduced to below levels of concern after implementation of the 1999 standards. 38 The 1999 Assessment found that in addition to the cancer risk reductions for the overall population, the 1999 standards would result in lower cancer risks for the children of especially sensitive sub populations. Children of subsistence farmers, who potentially face the greatest individual risk of any receptor population, were expected to experience a reduction in individual cancer risk by a factor as high as 0.005. Risk reductions may be associated with the proposed HWC MACT replacement standards, particularly near facilities with boilers and industrial furnaces that are not subject to regulation under the 2002 interim standards.

Benefits from Non Cancer Risk Reductions Most of the human health benefits from the proposed HWC MACT replacement standards come from reductions in particulate matter. Some additional benefits which are not quantified in this analysis, may come from reductions in exposure to lead, mercury, chlorine, and dioxin for people living near combustion facilities. 39 Total annual health benefits are valued at about $ 5$ 4.12 million forunder the Option 1 Floor and Option 2 Floor and,*** $ 4.16 million under*** the Agency Preferred Approach, and $ 10$ 8.08 million for Option 3 Floor.

Particulate Matter. The proposed HWC MACT replacement standards are expected to avoid less than one premature death for each of the regulatory options, 54 illnesses annually for Option 1 Floor and Option 2 Floor and Agency Preferred Approach, and 105 illnesses annually for FINAL DRAFT: March 2004 40 U. S. EPA, Environmental Health Threats to Children, EPA 175 F 96 001, September 1996, page 4.

6 29 Option 3 Floor; all illnesses are associated with exposure to PM. These and other human health benefits related to reduced PM exposure are valued at $ 5$ 2.68 million to $ 10$ 5.64 million per year under the Agency Preferred Approach. Benefits from reduced exposure to PM come primarily from liquid boilers. Reductions in the number of respiratory diseases account for over half of the morbidity benefits. While separate results are not available for children, it is safe to assume that many of the respiratory health benefits will be experienced by children, who are thought to be especially vulnerable to the effects of PM exposure. 40 Mercury. *** The 1999 standards were expected to reduce mercury emission by four tons per year. The proposed HWC MACT replacement standards are expected to reduceMercury emitted from hazardous waste burning incinerators, kilns, boilers, and other natural and man made sources is carried by winds through the air and eventually is deposited to water and land. Recent estimates ( which are highly uncertain) of annual total global mercury emissions by an additional one ton per year ( Exhibit 6 5). The benefitsfrom all sources ( natural and anthropogenic) are about 5,000 to 5,500 tons per year ( tpy). Of this total, about 1,000 tpy are estimated to be natural emissions and about 2,000 tpy are estimated to be contributions through the natural global cycle of re emissions of mercury associated with the reduction under the proposed HWC MACT replacement standards are not quantified in this analysis.

The 1999 Assessment found risk reductions in recreational anglers potentially exposed to mercury contaminated fish could be significant, with fewer anglers at risk for having offspring with developmental abnormalities. Baseline mercury risks are greatest for subsistence fishermen, individuals who obtain a significant portion of their dietary fish intake from self caught fish. Subsistence fishermen face an overall non cancer risk with a hazard index as high as 10 for some individuals that is driven primarily by methyl mercury. The 1999 Assessment found the baseline risks for mercury to be less than one for methyl mercury intake from fish for recreational anglers andpast anthropogenic activity. Current anthropogenic emissions account for the remaining 2,000 tpy. Point sources such as fuel combustion; waste incineration; industrial processes; and metal ore roasting, refining, and processing are the largest point source categories on a world wide basis. Given the global estimates noted above, U. S. anthropogenic mercury emissions are estimated to account for roughly 3 percent of the global total, and U. S. hazardous waste burning incinerators, kilns, and boilers are estimated to account for about 0.0045 percent of total global emissions.

Mercury exists in three forms: elemental mercury, inorganic mercury compounds ( primarily mercuric chloride), and organic mercury compounds ( primarily methylmercury). Mercury is usually released in an elemental form and later converted into methylmercury by bacteria. Methylmercury may be more toxic to humans than other forms of mercury, in part because it is more easily absorbed FINAL DRAFT: March 2004 41 Regulatory Impact Analysis of the Final Industrial Boilers and Process Heaters NESHAP: Final Report, February 2004.

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

6 30 in the body41. If the deposition is directly to a water body, then the processes of aqueous fate, transport, and transformation begin. If deposition is to land, then terrestrial fate and transport processes occur first and then aqueous fate and transport processes occur once the mercury has cycled into a water body. In both cases, mercury may be returned to the atmosphere through resuspension. In water, mercury is transformed to methylmercury through biological processes and for exposures affected by this rulemaking. Methylmercury is considered to be the form of greatest concern. Once mercury has been transformed into methylmercury, it can be ingested by the lower trophic level organisms where it can bioaccumulate in fish tissue ( i. e., concentrations of mercury remain in the fish's system for a long period of time and accumulates in the fish tissue as predatory fish consume other species in the food chain). Fish and wildlife at the top of the food chain can, therefore, have mercury concentrations that are higher than the lower species, and they can have concentrations of mercury that are higher than the concentration found in the water body itself. In addition, when humans consume fish containing methylmercury, the ingested methymercury is almost completely absorbed into the blood and distributed to all tissues ( including the brain); it also readily passes through the placenta to the fetus and fetal brain42.

Based on the findings of the National Research Council, EPA has concluded that benefits of Hg reductions would be most apparent at the human consumption stage, as consumption of fish is the major source of exposure to methylmercury. At lower levels, documented Hg exposure effects may include more subtle, yet potentially important, neurodevelopmental effects. Some subpopulations in the U. S., such as: Native Americans, Southeast Asian Americans, and lower income subsistence fishers. Following the implementation of the proposed HWC MACT replacement standards, the hazard index, may rely on fish as a primary source of nutrition and/ or for cultural practices. Therefore, they consume larger amounts of fish than the general population and may be at a greater risk to the adverse health effects from Hg due to increased exposure. In pregnant women, methylmercury can be passed on to the developing fetus, and at sufficient exposure may lead to a number of neurological disorders in children. Thus, children who are exposed to low concentrations of methylmercury prenatally may be at increased risk of poor performance on neurobehavioral tests, such as those measuring attention, fine motor function, language skills, visual spatial abilities ( like drawing), and verbal memory. The effects from prenatal exposure can occur even at doses that do not result in effects in the mother. Mercury may also affect young children who consume fish containing mercury. Consumption by children may lead to neurological disorders and developmental FINAL DRAFT: March 2004 6 31 problems, which may lead to later economic consequences.

