TECHNOLOGY, PREVALENCE, AND ECONOMICS
       OF LANDFILL DISPOSAL OF SOLID WASTE'
             This  report  (SW-754),
    performed for  the Off-lee  of  Solid Wast.e
under contract no. 68-01-4895, Is  reproduce
        ute             »-    •   nns  s
  attributed to the contractor and not  to  the
             Off -Lee of Sol-id Waste
     U.S. ENVIRONMENTAL PROTECTION  AGENCY
                     1980

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tffPISrif "..-


IfHiiMr-1^
   f:: , :•'. • _,..,.
,.:.:-  |nis report. w|ff%^^                          Int""

i4w fork,"'under contract no.  68-01-4895.





fliP:v?ewP^i  DolTcfes of the U.S. Environmental  Protection Agency, nor

KesmllioFof commercial products constitute  endorsement by the


li.S, Goverrimerit."  "  J " '
                              .



                     nenvironin

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                                  FOREWORD
     This report has been developed  under contract number 68-01-4895  to
  provide information for the Office of SoXid B,ste i0 use in developing
  ,-xa.lin.. for the landfil! disposal  o( .„„, ^  ^  ^^^    •
  the classification of solid ...t.  disposal  facilities.  These
  activities are undated  under Sections  1008  and 4004,  respectively
  94-580. EeS°U"e  C0"e""i°"  -« •••o-ry  Act  of  1976.  Public


      Landfill  disposal of  solid »,st.  is revie»ed in  terms of,  ,1, the
  use of  landfills  for  disposal,  (a)  technics co™nly e»ployed for
  ...h disposal,  and  ,3, the costs  associated »ith iandfil!  disposal by
 those techniques.   This report also presents estimates of  the
 anticipated increases  in costs of iandfill disposal! as  a result  of the
      Heferences to the information  contained in this report are found
    Environment,! and Economic lnp.«  statements (E^a,  »hich h,v« been
            "  C°"Jnn0"°"  -1"  «•  ->llo»lng! "Sidelines  for  th.
          Disposal  of Solid Baste" ,40 CFR 241), and: "Criteria  for the

                         """ DiS°Sal  '               —ices" ,40
      Jnformation  presented  in  this  report is  based  upon  ,»  early
»or,lng draft  of  the  Suidelines  and th.  Pebruaryie,  1978 propog,a?
cr.ter.a ,43 CFE 4942).   Some information  contained in the tl  KXs's
»ay, therefore,  appear  inconsistent  wlth  this  report.   any  such
.ncons.st.ncies  shouid  be  attributed  to  more  current  information

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                          ACKNOWLEDGEMENTS
document were:
          Fred C. Hart Associates.  Inc.

          Celia Y.C. Chen
          William H. Crowell
          Fred C. Hart (Project Director)
          James E. McCarthy
          James A. Rogers

          WayneT^usa  (Assistant Project Manager)
          Timothy D. Van Epp
          Sandy  P. Wright  (Project Manager)
                              S
 State and industry personnel.
                                                                 '

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                             TABLE OF CONTENTS
  SECTION
                                                                  PAGE
 List of Tables	         •

 List of Figures  	  .....               !

 I.  . Executive Summary	       :          .,

 II.  Introduction 	
      A.  Scope of Work   . .  . \	   d
      B.  General Methodology  ..'.'.'.' .'.'!!.'''""'''   4
      C.  Data Sources ...              	I....   
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                                                                 85
VI 1 1. Impact of the Guidelines on Energy Use
     A.  Background ......................   °
     B.  Estimating Construction Energy Impacts ........   »b
     C.  Estimating Operating Energy Impacts  .........   88
                                                                 89

                                                                 92
References Cited  	

Bibliography  	

Personal Communications 	   97

Appendix A.  Sample Baseline Cost Curves  ...........   A-l

Appendix B.  Unit Cost Calculations and Assumptions ......   B-l

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                         LIST OF TABLES
TABLE
                                                            PAGE
  1
  2

  3
  4
  5

  6

  7

  8

  9

 10

 11

 12
 13
 14

 15


 16

 17

 18

 19


 20


 21

 22
 Landfill Prevalence by Size Category  .  .  .
 Existing Technology Levels and Assumed
     Upgrading Technology  	
 Upgrading Technology Costs.  .  	
 Alternate Upgrading Technology Costs  .  .  .
 Crop Residues as a Waste Management
     Problem	
 Prevalence of Municipal  Landfills
     by Location, 1978   	
 Standard Industrial  Classification  Codes
     for Manufacturing Industries   	  ,
 Waste Generation by Manufacturing  Industries
     in the United States  	
 Waste Generation by Manufacturing  Industries
                  California	
                  by Large  Firms in  San Jose,
    in San Jose,
Waste Generation
    California
Waste Generation
    California
Waste Generation
Industrial Solid
Estimated Number
                  by  Small  Firms  in  San Jose,
                  in Wisconsin, by SIC Group  . •.
                  Waste Production	:.
                  of Industrial Landfills,     I
    by Size Category	   !
Number of Ash Landfills by Daily Capacity    ' f
    for Steam Electric Power Plants, by
    Plant Type	;>
Estimation of U.S. Population in	f
    Environmentally Sensitive Areas   ....:.
Impact of Guidelines on Operating Costs of    i
    Municipal Solid Waste Landfills (Costs/Ton!)
Impact of Guidelines on Operating Costs       :
    of Industrial Waste Landfills (Costs/Ton) i.
Impact of Guidelines on Operating Costs of    i
    Pollution Control  Residue Landfills       i
    (Costs/Ton)   	!.
Summary of Impact of Landfill Guidelines on   \
    Operating Costs of Landfills              ;
    (Costs/Ton)  . . .	;.
Aggregate Impact of Guidelines on Annual      i
    Landfill  Operating Costs	:.
Effect of Change in On-site Clay Availability '
    Assumption on Guidelines Cost Impacts .  . L
  8

 21
 26
 27

 32

 34

 37

 38

 40

 41

 42
 43
 45

 46


 50

 60

 66

 67


 68


69

70

72
                               111

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                        LIST OF TABLES
                          (continued)
TABLE
                                                           PAGE
 23   Aggregate Impacts of Guidelines on
          Landfill Costs Under Alternative
          Sensitive Area Assumptions  ......
 24   Trend in Mixed-Waste Resource Recovery
          Facilities Implementations  . 	
 25   Conversion Technologies at Existing
          Recovery Facilities, 1976  . ._	
 26   Upgrading Technologies Resulting  in
          Increased Energy Operating Costs   .  .  .
 27   Total Increased Capital Costs  Per Ton  and
          Percent Increase in Construction Energy
          Use  for Upgraded Facilities  	
73

82

82

86


87
                                   iv

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                         LIST OF FIGURES
FIGURE
                                                                PAGE
  1    Sanitary Landfill  Operating Costs	i.            9
  2    Sanitary Landfill  Costs  	  ......   ^
  3    Average Sanitary Landfill  Disposal  Cost'  '  % '  '
          for Under 20,000 Population	''.',..       11
  4    Scale Economies  in Landfill	      '.''''   12
  5    Current Sanitary Landfill  Costs   	  .......   ^
  6    Composite Sanitary Landfill  Costs  	    :           15
  7    Concentration of Wetlands  in the  U.S.   ......  .'  .'  '   53
  8    Existing Flooding  Problems  	  ..!..''   54
  9    Continuous  Permafrost  in the U.S.   ......  I  ....   55
 10    Estimated Extent of Sole or  Principal Source    !
          Aquifers,  Coterminous U.S	  .  i  .         57
 11    Environmentally  Sensitive Areas in  the  U.S.   .'I!''*   58
 12    Impact of Higher Landfill User Charges
          on  Demand	_           75
 13    Optimal  Location/Market Area for  	  .....
          Sanitary Landfill 	               78
 14    Waste  Collection Area  for Various           .......
          Waste  Generation  Densities	   80

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                          I.    EXECUTIVE  SUMMARY
   f  +JhrS-re?°rt  eyraluates  the costs and economic and energy use impacts
  of  the Guidelines  for the Landfill Disposal of Solid Waste to be pro-
  posed under Section  1008 (a) of P.L. 94-580, the Resource Conservation
  and Recovery Act.  This analysis was accomplished in si'x steps.  Each
  step and the conclusions drawn from them are summarized briefly below.
 mnrfPi-g data u°"u landfi11 tyP65 were used to select three
 model landfill sizes on which to base subsequent cost, leconomic, and
 energy use considerations.  The landfill sizes chosen -I- 10, 100, and
 300 tons per day (TPD) - represent capacity ranges of 0 to 50, 50 to
 200, and greater than 200 TPD.                         ;

      Second' cinrent 'landfill practices were defined ins terms of the
 lp nl??1? J   Derating procedures utilized most commonly, and base-
 line unit costs were identified for each of the three model landfill
 sizes.  Currently,  most landfills use only ditching for surface runoff
 control  and daily cover and clay liners for leachate control.  Current
 disposal  costs range from $2.00 to $12.00 per ton,  averaging $11.15 per

 llr ?on  -VSn^n™-! SUe^ $6'65 Per t0n at 10°  TPD s'te* and $5.§r
 ?n tn 5n        TS°  S1*?S;   These total  unit costs represent approximately
 20 to 30  per cent capital  costs and 70  to 80 per cent operating expenditures.

 tn ^h51rd'^an'OUS ava}lal?le landfill  practices which make it  possible
 to achieve  the recommendations  of the Guidelines are identified and the
 unit costs  of these alternate methods were  estimated.   A  variety of
 landfill  upgrading  technologies  were assumed.   These covered waste
 processing,  gas control,  leachate  control,  surface  runoff control,  and
 monitoring    Leachate  controls,  such as  impermeable daily cover (off-
 site source)  and  diking, will  incur the  highest landfill  technology unit
 costs, accounting for  anywhere  between two-thirds and  all of the  total
 incremental  costs due  to the  Guidelines,  depending  on  landfill  type
 size,  and sensitivity.                                  ;        ^  '
             W5ule  these Guidelines are only advisory arid compliance is
 ««    A    ^he aggregate costs of application of the (Guidelines were
 estimated.  This is accomplished by (1) estimating the population of
 various types of landfills, (2) determining the prevalence of various
 environmentally sensitive site conditions, (3) determining the tech-
 nologies required by the possible combinations of facility type and
 environmental conditions, and then (4) summing the costs' for each cate-
 gory to arrive at an aggregate national cost.   Based on a literature
 search and stated assumptions, the report concludes that! there are
 81,317 landfills in the United States, of which 81% are &t privately
 ?anHd--i? dustr1al Slte,s:  The report further estimates thkt 73% of all
 n? til r-5r?-  Catedvin env1r°nmentally sensitive areasl   Application
 of the Guidelines would result in increased costs of $2,070.3 million,  a
 rnJS™*  -irr6956 °Her current costs ^ all  landfills in the Nation
 complied with these advisory Guidelines.   The  impact is greatest for -
 small sites (0-50 TPD)  located in environmentally sensitive arias.
vimiQi      ™  ec°nomic effects of the increased costs  identified  pre-
viously are considered.   These considerations  are grouped  into  two

                                   -i-                   ;

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categories:  (1) impacts on the supply of landfills; and (2) impacts on
the demand for landfill services.  Briefly, the major impacts on land-
fill supply will be:  (1) increased disposal fees for landfill users;
(2) higher taxes for landfill support; (3) changes in the profits of
private landfill owners; (4) changes in the profits of industries with
on-site disposal; and (5) regionalization and consolidation of waste
handling.  Increased costs for landfill services, on the other hand,
will cause the demand for landfill services to decrease in favor of
increased source reduction, energy and resource recovery, other legal
waste disposal methods, and illegal dumping.

     Finally, current and expected landfill energy use at existing
facilities as a result of Guidelines implementation was considered.
Construction energy use will rise anywhere  from 1 per cent for a 300 TPD
pollution control residue landfill located  in an environmentally non-
sensitive area to 144 per cent for a 10 TPD municipal landfill sited in
a  sensitive area.  Operating use will  increase 100 per cent at most
industrial and pollution control residue  landfills which do not already
apply impermeable daily  cover.
                                    -2-

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                            II.  INTRODUCTION
 A.   Scope of Work
      I   Tp«e ?f th1s report is to consider the costs,  economic
         J-?ie?eCtS'?n S"r?? USG °f aPP11cat1on of the Guidelines for
    P i   S «S1SE2Sa] °f S°lld WaSte t0 be Pr°P°sed under  Section  1008(a)
  V   A Z"   ' the Resource Conservation and Recovery Act (hereafter
 referred to as the Act). The Guidelines contain recommended  considerations
 of ^H?^cL ?! H?-??10rVduS1Jn'  ^ruction,  operation  and maintenance
 °!j°lld waste landfi Is which if applied on  a case-by-ease  basis  should
 assist in complying with the "Criteria for Classification  of Solid Waste
 4004U)  of'the'Act       CR ^  deVeloped 1n accordance  with Section

      The Guidelines are applicable to the landfill  disposal  of all solid
 waste.   They delineate recommended practices  but do  not  'contain specific
 requirements.   The Guidelines  are  not mandatory.  There  will be no
 Federal  enforcement of the  Guidelines.  Thus,  for the  purposes of  assessing
 the economic impact of the  Guidelines,  it is  assumed that  all States
 will  adopt  programs which require  compliance  with the  Guidelines.
                                                         I
      The scope  of  the  Guidelines covers seven  areas, as  follows:
               Section

               241.200
               241.201
               241.202
               241.203
               241.204
               241.205
               241.206
                                        Site Selection
                                        Design
                                        Leachate Control
                                        Gas  Control
                                        Runoff Control
                                        Operation
                                        Monitoring
ofethis°repS?td Pract1ces  1n each  of these  areas
                                                     discussed in Section  IV
mpni        '     °f thf .a^Ption of the Guidelines,  significant  environ-
mental benefits are anticipated - particularly in the protection  of  ground
and surface-water resources.   For obtaining these and other benefits, costs
will be incurred as existing facilities undertake an operational upqradinq
program and as new facilities are sited,  designed and Operated.  The  major
near-term costs associated with Guidelines  application will  be incurred
through the upgrading of existing facilities.            :
                                                        I

9zii 9me^r°^'SJ°ns c°ntained in Sections 241.200 (site selection) and
241.201 (design) would only be applicable to  new  facilities.  The  various
practices discussed under each of the  remaining five sections of the Guide-
lines can be used individually or in combination  at  existing facilities to
                                   -3-

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achieve environmental benefits, as dictated by site-specific conditions.
will not be possible, nor necessarily beneficial, however, for all facili-
ties to institute all of the practices outlined in the aforementioned seven
sections of the Guidelines.
                                                                    It
B.   General Methodology


     1    Format.   The analysis of economic and energy impacts contained in
this report proceeds through  six steps, each of which corresponds to a
section of the  report.

     The  first  step is the  selection  of model  landfills.   Existing data on
landfill  types  have been  used to select three  sizes  of  landfill which serve
as  the basis  for all subsequent consideration  of costs, economic  impacts,
and energy use.

     The  second step is to  identify baseline  costs for  facilities in each of
the three model  sizes.  Baseline costs are defined as the unit costs incurred
by  facilities with the mix  of technologies and operating  procedures  currently
 in  use.

     The  third  step is to estimate the costs  of alternate methods of compli-
 ance with the Guidelines.  This section of the report first identifies  the
 recommended  practices  in  seven specific areas of siting,  design  a™
 operation.   The report then estimates unit costs of the alternate methods  in
 each category.

      The fourth step is  to estimate the aggregate costs of compliance  with
 the Guidelines.  This  is  accomplished by (1)  estimating the population of
 various types of landfills, (2) determining the prevalence of various  envi-
 ronmentally sensitive site conditions, (3) determining the technologies
 reouired by the possible combinations of facility type and environmental
 conditions,  and then (4)  summing the costs for each category to arrive at an
 aggregate national cost.

      The fifth  step is to consider the economic effects of the increased
 costs identified in Steps 3 and 4.  Ten specific  effects  are considered
 grouped  into two major categories:   (1) effects on  the supply of ^ndfils,
 and (2)  effects on demand for  landfill services,  as opposed to other
 of solid waste  management.

      Finally   the sixth  step  considers current energy  consumption and in-
 creased  energy  use as a  result of Guideline  implementation for the three
 model landfills.
                       This  report was  the  second major  deliverable  under
  Contract No.  68-01-4895.   It was the  result of a concentrated  effort  over  a
2.   Methods.
  boni.rai.1. iiu.  oo ui  Tt>.7v>.   A* ""-  ~"~  •—•-•- -•  - —       .       .    L.-nn
  very short period  of time — most of  the  analysis and writing having been
  undertaken during  a four  week period.

       The methods used in  data collection  were dictated by the time  con-
  straints.   Primary emphasis was placed on a review of available literature,
                                     T-4-

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  supplemented by telephone contacts with a small  number of industry associ-
                       °"S *»««»** "> the areas of
       Because of constraints in time and in the  availability of  research  an
              'fr6 °f ^T11 Pr!valence  a"d costs was 'obta?neS   Given ?he
   ssumotions   ?or Si"1?? key^anab1es' * wa* necessary  to make  numerous
  the text aiAnr, SitJ Jh    Sf   -6Se  a!sumPtlons  have been clearly stated in
  the text along with the  reasoning which led to  their  adoption   By adootina
  this approach,  iVwas hoped that useful  comments would be  stimulated as to
  the adequacy of the assumptions, so that further revisions  of the  report
  would rest  on the best available estimates.                         P
  C.   Data Sources
      1*    Sources Utilized
                            in the Preparation of the Draft Report    A
                                          1S C0nta1ned *H the Reference
                                      were ut111zed-
2'    Potential Sources for
Revision

ln **
                                          of
                                             this Report    Several  methods
                                                have been: discussed
                                          focused on the   evaience  °f
      The data on prevalence of landfill  types used in thlis  reoort arp  ^<;
 complete as can be obtained without undertaking a major  ong-term JffoS  to
 conduct a nat!onal survey of landfill  sites.   EPA is  currently  undertaking
 3ffl  an?UKVey ^fr,^6 ™™°rity of Section  4005 of  RCRA?  but  32 resuHs9
             aval  able until  after the  scheduled completion  of this contract
                                       seem                          "'
     A second problem area relates to the adequacy of the data

cst da?aS;.nSt6 S°f ""^ ^ 1n thl'S W «^J SSlM
cost data reported by operating landfills and (2) engineering cost esti-
            f°rmer' Wh!i1S Preferable be^se they reflect ISuSl  JpSratlng
           t    ge"fally n°u reP°rte(i 1n sufficient detail  in the available
                    6m°re £han a" °^er-of-magnitude range  for cost data.
                        must "P/*1^ S1te Slze'  site conditions,  type of
cess watP               Procedures, and type of technologies used to pro-
cess waste and to minimize environmental impacts.   None of the existina
literature sources reported the information*^ such exhaustive deiail  9
To
     As a result, engineering cost estimates were
the compliance costs.  These estimates were based
personal communications.   Efforts should continue
mates.  One way in which they might be improved is
of a sample of permit application files in States
solid waste .disposal facilities.   Such permit appl
detailed information on site characteristics, type
waste handled, and technologies utilized for waste
                                                  used  to  identify most of
                                                  on  exis|ting  literature and
                                                  to  improve these esti-
                                                   through a detailed review
                                                  that  require permits for
                                                  ications should contain
                                                   and  projected amount of
                                                   processing, leachate
                                  -5-

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control, gas control, etc.   This information could be frrelfed.wl^ cost
data fof the facilities to provide a more accurate picture of existing unit
costs and projected impacts of the Section 1008 Guidelines.

     A third problem area relates to the lack of data relating to energy use
at landfill disposal sites.  In general the literature does not provide
enerqy use figures for actual construction, operation, and maintenance.
Available data on energy use are generally provided only as lump sum utility
expenditures.

     As with the landfill prevalence and unit cost data, methodologies were
developed in this study to estimate the impact of the Guidelines on energy
use   A more adequate method of assessing energy impacts would require a
survey of actual facilities to develop an energy data base.
                                  -6-

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                  HI.  MODEL LANDFILLS SELECTION CRITERIA
      The first step in the analysis of economic and energy impacts of the
 Guidelines was to identify model landfills to be used as the basis of cost
 estimates.  Three factors were considered in choosing the models-  (a) pre-
 valence of the model types; (b) differences in unit cost: for the proposed
 models; and (c) compatibility with the models chosen by lEmcon, Inc   in
 their Draft Environmental Impact Statement for Proposed 'Criteria for Clas-
 sification of Solid Waste Disposal Facilities under Section 4004 of RCRA
 (1978).  Since cost estimates for both Section 4004 Criteria and the Guide-
 lines ^ will require many of the same technologies and operating procedures
 choosing a compatible model would make possible a comparison of these esti-
 mates.   The result of this comparison would serve to reinforce and improve
 the estimates provided by the earlier Emcon study.       I
                                                         t
                                                         i
 A.    Prevalence                                         l
                                                         \
                                                         f

      The most comprehensive data on landfill  prevalence are those provided
 by  Waste Age in its  1977  survey of U.S.  disposal  practices  (Reference 1)
 These data are organized  into six size categories,  as  shown in Table  1
 Since data were presented in size categories,  rather than by technology
 utilized,  by type  of waste handled,  or by site conditions,  this would sug-
 gest that size be  the variable determining the choice  of1models.
                                                         !

