[Federal Register: May 29, 2008 (Volume 73, Number 104)]
[Notices]
[Page 30916]
[DOCID:fr29my08-59]

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DEPARTMENT OF ENERGY

Federal Energy Regulatory Commission

[Docket No. CP08-402-000]

Natural Gas Pipeline Company of America LLC; Notice of Request
Under Blanket Authorization

May 21, 2008.
    Take notice that on May 15, 2008, Natural Gas Pipeline Company of
America LLC (Natural), 3250 Lacey Road, Suite 700, Downers Grove,
Illinois 60515, filed in Docket No. CP08-402-000, a prior notice
request pursuant to sections 157.205, 157.208, 157.211, and 157.212 of
the Federal Energy Regulatory Commission's regulations under the
Natural Gas Act for authorization to construct and operate facilities
to connect Natural's pipeline system to Kinder Morgan Louisiana
Pipeline LLC (KMLP) in Cameron Parish, Louisiana in order to receive
re-vaporized liquefied natural gas (LNG) or to deliver natural gas, all
as more fully set forth in the application, which is on file with the
Commission and open to public inspection. The filing may also be viewed
on the Web at http://www.ferc.gov using the ``eLibrary'' link. Enter
the docket number excluding the last three digits in the docket number
field to access the document. For assistance, contact FERC at
<EMAIL_ADDRESS>or call toll-free,<PHONE_NUMBER> or TTY,
(202) 502-8659.
    Natural proposes to construct and operate facilities necessary to
establish a bi-directional interconnect with KMLP at a new interconnect
point in Cameron Parish, Louisiana. The facilities include two 30-inch
taps, and appurtenances, on Natural's existing Louisiana No. 1 and No.
2 pipelines located south of Highway 82 in Cameron Parish, Louisiana.
The facilities will interconnect with Natural's system to Leg 2 of KMLP
(a one mile 36-inch pipe) and will support Natural's lease of capacity
to KMLP previously approved in Docket No. CP06-448-000. This
interconnect will allow Natural to receive re-vaporized LNG from KMLP
or to deliver natural gas to KMLP. KMLP will install and own bi-
directional ultrasonic meters, a gas filter, electronic flow
measurement equipment, and monitoring devices. The estimated cost of
the project is approximately $1.03 million and all costs associated
with the project will be reimbursed by KMLP. The proposed in-service
date for the interconnect facilities is September 1, 2008.
    Any questions regarding the application should be directed to
Norman Watson, Director, Business Development, Natural Gas Pipeline
Company of America LLC, 500 Dallas Street, Suite 1000, Houston, Texas
77002, at<PHONE_NUMBER> or Bruce Newsome, Vice President, Natural Gas
Pipeline Company of America LLC, 3250 Lacey Road, Suite 700, Downers
Grove, Illinois 60515, at<PHONE_NUMBER>.
    Any person may, within 60 days after the issuance of the instant
notice by the Commission, file pursuant to Rule 214 of the Commission's
Procedural Rules (18 CFR 385.214) a motion to intervene or notice of
intervention. Any person filing to intervene or the Commission's staff
may, pursuant to section 157.205 of the Commission's Regulations under
the Natural Gas Act (NGA) (18 CFR 157.205), file a protest to the
request. If no protest is filed within the time allowed therefore, the
proposed activity shall be deemed to be authorized effective the day
after the time allowed for protest. If a protest is filed and not
withdrawn within 30 days after the time allowed for filing a protest,
the instant request shall be treated as an application for
authorization pursuant to section 7 of the NGA.
    The Commission strongly encourages electronic filings of comments,
protests, and interventions via the Internet in lieu of paper. See 18
CFR 385.2001(a)(1)(iii) and the instructions on the Commission's Web
site (http://www.ferc.gov) under the ``e-Filing'' link.

Kimberly D. Bose,
Secretary.
[FR Doc. E8-11915 Filed 5-28-08; 8:45 am]

BILLING CODE 6717-01-P


The analysis underestimates the total value of benefits from the MP& M regulation because it does not account for people s WTP for water quality improvements to distant water bodies.

For example, economic values for improving nationally significant water bodies ( e. g., Great Lakes, Chesapeake Bay, Long Island Sound) are likely to be substantial at a regional level or even nationwide.

The analysis of recreational fishing ignores effects that occur in secondary industries. ()

The analysis of recreational benefits ignores potential economic effects on tourism industries stemming from improved recreational opportunities. a positive effect on industries supplying bait, tackle, charter boats, etc. r demand for boating may have positive effects on industries such as boat construction, sales, rentals, boating equipment, marinas, racing activities, etc. ovements in wildlife viewing and near water recreation opportunities may benefit industries involved in providing other recreational opportunities, such as tours, books, binoculars, etc.

The analysis of recreational benefits ignores changes in the value of water based recreational activities other than fishing, wildlife viewing,

and boating ( e. g., swimming or waterskiing). () The estimate of recreational benefits is incomplete because it includes only a subset of recreational activities ( i. e., fishing, wildlife viewing, and boating) which society may value improved aquatic habitat.

activities, such as swimming or waterskiing.

changes in the affected reaches, such as improved taste and odor. Exc Improved recreational fishing may have An increase in consume Impr for It ignores changes in value for other water based recreational In addition, the analysis did not consider other 15 23 MP& M EEBA Part III: Benefits Chapter 15: Recreational Benefits Table 15.14: Key Omissions, Biases, and Uncertainties in the Analysis for Improved Recreational and Nonuse Benefits Assumption/ Limitation Direction of Impact on Benefit Estimates Extrapolating from sample facility results to national results is based on the sample facility weights (?)

This extrapolation technique is not ideal and introduces uncertainty into the analysis. ility sample weights are based on facility size and type of industry. se weights do not necessarily account for the frequency benefit pathway characteristics in the MP& M facility universe. Therefore benefit estimates may suffer from uncertainties associated with the extrapolation method. For example, a sample facility may have a significant impact on benefit estimates if it is more likely to be located in a densely populated area, such as a facility located in Cleveland, Ohio, or a facility discharging in Long Island Sound, than the facilities it represents.

To improve accuracy of the national benefit estimates, EPA used an alternative extrapolation method ( i. e., post stratification extrapolation).

weights that account for the distribution of benefit pathway characteristics, including water body type and population size, in the MP& M facility universe. ppendix G summarizes this extrapolation approach.

Congestion Externalities (+)

Recreational benefits associated with water quality improvements can be eroded by congestion if policies greatly increase the number of participants. can be particularly problematic when policies affect geographically scattered sites, so that there is considerable switching to the improved site from substitute sites. be a lesser problem for national regulations that might affect the total number of recreation days and the overall value of recreational opportunities, but are less likely to have a large effect on industrial sites relative to its substitutes.

Benefits Transfer The waters assessed by local level studies are not necessarily nationally representative. (?) The studies selected came from the Midwest and the Northeast. valued, as well as respondent preferences, may not be representative of the rest of the country.

Types of water quality changes expected from the MP& M rule may differ from the water quality changes considered in the original studies. (?)

The types of water quality changes expected from the MP& M regulation are only roughly comparable with the majority of water quality changes considered in the original studies ( Tudor et al. is the only exception). paucity of available studies, the Agency made simplifying assumptions to   map  the water quality changes valued in the original studies onto those expected from the rule. lthough these assumptions are likely to increase uncertainty associated with recreational benefits estimates, the direction of bias is not known.

Compatibility of time periods considered in the original studies and in the analysis of MP& M costs and benefits. (+)

Most studies considered in the benefits transfer analysis did not specify payment periods. The scenario in the Farber and Griner ( 2000) paper asked for payments for the next five years.

This scenario implies that five years of pollution control will result in permanent water quality changes. the MP& M regulation assumes that pollution control continues over 15 years and that water quality improvements depend on continued operation of the water pollution controls.

opposed to the total value paid over five years, annualized over the 15 years considered in the cost analysis. assumption may result in an overestimation of the regulation s benefit.

The magnitude of this error is unlikely to be significant because this study is used in combination with other surface water valuation studies.

Baseline Value of Fishery Converting annual WTP values to per trip values (+) EPA converted annual WTP values reported in the three CV studies used in this analysis to per trip values by dividing seasonal welfare gain per user reported in each CV study by the average number of fishing, boating, or viewing days in a given state. his calculation implies that every individual participates in only one activity, which may not be the case. This implication may result in an overestimation of the per trip welfare gain, and, consequently, an overestimation of total recreational benefits from the final rule. Fac The The opposite may also be true.

This method relies on adjusted sample facilities A This Congestion may As a result, the resources Due to the A The analysis of EPA therefore chose the annual WTP values presented in the paper, as This T 15 24 MP& M EEBA Part III: Benefits Chapter 15: Recreational Benefits Table 15.14: Key Omissions, Biases, and Uncertainties in the Analysis for Improved Recreational and Nonuse Benefits Assumption/ Limitation Direction of Impact on Benefit Estimates This analysis estimates the baseline value of the fisheries at locations across the country using a range of values for all types of fisheries. (?)

Site specific fisheries may have higher or lower baseline values, and thus, higher or lower benefits from reduced MP& M discharges.

The total number of recreational person days in the counties abutting MP& M reaches is evenly distributed across all reach miles in these counties. (+) This method for estimating the number of recreational users potentially affected by water quality improvements from the final regulation accounts for the quantity but not quality of potential recreational opportunities available to recreational users. re may be important substitute sites in or outside the counties abutting MP& M reaches. recreationally important substitute sites may result in overestimation of benefits from the final regulation.

Ideally the analysis would consider recreational importance of both sites affected by MP& M discharges and substitute sites.

Nonuse Values Nonuse values are estimated as one

half of recreational use benefits. (?)

It is unknown what bias estimating nonuse values based on recreational use values has on benefits.

Overall Impact on Benefits Estimates (?) The Ignoring + Potential overestimate. ? Uncertain impact.  Potential underestimate.

Source: U. S. EPA analysis.

15 25 MP& M EEBA Part III: Benefits Chapter 15: Recreational Benefits GLOSSARY 1Q10: the lowest one day average flow with a recurrence interval of ten years.

7Q10: the lowest consecutive seven day average flow with a recurrence interval of ten years.

ambient water quality criteria ( AWQC): published and periodically updated by the EPA under the Clean Water Act.