In response to potential risks of mercury containing fish consumption, EPA and FDA have issued fish consumption advisories which provide recommended limits on consumption of certain fish species for different populations. EPA and FDA have developed a new joint advisory that was released in March 2004. This new FDA EPA fish advisory recommends that women and young children reduce the risks of Hg consumption in their diet by moderating their fish consumption, diversifying the types of fish they consume, and by checking any local advisories that may exist for local rivers and streams. This collaborative FDA EPA effort will greatly assist in educating the most susceptible populations. Additionally, the reductions of Hg from this regulation may potentially lead to fewer fish consumption advisories ( both from federal or state agencies), which will benefit the fishing community. Currently 44 states have issued fish consumption advisories for non commercial fish for some or all of their waters due to contamination of mercury. The scope of FCA issued by states varies considerably, with some warnings applying to all water bodies in a state and others applying only to individual lakes and streams. Note that the absence of a state advisory does not necessarily indicate that there is no risk of exposure to unsafe levels of mercury in recreationally caught fish. Likewise, the presence of a state advisory does not indicate that there is a risk of exposure to unsafe levels of mercury in recreationally caught fish, unless people consume these fish at levels greater than those recommended by the fish advisory.

Reductions in methylmercury concentrations in fish should reduce exposure, subsequently reducing the risks of mercury related health effects in the general population, to children, and to certain subpopulations. Fish consumption advisories ( FCA) issued by the States may also help to reduce exposures to potential harmful levels of methylmercury in fish. To the extent that reductions in mercury emissions reduces the probability that a water body will have a FCA issued, there are a number of benefits that will result from fewer advisories, including increased fish consumption, increased fishing choices for recreational fishers, increased producer and consumer surplus for the commercial fish market, and increased welfare for subsistence fishermen may be further reduced, suggesting that subsistence fishermen will potentially experience reduced risks of having children with developmental abnormalities. This reduction is likely to be less than the reductions described in the 1999 Assessment, but relying on past analyses may also underestimate the benefits of reduced mercuryfishing populations.

There is a great deal of variability among individuals in fish consumption rates; however, critical elements in estimating methylmercury exposure, as mercury health science is continuing to evolve. and risk from fish consumption include the species of fish consumed, the concentrations of methylmercury in the fish, the quantity of fish consumed, and how frequently the fish is consumed. The typical U. S. consumer eating a wide variety of fish from restaurants and grocery stores is not in danger of consuming harmful levels of methylmercury from fish and is not advised to limit fish FINAL DRAFT: March 2004 6 32 consumption. Those who regularly and frequently consume large amounts of fish, either marine or freshwater, are more exposed. Because the developing fetus may be the most sensitive to the effects from methylmercury, women of child bearing age are regarded as the population of greatest interest. The EPA, Food and Drug Administration, and many States have issued fish consumption advisories to inform this population of protective consumption levels.

The EPA's 1997 Mercury Study RTC supports a plausible link between anthropogenic releases of Hg from industrial and combustion sources in the U. S. and methylmercury in fish. However, these fish methylmercury concentrations also result from existing background concentrations of Hg ( which may consist of Hg from natural sources, as well as Hg which has been re emitted from the oceans or soils) and deposition from the global reservoir ( which includes Hg emitted by other countries). Given the current scientific understanding of the environmental fate and transport of this element, it is not possible to quantify how much of the methylmercury in locallycaught fish consumed by the U. S. population is contributed by U. S. emissions relative to other sources of Hg ( such as natural sources and re emissions from the global pool). As a result, the relationship between Hg emission reductions from Phase I and Phase II sources assessed in this rule, FINAL DRAFT: March 2004 43The primary form of lead exposure to children is via ingestion of contaminated soil.

6 33 and methylmercury concentrations in fish cannot be calculated in a quantitative manner with confidence. In addition, there is uncertainty regarding over what time period these changes would occur.

Given the present understanding of the Hg cycle, the flux of Hg from the atmosphere to land or water at one location is comprised of contributions from: the natural global cycle; the cycle perturbed by human activities; regional sources; and local sources. Recent advances allow for a general understanding of the global Hg cycle and the impact of the anthropogenic sources. It is more difficult to make accurate generalizations of the fluxes on a regional or local scale due to the sitespecific nature of emission and deposition processes. Similarly, it is difficult to quantify how the water deposition of Hg leads to an increase in fish tissue levels. This will vary based on the specific characteristics of the individual lake, stream, or ocean.***

Lead. The proposed HWC MACT replacement standards will reduce lead emissions by approximately five to seven tons per year for the Floor and Agency Preferred Approach options ( Exhibit 6 5). In comparison, the 1999 standards were expected to reduce lead emissions by 89 tons per year, and were expected to reduce cumulative lead exposures for twoseven children age 0 5 to less than 10 µ g/ dL. The benefits associated with the proposed HWC MACT replacement standards are therefore expected to be modest, reducing the cumulative lead exposures for less than twoseven children age 0 5 less than 10 µ g/ dL annually. 43 The proposed HWC MACT replacement standards will also result in reduced lead levels for children of sub populations with especially high levels of exposure. Children of subsistence fishermen, commercial beef farmers, and commercial dairy farmers who face the greatest levels of cumulative lead exposure will also experience comparable reductions in overall exposure as a result of the MACT standards. The small number of cases identified in the 1999 Assessment suggests that these benefits may be modest.

