Economic Impact Analysis (EIA) Small Municipal Waste Combustors, Emissions Guidelines And New Source Performance Standards


               United States
               Environmental Protection
               Agency
                   Office Of Air Quality
                   Planning And Standards
                   Research Triangle Park, NC 27711
EPA-452/R-00-OOI
May 2000
               Air
&  EPA
Economic Impact Analysis (EIA): Small Municipal
Waste Combustors-Emissions Guidelines and New
Source Performance Standards
                                                 U.S. Environmental Protection Agency
                                                 Region 5, Library (PI-12J)
                                                 77 West Jackson Boulevard, 12th Floor
                                                 Cnicago, IL 60604-3590

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In 1995, the U.S. Environmental Protection Agency (EPA) promulgated regulations
for municipal waste combustion units (MWCs). New Source Performance Standards (NSPS)
were-adopted for new MWCs (Subpart Eb) and Emission Guidelines (EG) were adopted for
existing MWCs (Subpart Cb). Litigation followed the promulgation of these regulations. In
1997, the U.S. Court of Appeals ruled that EPA must develop separate regulations for small
and large MWCs. The court indicated that the regulations adopted in 1995 were not
consistent with Section 129 of the Clean Air Act. In response to this ruling, EPA published a
Direct Final Rule on August 25,1997, amending the 1995 regulations so that they applied
only to large MWCs with an individual unit capacity greater than 250 tons per day (tpd).

As a result of these changes, regulations must be reestablished for small MWCs.
Small MWCs are those with an individual unit capacity between 35 and 250 tpd. Different
regulations with different subpart designations are being used for the small MWC rules.
Subparts Eb and Cb, as revised in 1997, will remain as regulations for the NSPS and EG for
large MWCs. Subparts AAAA and BBBB will be used for small MWCs.

This report provides the results of the economic impact analysis (EIA) of the
regulation for small MWCs under the new Subparts AAAA and BBBB regulations. This EIA
supercedes the March 1999 EIA that supported the August 30,1999, proposal of Subparts
AAAA and BBBB regulations for small MWCs. The principal difference between this EIA
and the earlier EIA (March 1999) is that an additional control alternative (Alternative I*) has
been considered. This EIA evaluates three control alternatives for existing MWCs
(Alternatives I, I*, n), using the same economic impact methodology used in March 1999.
This report describes the expected impacts of both the EG requirements on existing facilities
(Sections 1 through 5) and the NSPS on new facilities (Section 6).

In these regulatory alternatives for existing MWCs, the small MWC population was
subcategorized based on (1) aggregate capacity of the plant where the individual MWC unit
is located and, for some alternatives, (2) combustor type. The resulting subcategories are as
follows: (1) Class A units are defined as nonrefractory-type small MWCs located at plants

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with an aggregate capacity greater than 250 tons of municipal solid waste (MSW) per day; (2)
Class B units are refractory-type small MWCs located at plants with an aggregate plant
capacity greater than 250 tons of MSW per day; and (3) Class C units are small MWCs
located at plants with an aggregate plant capacity less than or equal to 250 tons of MSW per
day.
Under Regulatory Alternative I for existing MWCs, different air pollution controls are
required for the different MWC unit classes. Class A units would be required to implement a
technology with the performance characteristics of a spray dryer (SD)-based control system.
MWCs in Classes B and C would be. required to implement a technology with the
performance characteristics of a dry sorbent injection (DSI)-based control system. All three
classes would also be required to install fabric filters (FF) or electrostatic precipitators (ESP)
for metal and particulate matter controls, and carbon injection (CI) for mercury control.1
Class A units would also need to install selective noncatalytic reduction (SNCR) for
controlling nitrogen oxides (NOX).
Under Regulatory Alternative I* for existing MWCs, the stringency of Class B
control requirements is increased such that both Class A and B units would be required to
implement control technology with the performance characteristics of an SD-based control
system. Class C control requirements and CI and SNCR requirements are the same as under
Alternative I.
Under Regulatory Alternative n for existing MWCs, the stringency of Class C control
requirements is increased such that Class A, B, and C units would be required to implement
control technologies with the performance characteristics of an SD-based control system. CI
and SNCR requirements are the same as under Alternative I.
New MWCs are subject to the NSPS and will be required to install air pollution
control technologies with the performance characteristics of an SD-based control system.
Additionally, units located at MWC plants with an aggregate capacity greater than 250 tons
of MSW per day would also be required to install NOX control systems such as SNCR. No
other alternative is provided because this is the MACT floor performance level for new
MWCs.
'Refuse-derived fuel facilities do not require mercury (Hg) control by carbon injection, because they
have sufficient unburned carbon in the fly ash in the flue gases to control Hg and they meet the Hg emission
limits.