The criteria reflect the latest scientific knowledge on the effects of specific pollutants on public health and welfare, aquatic life, and recreation. The criteria do not reflect consideration of economic impacts or the technological feasibility of reducing chemical concentrations in ambient water. The criteria serve as guides to states, territories, and authorized tribes in developing water quality standards and ultimately provide a basis for controlling discharges or releases of pollutants into our nation s waterways. AWQC are developed for two exposure pathways: ingestion of the pollutant via contaminated aquatic organisms only, and ingestion of the pollutant via both water and contaminated aquatic organisms.

benefiting reaches: reaches where the MP& M rule is expected to eliminate existing AWQC exceedences. These receiving waters are likely to experience significant water quality improvements as a result of the reduced MP& M discharges.

A reach is considered to benefit if at least one AWQC exceedance is eliminated due to reduced MP& M discharges.

benefits transfer: involves the application of value estimates, functions, and/ or models developed in one context to address a similar resource valuation question in another context. Often a meta analysis is undertaken where benefits estimates based on existing studies are used to develop new estimates which are applicable to the scenario under consideration. This process accounts for relevant differences in study characteristics, such as the quality of environmental resource, the environmental change considered, and the user population being investigated.

contingent valuation ( CV): directly asks people what they are willing to pay for a benefit and/ or willing to receive in compensation for tolerating a cost through a survey or questionnaire. Personal valuations for increases or decreases in the quantity of some good are obtained contingent upon a hypothetical market. The aim is to elicit valuations or bids that are close to what would be revealed if an actual market existed.

conventional pollutants: biological oxygen demand ( BOD), total suspended solids ( TSS), oil and grease ( O& G), pH, and anything else the Administrator defines as a conventional pollutant.

dissolved oxygen ( DO): oxygen freely available in water, vital to fish and other aquatic life and for the prevention of odors. DO levels are considered a most important indicator of a water body's ability to support desirable aquatic life.

Secondary and advanced waste treatment are generally designed to ensure adequate DO in waste receiving waters.

( http:// www. epa. gov/ OCEPAterms/ dterms. html)

Metal Products and Machinery ( MP& M): industry includes facilities that manufacture, rebuild, and maintain metal parts,

products, or machines.

National Demand Study ( NDS): U. S. EPA and the National Forest Service conducted the National Demand Survey for Water Based Recreation in 1993. The survey collected data on demographic characteristics and water based recreation behavior using a nationwide stratified random sample of 13,059 individuals aged 16 and over.

nonconventional pollutant: catch all category that includes everything that is not classified as a priority pollutant or a conventional pollutant.

piscivorous: feeding preferably on fish.

priority pollutant ( PP): 126 individual chemicals that EPA routinely analyzes when assessing contaminated surface water,

sediment, groundwater, or soil samples.

toxic pollutants: EPA s Office of Water narrowly defines a toxic pollutant as one of 126 priority pollutants. This definition is not completely synonymous with pollutants that have a   toxic  effect. Many nonconventional pollutants may also be hazardous to aquatic life and human health.

  toxic  pollutant: any pollutant that has an adverse effect on aquatic life or human health.

15 26 MP& M EEBA Part III: Benefits Chapter 15: Recreational Benefits travel cost ( TC) model: derives values by evaluating expenditures of recreators. Travel costs are used as a proxy for price in deriving demand curves for the recreation site. ( http:// www. damagevaluation. com/ glossary. htm)

U. S. Fish and Wildlife Service ( FWS): the principal federal agency responsible for conserving, protecting, and enhancing fish, wildlife, and plants and their habitats for the continuing benefit of the American people.

( http:// www. fws. gov/ r9extaff/ pafaq/ fwsfaq. html)

willingness to pay ( WTP): maximum amount of money one would give to buy some good.

( http:// www. damagevaluation. com/ glossary. htm)

15 27 MP& M EEBA Part III: Benefits Chapter 15: Recreational Benefits ACRONYMS 1Q10: the lowest 1 day average flow with a recurrence interval of 10 years 7Q10: the lowest 7 day average flow with a recurrence interval of 10 years AWQC: ambient water quality criteria CV: contingent valuation DO: dissolved oxygen FWS: U. S. Fish and Wildlife Service MP& M: Metal Products and Machinery NDS: National Demand Study TC: travel cost WTP: willingness to pay 15 28 MP& M EEBA Part III: Benefits Chapter 15: Recreational Benefits REFERENCES Belton, T., R. Roundy and N. Weinstein. 1986. Urban Fishermen: Managing the Risks of Toxic Exposure. Environment,

Vol. 28. No. 9, November.

Brown, T. 1993.   Measuring Nonuse Value: A Comparison of Recent Contingent Valuation Studies.  In: Bergstrom, J. C.,

Benefits and Costs Transfer in Natural Resource Planning. Sixth Interim Report. Athens, GA: University of Georgia,

Department of Agriculture and Applied Economics.

Bergstrom, J. C. and K. Boyle. 1990.   Using Benefits Transfer to Value Groundwater Benefits: Conceptual Issues.

Presented at the joint AAEA/ AERE meeting in Orlando, FL. August 1993.

Bergstrom, J. C. and H. K. Cordell. 1991.   An analysis of the Demand for and Value of Outdoor Recreation in the United States.  Journal of Leisure Research, Vol. 23, No. 1: 67 86.

Carson, R. T., and R. C. Mitchell. 1993.   The Value of Clean Water: The Public s Willingness to Pay for Boatable,

Fishable, and Swimmable Quality Water.  Water Resources Research 29( 7): 2445 2454.

Connelly, N. and B. Knuth. 1993. Great Lakes Fish Consumption Health Advisories: Angler Response to Advisories and Evaluation of Communication Techniques. Human Dimensions Research Unit, Dept. of Natural Resources, NY State College of Agriculture and Life Sciences, Cornell University, HDRU Series No 93 3, February.

Connelly, N., B. Knuth, and C. Bisogni. 1992. Effects of the Health Advisory and Advisory Changes on Fishing Habits and Fish Consumption in New York Sport Fisheries. Human Dimensions Research Unit, Dept. of Natural Resources, NY State College of Agriculture and Life Sciences, Cornell University, HDRU Series No 92 9, September.

Desvousges, W. H. et al. 1987.   Option Price Estimates for Water Quality Improvements: A Contingent Valuation Study for the Monongahela River.  Journal of Environmental Economics and Management, 14: 248 267.

Farber, S. and B. Griner. 2000. Valuing Watershed Quality Improvements Using Conjoint Analysis. University of Pittsburgh, PA.

Fisher, A. and R. Raucher. 1984.   Intrinsic Benefits of Improved Water Quality: Conceptual and Empirical Perspectives.

In: Advances in Applied Microeconomics, Vol. 3, V. K. Smith, editor, JAI Press.

Harpman, D. A., M. P. Welsh, and R. C. Bishop. 1993.   Nonuse Economic Value: Emerging Policy Analysis Tool.  Rivers,

Vol. No. 4.

Jakus, P. M., M. Downing, M. S. Bevelhimer, and J. M. Fly. 1997.   Do Sportfish Consumption Advisories Affect Reservoir Anglers  Site Choice?  Agricultural and Resource Economic Review, 26( 2).

Knuth, B. and C. Velicer. 1990. Receiver Centered Risk Communication for Sportfisheries: Lessons from New York Licensed Anglers. Paper presented at the American Fisheries Society Annual Meeting, Pittsburgh, Penn, August.

Lant, C. L. and R. S. Roberts. 1990.   Greenbelts in the Cornbelt: Riparian Wetlands, Intrinsic Values, and Market Failure.

Environment and Planning A, Vol. 22: 1375 1388.

Lyke, A. J. 1993.   Discrete Choice Models to Value Changes in Environmental Quality: A Great Lakes Case Study.  PhD dissertation. Madison, WI: University of Wisconsin, Department of Agricultural Economics.

Montgomery, M. and M. Needelman. 1997.   The Welfare Effects of Toxic Contamination in Freshwater Fish.  Land Economics 73( 2): 211 223.

Phaneuf, D. J., C. L. Kling, and J. A. Herriges. 1998.   Valuing Water quality Improvements Using Revealed Preference Methods When Corner Solutions are Present.  American Journal of Agricultural Economics 80: 1025 1031.

15 29 MP& M EEBA Part III: Benefits Chapter 15: Recreational Benefits Silverman, W. 1990. Michigan s Sport Fish Consumption Advisory: A Study in Risk Communication. Thesis submitted in partial fulfillment of the requirements for the degree of Master of Science ( Natural Resources) at the University of Michigan,

May.

Tudor, L., E. Besedin, M. Fisher, and S. Smith. 1999a.   Economic Analysis of Environmental Regulations: Application of the Random Utility Model to Recreational Benefit Assessment for the MP& M Effluent Guideline.  Presented at the annual American Agricultural Economics Association meeting, Nashville TN.

Tudor, L., E. Besedin, S. Smith, and L. Snyder. 1999b.   What Pollutants Matter for Consumers of Water Based Recreation?  Presented at the annual Northeastern Agricultural and Resource Economics Association meeting, Morgantown,

WV, June.

Tudor, L., et al. 2002. Economic Analysis of Environmental Regulations: Using a Random Utility Model to Assess Recreational Benefits for Effluent Guidelines. Final Report. Washington, DC: U. S. EPA. January.

U. S. Department of Commerce, Bureau of the Census. 1996. Projections of Household by Type 1995 2010 ( series 1).

http:// www. census. gov/ population/ projections/ nation/ hh fam/ table1n. txt.

U. S. Department of the Interior. 1993. 1991 National Survey of Fishing, Hunting, and Wildlife Associated Recreation, DOI,

March.

U. S. Environmental Protection Agency ( U. S. EPA). 1986. Quality Criteria for Water. EPA 440/ 5 86 001.

U. S. Fish and Wildlife Service ( USFWS). 1996. 1996 National Survey of Fishing, Hunting, and Wildlife Associated Recreation. U. S. Fish and Wildlife Service and Bureau of the Census.

Walsh, R. G., D. M. Johnson, and J. R. McKean. 1992.   Benefit transfer of Outdoor Recreation Demand Studies, 1968

1988.  Water Resource Research, Vol. 28, No. 3: 707 713.

West, P., R. Marans, F. Larkin, and M. Fly. 1989. Michigan Sport Anglers Fish Consumption Survey: A Report to the Michigan Toxic Substances Control Commission, University of Michigan School of Natural Resources, Natural Resources Sociology Research Lab, Technical Report # 1, May.