NOTE: This chapter does not provide quantified or monetary estimates of the benefits associated with reduced dioxin emissions. However, estimates of the benefits associated with reduced dioxin emissions under the revised proposal for the HWC MACT replacement standards are available in EPA, " Addendum to the Assessment of the Costs, Benefits, and Other Impacts of the Hazardous Waste Combustion MACT Standards: Proposed Rule," March 2004. This document is available in the docket. FINAL DRAFT: March 2004 6 34 Human Health Benefits Summary The measurable annual human health benefits associated with emission reductions from Option 1 Floor and Option 2 Floor of the HWC MACT replacement standards include less than one avoided premature death, reductions of 1.3 hospital admission ( respiratory illness and cardiovascular disease involve hospital admissions), ten cases of bronchitis, 5242 cases of respiratory symptoms, and about 4,200 days of work loss or MRAD. For Option 3 Floor annual human health benefits include less than one avoided premature death, reductions of three hospital admission, 19 cases of bronchitis, 10283 cases of respiratory symptoms, and about 8,200 days of work loss or MRAD. Additional ecological and human health benefits are possible but not quantified in this analysis due to lack of data. Exhibit 6 86 summarizes the quanitifiable human health benefits across combustion sources for the Agency Preferred Approach and Floor options 1 through 3. Overall, the majority of the human health benefits are due to reductions in liquid boiler emissions. This is primarily due to the fact that liquid boilers comprise the largest portion of the total number of hazardous waste combustion systems, roughly 40 percent.

Annual human health benefits associated with emission reductions from the Agency Preferred Approach include less than one avoided premature death, reductions of 1.3 hospital admission, ten cases of bronchitis, 5343 cases of respiratory symptoms, and about 54,000200 days of work loss or MRAD. The Agency Preferred Approach does have additional health benefits that are not quantified, including Clchlorine, dioxin, metals, etc. This analysis quantifies only the human health benefits associated with reduction in PM emissions. Thus, the quantified Agency Preferred Approach benefits do not differ greatly from Option 1 Floor and Option 2 Floor and are less than Option 3 Floor ( ExhibitExhibits 6 4 and 6 5).

However, one of the greatestmost substantial differences between the HWC MACT Standards Floor options and the Agency Preferred Approach; is the increased reduction in dioxin emissions withunder the Agency Preferred Approach; a six foldn eleven fold increase in emissions reduced is expected under the Agency PreferencePreferred Approach when compared to the Option 1 Floor ( see Exhibit 6 3). The primary concern associated with dioxin is increased cancer risk. In the 1999 Assessment cancer risk reductions linked to consumption of dioxin contaminated agricultural products exported beyond 20 km of the facility accounted for the majority of the 0.376 cancer cases per year that were expected to be avoided due to the 1999 standards. Although tThe incremental reduction in dioxin emissions from the Agency Preferred Approach areis expected to be about 12 times less than6 percent of the reductions achieved under the 1999 standards,*** recent studies have shown a substantial increase in cancer risk estimates for exposure to dioxin. ( See, for example, Steenland et al. ( 1999), Fingerhut et al. ( 1991), Becher et al. ( 1996), Flesch Janys et al. ( 1995, 1998, 1999), Manz et al. ( 1991), Ott et al. ( 1996), FINAL DRAFT: March 2004 44 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.

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

46 Baseline cancer risk for subsistence farmers ages 0 5 and 6 11 associated with cement kiln emissions was 2E 05; it remained 2E 05 following the implementation of the 1999 standards. It is important to emphasize that because of the absence of subsistence farmer population estimates, these hypothetical scenarios represent only the upper bound, worst case risks possible. No conclusions can be made as to the incidence rates associated with these 6 35 Zober et al. ( 1990), Kogevinas et al. ( 1997), Saracci et al. ( 1991), and Hooiveld et al. ( 1996, 1998)). 35 *** As a result, benefits.

*** For the past 12 years the Agency has been conducting a reassessment of the human health risks associated with reductions in dioxin may be significantly higher than the quantified estimates provided here ( e. g. because the estimates here are based on older studies). dioxin and dioxin like compounds. This reassessment44 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.***

Reduced dioxin emissions may result in additional cancer risk reductions for the most sensitive sub populations,: subsistence fishermen and farmers, and their children. Because we do not have population data for the most sensitive sub populations, we can only describe individual risk results for subsistence farmers and fishermen and cannot make statements concerning the total number of people that may experience health benefits associated with the Agency Preferred Approach. In 1999, across all receptor populations, individual cancer risks were greatest for subsistence farmers. These cancer risks were driven primarily by dioxin and arsenic. Subsistence farmers exposed to the highest individual risks faced getting cancer with a probability of five in 100,000.45 With the exception of one particular scenario, the cancer risk for all subsistence farmers was reduced to below levels of concern after implementation of the 1999 standards, based on risk data available at the time. However the 1999 standards did not address boilers and industrial furnaces. 46 Children of subsistence farmers, who FINAL DRAFT: March 2004 hypothetical worst case individual risks.

6 36 potentially face the greatest individual risk of any receptor population, were expected to experience a reduction in individual cancer risk by a factor as high as 0.005. FINAL DRAFT: March 2004 6 37 Exhibit 6 64 HUMAN HEALTH BENEFITS SUMMARY: BASELINE TO AGENCY PREFERRED APPROACH Type of Benefit Reduction in Number of Cases per Year Annual Undiscounted Value ( 2002$) ( millions)

Human Health Benefits Premature deaths avoidedavoideda 0.3 $ 2$ 1.81 ($ 0.33  $ 3.279)

Respiratory illness 0.9 $ 0.01 Cardiovascular disease 0.4 $ 0.01 Chronic bronchitis 5.7 $ 2.7314 Acute bronchitis 4.3 $ 0 Lower respiratory symptoms 38.4 $ 0 Upper respiratory symptoms 4.5 $ 0 Work loss days 451.1 $ 0.05 Minor restricted activity days 37573,757.8 $ 0.2115 Restricted Activity Days 1,237.5 NAb Total Annual Monetary Benefits $ 5.28 $ 4.16 ($ 2.68  $ 5.64)