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Estimated total annual costs of the regulatory alternatives are about $50 million for
Regulatory Alternative I, $68 million for Regulatory Alternative I*, and $89 million for
Regulatory Alternative EL These costs are the worst-case (highest possible) social costs of
the regulation. These costs are based on the assumption that the minimum cost response of
all small MWC operators is to install the MACT controls. If another option would be less
costly, presumably the operator would select that alternative. One alternative is to close
down the MWC. This response may be particularly attractive if a small MWC is being used
in an application with a very low annual utilization factor (i.e., operates only 1 or 2 days per
week). Closing the facility will also have costs associated with it because another method
(e.g., landfilling) must be found to manage the solid wastes. However, when the cost of
landfilling is less than the cost of MWC operation plus compliance, facility closure is the
economic response to these regulations. If a facility closes down, the actual social cost of the
regulation will be less than what we estimate here, assuming that landfilling services are
appropriately priced. Available data indicate that since 1995 more than 30 percent of all
small MWCs have closed and these cities are using alternative disposal methods.

The social costs are distributed across the three ownership categories: business-
owned units, government-owned units, and units owned by nonprofit organizations. Under
Regulatory Alternative I, business-owned units will incur about $17.1 million, or 34 percent
of the total annual cost of the regulation. This cost increase averages $17.97 per ton of waste
combusted by the MWCs requiring a retrofit of an air pollution control device (APCD)
system. Government-owned units will incur annual incremental costs due to the regulation in
the amount of $32.2 million, or 64 percent of the total annual compliance costs. This is an
increase of $19.03 per ton of waste combusted for the affected sources. One nonprofit
organization owns two MWCs that will be affected by the regulation. These two units will
together incur annual incremental costs due to the regulation of approximately $0.7 million,
or 1 percent of the total annual compliance costs. This is an increase of $30.49 per ton of
waste combusted for these sources.
Under Regulatory Alternative I*, these costs are distributed as follows. Business-
owned units incur about $21.3 million, or 32 percent, of the total annual cost of the
regulation, representing an increase of $22.35 per ton of waste combusted. Government-
owned units will incur annual compliance costs in the amount of $45.5 million, or 67 percent
of the total annual compliance costs. This is an increase of $26.89 per ton of waste
combusted for the affected sources. The two MWCs owned by a nonprofit organization will
together incur annual incremental costs due to the regulation of approximately $0.7 million,

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or 1 percent of the total annual compliance costs, representing an increase of $30.49 per ton
of waste combusted.

Under Regulatory Alternative n, these costs are distributed as follows. Business-
owned units incur about $27.0 million, or 30 percent of the total annual cost of the regulation,
representing an increase of $28.30 per ton of waste combusted. Government-owned units
will incur annual compliance costs in the amount of $61.0 million, or 69 percent of the total
annual compliance costs. This is an increase of $36.04 per ton of waste combusted for the
affected sources. The two MWCs owned by a nonprofit organization will together incur
annual incremental costs due to the regulation of approximately $0.9 million, or 1 percent of
the total annual compliance costs, representing an increase of $41.79 per ton of waste
combusted.

The total cost of the regulatory requirements under the NSPS are estimated to be
$8.1 million annually for every new MWC in operation in the fifth year following adoption.
This cost averages to $51.66 per ton of waste combusted.

1. Affected Entities

MWCs are used to reduce the volume of MSW that must be transported and
landfilled. MWCs typically reduce the volume of waste by 90 percent, thereby extending
landfill life by a factor of ten. These combustors are not exclusively "municipal"; other types
of organizations might use them, either on a fee-for-service basis or as part of a captively
operated waste management activity designed to self-manage the waste generated by some
activity. Municipal waste typically refers to the type of waste being combusted and not to the
ownership of the MWC.
The small MWCs affected by the regulation are based on the 1998 national inventory
of small MWCs (Tucker, 1998). This inventory is an updated version of the 1995 inventory
(Cone and Kane, 1997). The update shows that since 1995 the number of small MWCs has
decreased by 37 percent (from 143 to 90), the number of plants by 37 percent (from 65 to
41 plants), and aggregate capacity by 38 percent (from 13,774 to 8,551 tpd).2 Of the
90 remaining units subject to regulation, 29 percent are owned by private businesses,
2An MWC plant typically has multiple units to increase operating flexibility. Most plants have two or
three units. The units are usually located beside each other and typically share common equipment such as
municipal waste pit, fuel feeding system, ash handling system, and stack.

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69 percent are owned by government entities, and 2 percent are owned by a nonprofit
organization (see Table 1). Government-owned entities include five units owned by the
federal government and 57 units owned by city/county governments. Based on the type of
combustor, the inventory consists of 31 mass burn units3 (44 percent of total daily capacity),
51 modular units4 (38 percent of total daily capacity), and eight refuse-derived fuel units5
(18 percent of total daily capacity) (Tucker, 1998).
Table 1. Distribution of Small MWCs
Nonprofit
Business Government Organization
Number of Plants
Number of Plants as a Share of
Total (%)
Number of MWCs at Plants
Number of MWCs as a Share of
Total (%)
Total Capacity (TPD)
Capacity as a Share of Total (%)
11
27%

26
29%

3,056
36%
29
71%

62
69%

5,423
63%
1
2%

2
2%

72
1%
Total
41

8,551

2. Affected Entities' Potential Responses to Regulation
Owners and operators of small MWCs that do not currently meet the MACT
standards must incur additional costs if they elect to continue to use their units. The extra
costs will include a one-time outlay for capital items (within 2 or 3 years after the standards
are in place) and annual expenditures for equipment operation and maintenance. These costs
3These include water wall, refractory, and rotating combustor units.