15 30 MP& M EEBA Part III: Benefits Chapter 16: POTW Benefits INTRODUCTION The final rule only regulates direct dischargers. Therefore,

the selected option does not affect POTW operations. For the alternative policy options that consider both direct and indirect dischargers, EPA evaluated two categories of productivity benefits for publicly owned treatment works ( POTWs):

  reduced interference with the operations of POTW s, and   reduced contamination of sewage sludge ( i. e.,

biosolids) at POTWs that receive discharges from MP& M facilities.

Interference with POTW processes occurs when high levels of toxics, such as metals or cyanide, kill bacteria required for wastewater treatment processes. The removal of these pollutants would eliminate the need for extra labor and materials to maintain POTW operations. Chapter 16: POTW Benefits CHAPTER CONTENTS 16.1 nterference with POTW Operations . . . 16 2 16.2 ng Benefits from Reduced Sludge Contamination ................. ....... 16 2 16.2.1 ................. ....... 16 2 16.2.2 Practices ................. ............ 16 4 16.2.3 Quality Benefits ................. ...... 16 7 16.2.4 and Practices . . 16 8 16.2.5 ying Sludge Benefits ........... 16 10 16.3 ated Savings in Sludge Use/ Disposal Costs 16 15 16.4 Limitations ................. . 16 16 Glossary ................. ................. .. 16 18 Acronyms ................. ................. . 16 19 References ................. ................. 16 20 Reduced I Assessi Data Sources Sludge Generation, Treatment, and Disposal Overview of Improved Sludge Sludge Use/ Disposal Costs Quantif Estim Methodology Toxic priority and nonconventional pollutants may also pass through a POTW and contaminate sludge generated during primary and secondary wastewater treatment. 1 POTW treatment of wastewater with reduced pollutant concentrations translates into cleaner sludge, which can be disposed of using less expensive and more environmentally benign methods. In some cases, cleaner sludge may have agricultural applications, which would generate additional resource conservation benefits.

Some MP& M pollutants that pass through a POTW and contaminate sludge are not currently subject to sewage sludge pollutant concentration limits. The alternative policy options would reduce concentrations of these pollutants in sewage sludge as well, which may translate into reduced environmental and human health risks. EPA did not estimate the reduced risk attributable to the reduction of these pollutants.

Wastewater from MP& M facilities also contains hazardous air pollutants ( HAPs). These pollutants may represent unacceptable health risks to POTW workers if released into the air at high enough concentrations during the wastewater treatment cycle. This reduction in pollutants may translate into health benefits to POTW workers and those living near POTWs.

The remaining sections of this chapter present methodology for estimating benefits to the receiving POTW s from reducing pollutants in the wastewater of indirect MP& M dischargers. As noted above, the final option does not affect POTW operations since it regulates direct dischargers only. For the alternative options that consider both direct and indirect dischargers, EPA evaluated two benefits measures associated with MP& M pollutants: ( 1) the reduction in pollutant interference at POTWs; and ( 2) pass through of pollutants into the sludge, which limits options for POTW disposal of sewage sludge.

1 The term sewage sludge, also called biosolids, is often shortened to sludge throughout this chapter for simplicity.

16 1 MP& M EEBA Part III: Benefits Chapter 16: POTW Benefits 16.1 REDUCED INTERFERENCE WITH POTW OPERATIONS High levels of some MP& M pollutants ( such as metals, chlorobenzene, polyaromatic hydrocarbons, and oil and grease) can kill bacteria that are required for the wastewater treatment process ( U. S. EPA, 1987). POTWs affected by such " inhibition problems" may incur extra labor and materials costs to maintain system operations. As a partial measure of the economic benefits resulting from the alternative regulatory options, EPA estimated the extent to which reduced MP& M discharges would decrease pollutant concentrations to below POTW pollutant inhibition values, using the following steps:

  estimate the baseline and post compliance influent concentrations for each POTW receiving discharges from MP& M facilities, based on annual pollutant loadings from the MP& M facility, the number of POTW operating days per year, and the gross volume of influent;

  compare baseline and post compliance influent concentrations with available inhibition levels ( see Table I. 5 in Appendix I); and   estimate the change in the number of POTWs in which influent concentrations of MP& M pollutants exceed POTW inhibition values.

Adverse effects on POTW operations, including inhibition of microbial degradation, are likely when influent concentrations of one or more pollutants exceed an inhibition value. EPA estimated influent concentrations in excess of POTW inhibition values for the sample facilities for the baseline and the alternative regulatory options. Results of this analysis are presented in Appendix I of this report. Eliminating the exceedances will result in operating cost savings to POTWs. EPA has not estimated a monetary value for this benefit, however, due to data limitations.

The final rule only regulates direct dischargers. Therefore, the selected option does not affect POTW operation. For the alternative policy options that consider both direct and indirect dischargers, EPA estimated that 51 PO TW s had influent concentrations in excess of biological inhibition values for one or more pollutants under the baseline conditions corresponding to the 433 Upgrade Options. This represents 0.3% of the over 16,000 POTWs operating nationwide. ( Table I. 12 in Appendix I provides detailed information on pollutants exceeding POTW inhibition criteria.) Both upgrade options would eliminate exceedances of POTW inhibition criteria in 21 POTWs.

EPA s analysis finds that influent concentrations in 293 POTWs exceed biological inhibition values for one or more pollutants under the Proposed/ NODA Option. The Proposed/ NODA Option would eliminate inhibition criteria exceedances in 156 of the affected POTW. 2 POTWs may impose local limits to prevent inhibitions. If local limits are in place, the estimated reduction in potential inhibition problems at the affected POTWs may be overstated. In this case, however, the estimated social cost of the MP& M regulation is also overstated.

16.2 ASSESSING BENEFITS FROM REDUCED SLUDGE CONTAMINATION 16.2.1 Data Sources The analysis of POTW benefits from improved sludge quality draws on several data sources. The § 308 POTW Surveys provide most of the required information. EPA collected information from 147 POTWs representing a 98 percent response rate to the 150 surveys that were mailed. EPA also used the § 308 survey of MP& M facilities. The two data collection efforts were not designed to provide a match between the MP& M sample facilities and the POTWs to which they discharge. EPA obtained a significant amount of information from the POTW Surveys, but had substantially less information on the POTWs that receive discharges from the MP& M facilities. To address this data limitation, EPA used the POTW Survey data to infer 2 The total number of facilities reported for the Proposed/ NODA Option analysis differs from the facility count reported for the final rule and the upgrade options ( Directs + 413 to 433 Upgrade Option, Directs + All to 433 Upgrade Option). After deciding in July 2002 not to consider the NODA option as the basis for the final rule, EPA did not perform any more analyses on the NODA option  including not updating facility counts and related analyses for the change in subcategory and discharge status classifications.

16 2 MP& M EEBA Part III: Benefits Chapter 16: POTW Benefits information on the key factors that are likely to influence choice of sewage sludge use and disposal practices for the POTWs receiving discharges from the MP& M facilities.

The POTW Survey contains three sections. Section 1 provides general information on POTW location and size. Section 2 provides data on the cost of administering pre treatment programs ( see Appendix F). Section 3 contains data on the cost of treating and disposing of sewage sludge and provides new and more consistent data for analyzing the effect of reduced pollutant loadings on sewage sludge management costs.

The POTW Survey asked for the following information:

  current sludge disposal practices;

  sludge disposal costs for one or more disposal methods;

  reasons for not using a less expensive disposal method;

  number of MP& M facilities discharging to the POTW, by flow size ( less than 1 million gal/ year; 1 6.25 million gal/ year; greater than 6.25 million gal/ year);

  total metal loadings discharged to the POTW from all sources; and   percentage of total metal loadings attributable to MP& M facilities.

The POTW Survey was intended to address data limitations encountered in the Phase 1 analysis, particularly the inadequacy of information about POTWs that receive discharges from the MP& M sample facilities. The only information available for the Phase I analysis was POTW geographic location, influent volume, and the metals content of the discharge received from the sampled MP& M facilities. Discharges to the POTW by non sampled MP& M facilities and by non MP& M facilities were not known. These discharges may significantly affect sewage sludge quality, however, resulting in a discrepancy between predicted and actual pollutant concentrations in sewage sludge and the corresponding disposal practices. In addition, lack of information on the factors that may influence a POTW's decisions about sludge management practices introduced additional uncertainty in the analysis.

EPA used the POTW Survey to calculate the following parameters:

  baseline percentage of the total metal loadings to POTWs by POTW flow category attributable to MP& M facilities;

  post compliance loading reductions for non sampled MP& M facilities discharging to the receiving POTWs;

  costs of sewage sludge disposal practices; and   percentage of qualifying sludge that is not beneficially used for any of the following reasons: lack of land; lower cost alternative; inability to meet vector or pathogen requirements; poor weather; stricter state standards; and other reasons.

EPA also used the data provided by the Association of Metropolitan Sewerage Agencies ( AMSA) to refine its analysis of POTW benefits for the final rule. AMSA provided EPA with comments on the proposed MP& M rule and supplemented these comments with a spreadsheet database ( AMSA, 2000). The database contains data from an AMSA formulated survey and covers responses from 176 POTWs, representing 66 pretreatment programs. The AMSA survey was conducted to verify data from EPA's survey of POTWs and therefore included similar, although fewer, variables compared to EPA's survey.

EPA used the results of the AMSA survey to supplement information from the MP& M POTW Survey on percentage of metal loadings contributed by MP& M facilities and the number of MP& M facilities served by POTWs. Based on the results of the joint analysis of the EPA and AMSA surveys, EPA revised the following elements of the POTW benefits methodology: ( 1)

the number of MP& M facilities served by small, medium, and large POTW s, ( 2) percentage of metal loadings contributed by MP& M facilities, and ( 3) percentage of qualifying sludge that is not land applied.

Finally, EPA used other data sources in this analysis, including Handbook for Estimating Sludge Management Costs ( EPA,

1985) and Regulatory Impact Analysis of the Part 503 Sludge Regulation ( EPA, 1993b).

16 3 MP& M EEBA Part III: Benefits Chapter 16: POTW Benefits 16.2.2 Sludge Generation, Treatment, and Disposal Practices a. Sludge generation POTW s generally treat wastewater from industrial indirect dischargers along with domestic wastewater. Sludge results from primary, secondary, and advanced wastewater treatment. The extent and type of wastewater treatment determine the chemical and physical character of the sludge. Sludge may be conditioned, thickened, stabilized, and dewatered to reduce its volume.