Notes:

a. *** Avoided mortality is expressed in millions of 1999 dollars. Range of avoided mortality benefits reflects VSL range of $ 1.0 million to $ 10.0 million, consistent with the range presented in U. S. EPA Benefits of the Proposed Inter State Air Quality Rule, January 2004.*** b. To avoid potential double counting with minor restricted activity days, benefits associated with restricted activity days are not monetized. FINAL DRAFT: March 2004 6 38 Exhibit 6 75 HUMAN HEALTH BENEFITS SUMMARY: BASELINE TO PROPOSED HWC MACT REPLACEMENT STANDARDS FLOOR OPTIONS Option Option 1 Floor Option 2 Floor Option 3 Floor Type of Benefit Reduction in Number of Cases per Year Annual Undiscounted Value ( 2002$) ( millions) Reduction in Number of Cases per Year Annual Undiscounted Value ( 2002$) ( millions) Reduction in Number of Cases per Year Annual Undiscounted Value ( 2002$) ( millions)

Human Health Benefits Premature deaths avoided 0.3 $ 2$ 1.79 ($ 0.33  $ 3.256) 0.3 $ 2$ 1.79 ($ 0.33  $ 3.256) 0.6 $ 4$ 3.53 ($ 0.64  $ 6.42)

Respiratory illness 0.9 $ 0.01 0.9 $ 0.01 1.7 $ 0.02 Cardiovascular disease 0.4 $ 0.01 0.4 $ 0.01 0.8 $ 0.01 Chronic bronchitis 5.6 $ 2.7112 5.6 $ 2.7112 11.0 $ 54.2813 Acute bronchitis 4.3 $ 0 4.3 $ 0 8.4 $ 0 Lower respiratory symptoms 38.1 $ 0 38.1 $ 0 74.2 $ 0 Upper respiratory symptoms 4.4 $ 0 4.4 $ 0 8.6 $ 0 Work loss days 447.3 $ 0.05 447.3 $ 0.05 874.7 $ 0.110 Minor restricted activity days 37263,726.1 $ 0.2115 37263,726.1 $ 0.2115 72877,287.2 $ 0.4029 Restricted activity days 1,227.1 NAb 1,227.1 NAb 2,399.8 NAb Total Annual Monetary Benefits $ 54.2312 $ 5.23$ 10.25($ 2.66

$ 5.59) $ 4.12 ($ 2.66  $ 5.59) $ 8.08 ($ 5.19  $ 10.97) FINA 6 39 Notes: a. *** Range of avoided mortality benefits reflects VSL range of $ 1.0 million to $ 10.0 million, consistent with VSL estimates presented in U. S. E Inter State Air Quality Rule, January 2004.*** b. To avoid potential double counting with minor restricted activity days, benefits associated with restricted activity days are not monetized. FINAL DRAFT: March 2004 6 40 Exhibit 6 86 BENEFITS SUMMARY: CASES AVOIDED BY SOURCE, BASELINE TO PROPOSED HWC MACT REPLACEMENT STANDARDS Agency Recommended Approach Option 1 Floor Option 2 Floor Option 3 Floor Type of Benefit Reduction in Number of Cases per Year Annual Undiscounted Value ( 2002$ millions) Reduction in Number of Cases per Year Annual Undiscounted Value ( 2002$ millions) Reduction in Number of Cases per Year Annual Undiscounted Value ( 2002$ millions) Reduction in Number of Cases per Year Annual Undiscounted Value ( 2002$ millions)

LWAK/ Human Health Benefits Premature deaths avoided 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Respiratory illness 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Cardiovascular disease 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Chronic bronchitis 0.1 $ 0.043 0.1 $ 0.043 0.1 $ 0.043 0.1 $ 0.043 Acute bronchitis 0.1 $ 0.00 0.1 $ 0.00 0.1 $ 0.00 0.1 $ 0.00 Lower respiratory symptoms 0.5 $ 0.00 0.5 $ 0.00 0.5 $ 0.00 0.5 $ 0.00 Upper respiratory symptoms 0.1 $ 0.00 0.1 $ 0.00 0.1 $ 0.00 0.1 $ 0.00 Work loss days 4.2 $ 0.00 4.2 $ 0.00 4.2 $ 0.00 4.2 $ 0.00 Minor restricted activity 35.0 $ 0.00 35.0 $ 0.00 35.0 $ 0.00 35.0 $ 0.00 Subtotal $ 0.043 $ 0.043 $ 0.043 $ 0.043 Cement Kilns/ Human Health Benefits Premature deaths avoided 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Respiratory illness 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Cardiovascular disease 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Chronic bronchitis 0.1 $ 0.043 0.1 $ 0.043 0.1 $ 0.043 0.1 $ 0.064 Acute bronchitis 0.1 $ 0.00 0.1 $ 0.00 0.1 $ 0.00 0.1 $ 0.00 Lower respiratory symptoms 0.6 $ 0.00 0.6 $ 0.00 0.6 $ 0.00 0.9 $ 0.00 Upper respiratory symptoms 0.1 $ 0.00 0.1 $ 0.00 0.1 $ 0.00 0.1 $ 0.00 Work loss days 4.1 $ 0.00 4.1 $ 0.00 4.1 $ 0.00 5.9 $ 0.00 Minor restricted activity 34.4 $ 0.00 34.4 $ 0.00 34.4 $ 0.00 48.9 $ 0.00 FINAL DRAFT: March 2004 Exhibit 6 86 BENEFITS SUMMARY: CASES AVOIDED BY SOURCE, BASELINE TO PROPOSED HWC MACT REPLACEMENT STANDARDS Agency Recommended Approach Option 1 Floor Option 2 Floor Option 3 Floor Type of Benefit Reduction in Number of Cases per Year Annual Undiscounted Value ( 2002$ millions) Reduction in Number of Cases per Year Annual Undiscounted Value ( 2002$ millions) Reduction in Number of Cases per Year Annual Undiscounted Value ( 2002$ millions) Reduction in Number of Cases per Year Annual Undiscounted Value ( 2002$ millions)