 B.    Unit Cost                                          I


      Unit  cost data  also  suggest  that  size should be the;key  variable in the
 choice  of^model  landfills,  due to  the  fact that there  are important economies
 of  scale  in  landfill  design  and operation  which lead to  lower unit costs at
 larger  sites.                                            |

      Data  relating unit costs  to  size  are  presented in Figures  1-4.   The
 actual  dollar  values  assigned  as  unit  costs are of little concern at  this
 stage of the analysis.  What is of interest is that all bf the  sources show
 an  initial steep decline  in  unit costs as  landfill capacity increases,
 followed by a  leveling off past some threshold.  The threshold  value  varies
 in  each of the  sources, but  in  no case was it higher than 300 tons per day
C.   Compatibility with Section 4004 EIS
     The final consideration in the choice of models was compatibility with
the models used by Emcon, Inc., in estimating the impacts, of the Section
4004 landfill criteria (Reference 6).   That analysis was based on four
models:
                                -7-

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                               TABLE 1
                LANDFILL PREVALENCE BY SIZE CATEGORY
          Size Category
      0-50   Tons Per Day
     50  -  100   Tons Per Day
    100  -  200   Tons Per Day
    200  -  500   Tons Per Day
    500  -1,000   Tons Per Day
      1,000+      Tons Per Day
      Unknown
Number of Landfills
     11,165
      1,195
        781
        485
        331
        129
      1,807
Source:   Reference 1.
                               -8-

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                                    FIGURE' 1

                        SANITARY LANDFILL OPERATING  COSTS
              4.00
     Tons Per Year  0
     Tons Per Day3  0
     Population6    0
100.000
 320
122.000
200.000
 640
244,000
300.000
 960
366.000
400,000 i
 1280
488.000
500.000
 16CO
610.CCO
           a.    Based on  a 6-day work  week.

           b.    Based on  national  average of  4.5 Ibs.  per  person  '
                 per calendar day.
Source:  Reference  2,
                                     -9-

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                                                   FIGURE 2

                                              SAMITAP.Y LANDFILL COSTS
o
I
                           PIECE OF  EQUIPMENT
                                  2 PIECES OF EQUIPMENT
                                                   3 PIECES OF EQUIPMENT
4 PIECES OF EQUIPMENT
Tons Per Year

Tons Per Day
Note:_ The dashed  portions of  the curve indicate overtime or second shifts allowing the site to be operated without
      purchasing  additional equipment.
 Source: -7oforence  3.

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                                         FIGURE  3



            AVERAGE SANITARY LANDFILL DISPOSAL COST FOR  UNDER 20.000 PflPliizmnM
            35
            30
            25
          (2 20
          «
          «§
          Q
            10
            0
Population    0



Tons Per Day
 JL
5,000




  13
10,000




   26
15,000




   39
20,000




   52
     Source:  Reference 4.
                                           -11-

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Capacity 1000's
 3
M /year
                                  FIGURE 4

                           SCALE ECONOMIES IN LANDFILL
4   8   12  16  20  24   28  32   36  40  44    48   52   56
Tons per day       12  24   36  48  60  72   84  96  108 120 132   144  160  172




            Note:  Tons  per day figure  assumes that  the waste has the same density as water.
           Source:   Reference 5.
                                           -12-

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10 TPD, 100 TPD  300 TPD, and 700 TPD.   Since there is an apparent consensus
that incremental economies of scale are quite small at sites larger than 300
IPD, it was decided through discussion with the Project'Offleer to eliminate
the largest of these models.   The other three models adequately demonstrate
the range of unit compliance costs at small, medium and!large sites.   At the
same time, they were compatible with models used in theiearlier study
                                 -13-

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      IV.   DEVELOPMENT OF BASELINE COST DATA FOR EXISTING FACILITIES
     A variety of references provide general baseline data for capital  and
operating and maintenance expenses for sanitary landfills.  Several  of these
sources graphically portray this information in a cost per ton vs.  daily
waste tonnage chart.  To estimate current landfill costs, a composite
graphical approach was utilized.  To accomplish this, the graphical  data
presented in References 2, 3, 7 and 8 were updated to 1977 dollars   Figure
5 presents the updated disposal costs per ton.  For two of these studies an
average modal cost curve was assumed midway between the upper and lower
bounds indicated in the original reference.  Appendix A presents each of the
original charts.  Figure 6 presents the composite curve.  Data points for
approximately two dozen case studies are also indicated in Figure 6 to
demonstrate potential variability of costs due to site-specific conditions
and variability of existing operations.  Appendix B presents more specific
data on the case studies.

     As  indicated, current disposal costs  (including capital and operating
expenses) range from  approximately  $2.00 to $12.00 per  ton.  Disposal costs
at ten ton per day  sites  average $11.15 per ton  ($12.29 per metric ton).
One hundred ton per day  sites  exhibit  economy of  scale  effects, with dis-
posal  costs averaging $6.65 per ton ($7.33 per metric ton).  Similarly,
three  hundred ton per day sites average approximately $3.95 per ton  ($4.3b
per metric ton).  Approximately 20  to  30 per  cent of these costs represent
design and construction  expenses, with the remaining 70 to 80  per cent
representing  operating expenditures.
                                   -TO-

-------
              FIGURE 5
CURRENT SANITARY  LANDFILL
     10-1000 TONS PER  DAY)
        400      500      600      700
WASTE  QUANTITY —  TONS PER  DAY
800
900

-------
    25.00-
  CO
  £C 20.00.
  O
  D
  o>
i  O
££
i  tr*.
    15.00-
H
(/)
O
O
     10.00.
  2
  0)
     5.00
                                                       FIGURE 6
                                        COMPOSITE  SANITARY  LANDFILL COSTS


                                             (0-4000 TONS  PER  DAY)
                  100
                                 300
200      300      400     500      600      700

     WASTE  QUANTITY   TONS  PER DAY
                                                                                800
                                                                                      900
1000

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              V.   IMPACT OF SECTION 1008 GUIDELINES  ON  COSTS
  A.    Recommended Technologies  and  Alternatives


       The  following  sections  summarize  the alternate technologies and
  approaches  as  recommended  by the Guidelines.

       ];   Site Selection.  Section 241.200 of the Guidelines recommends
  avoidance of environmentally sensitive areas and areas requiring complex
  engineering solutions, such  as locations traversed by pipes   Also
  recommended for  incorporation in the site selection process 'are evalu-
  ations of the  character and  availability of on-site soil!, potential
  socio-economic effects of  the facility, and cost estimates, taking into
  account future uses of the site.  The recommendations of! this section
 wlste landfil"             undertaken prior to the design. of any solid
 nf thP rmS™6 are Th alternat;ve Procedures suggested Within the text
 ot the Guidelines.  There are, however, provisions for proceeding with  a
 feasibility assessment for the siting of a disposal  facility in an
 environmentally sensitive area.   The Guidelines do not foreclose the

 that thl1^ °T SitlJ9/ la-2df111  1n such an area'  but rathe^ suggest
 that the level of study effort required in the pre-design  phase should

                         *** ^^ f°r s1t1ng a fac1 ^  in a non
      2-   .Design.   The Guidelines  recommend  that  the  following  factors
 be determined in designing  a landfill:

                types  and quantities  of waste
                current and  projected ground water  use    '
                background water  quality
                direction and rate  of ground water  flow
                depth  to water table
                potential  interactions with ground  and surface water
                site geology                              I
                hydraulic  conditions  and soil renovative capacity
                quality, quantity,  source and seasonal variation of surface water
                100-year flood  plain                      :
                water  balance
                initial  and final topography
                land use and zoning                       ;



Hit-      IheiI1nal <^sign, takin9 1nto consideration site-specific con-
nJtiM-'jKh P     6 5 JeVel of environmental  protection that is com-
patible with the proposed Criteria and Guidelines.   No specific  technical
alternatives are presented in this sections.             P^'nc  recnmcai
                                                         !


+K   Y  .Leachate Control.    This  section  of the  Guidelines  identifies
three basic alternatives for leachate control,  which  may be used indi-
vi dually or in combination:                               i

                                 -17-                    ;

-------
               control  of leachate production
               control  of the escape of leachate
               control  of the impact of leachate on the environment.


          Specific technologies that are recommended in the Guidelines,  and
that may be used singly or in combination, include the following:

               construction of surface runoff diversion
               structures to divert all of the water from
               a 24-hour, 25-year storm event

               construction of a dike around fills within
               a 100-year floodplain

          -    grading of fill to prevent standing surface
               water, but at slopes less  than 30% to avoid
               erosion

               use of cover material with low permeability
               and shrink/swell potential

               vegetation of final  cover

               protection of  underlying ground  water  by liner
               installation  (12-inch  impermeable, soil  or 
-------
 n,c •    ,,   ? Guidelines identify two categories  of gas! control  technology-
 passive Carriers and active barriers.   The  pros and cons  for  each  type
 of barrier are also discussed.   Passive barriers  would  consist of:

                vertical  cut-off walls  (clay or artificial
              .  materials)  extending  downward to an  impervious
                layer below the  fill

                venting system (gravel-filled trenches,  per-
                forated pipes or both)                   1

                gravel-filled trenches  in combination with
                cutoff walls.                            ;

           Active  barriers  include:                      •

                induced exhaust wells                    '
                induced exhaust  trenches                 i
                induced recharge trenches                i


          .Sn1:/!!e^!SLSL!?a?.?*!_c?!!tr:011 •.the  design  construction
                                                 , would be
,nrll,5;   R^off Control.     Recommended procedures to pontrol  runoff
include diversion of surface water, grading, construction of stilling
basins, final cover and vegetation of final  cover.   Since runoff control
is important to leachate control, as well as to the direct protection  of

oart'S SP^P  hT' rTft C°ntro1 tech"°l°9-<'es may be| incorporated  as
part of the leachate control approach for many sites.    l

 ,    f-   Operation.     Specific operating  technologies!recommended in
the Guidelines include the following:

               pre-treatment of  wastes  (e.g.,  de-watering)
               as  required;                              :

               application of 6  inches  of soil  or clay  daily

               application of final  cover (6 inches  of  im-
               permeable  clay and at least 18  inches of  '<
               topsoil)                                  I
                                                        i

               landfill compaction

               use of  balers,  shredders or stationary compactors
               at or before  delivery;                    I

               provision  of  safety devices and recommended practices

               eradication of  vectors, if they become established
                          •  .  •                          I
               initiation of  long-term maintenance program.
                                 -19-

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     7.   Monitoring.    The scope, frequency and duration of an environ-
mental monitoring program is largely contingent upon the site character-
istics identified during baseline studies undertaken during the design
phase.

     However, in general, the Guidelines recommend:

               monitoring of ground water, at least annually,
               at all landfills which have the potential for
               discharge to drinking water supply aquifers;

               monitoring of enclosed structures at landfill
               facilities to detect gases;

               monitoring of soils to detect gas migration.

     8.   Summary.   It  is important to emphasize that the mix of tech-
nologies  to  be employed in  the  location, design, construction, operation
and maintenance  of  landfill disposal facilities meeting the provisions of
the Section  4004 Criteria would differ widely from  case-to-case.  Simi-
larly, unit  costs for individual  technologies would differ widely, reflec-
ting  such factors as availability of raw materials  and  other resources.
Later  sections of this  report provide:   (a) estimated unit costs for  the
specific  technologies identified  in the Guidelines, and the sources for
those  cost estimates; and  Cb) assumptions  applied  in aggregating these
costs  to  the national level, and  the rationale  for  those  assumptions.

B.    Development of Unit Costs  for Upgrading Technologies
      To determine the economic effects  due to implementation  of  the  Guide-
 lines,  unit costs for required upgrading  technologies  were developed.
 These upgrading technologies are identified in Table 2.   The  table  identi-
 fies assumed technologies for waste processing, gas control,  leachate   _
 control, surface runoff, and monitoring at four types  of landfills  (muni-
 cipal,  industrial, construction, and pollution control residue).  The  table
 also considers differences in current and recommended  practices  at  sites
 considered to be environmentally sensitive.  The term "environmentally
 sensitive" is defined at length in Section VI. C.  of this report.   It
 includes wetlands, floodplains, permafrost areas,  critical habitats  of
 endangered species, and recharge zones  of sole source aquifers.


      Table 2 identifies a set of assumptions that must be superimposed on
 an assessment of existing practices at landfills in order to derive aggre-
 gated national costs of implementing the proposed Guidelines.  This set or
 assumptions is largely judgmental and identifies those technologies (or_
 practices) which may be required in facility upgrading in order to  attain
 or maintain status as a sanitary landfill.  The basic rationale behind
 these judgements is as follows:
                             -20-

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                                  TABLE  2                 |

        EXISTING TECHNOLOGY  LEVELS AND ASSUMED  UPGRADING TECHNOLOGY
      Assumed Current
     Technology Levels
                                        Assumed
                                Upgrading  Technologies
                           MUNICIPAL LANDFILLS
                  (in environmentally sensitive areas
 Waste Processing:   None
 Gas Control:
None
 Leachate Control:   Clay I fner
                     Daily cover
 Surface Runoff:      Ditching
 Monitoring:
None
Vertical  impermeable  barriers
      !
      i

Impermeable cover

Leachate  collection & treat-
ment (;new facilities only)

Pondi ng
      i
Dike cbnstruction

Gas & ileachate
                           MUNICIPAL  LANDFILLS
                        ('in non-sensitive  areas)
 Waste  Processing:    None

 Gas  Control:         None

 Leachate Control:    Permeable cover

 Surface Runoff:      Ditching

 Monitoring:          None
                              Vertical  impermeable barriers

                              Impermeable cover

                              None
                                    i
                              Gas &  leachate
                         INDUSTRIAL LANDFILLS
                 (in environmentally sensitive areas)
Waste Processing:   None

Gas Control:        None
                             None
Leachate Control:   Ingrequent permeable cover    Impermeable cover
                                                  Liners {new facilities only)
                                                         I
                                                  Leachatfe collection & treat-
                                                  ment (new facilities only)
                            -21-

-------
                                TABLE  2
                              (continued)
     Assumed Current
    Technology Levels
                                       Assumed
                               Upgrading Technologies
                            INDUSTRIAL LANDFILLS
                    (in environmentally sensitive areas)
                    ~~~(continued)
Surface Runoff:
Monitoring:
None
None
Ponding
Dike construction
Leachate
                            INDUSTRIAL LANDFILLS
                          (in non-sensitive areas)
Waste Processing:   None
Gas Control:
None
                                                  None
Leachate Control:    Infrequent permeable cover     Impermeable cover
                                                   Liners  (new facilities only)
Surface Runoff:      Ditching
 Monitoring:
 None
                               Ponding
                               Leachate
                            CONSTRUCTION  LANDFILLS
                     (in environmentally  sensitive  areas)
 Waste Processing:    None
 Gas Control:
 None
 Leachate Control:   None
 Surface Runoff:   -  Ditching
 Moni tori ng:
 None
 None
 Impermeable cover
 Ponding
 Dike construction
 Leachate
                                 -22-

-------
                                  TABLE 2
                                (continued)
       Assumed Current
      Technology Levels
                                          Assumed
                                  Upgrading Technologies
  Waste Processing:
  Gas Control:
  Leachate Control:
  Surface  Runoff:
  Monitoring:


  Waste Processing:
  Gas Control:
  Leachate Control:
 Surface Runoff:

 Monitoring:


 Waste  Processing:
 Gas Control:
 Leachate Control:

 Surface Runoff:
Monitoring:
                             CONSTRUCTION LANDFILLS
                            (in non-sensitive areas)
  None
  None
  .None
  None
  None
  None
  None
  None
  None
  POLLUTION CONTROL RESIDUE LANDFILLS
 (in environmentally sensitive areas)
 None                               j
 None
 None
 Ditching
 None
 None  :
 Impermeable cover
 Liner {new facilities only)
 Leachate collection & treat-
 ment (new facilities only)
 Ponding
 Dike construction
 Leachate
  POLLUTION  CONTROL  RESIDUE  LANDFILLSi
       (in non-sensitive  areas)
None
None
None

Ditching
None
None   ;
Impermeable cover
Liner ('new facilities only)
None
Leachate
                               -23-

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     1     Landfill  liners  cannot  be retrofitted.  Therefore, existing



qualfty will require only  minimal  upgrading to  assure continued protection
of ground water resources.

     2    New facilities will  need liners  plus  leachate collection and
treatment if they are located in  sensitive areas  since these areas are
General 1$ "wet" and are concentrated  in the  areas of the  country where
?nS oreciDtation is relatively high.  The  exception is  landfills to be
used forlispota  of construction wastes,  which are  inert and generally
pose less of a leachate problem than  that associated with other wastes.

     3    Liners which would allow slow migration of leachate to the
 not generally  be necessary.

      4    Municipal wastes are the only general category of wastes  that
 to the other.
      *    Most existing landfills,  regardless of  location, waste type and
 other factors' htve some provisions  for diverting  surface runoff to reduce
             actual operation of the facility  if  ^^7^^^

              ^r»                                     ? sec-



 placed  on runoff  control, it is considered that all  fills  in  sensitive
 (wet) areas  will  require upgrading of current practices.
       *    Mnnitnrina  is necessary  to assure continued environmental  pro-
  tection and^^Sre'thS^fSrtlveness of control  technologies  in  sensi-
  tive areas.   Leachate may be generated by any fil J *ype in a wet  ar ft\es  1n
  Therefore,  groundwater monitoring  should be instituted at all facilities
  sensitive areas.
       7     Safety precautions record- keeping, access, and vector control

  sw r                                                    "
  minimal   Therefore these  items are excluded from the table.
,  the readily  decomposable
and POTW sludges,  if  only
       Some other wastes may generate.gas [e-
       wastes of'the food processing industry
       partly digested).  In general, however, the other categories of
       waste can be assumed not to be candidates for gas control.
                                   -24-

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•H  *•*•  ,Table '2.Presents upgrading costs per ton of disposal for the
identified upgrading technologies.  The identified upgrading technologies
represent most commonly used state-of-the-art engineering practices for
achieving the objectives of the Guidelines.  Table 4 presents additional
unit cost.estimates for alternate control technologies? The alternate
technologies represent methods of compliance with the Guidelines which are
           °0rSe
                                      .          	  	—  — -. . >~^ i i i n_^  VV1 1 I V*I|  UIC
 i-ici-nH -,•« T=ki   -s      "T"""":  "'.  techno'ogi6s  that, when  compared to  those
 listed in Table  3, are  less desirable, are more  costly,'do not  represent
 current state-of-the-art, or are  applicable  to fewer sites.   It must  be
 TSSf1-zed'Tu°w?v^' ohat the  final cl?°1ce of  technologies will be site-
 speciric.   ine lable 3  technologies simply represent those which  we have
 assumed will be  the most common methods chosen to achieve compliance
                                                       i
     Cost data were developed  via an extensive literature search.  Where
 data were insufficient, an engineering estimate was .used.  In general!
 total construction and operating costs were estimated for each  upgrading
 technology and unit costs (per ton) were developed by dividing  the preslnt
vaiue OT total cost by the total expected waste tonnage !over an estimated
^niSLnc  f J-   \ Agp!r"d1x B Presents case examples and calculation
assumptions  for each of the upgrading technologies.
                                -25-

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                                                      TABLE 3



                                            UPGRADING TECHNOLOGY COSTS
Technology
Vertical Impermeable
Barrier
Dike Construction
Impermeable Daily Cover9
(on-site source)
Impermeable Daily Cover9
(off-site source)
Ponding
Gas Monitoring
Groundwater Water
Quality Monitoring
Natural Clay Liner
(Off-site source)
Leachate Collection
Facilities
Leachate Monitoring,
Removal and
Treatment
Cost/Ton
$1.30
2.40
0.75
5.30
0.10
0.15
0.60
3.20
0.95

5.80
10 TPn
(Cost/Metric Ton)
($1.43)
(2.65)
(0.83)
(5.84)
(0.11)
(0.17)
(0.66)
(3.53)
(1.05)

(6.39)
Cost /Ton
$0.30
0.55
0.35
2.65
0.05
0.03
0.10
1.50
0.40

1.10
100 TPD
f Pnc-t- /Merhvi r Ton^
V v/U b I*/ 1 1C U 1 1 1 ' ' v* • i
($0.33)
(0.61)
(0.39)
(2.92)
(0.06)
(0.03)
(o.n)
(1.65)
(0.44)

(1.21)
Cost /Ton

$0.15
0.30
0.25
1.75
0.04
0.01
0.05
1.35
0.30

0.50
300 TPD
(Cost /Metric Ton

($0.17)
(0.33)
(0.28)
(1.93)
(0.04)
(0.01)
(0.06)
(1.49)
(0.33)

(0.55)
a. "Impermeable" refers to a cover



   Source:  Appendix B.
type with relatively low permeability i.e., 1  X 10"7 cm/sec.

-------
X
TABLE 4
ALTERNATE UPGRADING TECHNOLOGY COSTS '
Technology
Shredding
j
Bali.ng

Permeable Daily Cover
(on-site source)
Permeable Daily Cover
(off-site source)
Vertical Pipe Vents
^ Perimeter Gravel Trenches
•-j
1 Gas Collection
Synthetic liner
Leachate Recycling
(not. including
collection)
Ditching
-•- Final Impermeable -Cover9
(on-site source)
Final Impermeable Cover9
(off-site source)
Cost/Ton





$0.60

1.90
0.90
1.60
2.50
4.00


0.45
0.15
-- 	
0.45

3.20
10 TPD
(Cost/Metric Ton)





($0.66)

(2.09)
(0.99)
(1.76)
(2.76)
(4.41)


(0.50)
(0.17)


(0.50)

(3.53)
Cost/Ton

™"

~

$0.30

0.95
0.45
0.35
0.55
. 1.90


0.10
- 0.04


0.20

1.50
100 TPD
(Cost/Metric Ton)

—

••

($0.33)

(1.05)
(0.50)
(0.39)
(0.61)
(2.09)


(0.11)
(0.04)


(0.22)

(1.65)
Cost /Ton

$7.00

5.00

0.20

0.65
0.40
0.20
0.30
1.65


0.05
0-02, ....
. .
0.20

1.35
300 TPD
(Cost /Metric Ton)

($7.72)

(5.51)

(0.22)

(0.72)
(0.44)
(0.22)
(0.33)
(1,82)


(0.06)
(0.02)

(0.22)

(1.49)
a. "Impermeable"  refers  to  a cover type with relatively low permeability, i.e., 1  X 10-7 cm/sec.