Sludge contains five classes of components: organic matter, pathogens, nutrients, inorganic chemicals, and organic chemicals.

The mix and levels of these components ultimately determine the human health and environmental impact of sludge use/ disposal, and so may also dictate the most appropriate uses and disposal practices ( EPA, 1993b).

Organic matter ( the primary constituent of sludge) comes from human waste, kitchen waste, and stormwater runoff. Organic and inorganic chemicals in sludge come from industrial processes that discharge to municipal sewers. The concentration of inorganic pollutants in sludge, including metals, depends upon the volume and type of industrial wastes discharged to the POTW, as well as the extent and character of stormwater runoff.

b. Sludge use/ disposal practices After treatment, sludge can be used in the following ways:

  Land Application: Spraying or spreading on the land surface, injection below the surface, or incorporation into the soil, for soil conditioning or fertilization of crops or vegetation. Agricultural lands ( pasture, range land, crops),

forest lands ( silviculture), and drastically disturbed lands ( land reclamation sites) may all receive sludge;

  Bagged Application: Collection of sludge in containers for application to land ( i. e., distribution and marketing);

  Surface Disposal: Disposal on land specifically set aside for this use, including surface impoundments ( also called lagoons), sludge monofills ( i. e., sludge only landfills), and dedicated sites ( i. e., land on which sludge is spread solely for final disposal);

  Co disposal: Disposal in a municipal solid waste landfill ( MSWL) or hazardous waste landfill; and   Incineration: Combustion of organic and inorganic matter at high temperatures in an enclosed device.

Land application and bagged application are beneficial uses of sludge. Both methods can be categorized as being " high" or " low," depending on pollutant concentrations in sewage sludge. " High" applications meet stringent limits on the total concentration of a given pollutant at a given application site. " High" sludge is exempt from meeting pollutant loading rate limits and certain record keeping requirements. " Low" applications meet less stringent " ceiling" limits for pollutants. Ceiling limits govern whether a sewage sludge can be applied to land at all. " Low" applications require more record keeping because POTWs must track total ( cumulative) loadings applied to each given site, in addition to tracking the concentration of sludge applied at any given time.

Many POTWs use more than one use/ disposal practice, which helps to maintain flexibility and avoid the capacity limitations of a single practice. The practice chosen depends on several factors, including:

  cost to prepare sludge for use/ disposal;

  pollutant concentrations;

  market demand for sludge;

  cost to transport sludge to use/ disposal sites;

  availability of suitable sites for land application, landfilling, or surface disposal;

  weather and other local conditions;

  allowance of a safety factor to account for unplanned or unforseen conditions;

16 4 MP& M EEBA Part III: Benefits Chapter 16: POTW Benefits   state environmental regulations; and   public acceptance ( EPA, 1993b).

The choice of use/ disposal method is restricted by the quality of the sludge generated by the POTW . Sludge for beneficial uses must meet more stringent standards for pollutant concentrations than sludge used or disposed of in other ways. Similarly,

sludge that is surface disposed in an unlined unit generally must meet more stringent standards than sludge surface disposed in a lined unit, disposed in an MSWL, or incinerated. Sludge disposed in a MSWL must meet more stringent standards than incinerated sludge.

Table 16.1 summarizes sludge use/ disposal methods according to the number and percent of dry metric tons ( DMT), based on information provided in Section 3 of the § 308 POTW Survey. The information presented in this table takes into account data provided by AMSA on POTW characteristics such as POTW flow and the total amount of sludge generated by each POTW.

Because the AM SA data was collected five years after the EPA POT W Survey was administered and it does not correspond to the base year of the analysis ( 1996), EPA did not use AMSA data to adjust the allocation of sludge to each use/ disposal method category.

Table 16.1: Sludge Use/ Disposal ( 1996) by POTWs Discharging > 2 Million Gallons/ Day a Use/ Disposal Sub Class Thousand DMT Percent of DMT Total Beneficial Use 2,641.2 39.9%

Land Application High 1,017.4 15.4%

Bag Application High 339.9 5.1%

Land Application Low 1,283.9 19.4%

Bagged Application Low 0 0%

Total Surface Disposal 528.2 8.0%

Surface Disposal: Unlined Unit 347.2 5.3%

Surface Disposal: Lined Unit 181.0 2.7%

Co Disposal: Municipal Landfill 1,768.8 26.8%

Incineration 1,129.9 17.1%

Unknown: Other 543.2 8.2%

All 6,611.2 100.0%

a The § 308 POTW Survey did not collect information from POTWs discharging < 2 million gallons per day.

Source: U. S. EPA, POTW Survey and AMSA Survey ( 2000) on Proposed MP& M Effluent Guidelines.

As Table 16.1 shows, 39.9 percent of total sludge tons reported by respondents is used beneficially ( land application and bagged application). Co disposal in a municipal landfill is the second most frequently used disposal method, accounting for 26.8 percent of all sludge disposed in the U. S. Surface disposal in unlined and lined units, incineration, and " other" disposal methods account for 5.3 percent, 2.7 percent, 17.1 percent, and 8.2 percent of all sludge tons, respectively. No sludge was sent to a hazardous waste landfill by the POTW Survey respondents.

c. Pollutant limits and disposal options Section 405( d) of the Clean Water Act, as amended, requires EPA to specify acceptable management practices and numerical limits for certain pollutants in sludge. The Agency published Standards for the Use/ Disposal of Sludge ( 40 CFR Part 503,

February 1993) to protect public health and the environment from reasonably anticipated adverse effects of pollutants in sludge ( U. S. EPA, 1993a). The standards include general requirements, pollutant limits, management practices, operational standards, monitoring frequency, record keeping, and reporting for the final use and disposal of sludge in four circumstances:

  sludge co disposed with household waste in a MSWL;

16 5 MP& M EEBA Part III: Benefits Chapter 16: POTW Benefits   sludge land applied for beneficial purposes ( including bagged sludge);

  sludge disposed on land or on surface disposal sites; and   incinerated sludge.

With the exception of MSWLs, the standards for each practice include numerical limits on sludge pollutant concentrations.

Part 503 sets limits on pollutant concentrations for land application at two levels:

  Land Application Low limits, which govern whether sludge can be applied to land at all; and   more stringent Land Application High limits which define, in part, sludge that is exempt from meeting certain record keeping requirements.

For sludge meeting only the Land Application Low limits, Part 503 contains pollutant loading rate limits. These determine the amount of sludge and associated pollutant content that may be applied to a particular site.

EPA did not establish pollutant specific, numerical criteria for toxic pollutants of concern in the sludge disposed in MSWLs,

because the design standards applicable to MSWLs are considered adequate to protect human health and the environment.

Also, MSWL sludge is co disposed with household waste, making precise numerical criteria infeasible. The Solid Waste Disposal Facility Criteria ( 40 CFR Part 258, Federal Register 50978, October 9, 1991) specify that POTW s using an MSWL must ensure that their sewage is non hazardous and passes the Paint Filter Liquid Test.

The pollutant limits for sludge land application, surface disposal, and incineration constrain a POTW's choice of sludge use/ disposal practice. Table 16.2 presents numerical limits for the three sludge use/ disposal practices for eight MP& M pollutants. The land application pollutant limits place restrictions on concentrations of metals in sludge; the surface disposal criteria cover a subset of the metals regulated for land application. The MP& M effluent limitations guideline covers five metals and causes incidental removal of the remaining three metals regulated under the Part 503 sludge regulation. The alternative policy options would improve the quality of sewage sludge generated by POTWs receiving discharges from MP& M facilities and, as a result, would increase sludge use/ disposal options for the affected POTWs.

Table 16.2: Sludge Use/ Disposal Pollutant Limits Pollutant Application Limits Surface Disposal Limits ( mg/ kg dry weight) a MP& M Pollutants of ConcernLow Limits ( Low)

( mg/ kg dry weight) High Limits ( High)

( mg/ kg dry weight)

Arsenic 75 41 73   Cadmium 85 39   Copper 4,300 1,500   Lead 840 300   Mercury 57 17   Nickel 420 420 420   Selenium 100 100   Zinc 7,500 2,800   a Pollutant limits for active sludge unit whose boundary is greater than 150 meters from the surface disposal site property line.

Source: Standards for the Use or Disposal of Sludge; Final Rules. 40 CFR Part 257 et al. Federal Register February 19,

1993a.

16 6 MP& M EEBA Part III: Benefits Chapter 16: POTW Benefits d. Reasons for not land applying qualifying sludge POTW characteristics including location, state regulations, and community concerns also affect use/ disposal methods for sludge. The POTW Survey provided information on the percentage of sludge that qualified for beneficial use but was not beneficially used. Survey data indicate that 57 percent of qualifying sludge was not land applied, for the following reasons:

  land application is more expensive than another method;

  land is not available for sludge application;

  the cumulative pollutant loads at the land application site used had been exceeded;

  the vector or pathogen requirements to land apply could not be met at an acceptable cost; and   inclement weather, concern over liability, stakeholder complaints, stricter state standards, desire to diversify practices, or technical problems.

Of the 57 percent of sludge that was not land applied, only 11 percent of qualifying sludge was otherwise beneficially used ( i. e., sold in bags). Therefore, only 50 percent of the total qualifying sludge is beneficially used. 3 In addition, POTW Survey data indicate that, on average, 7.5 percent of all sludge that qualifies for surface disposal is not surface disposed.

16.2.3 Overview of Improved Sludge Quality Benefits This section discusses potential economic productivity benefits resulting from cleaner sludge, describes the methodology used to estimate benefits to POTWs directly affected by the regulation, and presents the results of the analysis.

EPA expected that the alternative regulatory options would reduce MP& M facility discharges of eight metals with Part 503 limits. The influent pollutant reductions to the receiving POTWs translate into sludge with reduced pollutant concentrations,

allowing the sludge to meet the criteria for lower cost use/ disposal methods. The reduction in pollutants will then provide many POTWs with greater flexibility in the disposal of their sludge, and for some the opportunity to use less expensive methods of sludge use/ disposal. In some cases, wastewater treatment systems may be able to use the cleaner sludge in agricultural applications, generating additional agricultural productivity benefits. Numerous benefits will result from reduced contamination of sludge, including the following:

  POTWs may have less expensive options for use/ disposal of sludge. Methods involving stricter criteria are generally less expensive than the alternatives. In particular, land application usually costs substantially less than incineration or landfilling. As a result, under the alternative policy options sludge from some PO TW s may meet more stringent criteria for less expensive use/ disposal methods.