6 41 Subtotal $ 0.043 $ 0.043 $ 0.043 $ 0.065 All Incinerators/ Human Health Benefits Premature deaths avoided 0.0 $ 0.141 0.0 $ 0.141 0.0 $ 0.141 0.0 $ 0.260 Respiratory illness 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.1 $ 0.00 Cardiovascular disease 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Chronic bronchitis 0.3 $ 0.162 0.3 $ 0.162 0.3 $ 0.162 0.6 $ 0.293 Acute bronchitis 0.3 $ 0.00 0.3 $ 0.00 0.3 $ 0.00 0.5 $ 0.00 Lower respiratory symptoms 2.4 $ 0.00 2.4 $ 0.00 2.4 $ 0.00 4.4 $ 0.00 Upper respiratory symptoms 0.3 $ 0.010 0.3 $ 0.010 0.3 $ 0.00 0.5 $ 0.00 Work loss days 27.5 $ 0.00 27.5 $ 0.00 27.5 $ 0.00 50.4 $ 0.01 Minor restricted activity 229.1 $ 0.01 229.1 $ 0.01 229.1 $ 0.01 419.9 $ 0.02 Subtotal $ 0.3125 $ 0.3125 $ 0.3125 $ 0.5845 FINAL DRAFT: March 2004 Exhibit 6 86 BENEFITS SUMMARY: CASES AVOIDED BY SOURCE, BASELINE TO PROPOSED HWC MACT REPLACEMENT STANDARDS Agency Recommended Approach Option 1 Floor Option 2 Floor Option 3 Floor Type of Benefit Reduction in Number of Cases per Year Annual Undiscounted Value ( 2002$ millions) Reduction in Number of Cases per Year Annual Undiscounted Value ( 2002$ millions) Reduction in Number of Cases per Year Annual Undiscounted Value ( 2002$ millions) Reduction in Number of Cases per Year Annual Undiscounted Value ( 2002$ millions)

6 42 Coal Boilers/ Human Health Benefits Premature deaths avoided 0.0 $ 0.02 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Respiratory illness 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Cardiovascular disease 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Chronic bronchitis 0.1 $ 0.02 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Acute bronchitis 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Lower respiratory symptoms 0.4 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Upper respiratory symptoms 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Work loss days 4.2 $ 0.00 0.4 $ 0.00 0.4 $ 0.00 0.4 $ 0.00 Minor restricted activity 34.9 $ 0.00 3.2 $ 0.00 3.2 $ 0.00 3.2 $ 0.00 Subtotal $ 0.054 $ 0.00 $ 0.00 $ 0.00 HCl Production Furnaces/ Human Health Benefits Premature deaths avoided 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Respiratory illness 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Cardiovascular disease 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Chronic bronchitis 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Acute bronchitis 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Lower respiratory symptoms 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Upper respiratory symptoms 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Work loss days 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 FINAL DRAFT: March 2004 Exhibit 6 86 BENEFITS SUMMARY: CASES AVOIDED BY SOURCE, BASELINE TO PROPOSED HWC MACT REPLACEMENT STANDARDS Agency Recommended Approach Option 1 Floor Option 2 Floor Option 3 Floor Type of Benefit Reduction in Number of Cases per Year Annual Undiscounted Value ( 2002$ millions) Reduction in Number of Cases per Year Annual Undiscounted Value ( 2002$ millions) Reduction in Number of Cases per Year Annual Undiscounted Value ( 2002$ millions) Reduction in Number of Cases per Year Annual Undiscounted Value ( 2002$ millions)

6 43 Minor restricted activity 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 0.0 $ 0.00 Subtotal $ 0.00 $ 0.00 $ 0.00 $ 0.00 Liquid Boilers/ Human Health Benefits Premature deaths avoided 0.3 $ 21.1068 0.3 $ 21.1068 0.3 $ 21.1068 0.6 $ 43.1733 Respiratory illness 0.8 $ 0.01 0.8 $ 0.01 0.8 $ 0.01 1.6 $ 0.021 Cardiovascular disease 0.4 $ 0.01 0.4 $ 0.01 0.4 $ 0.01 0.7 $ 0.01 Chronic bronchitis 5.1 $ 21.4894 5.1 $ 21.4894 5.1 $ 21.4894 10.2 $ 43.9083 Acute bronchitis 3.9 $ 0.00 3.9 $ 0.00 3.9 $ 0.00 7.7 $ 0.00 Lower respiratory symptoms 34.5 $ 0.00 34.5 $ 0.00 34.5 $ 0.00 68.4 $ 0.00 Upper respiratory symptoms 4.0 $ 0.00 4.0 $ 0.00 4.0 $ 0.00 7.9 $ 0.00 Work loss days 411.1 $ 0.05 411.1 $ 0.05 411.1 $ 0.05 813.9 $ 0.1009 Minor restricted activity 3,424.3 $ 0.193 3,424.3 $ 0.193 3,424.3 $ 0.193 6,780.1 $ 0.3827 Subtotal $ 43.841 $ 43.841 $ 43.841 $ 97.584 Total $ 54.2816 $ 54.2312 $ 54.2312 $ 10.25$ 8.08 FINAL DRAFT: March 2004 47 Chestnut, L. and R. Rowe. 1989. " Economic Valuation of Changes in Visibility: A State of the Science Assessment for NAPAP," as cited in National Acid Preparation Assessment Program, Methods for Valuing Acidic Deposition and Air Pollution Effects. NAPAP State of Science and State of Technology Report No. 27, Part B. December, as cited in Industrial Economics, Incorporated, " Initial Review of Potential Benefits Associated with Hazardous Waste Combustion MACT Standards," Memorandum, prepared for U. S. EPA, 30 April, 2002. ..

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

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

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

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

6 44 VISIBILITY BENEFITS Particulate matter emissions are a primary cause of reduced visibility. Changes in the level of ambient PM caused by the reduction in emissions from the proposed HWC MACT replacement standards will increase the level of visibility in some parts of the U. S. Visibility directly affects people's enjoyment of a variety of daily activities. Individuals value visibility both in the places they live and work, in the places they travel to for recreational purposes. For example, Chestnut and Row ( 1989) examined WTP for improved visibility in recreational settings. 47 In addition, Chestnut and Dennis ( 1997) used data representative of the Eastern United States from McClelland et al. ( 19901) to measure WTP in residential areas. 48,49 EPAWe hasve incorporated these methods in The Benefits and Costs of the Clean Air Act 1990 to 2010. We can estimate the upper bound and lower bound benefits associated with PM emissions reductions with the proposed HWC MACT replacement standards using two different methodologies, each comparing reductions to those associated with the Clean Air Act.