-------
                                                       TABLE 4 (Concluded)
                                             10 TPD
                                                                               100 TPD
                                                                                                  300  TPD
i
to
oo
I
Techno!ogy
Final Permeable Cover
(on-site source)
Final Permeable Cover
(off-site source)
Revegetation
Fire  Control
Access Control
Litter Control
Compaction
fnci" /Tnn
L*Uo U/ lull
$0.40
1.30
0.25
0.04
0.90
0.05
1.90
(Cost/Metric Ton) Cost/Ton
($0.44)
(1.43)
(0.28)
(0.04)
(0.99)
(0.06)
(2.09)
$0.15
0.60
0.10
0.01
0.20
0.01
0.20
(Cost/Metric lor
($0.17)
(0.66)
(0.11)
(0.01)
(0.22)
(0.01)
(0.22)
1 ) UUbU/ IUM
$0.15
0.55
0.10
0.01
0.10
0.01
0.05
\^uo u/ ncui i
($0.17)
(0.61)
(0.11)
(0.01)
(0.11)
(0:01)
(0.06)
    Source:   Appendix B

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               VI-   AGGREGATE COST OF LANDFILL GUIDELINES
 A.   Approach
      In order to project the potential nationwide costs of implementinq
 the Section 1008 Guidelines, it was necessary to make a number of broad
 assumptions based on the finite amount of information currently avail-
 able.  In the ensuing discussion, the information base and consequent
 rationale for each assumption have been identified in order to allow the
 reader to recognize the limitations of the data, and the:categorizations
 and aggregation processes that were applied to those data.

      It was^not the intent of this study to provide a detailed economic
 assessment in which every case situation could be fully evaluated.   Such
 an approach would neither be feasible nor appropriate,  given  the flexi-
 bility inherent in the Guidelines.  The results of the  aggregate cost
 evaluation contained herein should, thus, be viewed within the context
 ot national  scale, and with an appreciation of the limitations in sen-
 sitivity of any analysis  conducted at this  scale.

      The enforceability and applicability of the Guidelines are  a pri-
 mary  concern in projecting  the cost of compliance.   There  will be no
 federal  enforcement of the  Guidelines;  however,  certain  recipients of
 Federal  assistance under  the provisions  of  RCRA must demdnstrate  com-
 pliance.   Therefore,  it is  assumed that  all  States  will  enact  programs
 requiring  the  adoption  of procedures  identified  in  the Guidelines.  The
 cost  of  compliance would  thus  be  State-induced.          i

   .   The Guidelines  are applicable to  all facilities  for -the landfill
 disposal of  non-hazardous solid wastes.   As  indicated earlier  the
 nearterm cost  effects  of  the Guidelines will be  incurred |by existing
 facilities which  could  feasibly upgrade operational  practices  in  order
 to achieve,  or  remain within,  the  Criteria  for classification  as  san-
 itary landfills.   Costs will also  be incurred for siting," design  and
 operation  of new  facilities.   Finally, costs will be incurred by exist-
 ing and new  sanitary landfills as  they undergo closure.  '

   _ The general  approach to assessing costs of upgrading! existing
 facilities involves multiplying incremental cost increases associated
with upgrading existing practices by the number of facilities which  may
 be required, under State programs, to undertake various upgrading pro-
 cesses.  Baseline and upgrading costs have been estimated1in Section IV
 and V of this report.                               '     i

     The potential extent of upgrading and costs thereof,:are a function
of:  (1) facility size; (2) waste type; (3) site characteristics; and
 (4) the extent of current practice of the technologies identified in the
Guidelines.                                              !
                                -29-

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     1    Facility Size.   Representative facility sizes are 10, 100 and
300 TPD lamlfills, as indicated earlier.  These models are intended to
represent facilities in the following ranges:  0-50 TPD, 50-200 TPD, and
greater than 200 TPD.

     2    Waste Type.   Waste types include five broad categories:
agricultural:, municipal, industrial, construction and pollution control
residues.

     3.   Site Characteristics.   Site characteristics, for purposes of
generalization, include environmentally sensitive areas including flood-
plains, wetlands, areas underlain by aquifers, and permafrost areas.
All other areas are placed in the "non-sensitive" category.

     4.   Extent of Current Practice of the Recommended Technologies.
The existing practice of Guidelines-level technologies can be broadly
sorted by waste type and site characteristics.  Table 2 (included in
Section V) was based on an assessment of available literature and pro-
vided a checklist of environmental  protection technologies currently
employed by a  "typical" landfill for a  given type of waste in environ-
mentally sensitive and  non-sensitive areas.  The indicated technologies
are meant to represent  the most commonly utilized technologies  at the
national level, and  are not meant to represent the complete set of
technologies in use  at  the various  types of  site.  Utilizing this table,
national upgrading costs can be aggregated by multiplying  unit  upgrading
costs by the prevalence of landfills in  each broad category.

      It  is  important to point  out that  where existing State programs
require  the  use of  technologies equivalent to, or more  stringent than
those  recommended  in the Guidelines, upgrading costs  would be  attrib-
utable to those existing programs and not to State enforcement  of  the
new  Federal  Guidelines.  State solid waste management programs  are
currently being examined by  another EPA contractor.   That  portion  of
total  upgrading costs  which  may be  attributable  to existing programs
should be subtracted from  the  total cost estimated here.


B.    Estimating  the Prevalence of Landfill Types


      1.   Agricultural Landfills.    Agricultural  wastes include wastes
 generated Trom raising and harvesting  animals,  grains,  fruits  and  vege-
 tables,  and other field crops.  They exclude food processing  wastes
which are  considered industrial.   Several  studies have produced data on
 agricultural waste generation.  However, a survey of EPA and  other solid
waste management literature and inquiries at the USDA's Soil  Conser-
 vation Service produced no specific quantitative data on agricultural
 waste disposal practices.   General  information on current disposal
 practices  indicates that essentially no single-purpose agricultural
 landfills  exist,  on-site or off-site.   The large majority of agricul-
 tural waste is returned to the land on the farmsite.  Manure and other
 livestock solid wastes from feedlot and dairy operations are normally
                                 -30-

-------
 collected and stockpiled on-site  until  they  can  be  spread  on  and  disked
 into  adjacent acreage.   Likewise,  as  Table 5 indicates, most  crop
 residues  are  shredded or chopped  and  disked  or plowed  back  into the
 topsoil.   Some crop  residues  are  removed  for burning and Composting.
 (References 8, 9).                                       ;
                                                         i

    m  The  land storage and disposal of all agricultural wastes can pose
 serious environmental problems, particularly with regard:to water pol-
 lution^  However, EPA's  "Solid Waste  Disposal Facilities Proposed Clas-
 sification Criteria" specifically  exclude from coverage solid waste
 storage facilities and agricultural wastes returned to the land   The
 disposal  of pesticide wastes, which also can  pose environmental problems
 is addressed  by Subtitle  C of RCRA, and, therefore is als'o not covered
 by the proposed Guidelines.  On-going research, demonstration, and
 development of agricultural waste  disposal technology also indicates
 that  the  number of future agricultural landfills will be [insignificant
 (Reference 8).  As a result of these considerations, agricultural  land-
 fills are not  considered  further in this report.

   .  ?•   Municipal  Landfills.   Municipal landfills primarily handle
municipal wastes, but may be privately or publicly owned or operated.
These sites may also accept other types of waste, such  a* non-hazardous
industrial wastes.                                       ;

     To determine the total  number of municipal  landfill si,  Fred C   Hart
Associates conducted a literature search followed by telephone inquiries
to update the 1977 Waste Age survey of landfills  (Reference 1):
     a.
     b.
The  literature/data base amassed by the project:
team was examined.  This included .the responses1 to
an Office of Solid Waste (EPA Headquarters) letter,
dated June  18,  1978, to the EPA Regional officek.
This letter requested the Regions to secure from
their respective States any information they might
have that could be used to upgrade the Waste Age
data base.  The replies to this request were reviewed.

EPA Regional representatives and several State  ;.
Solid Waste Representatives were contacted by  !
telephone.  Resource and time constraints, however,
precluded contact with all  fifty States.  Therefore,
only ten States, (Pennsylvania, Kentucky, New Jersey,
Oregon,_New York, Wisconsin, Illinois, Alabama,:Washington,
and California) were contacted.  A criterion utilized
in the selection of these particular States was'the
significant interest they had displayed with respect
to the earlier "Criteria" EIS (Reference 6).  In addition,
Mr. Richard W.  El dredge, Technical  Editor of Waste Age ,
who oversaw the Waste Age survey,  was  contacted;
                                -31-

-------
                                    TABLE 5



                  CROP RESIDUES AS A WASTE-MANAGEMENT PROBLEM
. 	 — 	 	 	 crop residue Nature of the residue,
Tvoical yield to be managed typical management
Croo tons/aero tons/acre ...Problem
Field crops like
canning tomatoes,
sugar beets, pota-
toes
Field crops
harvested dry,
like soybeans,
saf flower cotton
Truck crops
(market veget-
ables)
Orchard fruit

Rice, wheat,
other grains

Field corn

Cotton

Sugar cane





20 (wet weight)

1.5

5-30

5-15
(fresh weight)

3.0

4n
.U

0.5

60 (wet cane)





30 (wet weight)
to as little as
3 tons dry solids)

1.6

1.5:1 to 4:1
(crop residue)

2
(.primings only)

3.5

5 3
tj • W

1.5

40 (burned-off)





ull fruit and all
Tiaterial (stems,
eaves, roots)
disked back into top-
soil
Dried plant parts;
shredded and disked
nto topsoil

Green parts not har-
vested, disked back,
or removed for com"
posting
Prunings-burned;
leaves-compost on
surface; cull fruit-
also compost
Straw, disked or
burned

Dried stalks,
usually chopped and
plowed in
Dried total plant,
shredded, plowed into
topsoil .
Leaves burned before
harvest, cane harvested
and squeezed, then the
residual (bagasse)
burned at mill , field
trash chopped and
disked
	 — — 	 •
Source:  Reference 8.
                                         -32-

-------
       The  data  collection  efforts  outlined  did not significantly upgrade
     l«h£  Tt  5  Jy ^t  Waste A(je surve^' alth°"9h In some cases more
  reliable,  up-to-date data were substituted for that of Wa!ste Age   The

  1?  2^°lmnn«3Mr1Jy-mU1Cipal Iandf111s>  but in a small Dumber of cases
  it  was  impossible  to exclude data on industrial landfills'.
                                                          L

  rn,,nt«5S?J 2SotheS? dat?  ?ollect1on efforts» Fred C. Hart Associates
  counted 14,689 municipal  landfills nationwide.  This figure falls ap-
  proximately midway between the. Waste Age 1976 estimate of 15,821 land-
  fills and its  1977 figure of 14,126 municipal landfills.   Table 6 rep-
  resents the municipal landfill prevalence data.           :

  ,nHl ?;.  Industrial Landfills.    To date, the disposal  practices of
  industries have received relatively little public attention.   Conse-
  quently, very little data quantifying their waste generation  and dis-
  posal practices are available.  Since disposal  problems  are handled by

  lnS,,JJ     ^    715' the meth°ds °f d1sposal a"e as va™d as  the
  industries themselves.   In addition,  wastes are  often  disposed  of on-
  site, making assessment of the disposal  process  more difficult  to
 mlpSlSl;  Jo PH2Vlde a ba7^ t°r a99^gate cost assessment,  four major
 questions^ addressed:   (1) how much  industrial  waste  is generated;
 nr nSa*-lS 1tS/?rT a"d  how 1s  1t deposed;  (3)  is  it disposed on-site
 or off-site;  and (4)  what are the general  disposal site characteristics?

      Most  of the recent studies  that  were  examined defined industry
         ?????  r^  ^°l  gr°u^s of the  Standard Industrial Classi-
 d v< ™ Ifn  }   0Je l^™.^ Table 7).   In general, the manufacturing
 d vision represents those  industries  that would produce what is normally
 classified as industrial waste.   Estimates  of solid wasteiproduction  per
 industry are  usually  presented for the initial two digits !of the SIC
 Code, (SIC Groups 20  to 39).   In  order to remain consistent with exist-
 ing  studies,  this study also  defines  industries using the :SIC Code
 groupings.                                                •

      To  date, four  types of waste  generation  data have been assembled
 from investigations conducted by various "authorities:  community average
 per  capita industrial waste contributions; average waste generation in
 tonnage  per^employee per year (TEY); waste generation rateis reported for
 specific points; and waste generation data for industries determined to
 be potential hazardous waste generators.   Although none of these esti-
 mating measures is  ideal,   the estimates of projections of tons of waste
 per  employee per year (TEY) provide the most reasonable method of
 relating waste production to the manufacture of products  or commodities.
 The  TEY method is used in this investigation to determine  Current indus-
 trial solid waste generation rates.                       ;

      In an extensive survey of solid waste manaaement literature,  three
 sources were found containing TEY coefficients for each of'the 20 SIC
manufacturing industries (References 7,  8,  11).   Tables 8  through  12
 provide a range  of estimates for  industrial  solid waste generation    The
remaining tables of TEY coefficients or  the  equivalents  (multipliers,
annual waste volume per employee,  or waste  production  rate), reveal  a
                                -33-

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                      TABLE 6

PREVALENCE OF MUNICIPAL LANDFILLS BY LOCATION.  1978
          STATES
MUNICIPAL SITES
Region #1

Connecticut
Maine
Massachusetts
New Hampshire
Rhode Island
Vermont
               Sub-Total
Region #2

New Jersey
New York
Puerto Rico  and
Virgin Islands
                Sub-Total
 Region  #3

 Delaware
 Mary!and
 Pennsylvania
 Virginia
 West Virginia
                Sub-Total
 Region #4

 Alabama
 Florida
 Georgia
 Kentucky
 Mississippi
 North Carolina
 South Carolina
 Tennessee
                Sub-Total
 Region #5

 Illinois
 Indiana
 Michigan
 Ohio
 Minnesota
 Wisconsin
    296
    635
     936
     132
     330
     480
     140(a)
     N/A
     170
     211
     148   .
                 Sub-Total
   1,611
     300
     149
     572
     250
     405
    1,297
    2,973
                           -34-

-------
                       TABLE 6 (continued)

 PREVALENCE OF MUNICIPAL LANDFILLS BY LOCATION, 1978
           STATES
 Region #6

 Arkansas
 Louisiana
 New Mexico
 Texas
 Oklahoma
 Region #7

 Iowa
 Kansas
 Missouri
 Nebraska
 Region  #8

 Colorado
 Montana
 North Dakota
 South Dakota
 Utah
 Wyomi ng
Region #9

Arizona
California
Hawaii
Nevada
Region #10

Alaska
Idaho
Oregon
Washington
                Sub-Total
                Sub-Total
               Sub-Total
               Sub-Total
MUNICIPAL SITES
    460
    365
    600
  l,093(b)
    188
  2,706
    322(c)
    341(d)
    165(e)
    449
               Sub-Total
  1,277
    220
    227
    135
    300
    174
    150
 1,206
   187
   605
    35
   113
   890
   350
   120
   158
   410
 1,038
United States Total:
14,689
                       -35-

-------
                          TABLE 6 (continued)
a.

b.

c.


d.


e.
On-site industrial sites included.

Includes fly-ash disposal sites.

Includes 225 sites currently in process
     of being closed.

Includes 218 sites currently in process
     of being closed.

Includes 48 sites currently in process
     of being closed.
 Source:    Fred C.  Hart Associates,  Inc.
                                       -36-

-------
                                TABLE 7                 ;
              STANDARD INDUSTRIAL CLASSIFICATION CODES FOR
                        MANUFACTURING INDUSTRIES        i
 Major Group 20.
 Major Group 21.
 Major Group 22.
 Major Group 23.

 Major Group 24.
 Major Group 25.
 Major Group 26.
 Major Group 27.
 Major Group 28.
 Major Group 29.
 Major Group 30.
 Major Group 31.
 Major Group 32.
 Major Group  33.
 Major Group  34.

 Major Group 35.
 Major  Group 36.
 Major  Group 37.
 Major  Group 38.
 Food and kindred products            ' '•
 Tobacco manufactures                  ;       .
 Textile mill  products
 Apparel  and other finished  products  made  from fabrics  and
 similar materials
 Lumber and  wood  products, except  furniture
 Furniture and fixtures                 ;
 Paper and allied products
 Printing, publishing, and allied  industries
 Chemicals and allied products
 Petroleum refining and related industries
 Rubber and  miscellaneous plastics products
 Leather  and leather products           •
 Stone, clay,  glass, and concrete products
 Primary  metal  industries               ;
 Fabricated metal   products, except machinery and transportation
 equipment                              ;
 Machinery, except electrical           ;
 Electrical and electronic machinery,  equipment, and supplies
 Transportation equipment               ;
                                       i
Measuring, analyzing, and controlling instruments; photographic,
medical and optical goods; watches and clocks
Major Group 39.  Miscellaneous manufacturing industries
Source:  Reference  38
                                -37-

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                            TABLE  8
WASTE GENERATION BY MANUFACTURING INDUSTRIES IN THE UNITED STATES
in Tons per Employee per Year, TEY)


SIC
Code
20


22


23


24


25



26

27


28

29


30







Data
Industry Points
Food Processing
Solids
Liquids
Sludges
Textile-mill products
Sol i ds
Liquids
Sludges
Apparel
Solids
Liquids
Sludges
Wood products
Solids
Liquids
Sludges
Furniture
Solids
Liquids
Sludges
Paper and allied products
Solids
Liquids
Sludges
Printing, publishing
Solids
Liquids
Sludges
Chemicals and allied products
Solids
Liquids
Sludges
Petroleum
Solids
Liquids
Sludges
Rubber, plastics
Solids
Liquids
Sludges
31
11
1
16
15
1
20
0
0
10
0
0

7
0
0
21
9
8
24
12
0
39
23
28
4
1
1
13
8
1


Average
TEY
7.949
0.001
0.400
2.160
0.107
1.508
2.192
-
"•
8.531
-
—

2.783
-
—
3.987
0.010
0.012
5.835
0.013
—
8.862
2.599
2.554
1.594
0.041
0.003
9.835
0.072
0.084


Standard
deviation
10.451
0.036
™
1.854
0.233
~
6.197
•"
™"
7.648
—
**

3.578
—
«•
8.267
0.026
0.073
5.958
0.000
M
7.434
4.504
5.944
2.751
—
**
9.163
0.100
™ *

95%
Confidence
Limits
1.877
0.025

0.464
0.135

1.461
""

2.419
••
"

1.352
~
~
1.804
0.013
0.052
1.242
0.000
"
1.191
1.593
2.102
1.376
"•
"
2.541
0.071

                           - 38 -

-------
                            TABLE 8  (continued)
                                         »


           HASTE GENERATION BY MANUFACTURING INDUSTRIES  IN  THE  UNITED  STATES
(in Tons per Employee per Year. TEY)


SIC
Code
31



32



33



34



35



36



37



38




39





Industry
Leather
Solids
Liquids
Sludges
Stone, clay
Solids
Liquids
Sludges
Primary metals
Solids
Liquids
Sludges
Fabricated metals
Solids
Liquids
Sludges
Non-electrical machinery
Solids
Liquids
Sludges
Electrical machinery
Solids
Liquids
Sludges
Transportation equipment
Solids
Liquids
Sludges
Professional and Sci.
instruments
Solids
Liquids
Sludges
Miscellaneous manufacturing
Solids
Liquids
Sludges


Data
Points

2
0
0

18
1
7

13
5
1

42
22
23

47
21
18

21
15
0

8
4
6
•

7
5
0

25
0
0


Average
TEY

8.989
—
»

6.412
0.005
0.011

3.184
1.397
0.423

6.832
0.014
0.055

3.89
0.258
2.453

2.941
0.172
_

2.562
0.319
0.191


1.769
0.074
, «

1.603
_
_
i :

Standard
deviation

6.986

mm '

15.300

:0.024

8.210
12.067


;9.180
i 0.024
>2.268

; 1.448
'0.137
2.361

7.009
:0.077


;4.097
;0.183
10.124

'
,2.061
10.088


1.883
i
'—

95%
Confidence
Limits

4.941

_

3.606

0.017

2.277
8.534


1.416
0.009
1.307

0.211
0.052
1.363

1.529
0.039


1.449
0.129
0.880


0.779
0.062


0.377

•*
Source:  Reference 8
                                   - 39 -

-------
                                    TABLE 9
     WASTE GENERATION BY MANUFACTURING INDUSTRIES IN SAN JOSE. CALIFORNIA
        Industry
 Nondurables
 Food products
    Seasonal foods
    Other foods
     Total food products
 Paper, printing and publishing
 Chemicals
 Other nondurables
    Textiles and apparel
    Rubber and plastics
    Leather

      Total other nondurables

 Durables
 Stone, clay, glass, and  concrete
 Primary and fabricated metals
 Electrical and nonelectric  machinery
 Other durables
    Lumber and wood  products
    Furniture and fixtures
    Transportation  equipment
    Instruments

      Total other durables

    Other manufacturing

      Total manufacturing employment
Employment
 July 1967
 2,200
11,482
13,632
 6,478
 1,900

 2,193
 1,835
   355

 4,383
 3,708
15,250
12,478

 1,033
 1,562
 2,768
   915

 6,278

 2,500

66,657
  Multipliers
ton/ employee/ yr
    5.56570
    4.81855

   12.87060
    8.21075

     .52575
    1.54810
    2.49365
   18.11425
    6.7300
    3.58040

   21.68805
   20.15545
    3.39330
    2.51700
     2.49365
                                                                               Wastes
                                                                               ton/yr
 12,245
 55,304

 83,376
 15,600

  1,153
  2,841
    885
 67,168
102,632
 44,676

 22,404
 31,483
  9,393
  2,303
  6,234

457,697
a Basic employment data are from the State of California Department of Employment
  Community Labor Market Survey.  Data were adjusted to exclude Union City which is  not
  in the study area.  Employment in the categories "Other Durables" and "Other Non-
  durables" was distributed to the relevant SIC groups by using the same proportions
  as existed in the 1965 employment data from ABAG.