  Some sludge currently meeting only Land Application Low concentration limits and pollutant loading rate limits would meet the more stringent Land Application High concentration limits. Users applying sludge meeting Land Application High pollutant limits would be exempt from meeting pollutant loading rate limits. They would have fewer record keeping requirements than users of sludge meeting only Land Application Low concentration and loading rate limits.

  By land applying sludge, POTW s may avoid costly siting negotiations for more contentious sewage sludge use or disposal practices, such as incineration.

  POTW sludge provides supplemental nitrogen, which enhances soil productivity when land applied. Sludge applied to agricultural land, golf courses, sod farms, forests, or residential gardens is a valuable source of nitrogen fertilizer.

  Non point source nitrogen contamination of water may be reduced if sludge is used as a substitute for chemical fertilizers on agricultural land. Compared to nitrogen in most chemical fertilizers, nitrogen in sludge is relatively insoluble in water. The release of nitrogen from sludge occurs largely through continuous microbial activity,

resulting in greater plant uptake and less nitrogen runoff than from conventional chemical fertilizers.

3 Percent of Qualifying Sludge Beneficially Used = ( 100%   57%) +[( 57% × 11%)/ 100%]= 50%

16 7 MP& M EEBA Part III: Benefits Chapter 16: POTW Benefits   The organic matter in land applied sludge can improve crop yields by increasing the ability of soil to retain water.

  Reduced concentrations of sludge pollutants not currently regulated may reduce human health and environmental risks. Human health risks from exposure to these unregulated sludge pollutants may occur from particulate inhalation, dermal exposure, ingestion of food grown in sludge amended soils, ingestion of surface water containing sludge runoff, ingestion of fish from surface water containing sludge runoff, or ingestion of contaminated ground water.

  Land application of sludge satisfies an apparent public preference for this practice of sludge disposal, apart from considerations of costs and risk.

This analysis assumes that POTWs will choose the least expensive sludge use/ disposal practice for which their sludge meets pollutant limits. POTW s with sludge pollutant concentrations exceeding the Land Application High, Land Application Low,

or surface disposal pollutant limits in the baseline may be able to reduce sludge use/ disposal costs after MP& M facilities have complied with the effluent limitations considered under alternative regulatory options.

As public entities, POTW s are not forced by the market to act as profit maximizing or cost minimizing agents, but rather are assumed to optimize their jurisdictional welfare function. POTW s take factors other than cost into consideration when determining their sludge use/ disposal methods. These factors may include the desire to be perceived by the public as using sludge in an environmentally friendly way, or the desire to enhance relationships with clients by providing no cost or low cost fertilizer. Greater flexibility in disposal practices may therefore provide benefits beyond cost savings.

16.2.4 Sludge Use/ Disposal Costs and Practices This section summarizes the estimated cost differences of various use and disposal methods, based on the POTW Survey.

Alternative sludge use/ disposal practices costs vary considerably among POTWs, based on several factors, the most important being the availability of local agricultural land or land suitable for surface disposal of sludge. Table 16.3 lists and ranks the use/ disposal methods from least expensive to most expensive, according to the average qualitative ranking of each method in the POTW Survey.

Table 16.3: National Estimate of Qualitative Ranking of Use/ Disposal Methods Mean Rankings Least Expensive Land Application High   Land Application Low MSWL   Bagged Application High Surface Disposal in Unlined Unit   Bagged Application Low Surface Disposal in Lined Unit   Incineration Most Expensive Hazardous Waste Landfill Source: U. S. EPA, § 308 POTW Survey.

Land Application Low and Land Application High were ranked as the two cheapest sewage sludge disposal options,

supporting the assumption that beneficial use of sludge offers cost savings. The third least expensive option co disposal in an MSWL costs less on average than either bagging sludge or surface disposing in an unlined unit.

16 8 MP& M EEBA Part III: Benefits Chapter 16: POTW Benefits EPA used the POTW Survey data as the primary source for estimating an average difference in costs among certain combinations of use/ disposal practices ( e. g., the cost savings achieved by switching from incineration to land application).

Table 16.4 compares the cost savings realized by switching to sludge land application and surface disposal practices from less stringently regulated sludge use/ disposal practices. While on average the estimates provided in Table 16.4 are expected to hold, the cost savings will vary for individual POTWs. POTWs whose sludge qualifies for beneficial use post compliance but did not qualify for such use in the baseline may achieve cost savings in some, but not all, circumstances. For example, a POTW may not achieve cost savings from agricultural application due to sludge transportation costs or because there are less expensive alternatives for that particular facility. Switching from sewage sludge co disposal in a MSW L to surface disposal offers no savings to a POTW.

Table 16.4: Cost Savings for Shifts in Sludge Use/ Disposal Practices ( 2001$/ DMT)

Switch From Switch To:

Land Applicationa ( High) Land Applicationa ( Low) Sold in a Bag for Land Application Surface Disposal on Unlined Unit Surface Disposal on Lined Unit Incineration $ 103.82 $ 103.82 $ 95.91 $ 103.08 No Saving Surface Disposal on Lined Unit $ 126.39 $ 126.39 $ 71.89 Surface Disposal on Unlined Unit $ 6.44 $ 6.44 $ 0.59 Co disposal: MSWL $ 100.44 $ 100.44 $ 69.96 No Saving No Saving Land Application Low $ 0.54 1.09 a EPA assumes that the costs of land application to forests, public contact sites, and reclaimed land are similar to the costs of agricultural application.

Source: U. S. EPA analysis of the § 308 POTW Survey data.

The cost section of the POTW Survey did not distinguish between low and high land application or low and high bagged application. Therefore, costs provided in the survey reflect the cost of both methods. To estimate the cost savings of avoiding these requirements by meeting Land Application High limits, EPA used the compliance requirements for meeting Land Application Low limits for bulk sludge ( U. S. EPA, 1997). These cost savings provide a partial measure of the monetary benefit of improved sludge quality.

EPA estimates that the incremental record keeping associated with the cumulative Land Application Low limits requires two to four hours per application. Materials costs for meeting these requirements should be negligible. EPA estimated the record

keeping costs avoided from upgrading sludge quality from Land Application Low to Land Application High standards, using the following assumptions:

  a 40 acre site is a typical site size for land application ( approximately 16 hectares) ( US EPA, 1997);

  the typical application rate for land application is 7 DMT per hectare per application ( US EPA, 1997); and 4   labor at POTWs costs an average of $ 30.42 per hour ( 2001$), based on the § 308 POTW Survey.

Based on these assumptions, EPA estimated that $ 0.54 to $ 1.09 would be saved per DMT of sludge upgraded from Land Application Low to Land Application High. 5 4 See Appendix F for detail.

5 Savings per DMT are calculated by dividing the estimated labor cost per application ($ 30.42 per Hour * Hours per Application) by the total amount of sludge disposed of per one application ( 16 Hectares * 7 DMT per hectare).

16 9 MP& M EEBA Part III: Benefits Chapter 16: POTW Benefits 16.2.5 Quantifying Sludge Benefits EPA estimated the number of POTWs receiving MP& M discharges and the associated quantity of sludge that would not meet Land Application High pollutant limits, Land Application Low pollutant limits, or surface disposal pollutant limits under both the baseline and regulatory options. EPA then assumed that, as a result of compliance with the MP& M effluent limitations guideline, a POTW meeting all pollutant limits for a less costly sludge use/ disposal method would benefit from the reduced cost of that particular method. EPA estimated the reduction in sludge use/ disposal costs using the steps described below:

1. Estimate total industrial baseline and post compliance loadings of Part 503 regulated metals for each POTW with MP& M sample facility discharges;

2. Calculate the baseline and post compliance sludge pollutant concentrations for all MP& M wastewater discharged to the POTW;

3. Compare POTW sludge pollutant concentrations with sludge pollutant limits for surface disposal and land application;

4. Estimate baseline and post compliance sludge use/ disposal practices based on the estimated pollutant concentrations in sewage sludge;

5. Identify POTWs that upgrade their sewage sludge disposal practices under the alternative policy options; calculate the economic POTW benefits by multiplying the cost savings for the shift in practices by the quantity of newly qualified sludge; adjust the estimate of benefits for the percentage of POTWs that cannot land apply sewage sludge due to transportation costs or other reasons, such as cold temperature; and 6. Estimate national benefits using MP& M sample facility weights.

a. Step 1: Estimate total industrial baseline and post compliance loadings of Part 503 regulated metals EPA estimated the quantities of Part 503 metals discharged to POTWs receiving wastewater from MP& M sample facilities and facilities operating in other metal discharging industries. 6 EPA used POTW Survey data to estimate the total metal loadings and percent of total loadings discharged to POTWs by MP& M facilities.

The POTW Survey provides the following information:

  number of known MP& M facilities discharging to the POTW,

  total loadings of each regulated metal received by the POTW, and   percent of the total metal loadings attributable to MP& M industries.

6 EPA did not include metals from residential wastewater due to lack of data. The effect on the analysis of omitting residential metal loadings is not known.

16 10 MP& M EEBA Part III: Benefits Chapter 16: POTW Benefits Table 16.5 summarizes this information by POTW flow volume.

Table 16.5: MP& M Contribution to Total Industrial Loadings Received by POTWs MP& M Contribution POTW size ( million gallons per day)

2 10 11 50 > 50 MP& M facilities Average number of MP& M facilities per POTW small (< 1 MG/ year) 32.8 72.1 147.7 medium ( 1 6.25 MG/ year) 2.5 8.0 24.5 large (> 6.25 MG/ year) 1.2 2.7 10.4 Chemicals MP& M percentage of total loadings by weight Arsenic 7.4 14.0 7.0 Cadmium 16.1 23.4 12.8 Copper 18.9 21.6 10.9 Lead 13.8 19.8 10.3 Mercury 7.9 20.8 6.0 Nickel 25.1 24.4 15.8 Selenium 7.2 8.5 3.3 Zinc 20.2 16.0 8.2 Source: U. S. EPA, § 308 POTW Survey.