The first approach assumes a linear relationship between PM reductions and visibility improvements. A national decrease of PM emissions of two percent ( 823,000 tons annually) is associated with annual visibility benefits of roughly $ 2.75 billion ( in 2002 dollars). 50 Assuming a linear relationship, reduced PM associated with the proposed HWC MACT replacement standards could result in a visibility benefit from approximately $ 7$ 6.12 million for the Option 1 Floor and the Option 2 Floor, $ 8$ 7.41 million for the Agency Preferred Approach, and $ 12$ 10.89 million for Option 3 Floor, proportional to national reductions. This comparative approach of linear extrapolation produces similar results ($ 6.12 million to $ 11$ 10.89 million) when comparing benefits of emissions reductions of the Draft Regulatory Impact Analysis: Control of Emission from Nonroad Diesel Engines. 51 The Draft Regulatory Impact Analysis: Control of Emission from Nonroad Diesel Engines used a similar approach to the The Benefits and Costs of the Clean Air Act 1990 to 2010. FINAL DRAFT: March 2004 52 Although no quantified analysis of the proximity of facilities to Class 1 areas has been performed, facilities are distributed over a wide area including Gulf of Mexico Coast, Great Lakes, and the Mississippi which include numerous recreation areas. Also, the WTP of households for increases in residential visibility is higher than their WTP for recreational visibility. The EPA, in The Benefits and Costs of the Clean Air Act 1990 to 2010, estimated the WTP per household for residential visibility changes to be $ 141, and $ 65 to $ 137 for recreational visibility changes in National Parks ( depending on household and park location). Thus, visibility benefits are likely.

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

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

6 45 This approach has several limitations. In The Benefits and Costs of the Clean Air Act 1990 to 2010 and Draft Regulatory Impact Analysis: Control of Emission from Nonroad Diesel Engines EPA valued recreational visibility ( e. g., realized through visits to Class 1 areas, most of which are National Parks). 52 In this Assessment no quantified analysis of the proximity of facilities to Class I areas has been performed. Another limitation of this method is that it assumes that visibility improvements are related to direct PM emissions only. In both The Benefits and Costs of the Clean Air Act 1990 to 2010 and Draft Regulatory Impact Analysis: Control of Emission from Nonroad Diesel Engines EPA valued both direct PM emissions and gaseous PM precursors. No reductions in gaseous precursors are quantified for the proposed HWC MACT replacement standards, thus, this method may overestimate visibility benefits and represents the upper bound of potential visibility benefits.

The second approach is to assume a linear relationship between health benefits and visibility benefits associated with reduction in PM emissions. In The Benefits and Costs of the Clean Air Act 1990 to 2010 annual human health benefits of roughly $ 6893 to $ 1048 billion ( 2002 dollars) and visibility benefits of $ 2 to $ 3 billion are estimated for reductions in PM emissions. 53 In the Draft Regulatory Impact Analysis: Control of Emission from Nonroad Diesel Engines EPAthe Agency estimatesd human health benefits of $ 5861 to $ 1048 billion ( 2002 dollars) and visibility benefits of $ 1 to $ 2 billion associated with reductions in PM emissions. 54 Assuming a linear relationship between human health benefits and visibility benefits, the proposed HWC MACT replacement standards could result in a visibility benefit of approximately $ 13304,000900 for the Option 1 Floor and Option 2 Floor, $ 13405,000800 for the Agency Preferred Approach, and $ 26105,000500 for Option 3 Floor. This approach also has several limitations as it still does not take into account Class I areas, or any reductions in PM precursors. This method represents the lower bound of visibility benefits.

ECOLOGICAL BENEFITS This section provides a comparison of the ecological benefits derived in the 1999 Assessment and the potential benefits associated with the proposed HWC MACT replacement standards. Ecological benefits derived in the 1999 Assessment were based on a screening analysis for ecological risks that compared soil, surface water, and sediment concentrations with eco toxicological criteria based on de minimis thresholds for ecological effects. Because these criteria represented conservative values, an exceedence of the eco toxicological criteria only indicates the potential for adverse ecological effects and does not necessarily indicate ecological damages. For this reason, the benefits of avoiding adverse ecological impacts were discussed qualitatively. FINAL DRAFT: March 2004 55 Threatened and endangered species and/ or habitats were not included in the analysis.

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

6 46 The basic approach for determining whether ecosystems and/ or biota are potentially at risk consisted of five steps:

First, the risk assessment identified susceptible ecological receptors. Because combustion facilities are located across the country, ecological receptors for the screening analysis were chosen to represent relatively common species and communities of wildlife. 55

Second, the risk assessment developed eco toxicological criteria for receptors that represent acceptable pollutant concentrations ( e. g., at these levels, there is a low potential for adverse ecological effects). 56

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

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

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

To assess potential ecological benefits from the risk assessment results, the number of sectors or water bodies potentially at risk in the baseline with the number post 1999 standards were compared. The reduction in the number of sectors or water bodies potentially at risk indicated a potential for avoiding adverse ecological impacts. Monetary values were not assigned to these potential benefits because the surface area of land or water affected corresponding to the number of grid sectors or water bodies potentially at risk could not be calculated, and no clear link exists between an exceedance in the eco toxicological criteria and a real benefit measure, such as increased fish populations, for which a benefits transfer approach could assign monetary values. FINAL DRAFT: March 2004 57 The low end estimate assumed the same waterbodies or land areas are affected by different pollutants. That is, under the six square kilometers of land nearby incinerators that experienced ecological improvements associated with lead emission reductions are captured in the 87 square kilometers of land nearby incinerators associated with mercury reductions.

58 Although the primary pollutants which are detrimental to vegetation aesthetics and growth are tropospheric ozone, sulfur dioxide, and hydrogen fluoride, three pollutants which are not regulated in the MACT standards, some literature exists on the relationship between metal deposition and vegetation health. ( Studies cited in U. S. EPA. Mercury Study Report to Congress Volume VI, 1997) ( Several studies are cited in this report.), Volume VI: An Ecological Assessment for Anthropogenic Mercury Emissions in the United States. December 1997).