b Multipliers for the manufacturing industries were developed and reported in Table
  VI.  Comprehensive Studies of Solid Waste Management, Second Annual Report.
SOURCE:  C.G. Golueke and P.M. McGauhey, Comprehensive Studies of Solid Wastes Manage-
ment, Sanitary Engineering Research Laboratory, University of California, June 1970,
p.53.  (Reference 7)
                                        - 40 -

-------
                                     TABLE 10

              WASTE GENERATION BY LARGE FIRMS IN SAN  JOSE
                                                         , CALIFORNIA
Standard  industrial classification

Ordnance  and accessories
Canning and Preserving
Other food processing
Tobacco                       .
Textiles
Apparel
Lumber and Wood Products
Furniture and fixtures
Paper and Allied Products
Printing, publishing, and allied
Chemicals and allied
Petroleum refining
Rubber and plastics
Leather
Stone, clay, glass, and concrete
Primary metals
Fabricated metal products
Nonelectrical  machinery
Electrical machinery
Transportation equipment
Instruments
Miscellaneous  manufacturing industries
                                        Employment

                                           29.356
                                           11.389
                                            2.012
                                             NA
                                             NA
                                              601
                                             NA
                                             NA
                                              250
                                              968
                                             NA
                                             NA
                                              481
                                             NA
                                            1.258
                                           3.565
                                           8.872
                                           7.807
                                           4.100
                                            NA
                                            NA
    Annual
 Wastes,  vol

    vd3b
  I
 131.404
 102.238
  17.545
    NA
    NA
  ;1.248
    NA
  !  NA
  •9.360
   7.020
  :  NA
  i  NA
   9.069
    NA
   6.617
-' •  NA
  47.078
 101.153
  57.252
 100.776
  :  NA
    NA
Annual wastes
per employee,
	yd3b
 4.476
 8.977
 8.720
  NA
  MA
 2.077
  NA
  NA
37.440
 7.252
  NA
  NA
18.854
  NA
 5.260
  NA
13.206
13.206
 7.333
24.580
  MA
  NA
  NA - not available

    Data on employment were obtained for those large firms which were surveyed
    and included in the wastes calculationfrom the research department of the
    Association of Metropolitan San Jose (Greater San Jos^e Chamber of Commerce),

    FMC report.  Solid Waste Disposal System Analysis (Preliminary Report).
    Tables 10 and 11, 1968.                              ;
  P                       "5
    Annual wastes, vol. yd /employment                 -\

  d For canning and preserving, no individual firm data were available.   The
    industry total developed for the country as a whole was divided by the
    total employment in the industry (especially tabulated) to arrive at the
    multiplier.                                          :
SOURCE:  C.G. Goluke and P.11. McGauhey, Comprehensive Studies of Solid Wastes
Management, Sanitary Engineering Research Laboratory, University of California
January 1969, p.221.                                 •'.•••
Source:  Reference 7.
                                        - 41 -

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                                  TABLE 11

           WASTE GENERATION BY SMALL FIRMS IN SAN JOSE, CALIFORNIA
Weekly
wastes,
vol
per firm,
vd3a
Annual
wastes,
vol
per firm,
vd3b


Average
employment
per firmc
                                      2.500
                                  (Not surveyed)
                                     10.875
                                      4.000
                                     16.083
                                     23.000
                                     44.650
                                      6.448

                                      6.506
                                      NA
                                      5.275
                                      NA
                                      9.415
                                      2.000
                                      5.284
                                      4.450
                                      6.733
                                      4.550
                                      3.600
                                      1,250
  130.00

  565.50
   NA
   NA
  208.00
  836.33
1,196.00
2,321.80
  335.29

  338.31
   NA
  274.30
   NA
  489.60

  104.00
  274.75
  231.40
  350.13
  236.60
  187.20
   65.00
  MA

26.979
 5.882
17.247
13.767
35,479
13.289

18.439
  NA
 9.596
  NA
16.747

23.409
12.951
12.921
21.036
16.490
20.933
10.931
Annual waste,
   vol per
  employee,
    vd3d

    NA

  20.961
Standard industrial classification

Ordnance and accessories
Canning and preserving
Other food processing
Tobacco
Textiles
Apparel
Lumber and wood products
Furniture and fixtures
Paper and allied products
Printing, publishing,
  and allied
Chemicals and allied
Petroleum refining
Rubber and plastics
Leather
Stone, clay, glass, and
  concrete
Primary metals
Fabricated metal  products
Nonelectrical machinery
Electrical machinery
Transportation  equipment
 Instruments
Manufacturing
   industries

 NA - not available

 a Data obtained and calculated for each SIC on the basis  of small  firm questionnaire
   responses  supplied by FMC.

 b Weekly average in first column multiplied by 52.

 c Average size of small firm estimates from the contribution of firms by employment
   size, supplied by the California Department of Employment (Research and Statistics),
   San Francisco Office.

 d Annual wastes/average employment per firm.
  35.360
  48.492
  86.877
  65.442
  25.230

  18.348
     NA
  28.583
     NA
  29.235

    4.443
  21.214
  17.909
  16.645
  14.348
    8.943
    5.946
SOURCE:  C.6. Golueke and P.H. McGauhey, Comprehensive Studies of Solid Wastes
Management, Sanitary Engineering Research Laboratory, University of California,
January 1969, p. 221.

Source:  Reference 7.
                                       - 42 -

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                                          TABLE 12
                         HASTE GENERATION IN WISCONSIN, BY SIC  GROUP
S.I.C.
Group
20-39
20
22
23
24

25
26
27
28
29
30
31
32

33
34
35
36
37
38
39
50-51
52-59
52
53
54
55
56
57
58
59
60-67
70-89
70
72
73
76
79
80
89
90-94
Description
Manufacturing
Food Products
Textile mill products
Apparel
Lumber & wood products,
except furnitures
Furniture & fixtures
Paper & allied products
Printing & publishing
Chemicals
Petroleum refining
Rubber & plastics products
Leather & leather products
Stone, clay, glass & concrete
products
Primary metals
Fabricated metal products
Machinery, except electrical
Electrical & electronic machinery
Transportation equipment
Precision instruments
Miscel laneous Mfg. Industries
Wholesale trade
Retail trade
Retail building materials
Retail general merchandise
Retail food
Auto sales, service, repairs
Retail apparel
Furniture
Eating and drinking establishments
Miscellaneous retail trade
Financial operation
Services
Hotels
Personal services
Business services
Miscellaneous repair
Amusements, recreation
Medical & health
Miscellaneous services
Government

Waste
Generation
Coefficient
Ibs/cap/day

26.7
1.7
1.3
89.0

6.8
81.7
6.2
45.0
159.2
6.1
1.1
125.0

36.8
20.4
19.9
14.7
7.1
1.9
6.6
10.3

8.7
1.5
11.9
2.5
2.4
6.4
12.5
5.4
7.1

11.8
2.3
4.1
9.1
4.0
6.9
4.1

Annual Averages
State
Employment
1000s
493.6
57.7
6.7
7.0
16.8

8.5
43.4
26.2
10. 1

12.5
13.9
8.3

28.1
44.4
103.3
46.5
38.1
8.8
13.0
67.9
278.0
14.1
60.7
45.2
34.3
li.9
7.9
55.5
25.7
64.1
249.5
10.6
14.5
19.0
2.0
8.1
24.6
7.9
279.5
(1972)
Est. Waste
Production
tons /day
(7-day week)

770 3
/ i \j * \j
5 7
+J • /
4 fi
^* w
747.6

28 Q
t*J • J
1,172.9
81.2
227 3
<_ £_ / • O
38.1
7.7
518 8
*J X(_) • U
517 1
•J J. / • j.
452 9
~*J t_ • J
1 027 8
X 5 \J L. I • \J
341.8
135.3
8 4
\J* *T
4.9 0
"c. • y
^AQ 7
UT- 3 • /
61 3
\J J. • *J
A.K K
I*J • O
268 <5
t,\ju * y
42.9
14 ?
±T^ • O
25 3
<_ ^ • O
346 Q
«™U • ^
RQ A
\jy • t
227 6
C—C^ f • U
62 5
Wt_ • »J
16.7
30 n
\J^ • \J
q i
y • x
16 ?
X 
-------
 wide range of values for what are theoretically,  the same coefficients.
 In part this inconsistency arises from the fact that the TEY  data for
 each industry are based on plants with diverse production methods, which
 in themselves are often not reported for reasons  of propriety.   Another
 factor leading to such dispersion of data is company employment figures
.which often do not distinguish non-production workers who do  not directly
'generate the wastes, from the total  plant employment.  Consequently,
 most industrial waste generation rates are based  on the total employment
 numbers.  Lastly, the sample sizes as well as the sampling regions must
 also be considered in evaluating coefficient differences.

      For this study, coefficient values from Table 8 were chosen to
 estimate waste generation, since TEY coefficients in this table were
 broken down further into values corresponding to solid wastes, liquid
 wastes, and sludges.  Based on the assumption that solid wastes are
 generally disposed of in landfills,  the solid waste coefficients were
 utilized to calculate the total industrial waste destined for landfill
 disposal.  Results are presented in Table 13.

      Using the solid waste TEY's presented in Table 13 for each 2-digit
 SIC industry, one can evaluate the plant size distribution by number  of
 employees necessary to produce 0-50, 50-200, and greater than 200 TPD of
 solid waste (see Table 14).  Census of Manufacturers plant size categories
 are then reapportioned to fit the plant size distribution derived above.
 Once the number of plants in each waste volume generating category has
 been determined for each 2-digit SIC industry, a number of assumptions
 are made.  These assumptions relied heaviliy on EPA-supported studies of
 industrial hazardous waste disposal practices for two reasons: first,
 the studies provided the most detailed industry-specific analysis of
 industrial waste disposal practices; and  second, while the focus of the
 studies was hazardous waste, many of the  studies noted that  industry
 generally has  not developed separate disposal facilities for hazardous
 and non-hazardous solid waste.  Thus, the waste disposal practices
 described in  these  reports  (References 5, 12-29) provide a reasonable
 basis  for assumptions concerning solid waste disposal.

       Four assumptions were made:

       a.   Assume the same disposal  practices  (method  and  location)
           for potentially hazardous  and  non-hazardous wastes  in  every
           industry;

       b.   Assume all  solid wastes are  landfilled  unless  information
           exists which  indicates  otherwise;

       ci   Where industrial  hazardous  waste  practices  assessments
            have been performed  for one  or more  3-digit SIC  indus-
            tries within  a 2-digit industry,  the available disposal
            data were averaged  and the average was  applied over  the
            remainder of 3-digit SIC  industries  within the 2-digit
            SIC group;
                                  -44-

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                                                   TABLE 13

                                        INDUSTRIAL SOLID WASTE PRODUCTION
SIC
CODE

20
21
22
23
24
25
26
27
28
-P*
cn 29
30
31
32
33 .
34
35
36
37 '
38
39

TOTAL NUMBEF
OF EMPLOYEES
INDUSTRY (THOUSANDS)

Food Processing
Tobacco
Textile-Mill Products
Apparel
Wood Products
Furniture
Paper and Allied
Products
Printing, Publishing
Chemicals and Allied
Products
Petroleum
Rubber and Plastics
Leather
Stone, Clay
Primary Metals
Fabricated Metals
Non-Electrical
Machinery
Electrical Machinery
Transportation Equipment
Professional and Scien-
tific Instruments
Miscellaneous Manu-
facturing

1,527
^"6
838
1,213
592
398
590
1,073
848
141
597
240
592
1,091
1,420
1,979
1,521
1,604
502
394
>
;b TEYa
(SOLIDS)
7.949
N/A
2.160
2.192
8.531
2.783
3.987
5.835
8.862
1.594
9.835
8.989
6.412
3.184
6.832
3.189
2.941
2.562
1.769
1.603
TONS OF
_SOLIPS/YEAR__
12,138,000
N/A
1,810,080
2,658,896
5,050,352
1,107,634
2,352,330
6,260,955
7,514,976
224,754
5,773,145
2,157,360
3,795,904
3,474,744
9,701,440
6,311,031
4,473,261
4,109,448
888,038
631,582
TEYa
(ALL WASTES)
8.350
N/A
3.775
2.192
8.531
2.783
4.009
5.848
14.015
1.638
9.991
8.989
6.428
5.004
6.901
5.900
3.113
3.072
1.843
1.603
TONS OF
TOTAL WASTE/YEAR
12,750,000
N/A
3,163,450
2,658,896
5,050,352
1,107,634
2,365,310
6,274,904
11,884,720
230,958
5,864,717
2,157,360
3,805,376
5,459,364
9,799,420
11,676,100
4 734 R73
- -t-j / O"T jO/ O
4,927,488
925,186
631,582
                                                                                                        SOLID WASTE
                                                                                                           95.2
                                                                                                            N/A
                                                                                                           57.2
                                                                                                          100.0
                                                                                                          100.0
                                                                                                          100.0

                                                                                                           99.5
                                                                                                           99.8
                                                                                                          63
                                                                                                          97
                                                                                                          98
                                                                                                         100.0
                                                                                                          99.8
                                                                                                          63.6
                                                                                                          99.0
                                                                                                          54.1
                                                                                                          94 .-5
                                                                                                          83.4

                                                                                                          96.0

                                                                                                         100.0
a.  Reference 8.

b.  Reference 10.

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f
                                                                                           TABLE  14
SIC
i rnnF
.£, ""XL
CD
1 20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
•jg
OU
37
38

39
INDUSTRY
Food Processing
Tobacco
Textile Mill Pro-
duction
Apparel
Wood Products
Furniture
Paper and Allied
Products
Printing, Pub-
lishing
Chemicals and
Allied Products
Petroleum
Rubber and Plastics
Leather
Stone, Clay
Primary Metals
Fabricated Metals
Non-Electrical
Machinery
Electrical
Machinery
Transportation
Equipment
Professional and
Scientific
Instruments
Miscellaneous Manu-
facturing
TEY
(SOLIDS)
7.949,
7.949a
2.160
2.192
8.531
2.783
3.987
5.385
8.862
1.594
9.835
8.989
6.412
3.184
6.832
3.189

2.941
2.562

1.769
1.603
RANGE OF PLANT RANGE OF PLANT
SIZE GENERATING SIZE GENERATING
0-50 TPD SOLID 50-200 TPD SOLID
WASTE (NUMBER WASTE (NUMBER
OF EMPLOYEES) OF EMPLOYEESL
0-1,635
0-1,635
0-6,019
0-5,931
0-1,524
0-4,671
0-3,261
0-7; 228
0-1 ,467
0-8,156
0-1,322
0-1,446
0-2,027
0-4,083
0-1,903
0-4,077

0-4,420
0-5,074

0-7,349
0-8,110
1,635 -
1,635 -
6,019 -
5,931 -
1,524 -
4,671 -
3,261 -
2,228 -
1 ,467 -
8,156"
1,322"
1 ,446 -
2,027 -
4,083 -
1,903 -
4,077 -

4,420 -
5,074 -

7,349 -
8,110 -
6,542
6,542
24,074
23,723
6,095
18,685
13,042
8,912
5,868
32,623
5,287
5,785
8,110
16,332
7,611
16,306

17,681
20,297

29,395
32,440
NUMBER OF
PLANTS GENE-
RATING 0-50 TPD
SOLID WASTE
28,120
272
7,201
24,438
33,937
9,233
6,038
42,069
11,317
2,016
9,168
3,197
15,993
6,728
29,450
40,792

12,270
8,661

5,983
15,187
NUMBER OF
PLANTS GENE-
RATING 50-200
TPD SOLID WASTE
63
12
-
34
108
69
4
22
64
75
-

-
141

-
-
% OF ALL
PLANTS LAND- NUMBER OF ON-SITE
FILLING LANDFILLS.
ON-SITE
22.
22b
22h
22h
22£
22b
22b
Oc
<
20!
i
22u
20n
22b
701
1
0J
22b

22b
22b
0-50
6,186
60
1,584
5,376
7,466
2,031
1,328
0
4,527
403
0
160
3,518
1,346
6,479
28,554

0
1,905

1,316
3,341
50-200 200-t- TPD
14
0
0
0
3
0
0
0
43
0
0
0
5
13
16
0

0
31

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0

0
0

0
0
                                             TOTAL:
                                                                                                                                                  75,580     125

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                      TABLE 14 (Continued)              j

                             Notes

 a.TEY was unavailable for the tobacco industry.  The TEY for food
   processing was used as a proxy.

 b. Average of the ".% of all Plants Landfill ing On-Site" ifor those
   2-digit SIC industries for which hazardous waste practices assess-
   ments are available.

 c.Telephone Contact -- J. Grant, Director of Government Affairs
   Printing Industries of America, Washington, D.C.      ;

 d.Weighted average of the "% of Plants Landfilling  On-Slite" for:

             - inorganic chemicals $IC  281);           i
               References 12,  13, 14.                    '.

             - paint and allied products  (SIC 285);
               Reference 15.

             - organic chemicals, pesticides, and
              explosives  (SIC  286, 287);
               References  16,  17.                       :

   Weights  based  on  total  potentially  hazardous  waste  volume (dry MT/Y)

 e.Based on  percent  of total potentially.hazardous waste:volume
   (dry MT/Y)  landfill ing  on-site; Reference  18.         ;

 f.Reference  19.
                                                        i

 g.Based on oercent  of total potentially  hazardous waste  volume  (dry
   MT/Y) landfilled  on-site; Reference  20.               ;

 h. Reference  21.

 i.Reference  22.

j. Reference  23.                                         ;     .
                               -47-

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     d.   For 2-digit SIC industries for which no hazardous
          waste practices assessments have been performed,
          the disposal data available for the other 2-digit
          SIC's were averaged and the average was applied.

     Using the industrial hazardous waste practices assessments done for
EPA, the percentage of plants landfill ing on-site is determined.  This
percentage was applied to the numbers of plants in each waste volume
generating category to yield the numbers of  on-site landfills accepting
0-50   50-200, and  over 200 TPD  of solid waste.  The total  number of 0-50
TPD industrial on-site landfills is 75,580 while the number  of 50-200
TPD on-site  landfills is  125 and there are essentially no  on-site land-
fills  accepting more than 200 TPD of solid waste.

      In  a previous EPA study  (Reference 30), Fred C. Hart  Associates
estimated 10,558  industrial hazardous waste  generators would require
permits  for  on-site hazardous waste facility operation.  Assuming most
industries presently co-dispose hazardous  and non-hazardous  solid wastes
and that 90% of the establishments  landfill  or open dump these wastes,
9,502  industrial  on-site  hazardous waste  landfills must  exist nation-
'wide.   Since these landfills will  be  covered under Subtitle  C of RCRA,
this  figure  can be subtracted  from  the  total industry  solid  waste  land-
fill  figure  obtained  from Table 14  to yield  66,203  (or 66,094 10 TPD  and
 109  100 TPD) industrial  on-site non-hazardous solid waste  landfills
nationwide which  will  be subject to  the  proposed  Guidelines.
      4.   Construction, Demolition, and Disaster Debris
 There are very few single-purpose construction, demolition or
                                                        Landfills.
                                                              disaster
	 landfills.  The majority of construction wastes are used as  fill
material or are disposed at permitted municipal landfills.  Disposal
methods include separate burial, use for on-site construction such  as
for service roads, or burial along with the municipal solid waste.
Demolition wastes normally suffer the same fate as construction wastes,
except that a greater percentage is used for clean fill.  The Army Corps
of Engineers reports that there are no pre-planned or active disaster_
debris landfills.  These landfills are selected on a case-by-case basis
by local authorities at the time of the particular disaster.  Depending
on the type and amount of debris, and the availability of landfill_
sites, either existing municipal landfills or  new single-purpose sites
are selected.  These are used only once, covered over, and recorded only
   local authorities.  The data base developed in this report does not
                                                  Refinement of that data
                                                  minimum, contact with
                                                                      to
by 	.
represent national prevalence of debris fills.
base to include debris fills would require, at a
each State.  Since the number of such single-purpose fills is likely
be quite small, they are not considered further in this analysis.

     5    Pollution Control Residues.   The waste category of pollution
control residues includes:(a) flue gas desulfurization sludges (F6D> _
sludge); (b) ash generated by combustion of coal and oil; and (c) munici
pal waste water treatment plant sludges.  Sludges from the treatment of
non-hazardous industrial wastes other than ash and FGD sludge are
accounted for in the industry section.  Of the three waste types in the
                                -48-

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  Pollution Control  Residues  (PCR)  category,  sludges  from waste water
    e±rPntPl?n? "1"  1°^  conside^d  father"  It  is estimated that
     percent of treatment  sludges are  landfilled.  These si udqes are

                                             1dent1f1ed
       TIJ?1T?n:iain1n9 waste stream types are primarily generated by elec-
   «,m, ?ll  1SS'  u°ue  ° ^e large volume of wastes generated, it can be
 assumed  that each power plant disposes of the waste oniits1 own site

 *rpUrp^t?  Ud§e| Can be large 1n Volume> but at the P**ent time there
 ?n „  vl  Try fSW g°wer plants with act1ve scrubber systems.  According
 to a  recent Energy Resources Company, Inc.   study (Reference 31)  there

          Tar1^rMle ^^f T temS (which P^ducfwaste stream f'
           •   sa]eabl(r P^duct).  Seventeen of these facilities dispose
       o  G lnKponds; *lx umts use landfills; and one unit dumps its
 sludge in a borrow pit.   Seven units did not report on 'disposal  practices,


 fn«iIhf,,ScermaJ°r"??llut1?n Ttro1  residue 1s ash- Combustion of
 fossil fuels, especially coal  and oil,  generally produces an ash residue

 on coaieq^eS-d1?POS,al\  The ?leCtHc  power generating' industry re   es
        n,t?n ?ll-(irf1.stf'T1 electric power plants  to  generate  about 63%
        S JSJ 's electrical  capacity, with coal  at 38%  and oil-fired
  on          £  !°tal  "Paclty-   The amount of ash  residue generated
 depends  upon the  type of fuel  and  the ash content of the  fuel    The
 disposal  of the ash  is a practice  particular to the  plant involved.  We
 have  attempted  to estimate  the  population of combustion; ash disposal
 sites  in  the manner  described  below.