EP A estimated to tal baseline metal load ings from all M P& M sources, as follows:

( 16.1)

where:

PLM k, i = base line load ings of p ollutant k to PO TW ; from all MP & M sources (   g/ year);

LMPsmall, k, i = loadings of p ollutant k from sm all (< 1 MG/ y ear) sample MP& M f ac ilitie s, dis ch argin g to POTW i (   g/ year);

AvgNumSm = the average number of small MP& M fa cilitie s dis charging to P OTW i; EPA estimated the average numb er of M P& M facilities of a g iven size ( small, medium , large) tha t discharge to P OT W s in given flow categories, based on the § 308 PO TW Survey ( see Table 16.5); 7,8 SampleSm = number of MP& M sm all (< 1 MG/ year) sa mp le fa cilitie s dis charging to P OTW;

LMPmedium, k, i = loadings of p ollutant k from m edium ( 1 6.2 5 M G/ year) sam ple M P& M facilities, disch arging to PO TW s (   g/ year);

AvgNumM ed = the a verage nu mb er of med iu m MP& M fa cilities d ischarging to PO TW i ( based on th e POTW flow category ( see Table 16 .5));

7 EPA classified MP& M facilities as small, medium, and large flow in the POTW Survey, based on their discharge volume.

8 This analysis considers the following POTW flow categories: ( 1) from 2 MG/ day to10 MG/ day; ( 2) from 11 to 50 MG/ day; and ( 3) greater than 50 MG/ day.

16 11 MP& M EEBA Part III: Benefits Chapter 16: POTW Benefits SampleMed = n um b er of MP& M medium ( 1 6 .2 5 MG/ year) sa mp le fa cilities d ischar ging to PO TW i;

LMPlarge, k, i = load ings of p ollutant k fr om large (> 6.25 M G/ year) samp le MP& M f acilities d isch argin g to PO TW i (   g/ year);

AvgNumLg = the average number of large MP& M fa cilitie s dis charging to P OTW i ( based on the POTW flow category ( see Table 16.5)); and SampleLg = number of MP& M la rg e (> 6.25 MG/ year) sa mp le fa cilitie s dis charging to P OTW i.

EP A estimated to tal baseline metal load ings from all industrial sources using d ata from the P OT W Survey, as follows:

( 16.2)

where:

PLk, i = total ba seline loading s of po llutant k fr om all in du strial sources to POTW i (   g/ year),

PLM k, i = base line load ings of p ollutant k to POTW i from all M P& M sources (   g/ year),

100% = the total re ported P OT W transfers o f pollutant k from all industrial sources, and % MPk = the percentage of total repo rted P OT W transfers o f pollutant k fr om MP& M fa cilities in a g iv en POT W flow category ( see Table 16 .5).

Post compliance pollutant loadings to POT W s are calculated by subtracting the reduction in MP& M load ings due to the regulation from the e stimated total baseline loa dings.

b. ge quality First, for each metal with limits under the Part 503 regulation, EPA calculated POT W influent concentrations based on the pollutant loading a nd PO TW flow rates, as follows:

( 16.3)

where :

ICk, i = PO TW influent co ncentration o f polluta nt k (   g/ liter) for POTW i;

PLk, i = total lo ad in g of pollu ta nt k to POTW i (   g/ year) ;

Fli = OT W i flow ( liters/ day); and ODi = OT W i operation days ( 365 days/ year).

Second , EP A ca lculated sludge polluta nt con centra tions for each polluta nt:

( 16.4)

where :

PCk, i = concentra tion of p ollutant k in POTW i sludge ( mg/ kg or ppm),

ICk, i = OT W i influent co ncentration o f polluta nt k (   g/ liter or ppb),

TREk = treatment rem oval efficiency fo r pollutant k ( unitless),

PFk = sludge partition factor fo r pollutant k ( unitless), and SG = sludge gener ation fac tor (( L  mg)/(   g kg) or ppm/ ppb).

Th e par tition facto r represents the fraction of the pollutant lo ad ex pected to partition to sludg e during wastewater treatment.

This factor is chemical specific. EPA uses a sludge generation factor of 5.96 ( mg of chemical/ kg sludge)/( g chemical/ L of wastewater). The value of 5.96 is based on the " normal quantity of sludge produced " by a PO TW with primary sedimentation/ activated sludge/ digestion/ dewatering as reported in Wastewater Engineering ( Metcalf & Eddy, 197 2). The estimated sludge generation factor indicates that concentration in sludge is 5.96 ppb dry weight for every 1 ppb of pollutant removed and partitioned to sludge. Step 2: Calculate baseline and post compliance slud P P P 16 12 MP& M EEBA Part III: Benefits Chapter 16: POTW Benefits c. Step 3: Compare sludge pollutant concentrations at each POTW with limits for surface disposal and land application EPA next compared sludge baseline and post compliance pollutant concentrations to pollutant limits for land application and surface disposal using the following formula:

( 16.5)

where :

SE p = sludge exceeds c oncentratio n limits for d isposal or use pra ctice, p;

PCk = sludge polluta nt, k, concentration; and CRk, p = sludge polluta nt, k, criterion for disp osal o r use p ractice , p.

If any sludge pollutant concentration at a POTW exceeds the pollutant limit for a sludge use/ disposal practice in the baseline ( i. e., PC/ CR > 1), then EPA assumed that the POTW cannot use that sludge use/ disposal practice. , as a result of compliance with the MP& M regulation, a POTW meets all pollutant limits for a sludge use/ disposal practice ( i. e., PC/ CR   1), that PO TW is assumed to b enefit from an increase in sludge use/ dispo sal options.

d. imate baseline sludge use/ disposal practices at POTWs that can meet land application or surface disposal pollutant limits post compliance Benefits from changes in sludge use/ disposal practices depend on the baseline practices employed. hat PO TW s choose the least exp ensive sludge use/ disp osal p ractice for whic h their slud ge me ets po llutant limits. OT W s with sludge qualifying for land application in the baseline are assumed to dispose of their sludge by land application; likewise,

PO TW s with sludge me eting surfa ce disp osal p ollutant lim its ( but no t land applic ation p ollutant lim its) are ass ume d to dispose o f their sludge on surface d isposal sites.

EPA assumed that the mix of surface disposal practices employed by POT W s in the baseline ( e. g., surface disposal in a lined unit and su rface disposal in an un lined un it) ma tc he s th at of natio na l surface disposal practic es as ca lc ulated fr om th e POTW Survey ( see Table 16.1).

POTW Survey data indicate that 25 percent of total sludge meeting Land Application High standards is sold in bags and 75 percent is land applied. sold in bags. W meeting Land App lication H igh stand ards in the po st com plianc e scen ario is assumed to sell 25 p ercen t of its sludge in bags and to land apply the remainder.

Th e PO TW Surve y shows that 34 percent of total surface dispo sed sludge is dispo sed o f in lined un its and 6 6 pe rcent in unlined units. face disposal practices may not match the actual sludge disposal surface practices of any individual POTW . however, the assumed surface disposal practices are consistent with actual POT W sludge surface disposal practices. rvey data also showed that, on average, 7.5 percent of all sludge that qualifies for surface disposal was not surface disposed.

PO TW s generating slud ge exc eeding land app lication a nd surface d isposal pollutant limits in the baseline are assum ed to either incinerate sludge or place sludge in a MSWL. ey indicates that 39 percent of sludge not land applied or deposited in surface disposal sites is incinerated and 61 percent is placed in MW SLs. exceeding surface disposal and land application limits in the baseline is assumed to incinerate 39 percent of its sludge and co dispose of the rema inder. , this mix of sludge use/ disp osal p ractice s may not ma tch the a ctual slud ge disp osal p ractice s of any sin gle PO TW ; in aggregate, howe ver, the assumed distribution corresp onds to a ctual practices.

Using the sludge disposal cost differentials from Ta ble 16.4, EPA estimated savings for shifts into land application and surface disposal from the assumed mix of baseline use/ disposal practices ( see Table 16.6). As previously discussed, EPA assum ed that 50 p ercen t of sludge cou ld not be use d be neficially ( lan d ap plied or so ld in ba gs) and dispo sed les s exp ensive ly through agricultural application of sludge due to transportation costs, land availability, or weather constraints.

did not estimate benefits for this percentage of the sludge newly qualified for land application. If Step 4: Est EPA assumes t P None of the sludge meeting Land Application Low standards is Each POT This mix of sur In aggregate,

Su The surv Each POTW Again The Agency 16 13 MP& M EEBA Part III: Benefits Chapter 16: POTW Benefits e. Step 5: Calculate economic benefits for POTWs receiving wastewater from sample MP& M facilities Table 16.6 shows the cost savings for shifts from composite baseline sludge use/ disposal practices to land application or surface disposal. Reductions in sludge use/ disposal costs are calculated for each POTW receiving wastewater from an MP& M facility, using the following formula:

( 16.6)

where :

SCRi = e stim ated sludge use/ disposal cost reductio ns re su ltin g fr om th e regula tion fo r POTW i ( 2001$ );

FLi = OT W i wastewater flow ( million gallons/ year);

S = sludge to wastewater ratio, assumed to be 1,127 lbs. ( dry weight) per million gallons of water ( lbs./ million gallons) and divided by 2,200 to convert pounds to metric tons; and CDi = e stim ated cost diffe re ntia l betw ee n le as t costly composite ba se line use/ disposal meth od fo r whic h POTW i qualifie s and le as t costly use/ disposal meth od fo r whic h POTW i qualifies post compliance ( 2001$/ D MT ). P Table 16.6: Cost Savings from Shifts in Sludge Use/ Disposal Practices from Composite Baseline Disposal Practices ( 2001$/ DMT)

Baseline POTW Mix of Sludge Use/ Disposal Practices Post Compliance POTW Sludge Use/ disposal Practice Agricultural Application High ( 75%

of sludge meeting Land Application High pollutant limits) Bagged Sludge ( 25% of sludge meeting Land Application High pollutant limits) Agricultural Application

Low Surface Disposala ( Meet surface pollutant limits; do not meet land application pollutant limits)

Meets Land Application Low pollutant limits, but not Land Application High limits $ 0.54 1.09 N/ Ab N/ A N/ A Meets surface disposal pollutant limits, but not Land Application

Low limits Assumed disposal mix:

34% lined unit 66% unlined unit $ 126.39 $ 6.44 $ 71.89 $ 0.59 $ 126.39 $ 6.44 N. A.

Does not meet land application pollutant limits or surface disposal pollutant limits Assumed disposal mix:

39% incineration, 61% co disposal $ 103.82 $ 100.44 $ 95.91 $ 69.96 $ 103.82 $ 100.44 $ 0$ 103.08 N/ A a Surface disposal includes monofills, surface impoundments, and dedicated sites.

b Not applicable ( i. e., there is no cost savings).

Source: U. S. EPA, § 308 POTW Survey.