6 47 Ecological Benefit Results Ecological benefits were assessed in the 1999 Assessment based on reductions of approximately 100 tons per year in dioxin/ furans and selected metals. Lead was the only pollutant of concern for aquatic ecosystems. Mercury appeared to be of greatest concern for terrestrial ecosystems. Dioxin and lead emission reductions also provided some potential benefits for terrestrial ecosystems. Under the 1999 standards, the eco toxicological hazard quotient was reduced to below the level of concern for 38 square kilometers of water surface area. For terrestrial ecosystems, the land area that experienced reductions in ecological risk criteria below levels of concern ranged from 115 square kilometers to 147 square kilometers under the 1999 standards. 57 The proposed HWC MACT replacement standards will reduce dioxin/ furans and selected metals from 17 tons annually for Option 1 Floor and Agency Preferred Approach, Option 2 Floor 18 tons annually, and 22 tons annually for Option 3 Floor. In general the proposed HWC MACT replacement standards will produce fewer incremental benefits than those estimated for the 1999 Assessment ( and later, for the 2002 Interim standards). However, the 1999 Assessment did not estimate the ecological benefits of MACT standards for boilers and industrial furnaces. These systems were excluded from the universe in 1999 but are part of the universe addressed by the proposed HWC MACT repayment standards. As a result, while the total ecological benefits of the proposed rule are likely to be modest, areas near facilities with boilers may enjoy more significant ecological benefits under the proposed HWC MACT replacement standards than areas near facilities that have already complied with the 2002 Interim standards.

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

Forest Health and Aesthetics Mercury, lead, and chlorides are among the HAPs that can cause damage to the health and visual appearance of plants. 58 While the total value of forest health is difficult to estimate, visible deterioration in the health of forests and plants can cause a measurable change in recreation behavior. Several studies that measure the change in outdoor recreation behavior according to forest FINAL DRAFT: March 2004 59 See, for example, Brown, T. C. et al. 1989, Scenic Beauty and Recreation Value: Assessing the Relationship, In J. Vining, ed., Social Science and Natural Resources Recreation Management, Westview Press, Boulder, Colorado, as cited in Industrial Economics, Incorporated, " Initial Review of Potential Benefits Associated with Hazardous Waste Combustion MACT Standards," Memorandum, prepared for U. S. EPA, 30 April, 2002; this work studies the relationship between forest characteristics and the value of recreational participation. AFor estimates of the WTP of visitors and residents to avoid forest damage, also see Peterson, D. G. et al. 1987, Improving Accuracy and Reducing Cost of Environmental Benefit Assessments. Draft Report to the US EPA, by Energy and Resource Consultants, Boulder, Colorado, as cited in Industrial Economics, Incorporated, " Initial Review of Potential Benefits Associated with Hazardous Waste Combustion MACT Standards," Memorandum, prepared for U. S. EPA, 30 April, 2002; Walsh et al. 1990, Estimating the public benefits of protecting forest quality, Journal of Forest Management, 30: 175 189, as cited in Industrial Economics, Incorporated, " Initial Review of Potential Benefits Associated with Hazardous Waste Combustion MACT Standards," Memorandum, prepared for U. S. EPA, 30 April, 2002; and Homes et al. 1992, Economic Valuation of Spruce Fir Decline in the Southern Appalachian Mountains: A comparison of Value Elicitation Methods. Presented at the Forestry and the Environment: Economic Perspectives Conference, March 9 1, 1992 Jasper, Alberta, Canada for estimates of the WTP of visitors and residents to avoid forest damage., as cited in Industrial Economics, Incorporated, " Initial Review of Potential Benefits Associated with Hazardous Waste Combustion MACT Standards," Memorandum, prepared for U. S. EPA, 30 April, 2002.

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

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

6 48 health are available to place a value on aesthetic degradation of forests. 59 Although these studies are available, additional research is needed to fully understand the effects of these HAPs on the forest ecosystem. Thus, these benefits are not quantified in this analysis.

Productivity to Agricultural Land Emissions that are sufficient to cause structural and aesthetic damage to vegetation are likely to affect growth as well. Little research has been done on the effects of compounds such as chlorine, heavy metals ( as air pollutants), and PM on agricultural productivity. 60 Even though the potential for visible damage and production decline from metals and other pollutants suggests the proposed HWC MACT replacement standards could increase agricultural productivity these changes cannot be quantified.

WASTE MINIMIZATION BENEFITS As discussed in Chapter 5, all commercial combustion facilities that remain in operation will experience increased costs under the MACT standards. To protect their profits, combustion facilities will have an incentive to pass these increased costs on to their customers in the form of higher combustion prices. In 1999 we conducted a waste minimization analysis to inform the expected price change under the 1999 ( and later the 2002 interim) standards. Based on the results of this analysis, we estimated that as much as 240,000 tons of waste might be reallocated to waste minimization alternatives in response to higher combustion prices. 61 Since the publication of the 1999 Assessment, however, approximately 100,000 tons of waste have already been reallocated. In addition, given the current pricing structure of the hazardous waste combustion market, the costs of waste minimization FINAL DRAFT: March 2004 62 In the long term, waste minimization may take place as companies upgrade manufacturing processes. However, increased waste management costs are only one factor in these larger decisions. We therefore do not anticipate that the replacement standards would cause a significant change in the quantity of waste combusted.

6 49 alternatives in the short term generally exceed the cost of combustion. 62 When the additional costs of compliance with the MACT standards are taken into account, waste minimization alternatives still tend to exceed the higher combustion costs. This inelasticity in the demand for combustion suggests that in the short term large reductions in waste quantities are not likely.