      From previous studies,  the average ash  generation  figures oer olant
      erHm^aWa^  (^l ¥ 9enerati"9  capacity were derived!  first for
 rinr*  ?nn ?Sn f°rf 01J-fired  facilities.   Per MW,  coal  combustion pro-
 duces  300 tons  of ash per year or 0.82 tons  per day, based  on 365 days
 per year  of  operation.   The  corresponding figures for ash generation at
 oil-fired  plants  are  2.5 TPY and 0.007 TPD per megawatt;
 tn  thWeMneXt scaled ^^ mode1 landfill classes, established previously,
 to  the MW capacity figures for each type of plant.  In order for a coal-
 fired plant to generate from 0-50, 50-100 or 200+ tons of ash per day,
 its rated capacity had to fall within 3 ranges of values.  These values
 were 0 to 61 MW.^61 to 244 MW, or 245+ MW for each of the three model
 hS Ji Lr«P2CJ JSn'u,,1! the 53Se °f O1'l-f1red P^nts, the MW capacity
 had to exceed 7,100 MW to produce more than 50 tons per day of ash   Few
 plants attain one tenth that size.                      :
iinif                    numb!r Of coal- and oi'l -fired plants  in  the
United States, by category of ash production.   Oil-fired plants  fall
completely within the smallest category.   Coal-fired plants do not.   The
results, on a national level are that 729 plants  (621 oil-fired,  108
coal-fired) generate enough ash to fill ponds  and landfills of 0  to 50
TPD capacity; 75 plants, all coal -fired,  produce  50  to 200 tons of  ash
per day; and 217 plants, all coal-fired,  generate more tnan 200 tons  of
ash per day.
                                  -49-

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                                      TABLE  15

                      NUMBER OF  ASH  LANDFILLS BY  DAILY  CAPACITY  FOR
                       STEAM ELECTRIC  POWER PLANTS,  BY  PLANT TYPE a
  Total
                                           Number  of Plants  in Ash  Production
                                                    Categories  (TPD)
Plant Type
Oil-Firedb
Coal -Fired0
0-50
621
108
50-200
-
75
200+ Total
- • 621
217 400
729
                                                          75
217   1,021
     aPlants in service as of December 31,  1976,  according to the Federal  Energy
      Administration.

     ^Included among oil-fired plants are some plants firing gas or coal.
      However, it can be assumed that all the plants generate some oil-
      fired ash which must be landfilled.
     cNumbers represent plants firing coal only.
Source:  Reference 32.
                                   -50-

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     Data

IS  1 JSV
the total, 49%
figure implies
from immediate
watering process
           from the National Ash Association indicate thait 15% of the
                    1s used 1n construction and of the refraining 85% of
                is trucked to landfills and 51% is sluiced.  The latter
                disposal in ponds or lagoons which removes this fraction
                consideration.  However, at the conclusion of the de-
                   this ash volume is reportedly dredged and dumped on
      The practices of ash disposal are random; that is, they are not
 correlated wth size of plant, with ownership, with plant location in
 terms of either physiography or demography, nor with plant age.  Prac-
 tices are solely determined by the resources of the plant in question
 and not of a class of plants.  If 41.7% of ash is landfilled (49%
 trucked x 85% disposed), then the total number of landfills by capacity
 class, assuming a random disposal practice, is as follows-
 Number of landfills
                          0-50 TPD   50-200   200+
                            304
31
                                               90
Total
 425
 c-    Estimating the Prevalence of Environmentally Sensitive Area;
      Wetlands,  floodplains,  permafrost  areas,  critical  habitats,  and
 recharge zones  of sole  source  aquifers  are  considered  as  Environmentally
 Sensitive Areas (ESAs)  by  the  Criteria  and  Guidelines.  Karst  terrain  and
 active  fault zones are  not designated as  ESAs  by  the Proposed  Guidelines,
 but  are listed  nonetheless as  areas  to  avoid in sanitary landfill siting,
 and  to  protect  in landfill design  and operation.  The  total U.S.  area  of
 karst terrain and active fault zones is insignificant when mapped at the
 gross scale  used  for estimating the  extent  of  the other, more  prevalent
 hbAs.   For this reason, consideration of  ESAs  is  limited in this  report
 to wetlands, permafrost areas, floodplains, critical habitats, and areas
 overlying  sole  source aquifers.

      1.    Wetlands.   The  proposed Guidelines  define wetlands  as  "those
 areas that are  inundated or saturated by  surface or groundwater at a
 frequency  and duration sufficient to support,  and that under normal
 circumstances do  support,  a prevalence of vegetation typically adapted
 for  life in saturated soil conditions.   Wetlands generally include
 swamps, marshes,  bogs, and similar areas."  To estimate the aggregate
 National costs  of  sanitary landfill ing in wetland areas, it is first
 necessary  to map  and estimate the total  U.S. area of wetlands.   A recent
 inquiry at the  U.S. Fish and Wildlife Service indicates that the Federal
wetland inventory  is not yet complete,  and that no generalized U.S.
wetland map has superseded the 1956 USFWS Circular 39 map  (Reference 33)
                               -51-

-------
     Figure 7 represents a generalized adaptation of Reference 33.
Heavy concentrations of wetlands were identified by dots which rep-
resented 10,000 acres of wetlands.  These were outlined to indicate
Generalized areas of expected concentration of wetlands.  The total area
of wetlands in the U.S., as reported in Reference 33 is 74 million
acrel.  Data are still needed for Alaska, Hawaii  and the U.S. territories.
The map is subjective and intended only as a rough estimate of U.S.^
wetlands prevalence.  When the national wetland inventory is complete, a
refined estimate can be made.

     2    Floodplains.   The proposed Guidelines define floodplains as
"lowland and relatively flat areas adjoining inland and coastal waters,
including flood-prone areas of offshore islands, which  are inundated by
the  base  100-year  flood."  To estimate the  aggregate national costs  •
of sanitary landfilling in floodplains, it is first necessary to map and
estimate the total  U.S. area of 100-year floodplains.*  A recent inquiry
at the  Federal  Insurance Administration, which  administers the Federal
Flood Insurance  Program, indicates that the Federal floodplain mapping
effort  is not yet complete, and that no reliable generalized U.S.  flood-
plain map yet exists.   However, in a 1978  report,  the U.S. Water Resources
Council Reference  34)  produced a map of existing  U.S.  flooding problems
defined as  areas (river basins) that have  serious  or moderate  agricul-
tural,  urban and other  flooding.  Figure 8 shows WRC's  generalized areas
of serious  flooding.  When  the Federal  100-year floodplain mapping
effort  is  complete, a refined  estimate can be made of  the extent of
floodprone  areas.

      3     Permafrost Areas.    The proposed Guidelines  define permafrost
 areas as  areas  of "permanently frozen subsoil."  R.F.  Flint  s  Glacial
 and Quaternary  Geology (Reference 39) maps the  present extent of  con-
 tinuous and discontinuous  permafrost in the  northern hemisphere.   Figure
 9 was adapted  from Flint's map of continuous  permafrost areas.

      4    Critical  Habitats.    Critical habitats are those habitats
 which have been determined by the Secretary of the Interior to be crit-
 ical to the continued existence of  endangered species listed under
 Section 4 of the Endangered Species Act of 1973.  According to K.
 Schreiner of the Office of Endangered Species,  U.S.. Fish and Wildlife
 Service, the ultimate total U.S.  area of ^1t1"J habitat w! 11 be very
 small compared to  the total area of the other ESAs.  It wastherefore
 concluded that the identification of the known small areas of critical
 habitats would  lack meaning in the  national-scale maps used for this
 report   Further,  many critical  habitats are contained within the flood-
 plain  and wetland  areas.

      5    Areas Overlying Aquifers.   The proposed Guidelines recommend
 location of landfills  in areas which  are  not underlain by current  or
       This  approach  conforms  with  the  intent  of  Executive Order  11988
       dated May 24,  1977,  concerning floodplain  management.
                                    -52-

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             FIGURE 7
CONCENTRATION OF WETLANDS IN THE U.S
                                                                      . boun-
                                                               daries of
                                                               Wetland
                                                               Concentrations
                 Source:  Reference  33.

-------
r
                                                              FIGURE 8
                                                      EXISTING FLOODING PROBLEMS
                                                                            Areas that have serious agricultural, urban, and
                                                                            other flooding.
                                                                            Source:   Reference 34 .

-------
         FIGURE 9
CONTINUOUS PERMAFROST IN THE U.S.
             Source:   Reference 39

-------
planned drinking water sources.  Figure 10 shows the areas of major
aquifers in the country in which municipalities rely heavily on ground
water as a source of drinking water.  The map was adapted from U.S.
Geological Survey Hydro!ogic Atlas 194 (Reference 40) in consideration
of municipal water use data.

     6.   Total Environmentally Sensitive Area.   Figure 11 maps the
total U.S. Environmentally Sensitive Area as defined by the Section 4004
Criteria and the proposed Guidelines.  This map was produced by over-
laying Figures 7 through 10 representing the four separately mapped
ESAs.  Figure 11 indicates that approximately 50-60% of the area of the
coterminous United States is classified as environmentally sensitive.


D.   Estimating the Distribution of Sanitary Landfills


     For the purpose  of this report, it is assumed  that the distribution
of  sanitary landfills  roughly  correlates with population distribution.
To  determine the number of  landfills in ESAs, the following methodology
was used:

           a.    Determine which of  each State's  Standard
                Metropolitan  Statistical Areas  (SMSAs)  lie
                in  ESAs.  This  was  accomplished  by over-
                lapping a map of SMSAs with  the  composite
                ESA map in  Figure 11,  and  identifying  over
                lapping areas.   The population  of SMSAs in
                ESAs  was  then summed for  each  State.

           b.    Determine  the percentage  of  the  remainder
                of the State (non SMSA) which  lies  in ESAs
                using the  same  tools as  in (a)  above.
                Subtract the State's total  SMSA population
                from the State's total  population to yield
                the population of the remainder of the
                State.  Assuming an even  population  distrib-
                ution over the remainder of the State, apply
                the percentage ESA area found above to the
                population of the remainder of the State to
                obtain the ESA population in the remainder
                of the State.

           c.   Add the total State SMSA population in ESAs
                to the population of the remainder of the
                State  in ESAs to yield the total State
                population in ESAs.

           d.   Add all the State's total populations in ESAs
                together to obtain the total U.S. population
                in ESAs.
                                 -56-

-------
                                   FIGURE 10
ESTIMATED EXTENT OF SOLE  OR  PRINCIPAL SOURCE AQUIFERS; COTERMINOUS UNITED STATE
                                                                                   Estimated Extent
                                                                                     of Aquifers
                                              Source:  Reference  40

-------
                 FIGURE 11
ENVIRONMENTALLY SENSITIVE AREAS IN THE U.S.
                                                                Comoosite map
                                                                of Wetlands,
                                                                Continuous
                                                                Permafrost,
                                                                Existina  Flood-
                                                                inn  Problems,
                                                                and  Principal
                                                                Source Aquifers
                      Source:  Fred C.  Hart  Associates,  Inc.

-------
           e.    Determine the  percentage of the  total U.S.
                population which  resides in ESAs,  and apply
                this  percentage to  the  total  number of land-
                fills to  obtai.n the number  of landfills
                in  ESAs.     ""                       ;
                                                     i

     These data are  summarized in  Table 16.   As the table  indicates,  the
 total  U.S. population in ESAs is 154.5  million  or 73.1%  of the  total
 U.S. population.   If landfills are evenly  distributed according to
 population, then 73.1% or 59,443 landfills  in all,  lie in  ESAs.
E.   Aggregate Costs
     Tables 17-19 outline the potential impact of the proposed  landfill
Guidelines on the operating costs of various types of landfill  oper-
ations.  Table 20 presents the unit cost impact  (i.e;, costs/ton) of the
Guidelines on landfill sites handling municipal, industrial, and pollution
control residue waste respectively, with these operations further strat-
ified by daily capacity (ton/day) and whether they are located  in sen-
sitive or nonsensitive areas.  All of these results are then summarized
in Table 21.  These cost impact assessments ,are based on the landfill
prevalence data a,nd landfill upgrading cost estimates as developed in
Sections VLB. and V.B., respectively.  The aggregate incremental cost
figures in Table 21 show the amount by which these changes in unit costs
would affect the average annual  operating costs of each type of land-
fill, and the total of these Guidelines-related incremental costs for
all landfills nationwide.

     The factors that stand out most clearly in these tables are:
     1.
     2.
     3.
     4.
The  potential  cost  impact  is  substantial;  the  national
figure of $2038.0 million  is  approximately a 60  percent
increase over  the present  landfill operating cost esti-
mate of $3,539 million.

The  incremental costs due  to  the Guidelines reflect
the  scale economy assumptions made earlier in this
report for both base line  and upgrading technology
costs; this decreasing cost factor is the  most
significant for municipal  solid waste sites.

Leachate controls, and particularly the impermeable
cover requirement, represent the largest incremental
cost element, while surface runoff control is the
second largest factor.

The  industrial landfill population is responsible for
roughly 66 percent of the  total  incremental costs,
with virtually all of it falling on the small  (10
TPD) sites; the cost data  however, show that the
incremental impact per unit of waste was fairly
even among the three waste categories.
                              -59-

-------
                                                      TABLE 16
o
I
(1)


STATE
\J 1 r\ I L.
Maine
New Hampshire
Vermont
Massachusetts

Rode Island
Connecticut

New York








L-O 1 It'll
(2)


SMSAs
LOCATED IN
AN ESA
None
None
None
Boston
Worcester
Hone
Bridgeport
New Haven
(3)


SMSA
POPULATION



2,898
377

397
415
(4) (5) (6)

REMAINDER
OF STATE
TOTAL SMSA POPULATION
POPULATION STATE (Column 5
IN ESAsa POPULATION3 minus Col. 3)
0 1,047 1,047
0 808 808
0 470 470
3,275 5,800 2,525

0 937 937
812 3,088 2,276

(7)


PERCENTAGE
OF STATE
AREA IN
ESAs
40
5
5
30

0
40

(8)
REMAINDER
OF STATE
POPULATION
IN ESAsa
(Column 7
Times Col.
419
40
24
758

0
910

(9)

TOTAL STATE
POPULATION
IN ESAsa
(Column 8
6) Plus Col. 4)
419
40
24
4,033

0
1,722

Albany, Sche- 267b
nectady,
Troy
Binghamton
Buffalo
Nassau
New York
City
Rochester
Syracuse

p
151°
1,345
2,630

9,739
972
643


15,747 18,214 2,961







30







888







15,635






-------
          (1)
(2)
(3)
 TABLE 16 (Continued)


(4)           (5)
                                                                           (6)
                                                                 (7)           (8)           (9)
I
01


STATE
New Jersey


Pennsylvania




Ohio



Indiana

Illinois

Michigan



SMSAs
LOCATED IN
AN ESA 1
Jersey City
Long Branch
Newark
Paterson
Harrisburg
Johnstown
Lancaster
Philadelphia
Pittsburgh
York
Akron
Canton
Cincinnati
Cleveland
Columbus
Evans vi lie
Indianapolis
South Bend
Chicago
Peoria
Rockford
Detroit
Flint
Grand Rapids
Kalamazoo
Lansing
Trrrni r.«r-n UIXV-I.M i nut. KU'lnlHUCK
TOTAL SMSA REMAINDER OF STATE OF STATF TOTii C.TATI:
^M^fl DHDIII ATTflM CTATC- nr- r—ri\-rr- .nr-> • . O 1 n 1 C. 1 U 1 HL OlAlt
°"JO rurULttliuli olAlc Or STATF ARFA TM DDDMI flTTfiM nnnin nTrnn
PflPIH ATffiKl TM CCA a nnmii A n Jinit. ni\i-n in rUrULnllUI'i rUrULAI 1UN
598
2J80 3,592 7,325 3,733 15 560 4,152
*461
425
266
4J35 8,540 11,862 3,322 40 1,329 9,869
2,'365
343
677
406
I$f6 5'529 10'737 5,208 25 1,302 6,831
1,'057
290
.1,137 	 „ 1,708. 	 5,330- 3,622- -40 1,449 	 3,157 "
7,002
351 7,624 11,131 3,507 40 1,403 9,027
4,446
517
HI 6,215 9,098 2,883 100 2,883 9,098
438

-------
I
CTl
ro
i
           (1)
(2)
(3)
 TABLE 16 (Continued)


(4)           (5)
(6)
(7)
(8)
      West Virginia  Huntington
               291
                291
              1,791
1,500
                                                                                           67
               1,005
(9)
STATE
Wisconsin
Mi nnesota
Iowa
Missouri
North Dakota
.South Dakota
Nebraska
Kansas ;
Delaware
Mary! and
Wash., D.C.
Virginia
SMSAs
LOCATED IN SMSA
AN ESA POPULATION
Oshkosh
Madison
Milwaukee
Duluth
Minnesota
Davenport
Des Moines
St. Louis
None
None
Omaha
Kansas City
None
Baltimore
None
Newport
Norfolk
281
301
1,417
264
2,000
365
325
2,391


575
1,299

2,120

347
745
TOTAL SMSA
POPULATION
IN ESAsa
1,999
2,264
690
2,391
0
0
575
1,299
0
2,120
0
1,092
STATE
POPULATION
4,566
3,197
2,855
4,777
637
682
1,543
2,270
573
4,094
723
4,908
REMAINDER
OF STATE
POPULATION
2,567
933
2,165
2,386
637
682
968
971
573
1,974
723
3,816
PERCENTAGE
OF STATE
AREA IN
ESAs
100
88
50
30
60
48
28
28
0
22
0
15
REMAINDER
OF STATE
POPULATION
IN ESAsa
2,567
1,821
1,083
716
382
327
271
272
0
434
0
572
TOTAL STATE
POPULATION
IN ESAsa
4,566
3,085
1,773
3,107
382
327
846
1,572
0
2,554
0
1 ,664
                                                                                              1,296

-------
(1)
(2)
(3)
 TABLE 16 (Continued)
(4)           (5)
(6)
(7)
                                                                                            (8)
                                                                                            (9)
STATE
N. Carolina

S. Carolina

Georgia
Florida






Kentucky
Tennessee

Alabama
Mississippi
Arkansas
SMSAs
LOCATED IN SMSA
AN ESA POPULATION
Charlotte
Greensboro
Raleigh
Columbia
Greenville
Charleston
None
Ft. Lauderdale
Jackson
Lakeland
Miami
Orlando
Pensacola
Tampa
W. Palm Beach
Lexington
Louisville
Chattanooga
Knoxville
Memphis
Mobile
Jackson
Little Rock
588
757
458
349
509
352

756
661
255
1,370
549
259
1,276
412
282
886
389
427
863
389
275
350
T/vrn, • PERCENTAGE REMAINDER
SIA,KS5A' REMAINDER OF STATE OF STATE TOTAL STATE
POPULATION STATE OF STATE AREA IN POPULATION POPULATION
IN ESAsa POPULATION POPULATION ESAs IN ESAsa IN ESAs™

1,803 5,363 3,560 63 2,243 4,046

1,210 2,784 1,574 40 630 1,840
0 4,882 4,882 65 3,173 3,173



5,538 8,090 2,552 100 2,552 8,090



1,168 3,357 2,189 35 766 1,934


1,679 . 4,129 2,450 50 1,225 2,904
389 3,357 2,968 52 1,543 1,932
275 2,324 2,049 85 1,742 2,017
350 2,062 1,712 82 1,404 1,754

-------
I
en
          (1)
(2)
(3)
 TABLE 16 (Continued)


(4)           (5)
(6)
(7)
(8)
                                                                                       PERCENTAGE   REMAINDER
                                                                                                                   (9)
STATE
Louisiana

Oklahoma

Texas





Montana
Idaho
Wyoming
Colorado
New Mexico
Arizona

Utah
Nevada
SMSAs
LOCATED IN SMSA
AN ESA POPULATION
Baton Rouge
New Orleans
Shreveport
Oklahoma City
Tulsa
Austin
Beaumont
. Corpus Christi
Dallas
El Paso
Houston
San Antonio
None
None
None
None
Albaquerque
Phoenix
Tuscon
Salt Lake City
Las Vegas
402
1,083
343
750
572
375
102
298
2,464
390
2,168
960



.-
376
1,127
. 416
753
308
TOTAL SMSA REMAINDER
POPULATION STATE OF STATE
IN ESAsa POPULATION POPULATION
1,828

1,322



6,757



0
0
0
0
376
1,543
- . -
753
308
3S764

2,709



12,050



735
799
359
2,496
1,122
2,153

1,173
573
1,936

1,387



5,293



735
799
359
2,496
746
610

420
265
OF STATE
AREA IN
ESAs
100

100



30



15
20
8
15
2?
10

35
33
OF STATE
POPULATION
IN ESAs3
1,936

1,387



1,588



110
160
287
374
172
61

147
87
TOTAL STATE
POPULATION
IN ESAs3
3,764

2,709



8,345



110
160
287
374
548
1.604

900
395

-------
CTl
cn
i
           (1)
(2)
(3)
 TABLE 16 (Continued)


(4)           (5)
                                                                             (6)
                                                                  (7)
                                                                  (8)
               Total U.S. Population in Environmentally Sensitive Areas
(9)

STATE
Washington

Oregon
California










Alaska
1 1«* . « *
Hawaii'
SMSAs
LOCATED IN
AM CCA D/
mi u«Jr\ r\
Seattle
Spokane
Tacpma
Portland
Anaheim
Bakersfield
Fresno
Los Angeles
Oxnard Si mi
Valley
Sacramento
Salinas
San Francisco
San Jose ,
Stockton
Vallejo
None

Honolulu
"rn-rni o..^» rt-ivmnmac KCIIftlNULK
REMAINDER OF STATE OF STATE TOTAL STATE
DPULATION IN ESAsa POPULATION POPULATION ESAs INESAs^ ^N^SA^
1,383
301 2,076 3,476 1,400 20 280 2,356
i'062 L062 2,266 1,204 28 337 1,399
1,597
336
435
6,924

420 15,693 20,907 5,214 20 1,043 16,736
255
3,143
1,157
299
263
0 337 337 40 134 134

686 686 847 161 90 145 831
                                                                                                                   i54 545
     a.   In thousands.

     b.   One-third of total  SMSA population.
     c.   One-half of total  SMSA population.