EPA assumed that only 50 percent of the sludge qualified for land application is beneficially used ( i. e., land applied or sold in bags). The remaining 50 percent of the sludge newly qualified for land application will be disposed of by other methods;

therefore, EPA assumed that no cost savings will be associated with 50 percent of the sludge qualified for land application.

To ensure that these benefits are not overstated, this analysis includes an adjustment to the estimate of national sludge use/ disposal cost benefits for POTWs that may be located at some distance from agricultural sites. This adjustment does not apply to benefits from shifts into surface disposal.

16 14 MP& M EEBA Part III: Benefits Chapter 16: POTW Benefits f. Step 6: Estimate national sludge benefits EPA scaled the sludge use/ disposal cost reductions to the national level as follows:

( 16.7)

where:

NSCR = national estimated sludge use/ disposal cost reductions resulting from the regulation ( 2001$);

n = numbe r of PO TW s estimated to shift into meeting surface d isposal or land application p ollutant limits as a result of MP & M effluent limitations;

FWi = facility sample weights for facility or fa cilities d isch arging to PO TW i; and SCRi = e stim ated sludge use/ disposal cost reductio ns re su ltin g fr om th e regula tion fo r POTW i ( 2001$ ).

16.3 ESTIMATED SAVINGS IN SLUDGE USE/ DISPOSAL COSTS Of the POTWs receiving discharge wastewater from MP& M facilities, 1,020 POTWs exceed the Land Application High pollutant limits and 856 exceed the Land Application Low pollutant limits at baseline discharge levels under the alternative options considered for the final rule. This represents approximately 6 percent of the over 16,000 operating POTWs nationwide. The number of POTWs exceeding Land Application High and Land Application Low pollutant limits under the Proposed/ NODA Option at baseline conditions is equal to 5,328 and 3,728, respectively. 9 The final rule only regulates direct dischargers and, as a result, sewage sludge quality will not be affected by the selected option. EPA, however, did estimate savings in sludge disposal costs for the alternative options which consider both direct and indirect dischargers. EPA used the estimated sludge use/ disposal cost differentials presented in Table 16.6 to calculate cost savings for the POTWs expected to upgrade their sludge disposal practices under alternative policy options. These results are presented in Table 16.7 below. The benefits are estimated at $ 11,319 to $ 22,539 ( 2001$) annually for both upgrade options.

The Proposed/ NODA Option would result in more substantial cost savings ( i. e., $ 22.8 million ( 2001$)) to POTWs. However,

the Proposed/ NODA Option is not directly comparable to the two upgrade options due to inconsistent baselines.

9 The total number of facilities reported for the Proposed/ NODA Option analysis differs from the facility count reported for the final rule and the upgrade options ( Directs + 413 to 433 Upgrade Option, Directs + All to 433 Upgrade Option). After deciding in July 2002 not to consider the NODA option as the basis for the final rule, EPA did not perform any more analyses on the NODA option  including not updating facility counts and related analyses for the change in subcategory and discharge status classifications.

16 15 MP& M EEBA Part III: Benefits Chapter 16: POTW Benefits Table 16.7: ional Estimate of Cost Savings from Shifts in Sludge Use/ Disposal Under the Alternative Policy Optionsa Shift Category/ Number of POTWs Associated Sludge Quantity ( DMT/ Year) Estimated Benefits ( 2001$)

Directs + 413 to 433 Upgrade Upgrade from minimum Land Application Low limits to Land Application High pollutant limits 15 16,548 $ 11,319 to $ 22,539 Upgrade from not meeting land application or surface disposal limits to Land Application High pollutant limits 0 $ 0 Upgrade from not meeting land application or surface disposal limits to Land Application Low pollutant limits 0 $ 0 Total 15 16,548 $ 11,319 to $ 22,539 Directs + All to 433 Upgrade Upgrade from minimum Land Application Low limits to Land Application High pollutant limits 15 16,548 $ 11,319 to $ 22,539 Upgrade from not meeting land application or surface disposal limits to Land Application High pollutant limits 0 $ 0 Upgrade from not meeting land application or surface disposal limits to Land Application Low pollutant limits 0 $ 0 Total 15 16,548 $ 11,319 to $ 22,539 Proposed/ NODA Option Upgrade from minimum Land Application Low limits to Land Application High pollutant limits 45 88,389 $ 60,458 to $ 120,386 Upgrade from not meeting land application or surface disposal limits to Land Application High pollutant limits 24 140,460 $ 6,725,273 Upgrade from not meeting land application or surface disposal limits to Land Application Low pollutant limits 25 316,565 $ 16,009,889 Total 93 545,414 $ 22,795,620 to $ 22,855,548 Nat 0 0 0 0 a Based on the Traditional Extrapolation.

Source: U. S. EPA analysis.

16.4 Methodology Limitations EPA used the POTW Survey to develop estimates of the cost saving differentials for the various sludge use/ disposal practices. Sludge use/ disposal costs vary by POTW. The POTWs affected by the MP& M regulation may face costs that differ from those estimated. As a result, the analysis may over or under estimate the cost differentials.

POTW Survey data were also used to estimate metal loadings to POTW s in the baseline analysis. There are two major limitations associated with this approach:

  The baseline metal loadings from individual MP& M facilities of interest may differ from this estimate. The effect of using the § 308 survey data to characterize the POTWs that receive MP& M discharges is therefore not known.

  The total share of metals coming from MP& M facilities is likely to be underestimated because lower flow MP& M facilities are not always known by the POTW. During the pretest of the MP& M POTW questionnaire, POTWs told EPA that they were not aware of many of the lower flow facilities that were discharging to them. The POTW would have to use the phone book in order to find and permit these facilities. EPA consequently considered exempting low flow facilities in the general metals and only oily wastes indirect discharge categories under some of the alternative regulatory options.

16 16 MP& M EEBA Part III: Benefits Chapter 16: POTW Benefits This analysis assumes that the mix of disposal practices estimated for a specific POTW may not match the actual sludge disposal practices used by that POTW. We know that the mix in the aggregate, as confirmed by the POTW Survey, is correct.

The practices used in this analysis are therefore consistent with actual POTW sludge surface disposal practices. Because accurate assumptions for specific POTWs could not be made, the analysis may over or underestimate the cost differentials.

EPA quantified, but did not monetize economic benefits from reducing interference with POTW operations for the alternative regulatory options. EPA did not estimate cost reductions that occur at POTW s with sludge inhibition problems caused by MP & M discharges. These omissions thereby underestimate the benefits of the regulation.

16 17 MP& M EEBA Part III: Benefits Chapter 16: POTW Benefits GLOSSARY hazardous air pollutants ( HAPs): air pollutants that are not covered by ambient air quality standards but which, as defined in the Clean Air Act, may present a threat of adverse human health effects or adverse environmental effects. Such pollutants include asbestos, beryllium, mercury, benzene, coke oven emissions, radionuclides, and vinyl chloride. MP& M pollutants include but are not limited to: chlorobenzene, dioxin, 1,4 isophorone, and pyrene.

( http:// www. epa. gov/ OCEPAterms/ hterms. html)

hazardous waste landfill: an excavated or engineered site where hazardous waste is deposited and covered.

( http:// www. epa. gov/ OCEPAterms/ hterms. html)

influent concentrations: measure of a pollutant's concentration in wastewater being received by a POTW for treatment ( see also: pollutant inhibition values).

interference: the obstruction of a routine treatment process of POTWs that is caused by the presence of high levels of toxics, such as metals and cyanide in wastewater discharges. These toxic pollutants kill bacteria used for microbial degradation during wastewater treatment ( see: microbial degradation).

microbial degradation: the breakdown of organic molecules via biochemical reactions occurring in living microorganisms such as bacteria, algae, diatoms, plankton, and fungi. POTWs make use of microbial degradation for wastewater treatment purposes. This process is inhibited by the presence of toxics such as metals and cyanide because these pollutants kill microorganisms.

municipal solid waste landfill ( MSWL): common garbage or trash generated by industries, businesses, institutions, and homes. Also known as municipal solid waste. ( http:// www. epa. gov/ OCEPAterms/ mterms. html)

pathogens: microorganisms ( e. g., bacteria, viruses, or parasites) that can cause disease in humans, animals and plants.

( http:// www. epa. gov/ OCEPAterms/ pterms. html)

pollutant inhibition values: determined threshold concentration for a pollutant, which when exceeded by the pollutant's influent concentration in wastewater received for treatment will have adverse effects on POTW operations, such as inhibition of microbial degradation ( see: microbial degradation).

publicly owned treatment works ( POTWs): a treatment works as defined by Section 212 of the Act, which is owned by a state or municipality. This definition includes any devices or systems used in the storage, treatment, recycling, and reclamation of municipal sewage or industrial wastes of a liquid nature.

( http:// www. epa. gov/ owm/ permits/ pretreat/ final99 . pdf)

silviculture: management of forest land for timber. ( http:// www. epa. gov/ OCEPAterms/ sterms. html)

vector: 1. An organism, often an insect or rodent, that carries disease. 2. Plasmids, viruses, or bacteria used to transport genes into a host cell. A gene is placed in the vector; the vector then " infects" the bacterium.

( http:// www. epa. gov/ OCEPAterms/ vterms. html)

16 18 MP& M EEBA Part III: Benefits Chapter 16: POTW Benefits ACRONYMS DMT: dry metric tons HAPs: hazardous air pollutants MSWL: municipal solid waste landfill POTWs: publicly owned treatment works 16 19 MP& M EEBA Part III: Benefits Chapter 16: POTW Benefits REFERENCES Association of Metropolitan Sewage Agencies ( AMSA). 2000. Survey on Proposed MP& M Effluent Guidelines.

Metcalf and Eddy. 1972. Wastewater Engineering. New York, NY: McGraw Hill, Inc.

Solid Waste Disposal Facility Criteria. 40 CFR Part 258, Federal Register 50978, October 9, 1991)

Standards for the Use/ Disposal of Sludge. 40 CFR Part 503, February 1993.

U. S. Environmental Protection Agency ( U. S. EPA). 1985. Handbook for Estimating Sludge Management Costs U. S. Environmental Protection Agency ( U. S. EPA). 1987. Guidance for Preventing Interference with POTW Operations.

U. S. Environmental Protection Agency ( U. S. EPA). 1993a. Standards for the Use and Disposal of Sludge; Final Rules. 40 CFR Part 257 et al., Federal Register, February 19.