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

*** No waste minimization impacts are captured in the quantitative analysis of costs and benefits presented in this Assessment. A quantitative assessment of the benefits associated with waste minimization at the source may result in double counting of some of the benefits described earlier in this chapter. For example, waste minimization may further reduce emissions of hazardous air pollutants and therefore have a positive effect on public health. Emissions reductions beyond those necessary for compliance with the replacement standards are also not addressed in this benefits assessment. In addition, waste minimization is likely to result in specific types of benefits not captured in this Assessment. For example, waste generators that engage in waste minimization will experience a reduction in their waste handling costs and could also reduce the risk related to waste spills and waste management. The cost of implementing waste minimization technology has not been assessed in this analysis. These costs are likely to at least partially offset corresponding benefits. *** FINAL DRAFT: March 2004 6 50 Exhibit 6 97 BENEFITS SUMMARY: BASELINE TO PROPOSED HWC MACT REPLACEMENT STANDARDS ( 2002 Dollars in Millions)

Option Agency Preferred Approach Option 1 Floor Option 2 Floor Option 3 Floor Type of Benefit Reduction in Number of Cases per Year Annual Undiscounted Value Reduction in Number of Cases per Year Annual Undiscounted Value Reduction in Number of Cases per Year Annual Undiscounted Value Reduction in Number of Cases per Year Annual Undiscounted Value Human Health Benefits Premature deaths avoidedavoideda 0.3 $ 2$ 1.81 ($ 0.33

$ 3.279) 0.3 $ 2$ 1.79 ($ 0.33

$ 3.256) 0.3 $ 2$ 1.79 ($ 0.33

$ 3.256) 0.6 $ 4$ 3.53 ($ 0.64 $ 6.42)

Respiratory illness 0.9 $ 0.01 0.9 $ 0.01 0.9 $ 0.01 1.7 $ 0.02 Cardiovascular disease 0.4 $ 0.01 0.4 $ 0.01 0.4 $ 0.01 0.8 $ 0.01 Chronic bronchitis 5.7 $ 2.7314 5.6 $ 2.7112 5.6 $ 2.7112 11.0 $ 54.2813 Acute bronchitis 4.3 $ 0 4.3 $ 0 4.3 $ 0 8.4 $ 0 Lower respiratory symptoms 38.4 $ 0 38.1 $ 0 38.1 $ 0 74.2 $ 0 Upper respiratory symptoms 4.5 $ 0 4.4 $ 0 4.4 $ 0 8.6 $ 0 Work loss days 451.1 $ 0.05 447.3 $ 0.05 447.3 $ 0.05 874.7 $ 0.110 Minor restricted activity days 37573,757.8 $ 0.2115 37263,726.

1 $ 0.2115 37263,726.

1 $ 0.2115 72877,287.2 $ 0.4029 Annual Monetary Health Benefits $ 54.2816 $ 5.23$ 5.23$ 1 0.25($ 2.68

$ 5.64) $ 4.12 ($ 2.66 $ 5.59) $ 4.12 ($ 2.66 $ 5.59) $ 8.08 ($ 5.19$ 10.97)

Visibility Annual Monetary Visibility Benefits $ 0.131 to $ 87.0341 $ 0.130 to $ 6.6312 $ 0.130 to $ 6.6312 $ 0.261 to $ 110.809 FINAL DRAFT: March 2004 6 51 Total Annual Monetary Benefits $ 52.4179 to $ 13.3105 $ 52.3676 to $ 11.8771 $ 52.3676 to $ 11.87$ 10.51 to$ 22.0571 Notes: a. *** Avoided mortality is expressed in millions of 1999 dollars. Range of avoided mortality benefits reflects VSL range of $ 1.0 million to $ 10.0 range presented in U. S. EPA Benefits of the Proposed Inter State Air Quality Rule, January 2004.*** FINAL DRAFT: March 2004 6 52 CONCLUSIONS Overall, the Agency Preferred Approach is expected to result annually in approximately*** $ 5$ 4.16 million*** in human health benefits beyond the baseline. In addition, the proposed Agency Preferred Approach is expected to result in $ 1005,000800 to $ 8$ 7.41 million in visibility benefits beyond the baseline ( see Exhibit 6 87 for a summary of the quantified annual monetary benefits of the proposed HWC MACT replacement standards). In particular, the Agency Preferred Approach is expected to result in:

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

Cancer risk reductions. The Agency Preferred Approach is expected to avoid less than 0.376 cancer deaths annually when compared to the 1999 standards. The value of this avoided cancer case is not quantified in this Assessment.

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

Reduced risk for *** subsistence fishermen associated with mercury. The hazard indexmercury. Reductions in methylmercury concentrations in fish should reduce exposure, subsequently reducing the risks of mercury related health effects in the general population, to children, and to certain subpopulations. Fish consumption advisories ( FCA) issued by the States may also help to reduce exposures to potential harmful levels of methylmercury in fish.

To the extent that reductions in mercury emissions reduces the probability that a water body will have a FCA issued, there are a number of benefits that will result from fewer advisories, including increased fish consumption,

increased fishing choices for recreational fishers, increased producer and consumer surplus for the commercial fish market, and increased welfare for subsistence fishermen may be reduced, suggesting that subsistence fishermen will potentially experience reduced risks of having children with developmental abnormalities, but this reduction is FINAL DRAFT: March 2004 6 53 likely to be small based on the 1999 Assessment. fishing populations.*** FINAL DRAFT: March 2004 6 54

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

Potential improvement in visibility. An upper bound estimate of visibility benefits, assuming a linear relationship with WTP for improved visibility and particulate matter concentration visibility improvements associated with particulate matter, could result in benefits of $ 8$ 7.41 million annually for a 30 percent change in particulate matter concentration from the baseline. A lower bound estimate of visibility benefits, assuming a linear relationship between human health benefits and visibility benefits reductions in PM emissions, could result in $ 1005,000800 in visibility benefits.

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

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

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

Waste minimization benefits. The Agency Preferred Approach is likely to produce a small reduction, if any, in short term generation waste combusted because the demand for combustion is relatively inelastic. However, impacts fo this rule on long term process decisions are unknown. FINAL DRAFT: March 2004 6 55 It is important to emphasize that the monetized portion of the benefits represent only a portion of the benefits associated with this rule. Specifically ecological benefits, chlorine, dioxin, mercury, lead, etc. health benefits are not quantified or monetized. In some locations these benefits may be significant. In addition, specific sub populations near combustion facilities, including children and minority populations, may be disproportionately affected by environmental risks and may therefore enjoy more significant benefits. Chapter 7 provides a more detail discussion of the environmental justice and children's health implications of this proposed rule.