     Source:   Fred C.  Hart  Associates,  Inc.

-------
                                              TABLE 17
       IMPACT OF GUIDELINES ON OPERATING COSTS OF MUNICIPAL SOLID HASTE LANDFILLS  (COSTS/TON)
Required Technologies
     Gas Control
Vertical Impermeable Barriers
                                                               Site Condition and Size Categories
     10 TPD                   100 TPD                  300 TPD
Sensitive Non-Sensitive  Sensitive Non-Sensitive  Sensitive Non-Sensitive
   $1.30     $1.30
$0.30     $0.30
$0.15     $0.15
Leachate Control
Imper. Daily Cover (off-site source)
Dike Construction3
     Surface Runoff
Ponding
Dike Construction9
     Monitoring
Gas Monitoring
Ground Water Quality Monitoring
Total Incremental Costs
Baseline Costs
Total Post-Guidelines Costs
Percent Increase
5.30
1.20
0.10
1.20
0.15
0.60
$9.85
11.15
;2i7oo~
88%
5.30
-
0.15
0.60
$7.35
11.15
$18.50
66%
2.65
0.28
0.05
0.27
0.03
0.10
$3.68
6.65
$10.33
55%
2.65
-
0.03
0.10
$3.08
6.65
$9.73
46%
1.75
0.15
0.04
0.15
0.01
0.05
$2730
3.95
$6.25
58%
1.75
.
0.01
0.05
$1.96
3.95
$5.91
50%
a.   Dike construction costs were divided equally between leachate and surface runoff control functions.

-------
                                                         TABLE  18
01
~J
I

Required Technologies
Gas Control
Leachate Control
Imper. Daily Cover (off-site source)
Surface Runoff
Ponding .
Dike Construction
Mom' tori ng
Gas Monitoring
Ground Water Quality Monitoring

Total Incremental Costs
Due to Guidelines
Baseline Costs
i ota i rosi-buiae n nes Losts
Percent Increase

10 TPD
Sensitive Non-Sensitive


$5.30 $5.30
0.10
2.40
0.15 0.15
1.60 0.60

$8.55 $6.05
11.15 11.15
$19.70 $17.20
77% 54%
Site Condition and Size Categories
TOO TPD 300 TPD
Sensitive Non-Sensitive Sensitive Non-Sensitive


$2.65 $2.65
0.05
0.55
0.03 0.03
-.10 0 10

$3.38 $2.78
6.65 6.65
$10.03 $9.43 - """ _
51% 42%

-------
                                                     TABLE  19
                  IMPACT OF GUIDELINES ON OPERATING  COSTS OF  POLLUTION  CONTROL  RESIDUE LANDFILLS  (COSTS/TON)
en
CO
Required Technologies

     Gas Control

 Leachate Control
Imper. Daily Cover (off-site source)

     Surface Runoff
Ponding
Dike Construction

     Monitoring
Ground Water Quality Monitoring

Total  Incremental  Costs
  Due  to  Guidelines
Baseline Costs
Total  Post-Guidelines  Costs
Percent Increase
10 TPD
Sensitive Non-Sensitive
$5.30 $5.30
$0.10
2.40
0.60 0.60
$8.40 $5.90
11.15 11.15
$15755" $17.05
75% 53%
100 TPD
Sensitive Non-Sensitive
$2.65 $2.65
$0.05
0.55
0.10 0.10
$3,35 $2.75
6.65 6.65
$10700" $9.40
50% 41%
300 TPD
Sensitive Non-Sensitive
$1.75
$0.05
0.30
0.05
$2.14
3.95
$6.09
54%
$1.75
-
0.05
$1.80
3.95
$5.75
46%

-------
                                                      TABLE 20

                SUMMARY OF IMPACT OF LANDFILL GUIDELINES ON OPERATING COSTS OF LANDFILLS (COSTS/TON!a
I
CTl
UD
I

Landfill Baseline
Costs
Waste Types
Municipal
Post-Guidelines
Costs
Sensitive

$11.15
(12.29)



21.00
(23.15)
10 TPD
Non-Sensitive

$11.15
(12.29)



18.50
(20.39)
Sensitive

$6.65
(7.33)



10.33
(11.39)
IUM emu OIZ.K l/dLeqor
100 TPD
Non-Sensitive

$6.65
(7.33)



9.73
(10.73)
'ies
Sensitive

$3.95
(4.35)



6.25
(6.89)
300 TPD
Non-Sensi ti ve

$3.95
(4.35)



5.91
(6.51)
       Industrial

       Post-Guidelines
            Costs
       Percent Increase
                              19.70
                             (21.72)
   77%
 17.20
(18.96)

.   .54%
       Pollution Control  Residues
       Post-Guidelines
            Costs
       Percent  Increase
 19.55
(21.55)

   75%
 17.05
(18.80)

   53%
                                                                   55%
                                                     46%
 10.03
(11.06)

 -  51%
  9.43
(10.39)

   42%
                                                                10.00
                                                                (11.02)
                9.40
               (10.36)

                 41%
                 6.09
                (6.71)
                                                                                                                50%
 5.75
(6.39)
      a.   Costs in parenthesis are costs/metric ton

-------
                                                         TABLE  21

                            AGGREGATE  IMPACT OF  GUIDELINES  ON ANNUAL  LANDFILL OPERATING COST$a
                                                   Site Size Categories
   Haste Types

   Municipal

Annual  Costs/Site
# Sites
Total Costs (^million)

   Industrial
Annual  Cost/Site
# Sites
Total Costs ($million)

Pollution Control Res.

Annual  Costs/Site
# Sites
Total Costs ($million)

Total Costs

($ million).
                                        10 TPD
                                    100 TPD
                                                                                          300 TPD
Sensitive—Non-sensitive    Sensitive  Non-sensitive     Sensitive  Non-sensitive       Total
$ 25,610     $ 19,110
  (8,375)      (3,082)
$.214.5      $  58.9
                            $ 22,230     $ 15,730
                             (48,315)     .(17,779)
                            $ 1,074.0    $   279.7
                            $ 21,840     $ 15,340
                                (222)        (82).
                            $    4.8     $   1.3
                            $1,293.3     $ 339,9
$ 95,680     $ 80,080
  (1,610)        (593)
$ 154.0      $  47.5
                             $ 87,880     $ 72,280
                                   (80)          (29)
                             $  7.0       $   2.1
                              $ 87,100    $  71,500
                                   (23)           (8)
                              $    1.3     $	.6
                               $   163.0     $    50.2
$179,400    $152,880
    (752)       (277)
$ 134.9     $  42.3
                             $166,920
                                   (66)
                             $   n.o
             $140,400
                  (24)
             $    3.4
                              $   145.9     $   45.7
$  652.1
                                                         $1,362.8
$•   23.1
                                                                                                                  $2,038.0
 A.   Landfill operating year is assumed to be 260 days.

-------
  F-    Sensitivity Analysis of Cost Impacts
  1.
 2.
 of whlrh SSo hfo3 Pr??ent^h?re are based on numerous  assumptions,  all
 of which have been delineated in earlier sections.   The  results  are

 hlJS im?r£Vn to4ha"ges !n s?me of these assumptions,  while  others
 if^-!?      -,   effect on total costs-  Two assumptions, one from the
 landfill prevalence calculations and another from the  upgrading  tech-
 nology estimates, were tested to see how they would  SffStSe Guide-
 lines cost impacts outlined above:


           the portion of the landfills that have  on-site clay
           available for the impermeable cover process; and


           the percentage of total  landfills  located  In en-
           vironmentally sensitive vs.  non-sensitive  areas.


 imnn       22 Sh°WS  th(r substantial  difference in the; costs of the
 impermeable cover requirement  for operations  with an on-site vs  off-

 TPD  and^nn°TPne'-/he ValU6S  °f  $5'30>  $2'65' and ^-75 *>r 10 TPD,  100
 Iff  s?t 2nM^lS1feSi  ^sPfctively, assumed  that all: sites must rely on
 off-site sources  of  clay.   This assumption is reasonable since althouoh

 imieasroi?XwhenS1VeiareaS °f Clay?y  S°fls in  the ".$., the?e is reSly
 cm/secS  ?o  hp S5 °Jay c9mP°neJt  ls  sufficiently impermeable (1 x 10-7 'y
 cm/sec)  to  be effective  in  meeting the Guidelines.  However  if it is
 assumed  that  20 percent  of  landfills have on-site souses of clay, thl

     P

                                                    c
costs assuming 50 percent of sites  with  clay  avaiab'r(SefTablI 22).

     It is very unlikely that more  than  50  percent of the sites have
     I ! surfac\^  ^e percentage with on-site  clay? blsed Sn
cenl   l?tSh9ated d^a °.n.S011 types'  could eas11^ ^ under 20 per-
cent   Although no exact estimate can be  made, it is clear that
eventual cost results are very sensitive  to this fictor -- a
that supports the need for further  work  in this area
The unit costs of impermeable  cover  for  landfills with

anSloo ?PD   t are *°-75-.*0-35'  «nd $0.25 fir 10
and 300 TPD sites,  respectively.   See Table 3.
                                                                TPD,
                               -71-

-------
                               TABLE 22

       EFFECT OF CHANGE IN ON-SITE CLAY AVAILABILITY ASSUMPTION
                ON GUIDELINES COST IMPACTS ($ MILLIONS)
Assumption

0/100*
   (Baseline)

20/80*
   (% Change)

50/50*
   (% Change)
Site Size Categories
10 TPD
$1,641.7
100 TPD 300 TPD
$216.8 $211.8
TOTAL
$2,070.3
1,456.4
   (-11%)

1,177.0
   (-28%)
188.2
   (-13%)

145.5
   (-33%)
182.6
   (-14%)

138.9
   (-34%)
1,827.2
   (-12%)

1,461.4
   (-29%)
     0/100 = 0% have on-site clay, etc.
     The results of the second sensitivity analysis are presented in
Table 23.  Two alternative assumptions were substituted for the initial
estimate (labeled Baseline) that 73.1 percent of all landfills were
located in environmentally sensitive-areas:

Alternative Assumption 1:  50% in Sensitive/50% in Non-Sensitive Areas

Alternative Assumption 2:  10% in Sensitive/90% in Non-Sensitive Areas

     The second assumption is close  to the value used by the authors of
the Section 4004 Landfill Criteria EIS.  The data in Table 23 demonstrates,
however, that the impact of even large adjustments in this sensitive/
non-sensitive split is rather small.  A change in the on-site/off-site
clay assumptions, for example, from  0%/100% to 20%/80% or 50%/50% altered
total incremental costs by 12 percent and 29 percent, respectively.  By
comparison, an almost complete reversal of the sensitive/non-sensitive
split (i.e., from 73%/27% to 10%/90%) changed total costs by only 18 per
cent.  Although this change is of some significance, the overall results
are clearly rather insensitive to significant changes in this assumption.
                               -72-

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                                                                            TABLE 23

                                   AGGREGATE  IMPACTS OF GUIDELINES ON LANDFILL COST UNDER ALTERNATIVE SENSITIVE AREA ASSUMPTIONS
                                                                  ~~     ($ MILLION)       ~~	—
                    Haste Types
               Municipal

          Baseline:
          Alt. Ass.  1:
          Alt. Ass.  2:
              73.1/26.9
                  50/50
                  10/90
CO
I
     Industrial

Baseline:     73.1/26.9
Alt. Ass. 1:      50/50
Alt. Ass. 2:      10/90

     Pollution Control
          Baseline:
          Alt. Ass.
          Alt. Ass.
              73.1/26.1
          1:       50/50
          2:       10/90

Sensitive
$214.5
146 . 7
29.3
$1,074.0
734.6
146.9
•' $11.6
8.0
' 1.6
10 TPD
Non-Sensitive
$58.9
109.4
197.0
$279.7 $1
519.8 1
935.7 1
$3.0
5.6
10". 1.

Total
$273.4
256.1
226.3
,353.7
,254.4
,082.6
$14.6
13.6
11.7

Sensitive
$154.0
105.4
21.1
$7.0
4.8
1.0
$4.8
3.3
0.7
TOTAL GUIDELINE COSTS ($

Baseline:
Alt. Ass. 2:
AH. Ass. 3:
73.
1/26.9 $2
50/50 ' 1
10/90 1
100 TPD
Non-Sensitive
$ 47.5
88.2
158.8
$2.1
3.9
7.1
$1.4
"2.7
4.8
MILLION)
,070.3
,945.4 (-6%)
,705.2 (-18%)
300 TPD
Total Sensitive Non-Sensitive Total
$201.5 $134.9 $ 42.3 $177.2
193.6 .. 92.3 78.7 179.7
179.9 18.5 141.6 160.1
$9.1 - -
8.7 - -
8.1 -
$6.2 $26.5 $ 8.1 $34.6
6.0 18.1 15.2 33.3
5.5 3.6 27.4 31.0

GRAND
TOTAL
$652.1
629.4
566.3
$1,362.8
1,263.1
1,090.7
- $55.4
52.9
. ^.48.2, .

          3'    location's^T  Iff/PfiT d??1,l?1th't^.per^"tQ°f t0ta1 1andfills that are in environmentally sensitive vs.  non-sensitive
               locatTons,  i.e.,  73.1/26.9 - 73.1% sensTtive, 26.9% non-sensitive, 50/50 = 50% sensitive, 50% non-sensitive,  etc.

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            VII.   ECONOMIC EFFECTS OF INCREASED
                   OPERATING COSTS OF LANDFILLING
A.   Background
     The data presented in Sections V and VI outlined the probable
impact of the proposed sanitary landfill Guidelines on the per unit
operating costs of such facilities.  However, it is the reaction to
these additional costs by those residential, commercial, industrial and
government sectors directly and indirectly affected that will determine
the long-run net costs and overall effectiveness of the Guidelines.
When a particular business or government agency is faced with higher
operating costs, it can adjust through one of the following routes:

          change operating methods or technologies to
          avoid the costs;

          absorb the higher costs in the form of lower
          profits (higher subsidies);

          shift the higher costs backward on to suppliers
          (e.g., lower wages);

          shift the cost forward in the form of higher
          rates or prices to its customers.

     These four methods are of course not mutually exclusive, and
typically occur in various combinations as the affected parties search
for ways to minimize the burden of the added costs.   In the landfill
"industry" this type of situation is complicated by the fact that much
of the nation's solid waste handling capacity is pub!icy-owned  (although
frequently privately-operated), so the profit element is essentially re-
placed by various public mandates or regulations dealing with subsidy
limits, bond retirement guarantees based on user charges, and numerous
other economic, financial or political constraints.   Because of the
multiple objectives of the public sector, an analysis of the impacts of
additional costs is more difficult.

     The overall incidence patterns of these costs -- i.e., who bears
the burden of  them — will be determined by the particular mix  of
reactions outlined above.  These  can be roughly divided into two cate-
gories, which  are discussed in the following sections:

          supply effects:  reactions by the suppliers of the
          landfill services.
           demand effects:   reactions
           landfilling  services  (i.e.
 by  those  demanding  these
,  solid waste  generators).
                                  -74-

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 B.   Supply Effects
      The landfill operator faced with higher operating costs can either
 absorb the costs or seek out some method of avoiding them or shifting
 them elsewhere.  The analysis of these reaction patterns is similar in
 nature to an analysis of the incidence of various government taxes or
 fees; both depend principally on the financial conditions of the firms
 and the characteristics of the markets in which they are involved   Any
 increases in business costs will eventually be borne either by (a) those
 who provide the various factors of production (labor , capital, equip-
 ment) or (b) those buying the business 's goods or services.   The only
 remaining alternative is to revise the technological or institutional
 structure of the firm (e.g., new equipment,  consolidation with other
 tirms,  etcj  to avoid or minimize the impact of these costs by lowering
 costs in other areas.   The following sections address five major market
 and operational effects most applicable to landfill  operation.

 ,    .,.}•   Increase Disposal  Fees for Landfill  Users.   The ability of
 landfill  operators to  pass costs forward in  the form of higher user
 charges  typically depends  on the nature of the demand for their ser-
 vices.   If  the demand  is very price  elastic,  the potential  increase in
 revenue  will  be minimal  as many  of the landfill  users will find alter-
 native methods of meeting  their  waste handling needs.   This  is  demon-
 strated  in  the figure  below.

                              FIGURE  12              ;
                                    D  quantity  handled (tons)
      IMPACT OF HIGHER LANDFILL USER CHARGES ON DEMAND

A hypothetical landfill  is used by two waste generators represented bv
demand DI and D2 each of which dumps Q0 tons of waste annually at the

llll'it-   thf\l™tf 111  raiS6S US ratSS fr°m R° to Rl>  the m°re price-
Xnm nnVS*  ™    ¥£' rePresented by demand curve DI, reduces its demand
from QQ0 to QQi.   The more price inelastic generator, represented by
curve D£ shows a more modest drop from QQo to QQ2.
                               -75-

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                                                           ion
     The principal effect of the increase in rates is a decline in
quantity disposed, and, if demand is elastic, a decline in total rev-
enues for specific landfills.  However, the problems created by a highly
elastic market demand go beyond those of insufficient revenue generation.
All wastes formerly handled by the landfill must either be deposited
elsewhere or no longer disposed.   The first of these options raises.the
possibility of illegal dumping as well as the increased likelihood that
various landfill operators might avoid compliance, both of which are
serious enforcement problems.  The second option would be that gen-
erators might reduce their waste generation rates and/or expand re-
cycling efforts.  This question is covered in more detail in Sectiot
VII.C.

     2    Higher Taxes for Landfill Support.   A  response available  to
public"landfill operations is  to pass  the additional costs on to tax-
payers in the form of  higher subsidies for landfi 1  operations.  Some
municipalities  that have  formerly  assumed that all or  a specified portion
of landfill  costs would be paid by. landfill  users may  be  faced with  the
problem  of maintaining operating ratios  (operating revenues/operating
costs) while not  wanting  to  provide  any  significant  dlsl"f Jj^ *°
those  generators  who  should  be using  these  facilities.  As the  portion
of total  costs  covered by user charges drops,  other  public Avenue    _
sources  would be  required.   Some private landfill operating  costs could
also be  indirectly  subsidized  by taxpayers  through  investment,  tax
credits  or  loan guarantees  for landfill  upgrading or construction,
research and development grants,  or other forms  of  subsidy.   The spe-
cific policy of the agencies involved, the prevailing  methods used  to
finance everyday operating costs  or retire bonds, and  numerous•other _
 factors would have to be considered with the eventual  reaction tending
 to be highly site-specific.                                          .

      3    Decreases in Supplier Costs.   The theoretical  possibility
 exists'that landfills could reduce their additional  costs through     .
 decreases in supplier costs (e.g., lower wages, fuel costs,  etc.).    Ihis
 oossibility is raised for the sake of completeness only.   It is not  -
 loll dereda practical possibility for most landfill operations  except
 as part of a regionalization  and  consolidation effort (covered below in
 Part 6).
4.
                                                        If a land-
      4    Change  in Profits of Private Landfill Operators.
 fill operator  cannot  recover all  of  its additional costs through rate
 increases,  subsidies,  or  decreases in supplier  costs, the  impact will be
 borne by  the firm's stockholders  in  the form  of a  lower return on inves-
 ted  capital    Small impacts in this  area will probably not  cause any
 substantia  adjustments by these  firms, especially in the short-run, but
 the  ScrewedProfitability could reduce the  level of investment in such
 orations  andmake it more difficult to raise  the capital  necessary to
 upgrade existing  operations or build new ones.  For  those  landfills that
 are  publicly  owned but privately  operated  (roughly seven percent of the
 total  number  of sites presented  in the  Waste  Age  s"^)'.^ "^J"
 would  entail  a pass-through  of  costs to the relevant public agency with
 whom the operator has contracted.  The  affected agency would then be
                           -76-

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  forced  to either authorize  higher  user  charges,  provide alternative
  financial support to the operator  to cover the extra 'operating costs, or
  implement a substantial revision in its operations.  :

  ...   5>   Change in Profits of Industries with On-$ite Disposal    For
  those firms tnat handle part or ail of  their solid wastes at sites owned
  and operated by the firm, the higher disposal costs may mean a substan-
  tial financial loss if the  firm has a high waste generation rate and if
  disposal represents a significant element in the firm's overall oper-
  ating costs.  Conversion from open dump operations to sanitary landfill
  operations could, in extreme cases, mean closure for some financially
  vulnerable firms.   Others would be left virtually unaffected.   This type
  of pattern has been shown to exist for the hazardous waste regulations
  under Subtitle C of RCRA (Reference 5):   some industries (e.g , wool
  scouring and organic chemicals) would incur substantial cost increases
  and some closures,  while others would either have virtually no incremen-
 tal treatment costs (e.g.,  plastics,  paints)  or could: pass through all
 of them due to an  essentially price-inelastic demand (e.g.,  explosives)
 Industries that would be expected to  face  relatively substantial  solid
 f^Sr? ?ostVnc1ude f°od processing,  apparel,  wood  products,
 fabricated metals  and non-electrical  machinery.   It would  be necessary
 to undertake detailed studies  of each  of these industries  to determine
 whether they will  be adversely  affected  by the proposed Guidelines.