U. S. Environmental Protection Agency ( U. S. EPA). 1993b. Regulatory Impact Analysis of the Part 503 Sludge Regulation.

Final. Office of Water. EPA 821 12 93 006. March.

U. S. Environmental Protection Agency ( U. S. EPA). 1997. Economic Assessment for Proposed Pretreatment Standards for Existing and New Sources for the Industrial Laundry Point Source Category. Office of Water. EPA 821 R 97 008 ( pp 10 51  10 54).

16 20 MP& M EEBA Part III: Benefits Chapter 17: Environmental Justice & Protection of Children Chapter 17: Environmental Justice &

Protection of Children INTRODUCTION Executive Order 12898 requires that, to the greatest extent practicable and permitted by law, each federal agency must make achieving environmental justice part of its mission.

Therefore, EPA examined whether the final regulation will promote environmental justice in areas affected by MP& M discharges. CHAPTER CONTENTS 17.1 raphic Characteristics of Populations Living in the Counties Near MP& M Facilities ..... 17 1 17.2 Children from Environmental Health and Safety Risks ................. ...... 17 3 Glossary ................. ................. ... 17 4 Reference ................. ................. .. 17 5 Demog Protection of EPA concludes that discharges from MP& M facilities regulated under the final rule do not have a disproportional environmental impact on minority populations, based on the demographic characteristics of the populations residing in the counties affected by MP& M discharges.

The final rule is not subject to Executive Order 13045,   Protection of Children from Environmental Health Risks and Safety Risks" ( 62 FR 19885, April 23, 1997), because it is based on technology performance and not on health or safety risks.

However, EPA analyzed the reduction of children's health impacts associated with the MP& M regulation, and determined that reductions in the baseline lead exposure are minimal.

The following section assesses whether MP& M discharges have a disproportionally high impact on minority populations.

17.1 DEMOGRAPHIC CHARACTERISTICS OF POPULATIONS LIVING IN THE COUNTIES NEAR MP& M FACILITIES EPA assessed whether adverse environmental, human health, or economic effects associated with MP& M facility discharges are more likely to affect minorities and low income populations. This analysis uses data on the race, national origin, and income level of populations residing in counties traversed by reaches receiving discharges from the 32 sample MP& M facilities considered in the final rule analysis. The 32 sample facilities are located in 46 counties in 12 states. The MP& M survey was designed to provide a representative coverage of various types of MP& M facilities, but not of their geographical location. EPA is therefore able to analyze only the location characteristics of the sample facilities, and not all 43,901 MP& M dischargers. 1 EPA compared demographic data from the 1990 Population Census for the counties traversed by sample MP& M reaches with the corresponding state level indicators ( U. S. Census Bureau, 1990). EPA considered several demographic characteristics to assess the environmental justice of the final regulation, including the relative proportions of African Americans, Native Americans, and Asian or Pacific Islanders, median income, the proportion of the population below the poverty level, unemployment percentage, and the proportion of the population that are children. Table 17.1 presents the results of this analysis, which show that the demographic characteristics of MP& M counties generally reflect state averages.

EPA calculated median income for the group of counties in each state receiving MP& M discharges as a weighted average of 2 each county's median household income. County s populations are used as weights in this analysis. EPA calculated this summary variable in place of the true median household income for MP& M counties because appropriate census data are not 1 This estimate of MP& M facilities includes baseline closures.

2 Average median income in MP& M counties =

  i Median Income ( i) × Number of Households ( i)/   Number of Households ( i), where ( i) is a sample MP& M county.

17 1 MP& M EEBA Part III: Benefits Chapter 17: Environmental Justice & Protection of Children available. The Agency notes that comparing this weighted average median income to the state level median income may introduce uncertainty in the analysis.

Income data, as well as other characteristics examined to determine whether minority and/ or low income populations are subject to disproportionally high environmental impacts, show that the socioeconomic characteristics of populations residing in counties affected by MP& M discharges reflect corresponding state averages. Based on these findings, EPA expects that environmental benefits resulting from the MP& M rule will not accrue to populations disproportionally based on race or national origin and therefore will promote environmental justice.

Table 17.1: County Level Comparison of Demographic Data: Counties with Sample MP& M Facilities Versus Entire State State Counties %

White %

African

American % Native Am.,

Eskimo,

or Aleut % Asian or Pacific Islander Median Income %

Below Poverty Level %

Unemployed %

Children California MP& M Only 3 58.64% 11.82% 0.53% 11.20% $ 36,100 13.98% 7.04% 25.83%

Entire State 58 69.07% 7.39% 0.84% 9.57% $ 35,798 12.51% 6.65% 26.01%

Indiana MP& M Only 3 95.38% 3.76% 0.23% 0.41% $ 24,785 14.31% 7.42% 23.38%

Entire State 93 90.59% 7.75% 0.26% 0.66% $ 28,797 10.68% 5.74% 26.29%

Kentucky MP& M Only 1 98.44% 0.54% 0.12% 0.74% $ 34,485 7.40% 3.64% 29.38%

Entire State 120 92.06% 7.11% 0.19% 0.47% $ 22,534 19.03% 7.37% 25.93%

Maryland MP& M Only 1 94.61% 4.47% 0.35% 0.34% $ 36,019 7.50% 4.56% 26.86%

Entire State 24 71.03% 24.87% 0.30% 2.88% $ 39,386 8.27% 4.30% 24.31%

Mississippi MP& M Only 3 56.88% 42.46% 0.09% 0.47% $ 26,342 19.31% 6.93% 28.00%

Entire State 82 63.46% 35.59% 0.34% 0.49% $ 20,136 25.21% 8.43% 29.04%

Missouri MP& M Only 1 99.45% 0.04% 0.44% 0.04% $ 17,594 18.87% 4.00% 24.21%

Entire State 115 87.68% 10.69% 0.44% 0.77% $ 26,362 13.34% 6.16% 25.71%

New York MP& M Only 2 92.64% 4.90% 0.34% 0.78% $ 25,864 12.13% 10.57% 28.09%

Entire State 63 74.47% 15.90% 0.33% 3.83% $ 32,965 13.03% 6.88% 23.66%

North Carolina MP& M Only 3 88.47% 10.71% 0.23% 0.33% $ 26,189 10.75% 3.94% 24.10%

Entire State 100 75.60% 21.96% 1.25% 0.76% $ 26,647 12.97% 4.79% 24.27%

Ohio MP& M Only 2 89.17% 9.69% 0.24% 0.74% $ 28,527 11.70% 6.82% 24.76%

Entire State 89 87.81% 10.62% 0.21% 0.82% $ 28,706 12.54% 6.60% 25.85%

Oklahoma MP& M Only 4 82.68% 8.48% 6.99% 1.06% $ 26,456 13.63% 5.86% 26.20%

Entire State 77 82.26% 7.38% 8.03% 1.04% $ 23,577 16.71% 6.87% 26.60%

17 2 MP& M EEBA Part III: Benefits Chapter 17: Environmental Justice & Protection of Children Table 17.1: County Level Comparison of Demographic Data: Counties with Sample MP& M Facilities Versus Entire State State Counties %

White %

African

American % Native Am.,

Eskimo,

or Aleut % Asian or Pacific Islander Median Income %

Below Poverty Level %

Unemployed %

Children Pennsylvania MP& M Only 22 92.89% 6.12% 0.12% 0.64% $ 27,851 11.56% 6.46% 22.88%

Entire State 68 88.57% 9.15% 0.13% 1.14% $ 29,069 11.13% 5.97% 23.54%

Washington MP& M Only 1 84.94% 4.97% 1.18% 7.90% $ 36,179 7.96% 4.15% 22.56%

Entire State 40 88.64% 3.03% 1.71% 4.34% $ 31,183 10.92% 5.72% 25.86%

Source: U. S. EPA analysis of 1990 Census Data ( U. S. Bureau of Census 1990).

17.2 PROTECTION OF CHILDREN FROM ENVIRONMENTAL HEALTH AND SAFETY RISKS EPA assessed whether the final regulation will benefit children, including reducing health risk from exposure to MP& M pollutants from consumption of contaminated fish tissue and drinking water and improving recreational opportunities. EPA was able to quantify only one category of benefits specific to children: avoided health damages to pre school age children from reduced exposure to lead. This analysis considered several measures of children s health benefits associated with lead exposure for children up to age six. Avoided neurological and cognitive damages were expressed as changes in three metrics:

( 1) overall IQ levels; ( 2) the incidence of low IQ scores (< 70); and ( 3) the incidence of blood lead levels above 20 mg/ dL.

EPA also assessed changes in the incidence of neonatal mortality from reduced maternal exposure to lead. EPA s methodology for assessing lead related benefits to children is presented in Chapter 14 of this report.

The Ohio case study analysis showed that the final rule is expected to yield $ 422,000 ( 2001$) in annual benefits to children in the state of Ohio from reduced neurological and cognitive damages and reduced incidence of neonatal mortality. On the other hand, the national level analysis shows that benefits to children from reduced lead discharges are negligible nationwide. As noted in Chapter 18, different findings from these two analyses are likely to be due to insufficient data and a more simplistic approach used in the national level analysis.

Children over age seven are also likely to benefit from reduced neurological and cognitive damages from reduced exposure to lead. Giedd et al. ( 1999) studied brain development among 10 to 18 year old children and found substantial growth in brain development, mainly in the early teenage years. This research suggests that older children may be hypersensitive to lead exposure, as are children aged 0 to 7.

Additional benefits to children from reduced exposure to lead not quantified in this analysis may include prevention of the following adverse health effects: slowed or delayed growth, delinquent and anti social behavior, metabolic effects, impaired heme synthesis, anemia, impaired hearing, and cancer ( see Chapter 14 of this report for details).

17 3 MP& M EEBA Part III: Benefits Chapter 17: Environmental Justice & Protection of Children GLOSSARY MP& M reach: a reach to which an MP& M facility discharges.

17 4 MP& M EEBA Part III: Benefits Chapter 17: Environmental Justice & Protection of Children REFERENCES U. S Bureau of Census. 1990. 1990 Census of Population Data. http:// www. census. gov/.

Giedd, J. N., L. Blumenthal, N. O. Jeffries, F. X. Castellanes, Hong Liu, A. Zijdenbos, Tomas Paus, Alan C. Evans, and J.

Rapoport. 1999.   Brain Development During Childhood and Adolescence: A Longitudinal MRI Study.  Nature Neuroscience, Vol. 2, No. 10. October: 861 863.

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