    ,  6:    Regionalization and Consolidation of Waste Handling     The
 analysis of  economies  of scale  in  landfill operations ; presented  in
 Section  III  showed  that  cost savings could be  realized  through  con-
 solidation of  smaller  sites  into  one  large landfill  operation.  The
 implementation  of the  RCRA  landfill Criteria and  Guidelines  will  in-
 crease  the benefits  of consolidation due to the lower unit disposal

 SnSarv f^ • ?! " and.the shan'n9 of  the 1n1tial  financing burden of
 sanitary landfill capacity among more waste generators.  The solid waste
 management plans^of many states assume that a considerable amount of
 regional  consolidation will  occur.  The  New York State  plan, for example
 assumes  that the total number of landfills will fall by over 59 percent
 due .to the consolidation of  smaller sites and the expanded use of energy
 and material recovery plants (Reference  35).                      *"*;S that affect the consolidation decision
                      for scale economies;  b  the density, dispersion,
 r               rt the Wast^ SOUrces; and  -i9T 13 shows the location of this model facility in the
rn^fnfiL/MTCU-?r m?et area Of radius R'   Average; transportation
costs of lOtf/MT-mile and average haul distances of 2R were assumed   The
following equation for waste handling cost was then derived:
                                    -77-

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                     FIGURE 13

OPTIMAL LOCATION/MARKET AREA FOR SANITARY LANDFILL
                                                       Boundary  of  Waste
                                                       Collection Area
                          -78-

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              .   Cd = 20 + 143,800     ($/MJ)             :

                           (MTY)1-04

  Total disposal cost  then equals Cd + transporations cost?

                 Co = Cd + Ct                         •    ;

                    = 2($0.10)  (2R/3) + 20 + 143,800

                                               (MTY):
                                                  J.0$
    ,,a         diffe£entiated with  respect to  R and  this  derivative  was  set
  equal  to zero to find  the  value  of R that minimized  C0.  .Knowing  the
    '"         ^F  (wastes/^./sq. ™^)> the  t§ial  volume  If waste
                     , where p  = annual waste generation density    Substi-
                                                                        '
 to 65nn
 to 6500
                R0  =  78.4    .     -'    '

                     pO.338


     Figure  14  shows how the waste collection area decreases as the
      " of waste generation increases.  At a waste density of 100
        (equivalent  of roughly 120 persons/mi2 generating 5 Ibs/person/
        ° S?rV1ceM?^a.}s/855 mi  and the Per unit treatment costs are
           for  5 MTY/nvr/; (equivalent of 6 persons/mi2) the area increases
          <-, and at  1 MTY/rm^ the area is roughly 19,400 mi2.
     Clearly there are substantial assumptions included in this type of
model (e.g., the even distribution of wastes, the constant transportation
,,nf,?H °Ver ^W1ue mile!Se ™nge).  The transportation costs per mile
would probably be consTderably higher for the areas with shorter average
mllSSi hl«*   iiX^ C?StS °f the. ^icles would be spread over a smaller
mileage base.  If the transportation costs were doubled to 20<£/MT-mile
for the highest density area, the service area would drop from 855 mi 2
a? ftnn Slv't^inInnSM?vy ^"^l1 capacity would fall accordingly from
°5'°°   Y to 616
                      Mv
                 ,     MTY,  and unit costs would rise 8 percent
 to $25.23 -u. an increase of $121,000 in annual disposal  costs for those
 serviced in the revised service area.

      Even with these limitations,  this  type of analysis  does  give a  feel
 Tor the way in which scale economies and transportation  costs can jointly
 determine benefits  of regionalization and the  optimal  size  and location
 of the  waste treatment facility.   The RCRA Guidelines  and Criteria will
 force many (if not  all)  of the  small  landfill  sites to consolidate their
-nS nLn" a1much/nial]er "umbf of large sites.  The eventual  impact on
 net disposa  costs  and related  policy decisions will  then come from  the
 type of analyses presented above.
                                 -79-

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                             FIGURE 14
     WASTE  COLLECTION AREA  FOR VARIOUS WASTE GENERATION DENSITIES
 Waste Generation Density

 (MT/mi2/yr)
100J
         $23.26
                     $27.09
                        $28.99
                                                                           $40.70
                                                                                Market
                                                                             3t)   area
                                                                               (1000 mi2)
                                     -80-

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      A hypothetical  example showing  the  potential  impact of the Guide-

               "^"atlon follows.  Let. us assume that the landfill ng

            of states such as  North Dakota were to  be regionalized usinq

 Jf 69 273 Ssae/m?Ca*r  •nodel1°S!*""ed above.  The state has a land Irla
 or 09,273  sq.  mi. and a population  of roughly 640,000.   Assumino that

 o? I V?h^  SU1Sble ft"-,1™""""* ^ generated at a pe  capita rate
 of 4.5 Ibs/day,  the  annual  waste volume would be 525,600 tons  ?476 821

 MT).   Usmg the  Waste Age survey number of 200 known landfills  these
200
                                                  '000 MTY would  replace the
C.   Demand Effects

tl iHe? vU?es  P™art6offth-  Vari°US  "^tri.l.H.^"?; Je 1dan-
tidi  activities.   Part of  this may occur as the disposal costs ar-P

internalized into various  operations which then independently adjust







     2di.n^!i^n!td Resource gP^VPry.   The combined forces of higher
      H 3!S   J-     • '  "Increased Petroleum cost, and concern over pos-
                               -81-

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                            TABLE 24
TPPNH IN MIXED-WASTP PFSnilRCE RECOVERY FACILITIES IMPLEMENTATION
Facility Status
Operational
Under Construction
Advanced Planning9
Feasibility Studies'3
Total :
1974
15
- 7
23
25
70
1975
19
8
30
37
94
1976
21
10
33
54
118
 a    Advanced planning = request for proposals issued, final design
      underway and/or funding authorized.
 b.   Feasibility studies - expressed interest in or undertaken informal
      studies.
 Source:  Reference 37.
  The 21 operational  sites  used  the following  range  of  conversion/recovery
  processes:
                              TABLE 25
     CONVERSION T.Fr.HNOLOGIES AT  EX™TTNB RFCOVERY FACILITIES^1976
  Process
    Waste—-^Steam via Combustion
   . Waste-*Refuse Derived Fuel
   . Materials  or Gas Recovery
   . Compos t-^-Humus
   . Waste-^Gas via  Pyrolysis
No. of
Sites
13
4
2
1
1
Average Capacity/
Site (tons/day)
645
235
150a
200
200
   a    Materials recovery plant only; methane recovery plant operated at
        existing Mndfills and therefore had no tons/day figure.
   Source:   Reference 37.
-82-

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  The average capacity figure  for  the  steam-generating plants  is arti-
  ficially lowered  by demonstration-size  plants  (in the 20-50  TPD range)-

  inetheei1ooVal?efinnrTp!!e  6  lar9^  s1t«s  1s 9i° tons/da* wiih 3 s?te  '
  in  the 1,200 -  1,600 TPD range.   Plants  in the 1,200 TPD range are all
  located within  metropolitan  areas.   Such facilit es need a sirvicl area
  population  of about 500,000  in order to maintain that averagfflS
  IZn?™ •    averase size  of plants  under construction and in advanced
  nifn   oL'l  eyen  larger.   A  higher portion of these facilities will be
  usmg  RDF technologies, generally in combination with metal and
                      9eneration of steam via combustion is still
         n        C°.StS 2f many of these Plants are;rather high - up to
         PA^dail£ t0,n of capacity for P^nts completed in the 1974-1976
 laroe seal!  ^°hna?d ?i0nal ?XPerience in ^ing these technologies In
 large-scale (vs. pilot) operations may lower these costs, the cost of
 oubficP a^-^Still,impl£ & ^-term commitment.   IteierShele s, many
 Eff  L™  pnvaX sect?r. observers feel that material and energy recovery
 will become a self-sufficient reality in the United States.   Their
 S ;1r°?-.are -aS^d °n the lon9 histor^ of successful  operation of
 such facilities in Europe and elsewhere, and the fact that private
 investment has begun to occur in  the field.                 private
 no,. !he adde? C°StS °f RCRA wil1  encourage  this  trend,  especially  in or
 near large urban areas  where suitable  landfill  sites  are scarce and
 expensive and the waste density exists  that  is  necessary for"  "rge  scale
 recovery plants.   Much  of this  same  type  of  activity  will, of course
 occur in the industrial  sectors that also face  similar d spSsal colt"
 increases.   In combination with waste reduction,  energy  and material
 thP°Le^ ^hn1?r  w111  be aPP^ed  more  frequently,  depending on (1)
 the  market  for the recovered materials, within  or outside the firm   b)
 the  incremental  production costs of  the recovery  processes! and (c) the
 regional  costs of electricity and  other energy  forms

  ..u  ?*   Qtner Legal Waste Disposal Methods.   Other legal disoosal
 "f!^df  thatiW1"  l°nti?Ue ^° ex1st  after  implementation9'! thePGu?de-
 lines are volume  reduction  with disposal of residues), surface im-
 poundment   and  landspreading.  The costs of the latter two will  ITso be
 affected by RCRA,  as Guidelines for  surface Impoundments and  andspreadlnq
 nn?^ncUh   -n5er.SeCtl^n 10°8'  Decisions concerning waste dispS      9
 options by  industry and municipalities will change to reflect the  costs
 of these options after all  the Guidelines are issued.   Since the costs
                   lmP°undl"?nt and landspreading activities are not yet
                   '?p°slblto sa^ how the increases  in  the cost  of

                                                  the  Ch°ice °f
+    4<   Illegal  Dumping.    One option that is  unfortunately  available
n? ??S°rS a"5  Iandf1i!  °Perators is ^e continued  use  or o?e?ation
of illegal  open dumps.   The enforcement problem  will be most severe  for
the thousands of very small sites in rural  areas that  would f"e leVy
large increases in disposal costs under the RCRA Guidelines, even  if
                               -83-

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they were to implement the most cost-effective combination of site and
collection consolidation.  The enforcement costs for such operations,
due to their geographic dispersion, small sites, and overall detection
difficulty, will be rather high as well, forcing agencies to concentrate
onlv on large sites.  An enforcement management system would have to be
developed that could maximize the return on resources spent on enforce-
ment by taking into account such considerations as ground water con-
ditions, landfill size, waste types handled, and enforcement staff
constraints.
                                 -84-

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              VIII.  IMPACT OF THE GUIDELINES ON ENERGY USE
 A.    Background
      Guidelines implementation will result in increased energy con-
 sumption for both the construction (involved in upgrading) and operating
 phases of landfill operations.  Construction energy use will  increase
 due to the requirements for improved levels of environmental  protection
 with the concommittant use of more complex technologies such  as liner
 installation,  gas venting and collection systems,  leachate collection
 and treatment  systems, etc.   Similarly,  energy use associated with the
 operating phase will  increase due to energy requirements for  leachate
 pumping, more  frequent cover application,  etc.   As previously referenced,
 Table 2 presents those technologies which  have  been defined as required
 upgrading technologies for existing landfills and  which will  result in
 increased construction'energy use.   Similarly,  Table 26 indicates  those
 technologies which will  result in increased energy use  associated  with
 landfill  operation.                                  :


 B-    Estimating  Construction Energy Impacts


      Data detailing construction  energy  use (gasoline,  oil, diesel  fuel,
 electricity) for construction of  landfills  are  currently unavailable.
 To  estimate the  potential  increase  in  construction  energy use,  the
 assumption has been made  that increased  energy  use  is directly  propor-
 tional  to increased capital  expenditure.  The baseline  costs  for exis-
 ting  landfill operations,  as  previously  developed  in Section  III are
 $11.15,  $6.65 and  $3.95 per  ton for 10 TPD,  100 TPD and  300 TPD facil-
 ities,  respectively.   Approximately 25 percent  of  those  costs are
 attributable to  construction  costs,  as follows:  10 TPD  -  $2.78: 100
 TPD - $1.66; 300 TPD - $0.99.

      By utilizing  capital  upgrading  costs for the technologies iden-
 tified  in  Table 2, total upgrading  capital  costs can be  determined.
 Table B-l  (see Appendix B) presents  the  capital costs for  those up-
 grading technologies to be incorporated  into existing facilities.  Table
 27 converts the total   upgrading technology  capital  costs developed in
Appendix B to unit costs,  and sums  the unit costs of the appropriate
 technologies by landfill type, size, and site sensitivity.  This yields
 increased  capital costs per ton.  Increased construction energy use has
been assumed to be proportional to  increased capital costs of the re-
quired upgrading technologies.  Table 27 also shows the per cent increase
in construction energy use for upgraded facilities.  Consumption use is
expected to be primarily in the form of gasoline, oil, and diesel  fuel
utilization.
                               -85-

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                           TABLE  26
        UPGRADING TECHNOLOGIES  RESULTING IN INCREASED
        '	ENERGY OPERATING COSTS
Municipal
                     SENSITIVE FACILITIES


                        Industrial	
                                              Pollution Control
                                                   Residues
Groundwater Water   Impermeable Daily
Quality Monitoring  Cover
Gas Monitoring
                Groundwater Water
                Quality Monitoring
Impermeable Daily Cover


Groundwater Water Quality
Monitoring
                  NONSENSITIVE FACILITIES
Groundwater Water   Impermeable Daily
Quality Monitoring  Cover
Gas Monitoring
                 Groundwater  Water
                 Quality Monitoring
Impermeable Daily Cover


Groundwater Water Quality
Monitoring
 i.   Daily cover assumed as existing technology;  no increased energy use.
                                    -86-

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                                                         TABLE 27
oc>
~^J
I



Municipal
Sensitive
Nonsensitive
Industrial
Sensitive
Nonsensitive
IN CONST
10 TPD
Increased Capital
Cost/Ton

$3.99
1.49

2.62
0.22
'RUCTION ENERGY

% Increase9

144%
54%

94%
8%
USE FOR UPGRADED FAC
100 TPD
Increased Capital
Cost/Ton %

$0.93
0.33

0.62
0.07
-ixi iiiontHc
ILITIES

Increase9

56%
20%

37%
4%
>L
300 TPD
Increased Capital
Cost/Ton %

$0.51
0.17

0.35
0.05




52%
17%

35%
5%
Pollution Control
Residues
Sensitive
Nonsensitive

2.62
0.12

94%
8%

0.62
0.02

37%
1%

0.35
0.01

35%
1%
         a.    Baseline  construction  costs:   10 TPD,  $2.78;  100 TPD, $1.66; 300 TPD, $0.99

-------
C.   Estimating Operating Energy Impacts
     Table 26 lists upgrading technologies which will .^sult in in-
creased energy use during landfill operation.  For existing facilities
thHrin^y energy consuming technology is that of impermeable cover.
It has been assumed that municipal facilities for both sensitive^
nonsensitive areas apply daily cover.  Consequently, energy costs will
mt iScreast  For the remainder of the waste types, it has been assumed
that daily cover is not a common practice and that impermeable cover
application is energy intensive,.  A 100% increase in energy Requirements
for those sites which currently do.not ?PPly.daily cover might be a
reasonable estimate.  Consumption is primarily in the area of gasoline and
diesel fuel.
                                        -88-

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                            REFERENCES CITED
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8.
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                              -89-

-------
15.  Office of Solid .Waste.   Assessment of industrial  hazardous waste
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26.  Brown, J.A., ed.  Proceedings of the American Defense Preparedness
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                                    -90-

-------
  27.
  28.
 29.
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 Chemical Propulsion  Information Agency.  Environmental  impact
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 Development Planning and Research Associates, Inc.  .Economic impact
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 Processes Research   inc.  Alternatives for hazardous waste management
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                               Final reP°rt; demonstration/instructional
    «M™nn  M           assistance in hazardous waste management.
  Washington, U.S. Environmental  Protection Agency,  1977.   Various  pagings.

Energy Resources Company Inc.   Potential  costs to coal-fired generating
  Actnof 1976°mPaWith ^ ReSOUrCe  Co"servation and  Recovery
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 33'  Sh^hS;^'u??5i5;5-c^!?!?eA,^S!!nS of..^.United  States.   U.S.
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 35.   New York  State Department of  Environmental Conservation. Draft
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 36'   DeYaonrk"'fhe>rerfceLn! li/O^  SPat1al eco"°-^heory.  New


 37'   0fJ±<.Jfj2ll2 ?aS!e:_..ResourSe recoyery_and waste reduction;
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 38.   U.S.  Office of Management and Budget,  Statisitcal  Policy Division
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39'   F1Inc!,Ri977Glap1892and guaternary Seology.  New  York,  John Wiley & Sons,

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                                   -91-

-------
                          BIBLIOGRAPHY
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Arthur D. Little, Inc.  Integrated economic impact assessment of hazar-
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Battelle Columbus Laboratories.  Final report; assessment of industrial
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Battelle Columbus Laboratories.  Final report; assessment of industrial
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Bendersky, D.  Resource recovery from municipal wastes ~ a review and
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Bond, R.6., and C.P.  Straub.
  II.  CRC Press, 1972.
Handbook of environmental control; vol.
 Booz-Allen  &  Hamilton,  Inc.   Cost  estimating  handbook  for transfer,  shredding
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 Brown,  J.A.,  ed.   Proceedings of the American Defense  Prepardeness Assoc-
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 Brunner,  D.R.,  and D.J. Keller.  Sanitary landfill  design and operation.
   Washington, U.S. Environmental Protection Agency,  1972.   59 pp.

 Calspan Corporation.   Assessment of  industrial hazardous waste  practices
   in the metal  smelting and  refining  industry, 3  vol.   Washington, U.S.
   Environmental Protection Agency, 1977.

 Chemical  Propulsion Information Agency.   Environmental impact considerations
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   Johns Hopkins University,  undated.   Unpaged.
                                    -92-

-------
 Ctuan, E.S.K., and F. DeWalle.  Evaluation of  leachate treatment, vol. II;
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 Dean, R., W.  Leahy, and D. McKee.  Spatial economic theory.  New York
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 Department of Natural Resources, State of Wisconsin.  Solid waste manage-
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 Development Planning and Research Associates, Inc.  Economic impact analysis
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 Engery Resources Company Inc.   Potential  costs to coal-fired generating
   pia™of comPliance with the Resource  Conservation and Recovery  Act
   of 1976.   Unpaged.                                              J

 Flint, R.F.   Glacial  and quaternary geology.   New York,  John Wiley  & Sons,
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 Foster D. Snail,  Inc.   Final  report;  assessment of industrial  hazardous
   waste  practices,  rubber and  plastics  industry;  executive summary
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 Fred C.  Hart Associates,  Inc.   Final  report;  demonstration instructional
   materials  for technical  assistance  in hazardous  waste management.   Washington,
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 Geswein, A.J.   Liners  for land disposal sites;  an  assessment.   Environmen-
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 Goldberg, T.L.  Improving  rural solid waste management practices.  Environ-
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 Goodwin, R.H., and W.A. Niering.  Inland wetlands  of the United States-
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 Hickman, H.L., Jr.  Solid waste management.  District Heating, 57 (!)•
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Jacobs Engineering Co.  Assessment'of hazardous waste practices in the
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  Agency, 1976.  353 p.

Jones, J   Disposal  of power plant wastes.   Washington, U.S. Environmental
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Kruth, M.A., D.H.  Booth, and D.L.  Yates.   Creating a countywide solid
  waste management system; the  case  study  of Humphreys County,  Tennessee
  Environmental Protection Publication SW-110.   Washington, U.S  Govern-'
  ment Printing Office, 1972.   15  p.
                                  -93-

-------
Madison study focuses on financial aspects of landfilling milled trash.
  Solid Wastes Management, 17(2.):30  (4 p.).

Mantel!, C.L.  Solid wastes; origin, collection, processing and disposal.
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McGuiness, C.L.  U.S. Geological Survey Hydrologic Atlas 194.  Washington,
  U.S. Department of the Interior, 1964.

National Center for Resource Recovery, Inc.  Sanitary landfill:  a state-of-
  the-art study.  Lexington, Mass., 1974.  119 p.

Neely, G.A.  Landfill planning and operation.  American Public Works
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New York State Department of Environmental Conservation.  Sanitary
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New York State Department of Environmental Conservation.  Solid waste
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Newest homes in town border on the landfill.  Solid Wastes Management
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Office of Management and Budget, Executive Office of the President of the    :
  United States.  Standard industrial classification manual, 1972.
  Washington, U.S. Government Printing Office, 1972.  649 p.

Office of Solid Waste.  Assessment of industrial hazardous waste prac-
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  Washington, U.S. Environmental Protection Agency, 1976.  Various pagings.

Office of Solid Waste.  Assessment of industrial hazardous waste practices:
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  tions, and factory application of coatings.  Washington, U.S. Environ-
  mental Protection Agency, 1976.  296 p.

Office of Solid Waste.  Cost estimating handbook for transfer, shredding
  and sanitary landfill ing of solid waste.  Environmental Protection
  Publication SW-124c.  Washington, U.S. Government Printing Office, 1976.
  77 p.

Office of Solid Waste.  Decision-makers guide in solid waste management.
  Environmental Protection Publication SW-500.  Washington, U.S. Govern-
  ment Printing Office, 1976.  158 p.

Office of Solid Waste.  Draft environmental impact statement; proposed      ;
  criteria for classification of solid waste disposal facilities.
  Washington, U.S. Environmental Protection Agency, April 1978.

Office of Solid Waste.  Resource recovery and waste reduction; fourth report
  to Congress.  Report SW-600.  Washington, U.S. Environmental Protection
  Agency, 1977.
                                 -94-

-------
 Office of Solid Waste.  Solid waste facts.
   Protection Agency, May 1978.  13 p.
Washington, U.S. Environmental
 Office of Solid Waste Management Programs.  Disposal of sewage sludge into
   Office      ^1"  Report SW"71d'  Washington, U.S. Government Printing
 Office of Solid Waste Management Programs.  Assessment of industrial
   hazardous waste practices, inorganic chemicals industry.  U.S. Environ-
   mental Protection Agency, 1975.  Various pagings.

 Office of Solid Waste Management Programs.  Evaluation of solid waste
   baling and bale-fins, vol. 1., v.d.  Environmental Protection Publication
   iw-iiic.i.  Washington, U.S.  Environmental Protection Agency, 1975.  153 p.

 Processes Research,  Inc.  Alternatives for hazardous waste management
   in the organic chemical pesticides and explosives industries.
   Washington,  U.S.  Environmental Protection Agency, 1976.   Various
   pagings.

 The report  to  Congress; waste disposal practices and their effects  on
   groundwater.   Washington,  Office  of Water Supply and Office  of Solid
   waste,  U.S.  Environmental  Protection Agency,  January 1977.   512 p.

 Rossoff,  J., et al.   Disposal of by-products from nonregenerable flue
   gas  desulfunzation systems:   second progress report:  Washington,  U.S
   Environmental  Protection Agency,  May 1977.  278 p.

 SCS  Engineers.   Assessment of industrial  hazardous  waste practices  —
   leather tanning and finishing  industry.   Washington, ^U.S. Environmental
   Protection Agency,  1976.   233  p.

 Sather, J.H. ed.  Proceedings of the  National Wetland  Classification  and
   ^"f^o^Wo^shop,  University of Maryland, College  Park, Maryland,
   • ,"& •     '   9 5*   Washin9ton,  U.S.  Department  of Interior, Fish  and
   Wildlife Service, Office of Biological Services  (conducted by  the
   Wildlife Management Institute), July 1976.  248 p. plus Addendum.

 Schalit,  L., et al.   Hazardous solid  waste  streams  from organic  chemicals
   manufacturing and related  industries.  Cincinnati, U.S. Environmental
   Protection Agency,  undated.  Various  pagings.

 Shaw, S.P., and C.B.  Fredine.  Wetlands of  the United States.   U.S
   Fish and Wildlife Service Circular 39.  Washington, U.S.  Government
   Printing Office, 1956.  67 p.

 st°nf' R.S., and R.  Kahle.  Evaluation of solid  waste baling and land-
  filling.  Journal  of the Environmental Engineering Division,  (103):
  557-571.                                             .
Thompson, B., and I. Zandi.  Future of sanitary landfill.
  the Environmental Engineering Division, EEI (101):41-54.
              Journal  of
                                     -95-

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U.S. Department of Commerce, Bureau of the Census.  Statistical  abstracts
  of the U.S.; 98 annual edition.  Washington, U.S. Government Printing
  Office, 1977.

U.S. Department of Energy, Office of Utility Projections.  Inventory of
  power plants in the United States.  Washington, U.S. Department of
  Energy, 1977.  444 p.

U.S. Environmental Protection Agency, Effluent Guidelines Division.
  Technical report for revision of steam electric effluent limitations
  guidelines,  Sept. 1978.  532 p. plus Appendices.

U.S. Environmental Protection Agency.  Sanitary landfill:  Clark County,
  Arkansas.                                                        :.    •  -

Vevsar,  Inc.-   Draft report; alternatives for hazardous waste management
  in the  inorganic chemicals industry.  Washington, U.S. Environmental
  Protection Agency, 1977.  Various pdgings.

WAPORA,  Inc.   Assessment  of industrial hazardous  waste practices —
  electronic  components manufacturing industry.   Washington, U.S.  Environ-
  mental  Protection Agency, 1977.   145 p.  plus Appendices.

WAPORA,  Inc.   Final report; assessment of  industrial  hazardous waste
  practices — special  machinery manufacturing industries.  Washington,
  U.S.  Environmental Protection  Agency, 1977.  230  p. plus Appendices.   ,

Water  Resources Council,  Executive  Office  of  the  President of the
  United States.   The  nation's water  resources; the second national
  water assessment by  the U.S. Water  Resources Council;  review copy;
  summary report.   Washington, March  1978.  52 p.

Wilson,  D.G., ed_.   Handbook of  solid  waste management.   New York,  Van
  Nostrand Reinhold Company,  1977.   752  p.

Winfrey, A.J.  Financing solid waste  services;  solid waste management
   guide.  Division of  Solid Waste  Disposal, Kentucky State Department
   of Health,  May 1972.  41 p.

 1977 update for land disposal  practices  survey.   Waste  Age, January 1978.
   6 p.
                                   -96-

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                     PERSONAL COMMUNICATIONS
Anderson, W., Pickard and Anderson, Inc., June 1978.                  i

Federal Insurance Administration, Flood Insurance Program, Philadelphia,
  August 1977.                                         ;            H

Fogg, C., U.S. Department of Agriculture, Soil Conservation Service,
  Environmental Services Division, Washington, September 22, 1978.

Grant, J., Director of Government Affairs, Printing Industries of
  America, Washington, October 11, 1978.

Kohler, M., U.S. Department of Interior,  Fish and Wildlife Service,
  Washington, May 31, 1978.

Sanislow, J., Division Representative,  New York City,  Army Corps  of
  Engineers, Emergency Operations Branch, September 22,  1978.

Schreiner, K., Official  Contact,  U.S.  Department of Interior,  Fish and
  Wildlife Service,  Office of Endangered  Species, Washington,  September 29
                                -97-

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         APPENDIX A





SAMPLE BASELINE COST CURVES

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                                 FIGURE Al
                             SANITARY LANDFILL COSTS
            PIECE OF EQUIPMENT
                  2 PIECES OF EQUIPMENT
                                 3 PIECES OF EQUIPMENT
                                                        4 PIECES OF EQUIPMENT
               40      60     80      ICO      120     140     160
                  WASTE QUANTITY - THOUSAND TONS PER YEAR
180
200
Source:  Reference  3.

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                                          FIGURE   A2

          ESTIMATED SANITARY  LANDFILL  OPERATION  AND MAINTENANCE  COSTS
                $3,50
                                                           D    One dozer operating
                                                           20   Two dozers operating
                                                           OS   Dozers and scraper
                                                           ORS  Dozers, ripper, scrcpsr
                                                               Esiimcted by others
                                                               for Denver crea
I                                                            Maximum, overage and
                                                            minimum costs based on
                                                            characteristics of sites
                     0          20O         4OO.         600         80Q         K3OO
                            Filling  Rale, Tons  per  Average  Working Day
             Note : Chart shows how cost of ownership- and operation of equipment relates to the
             required filling rate.
Source:   Reference  7.
                                               A-2

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                                    FIGURE  A3

                              TYPICAL  LANDFILL  COSTS
             4.00
             3.00 *
             2.00 *
             1.00 -
   Tons Per Year
   Tons Per Day8
   Population15
 100.000
   320
 122,000
                      200,000      300,000       400,000
                        640          960          1280
                      244,000      366,000       488.000
3 Based on 6-day work week.
bBased on national average of 4.5 Ibs per person per calendar day.
500.000
 1600
610,000
Source:    Reference  2.
                                   FIGURE  A4

                    SANITARY  LANDFILL OPERATING COSTS
                           12
§ 10
                        c:
                        £-
                        VI
                        O
                        o
                        Q
                        I
                                      ADD TRANSPORTATION
                                      COST FOR TOTAL COSTS
                                               LANDFILL COSTS
                            TRANSFER-STATION
                            COSTS:
                            MILLED
                            BALED

                            UNPROCESSED
                                 _L
               _L
                                 200    400    600    800
                                 SOLID-WASTE FLOW, TONS/DAY
                                  1000
Source:   Reference  8.
                                       A-3

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              APPENDIX B



UNIT COST CALCULATIONS AND ASSUMPTIONS

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      For the  purposes  of developing  final  upgrading  unit  costs  a  cal-
 culation methodology was adopted  which  was similar in  approach  to the
  Draft  Environmental Impact  Statement Criteria  for Classification of
 Solid Waste Disposal Facilities." Major assumptions are  as  follows:

           Utilization  of 10  TPD,  100 TPD,  and 300 TPD  sites
           Corresponding  total  acreages  of  6  acres, 28  acres
           and  75  acres respectively
           Corresponding  total  perimeter lengths of 2,000  ft., 4,400 ft
           and  7,200  ft.  respectively
           260  days operation per  year
           In place refuse to soil cover rations of 1:1, 2:1  and 3:1
           respectively
           26,000, 260,000 and  780,000 total  ten year life capacity
           for  10 TPD,  100 TPD  and 300 TPD  facilities respectively

More  detailed  assumptions for  the selected and alternative upgrading tech-
nologies are as follows:

VERTICAL IMPERMEABLE BARRIER

           20'  depth, 60 cu.  ft./ft.  perimeter installation
           excavation @ $0.50/cu. yd., clay material  @ $3.00/cu.  yd.,
           placement @ $0.30/cu. yd.
           total unit cost $17.00/ft.     ($55.76/meter)

DIKE CONSTRUCTION

           10'  depth, 567 cu.  ft./ft.
          3:1  slopes
          materials and placement @  1.50 cu. yd.
          total unit cost $31.50/ft.    ($103.32/meter)

IMPERMEABLE DAILY COVER (ON-SITE SOURCE)

          total unit cost $0.60/cu. yd.    ($0.78/cu.  meter)

IMPERMEABLE DAILY COVER (OFF-SITE  SOURCE)             '.

          transport (? $1.00/cu. yd.,  clay material @  $3.00/cu. yd.
          placement @ $0.30  cu. yd.
          2 mile average  transport distance
          total unit cost $4.30/cu. yd.    ($5.62/cu.  meter)
                               B-l

-------
PONDING
          2" 24 hr. rainfall event
          runoff storage required for twice the site landfill  area
          excavation @ $0.50/cu. yd. (0.65/cu. meter) land @ $3,000/acre
          ($7,410/hectare)                                  rl  .   ^
          10 TPD, 0.4 acres, 5' depth; 100 TPD, 1.85 acres, 5'  depth;
          300 TPD, 2.5 acres, 10' depth
PERIMETER GRAVEL TRENCHES
          20' depth, 60 cu. ft/ft, perimeter installation
          excavation @ $0.50/cu. yd., gravel material @ $4.00/cu. yd,
          placement @ $0.30/cu. yd.                       .   .
          total unit cost $21.00/ft.   ($68.88/meter)
GAS COLLECTION
          perimeter installation
          total  unit  cost @ $20.00/ft for 10 TPD and 100 TPD sites,
          $15.00/ft for  300 TPD sites ($65.60/meter, $65.60/meter,
          $49.20/meter respectively
          Annual  operating costs  for 10 TPD, $4,000; 100 TPD, $8,800;
          300  TPD, $10,800
 SYNTHETIC LINER
           total  unit costs  including  site  preparation  and earth cover
           $3.60/sq.  yd.    ($4.31/sq.  meter)
 LEACHATE RECYCLING
           30" infiltration/year.
           10 TPD, $6,000 piping,  $2,000 pump station,  $500  annual  costs;
           100 TPD, $13,200 piping, $4,000 pump station,  $1,000  annual  costs;
           300 TPD, $21,600 piping, $10,000 pump station, $2,000 annual  costs
 DITCHING
           total unit cost $2.25/ft.   ($7.38/meter)

 FINAL IMPERMEABLE COVER (QN-SITE SOURCE)

           unit cost $0.60/cu. yd. @ 2' depth

 FINAL PERMEABLE COVER (ON-SITE SOURCE)

           unit cost $0.50/cu. yd. @ 2' depth

 FINAL PERMEABLE COVER (OFF-SITE SOURCE)

           unit cost $1.75/cu. yd. @ 2' depth

 REVEGETATION
($5.62/cu.  meter)



($0.65/oi.  meter)



($2.29/cu.  meter)
            total  unit  cost $l,000/acre    ($2,471/hectare)
                              B-2

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      The following table presents the development of technology unit
 costs in more detail:                                         yj
 GAS MONITORING

           10 TPD,  4 wells;  100 TPD,  8 wells;  300 TPD,  12  wells
           wells  @  $200/each,  labor @ $100/day
           sampling labor for  10 TPD, 4 man-days/year;  100 TPD
           8 man-days/year;  300 TPD,  12 man-days /year
           $1,000 monitoring. equipment

 6ROUNDWATER HATER  QUALITY MONITORING

           10 TPD,  3 wells;  100 TPD,  4 wells;  300 TPD,  7 wells
           quarterly sampling  @ $150/sample, $l,000/well
               ™9 7ab°r !°r  1° TPD'  5  man-days/year;  100 TPD, 4 man-days/year;
               TPD,  7 man-days/year @ $100/day

 NATURAL CLAY LINER (OFF-SITE  SOURCE)

           transport  @ $1.00/cu. yd.,  clay material @ $3.00/cu. yd
           placement  @ $0.30/cu. yd.                     .     •
           2-foot depth clay material
           2-mile average  transport distance
           total unit cost @ $4.30/cu. yd.   ($5.89/cu.  meter)

 LEACHATE COLLECTION  FACILITIES .
          ™nn 3d°Snn?0ll??tor p1p'e; 10° TPD' 14'300' collector pipe;
          300 TPD, 36,000' collector pipe
          100' collector pipe spacing plus perimeter
          total unit cost @ $7.00/ft.   ($22.96/meter)

LEACHATE MONITORING. REMOVAL AND TREATMENT

          6" infiltration/year,  450 gal /day /acre
          3.7*/cu. ft. respectively

PERMEABLE DAILY COVER (ON-SITE SOURCE)

          total unit cost $0.50/cu. yd.

PERMEABLE DAILY COVER (OFF-SITE SOURCE
                                          ($0.65/cu. meter)
                                               $0.30/cu.  yd,  placement
          @loS50/cu@  $°'75/CU- yd'
          1-mile  average  transport distance
          total unit cost $1.55/cu. yd.    ($2.03/cu. meter)
                                 B-3

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VERTICAL PIPE VENTS

          2 per acre § $2,000/vent

FIRE CONTROL

          one fire truck unit @ $1,000, $2,000, and $10,000 per site
          for 10 TPD, 100 TPD and 300 TPD sites respectively

ACCESS CONTROL

          perimeter installation
          total unit cost @ $12.00/ft.    ($39.36/meter)

LITTER CONTROL

          litter control fencing, 130  ft., 280 ft. and 450 ft. per
          10 TPD,  100 TPD and 300 TPD  sites  respectively @ $10.00/ft.
          ($32.80/meter)
 COMPACTION
           one machine @ $50,000
                                      B-4

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                                                                      TABLE Bl
                                                          UNIT  COSTS OF CONTROL TECHNOLOGIES
Technology
Vertical Imper-
meable Barrier
Dike Construction
Impermeable
Daily Cover (on-
site source)
Impermeable
Daily Cover (off-
site source)
Ponding
Gas
Monitoring
Groundwater Water
Quality Monitoring
Gas Collection
Facilities

Site Size
10 TPD
100 TPD
300 TPD
10 TPD
100 TPD
300 TPD
10 TPD
100 TPD
300 TPD
10 TPD
100 TPD
300 TPD
10 TPD
100 TPD
300 TPD
10 TPD
100 TPD
300 TPD
10 TPD '
100 TPD
300 TPD
10 TPD
100 TPD
300 TPD


Unit Costs
$17.00/ft.
II
II
$31.50/ft.
n
-
-
$ 0.50/cu. yd.
II
II
$200/wel 1
II
II
$l,000/well
II
$ 20/ft.

Capital Costs
Quantity
2,000'
4,400'
7,200'
2,000'
4,400'
7,200'
-
-
3,200 cu. yd.
15,000 cu. yd.
40,200 cu. vd.
4
8
12
3
4
7
2,000'
4,400'
7,200'


Total Unit Cost
$ 34,000
74,800
122,400
$ 63,000
138,000
226,800
$0.60/cu. yd..
- "
$4.30/cu. yd.
"
$ 2,800*
13,000*
27,500*
$ 1,800** $100/day
2,600**
3,400** ."
$ 3,000 $150/sample
4,000 . . "
7,000
$ 40,000
88,000
144,000

o a M COSTS
Quantity

-
5,200 cu. yd.
26,000 cu. yd.
52,000 cu. yd.
5,200 cu. yd.
26,000 cu. yd.
52,000 cu. vd.

4 days/year***
8 days/year***
12 days/year***
3 days/year****
4 days/year****
7 days/year****



Yearly
-
-
$ 3,120
15,600
31,200
$ 22,400
111,800
223,60'0

$ 400
800
1,200
$2,100
2,800
4,900
$ 4,000
8S800
1/L 400


Present

_.
$ 19,200
95,800
mfion
$ 137,300
686,500
1,372 900

$2,400
4,900
7 4fif)
$ 12,900
17,200
so ion
$ 24,600
54,000
no /inn

Total Costs/Ton
(1977 dollars)
$ 1.30
0.30
01 r
$ 2.40
0.55
Don
$ 0.75
0.35
Oor
$ 5.30
2.65
1 7Z
$ 0.10
0.05
Onyi
$ 0.15
0.03
Om
.1)1
$ 0.60
o.io -
OflC
$ 2.50
0.55
.JU
        	 land costs
  ** includes equipment costs at $1,000
 *** 8 samples/well/year
**** 4 samples/well/year

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Technology
Natural Clay
Liner
Leachate
Collection
Leachate
Treatment
Permeable Daily
Cover (on-site
source)
Permeable Daily
Cover (off-site
source)
Vertical Pipe
Vents
Perimeter Gravel
Trenches
* trpflfmont 7 Hai/r i

Site Size Unit Costs
10 TPD $4.30/cu. yd.
100 TPD
300 TPD
10 TPD $7.00/ft.
100 TPD "
300 TPD "
10 TPD
100 TPD
300 TPD
10 TPD
100 TPD
300 TPD
10 TPD
100 TPD
300 TPD
10 TPD $2000 per
100 TPD »
300 TPD
10 TPD $21.00/ft.
100 TPD »
300 TPD "

Capital Costs
Quantity
19,350 cu. yd.
90,340 cu. yd.
242,000 cu. yd.
3,500'
14,300'
36,000'
-
-
-
12
56
150 ••
2,000'
4,400'
7,200'


Total Unit Cost
$ 83,200
388,500
1,040,600
$ 24,500
100,100
252,000
L0(f/gal.'
0.5
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TABLE Bl (CONTINUED)
Technology
Synthetic
Liner
Leachate
Recycling
— - — ' — 	 	 ,
Ditching
Final Imper-
meable Cover
(on-site source)
Final Imper-
meable Cover
(off-site source)
Final Permeable
Cover (on-site
source)
Final Permeable
Cover (off -site
source)
Revegetation

Site Size
10 TPD
100 TPD
300 TPD
10 TPD
100 TPD
300 TPD
10 TPD
100 TPD
300 TPD
i i n
10 TPD
100 TPD
300 TPD
10 TPD
-100 TPD
300 TPD
	
10 TPD
100 TPD
300 TPD
10 TPD
100 TPD
300 TPD
10 TPD
100 TPD
300 TPD


Unit Costs
$ 3.60/sq. yd.
II
II
$ 3.00/ft.
II
n
$ 2.25/ft.
II
"
$ 0.60/cu. yd.
$ 4.30/cu. yd.
II
II
$ 0.50/cu. yd.
II
II
$ 1.75/cu. yd.
II
II
$l,000/acre

Capital Costs
Quantity
29,040 sq. yd.
135,520 sq. yd.
363.000 sq. yd.
2,000'
4,400'
7,200'
2,000'.
4,400'
7.200J 	
19,360 cu. yd.
90,340 cu. yd.
242.000 cu. yd.
19,360 cu. yd.
90,340 cu. yd.
242,000 cu yd
19,360 cu. yd.
90,340 cu. yd.
242,000 cu. vd.
19,360 cu. yd.
90,340 cu. yd.
242.000 cu. yd.
6 acres
28 acres
	 75 acres
	 	 _. 0 & M COSTS
Total Unit Cost Quantity
$ 104,500
487,900
	 1,306,800
$ 8,000*
17,200*
31,600*
$ 4,500
9,900
16,200
$ 11,600
54,200
145,200
$ 83,200
388,500
1,040,600
$ 9,700
45,200
121,000
$ 33,900
159,000
423,500 -
$ 6,000
28,000
75.000 	 ^
reany Present Total Costs/Ton
CoStS_ Worth (1977 rinllarc)
$ 4.00
1.90
$ 500 $ 3,100 $ 0.45
1,000 6,100 0 10
2,000 12,300 0 05
$ 0.15
0.04
0.02
$ 0.45
0.20
0.20
$ 3.20
1.50
1.35
$ 0.40
0.15
— - — i — : 	 ^_ 0.15
$ 1.80
0.60
0.55
$ 0.25
0.10
	 	 - o.io

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Technology
Fire Control
Access Control
Litter Control
Compaction

Site Size Unit Costs
10 TPD
100 TPD
300 TPD
10 TPD $ 12.00/ft.
100 TPD "
300 TPD
10 TPD $ 10.00/ft.
100 TPD "
300 TPD
10 TPD
100 TPD
300 TPD
Capital Costs
Quantity
1
1
1
2,000'
4,400'
7,200'
130'
280'
450'
1
1
1

Total Unit Cost
$ 1,000
2,000
10,000
$24,000
52,800
86,400
$ 1,300
2,800
4,500
$50,000
50,000
50,000
0 & M COSTS
Yearly Present Total Costs/Ton
Quantity Costs Worth (1977 dollars)
$ 0.04
0.01
0.01
$ 0.90
0.20
0.10
$ 0.05
0.01
0.01
$ 1.90
0.20
0.05
no 1821
SW-754
*U S GOVERNMENT PRINTING OFFICE: 1980 341-082/136

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                             EPA  REGION
U.S. EPA, Region 1
Waste Management Branch
John F. Kennedy Bldg.
Boston, MA 02203
617-223-5775

U.S. EPA, Region 2
Solid Waste Branch
26 Federal Plaza
New York, NY 10007
212-264-0503

U.S. EPA, Region 3
Hazardous Materials Branch
6th and Walnut Sts.
Philadelphia. PA 19106
215-597-7370

U.S. EPA, Region 4
Residuals Management Br.
345 Courtland St., N.E."
Altanta, GA 30365
404-881-3016
U.S. EPA, Region 5
Waste Management Branch
230 South Dearborn St.
Chicago, IL 60604
312-353-2197

U.S. EPA, Region 6
Solid Waste Branch
1201 Elm St.
Dallas, TX 75270
214-767-2645

U.S. EPA, Region 7
Hazardous Materials Branch
324 East  11th St.
Kansas City, MO 54108
816-374-3307
U.S. EPA, Regions
Waste Management Branch
1860 Lincoln St.
Denver, CO 80295
303-837-2221

U.S. EPA, Region 9
Hazardous Materials Branch
215 Fremont St.
San Francisco, CA 94105
415-556-4606

U.S. EPA, Region 10
Waste Management Branch
1200 6th Ave.
Seattle, WA 98101
206-442-1250

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