''These include starved and excess air combustor units.

5These include all units that use refuse-derived fuel.

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can be financed by diverting revenues from other applications, by borrowing, or by raising
prices or taxes as appropriate.

Faced with these costs, owners or operators may consider closing the facility. For
example, owners of MWCs located near landfills or with opportunities to construct a new
landfill may find that landfilling the entire volume of wastes that are now combusted costs
less than operating their MWC with the MACT APCD. Or they may institute or increase the
scope of recycling programs or source reduction programs to reduce the volume of waste to
be managed enough so that the unit can be closed. Several factors may affect these choices:

• institutional constraints, such as steam, electrical, or waste disposal contractual
obligations, may require continued operation of the MWC;
• costs of waste transport and disposal to landfills; and
• difficulty siting new waste disposal facilities resulting from "not in my backyard"
(NIMBY) attitudes in many communities.
A thorough analysis of the waste management choices would consider the benefits
and costs of all the substitute waste management alternatives. However, this requires
detailed information on the unique features of each of the facilities and, as such, is beyond
the scope of this analysis. Instead, this analysis uses a worst-case cost assumption: all
operators not currently in compliance with the standards are assumed to install the technology
needed to achieve the MACT requirements. Where substitution is less costly than
compliance, the assumption overstates, by an unknown amount, the cost of the standard.
Ratios are used to provide some insights regarding the relative cost burden imposed on these
operators.
3. Methods for Computing Cost and Emission Impacts
The key assumptions used in this economic impact analysis (EIA) are summarized in
Table 2. The no-substitution assumption implies that this analysis was conducted as if no
existing MWCs will close because of the regulation—the demand for combustion services
provided by these facilities was assumed to be perfectly inelastic (the demand curve was
assumed to be vertical; that is, rising cost/price of combustion leads to no change in the
quantity of combustion services demanded). The inelasticity could be due to the inelastic

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Table 2. Assumptions and Conventions
 Affected MWCs:  All MWCs with unit capacity between 35 and 250 tpd
 Monetary unit:  1997 dollars
 Capacity utilization rate: 85.49 percent (based on the average of capacity utilization
 rates per type of combustor, weighted by the percentage of the total capacity of such
 units in the inventory)
 No substitution in waste management; no facility closures (see text for discussion)
 Model plant assignment based on model plant combustion technology as reported in
 Table 3-4 (EPA, 1994), APCD at baseline as reported in Table 3-6 (EPA, 1994), and
 capacity as reported in Table 3-4 (EPA, 1994)
 Capital costs for each APCD:
    •   Incurred only at the outset of operation of the APCD
    •   Amortized over the lifetime of the APCD or the life of the plant, whichever is
        shorter
    •   Adjusted for capacity difference between actual and model plants using six-
        tenths rule
 Annual operating costs and revenues for each MWC and APCD:
    •   Invariant over the lifetime of the MWC or APCD with the exception of some
        performance, testing, and reporting costs
    •   Adjusted for capacity difference between actual and model plants
    •   Proportional to MWC capacity utilization (for analysis purposes if alternative
        capacity utilization rates are introduced)
 Required air pollution controls:
    •   PM/acid gas/metals (see text for discussion)
    •   NOX (see text for discussion)
    •   Hg (see text for discussion)
 Lifetime of physical equipment:
    •   Existing MWCs: 20 years after compliance costs begin
    •   APCDs: 20 years after compliance costs begin
 Market interest (discount) rate for annualizing capital costs:
    •   Public and nonprofit organization owners:  4 percent real municipal revenue
        bond rate
    •   Private owners:  7 percent real cost of capital rate/as recommended by the Office
	of Management and Budget (OMB, 1992)

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demand for waste management services per se,6 coupled with limited alternatives for waste
disposal due to either economic conditions or institutional arrangements that do not allow for
substitution in waste management. Thus, this no-substitution assumption is a worst-case cost
scenario because it leads to projections of higher national costs of control than are likely to
occur if there are less costly alternatives to compliance for some plants. That is, where
substitution is less costly than compliance it would be expected to be the MWC operators'
response of choice.

Where the baseline existing APCDs for MWCs do not meet the requirements of the
compliance alternatives, operators will have to install pollution control equipment for PM,
acid gas, metals, and Hg as required. This analysis examines three regulatory alternatives
beyond baseline.

Under Regulatory Alternative I, different air pollution controls are required for the
different MWC unit classes. Class A units would be required to implement a technology
with the performance characteristics of a SD-based control system. MWCs in Classes B and
C would be required to implement a technology with the performance characteristics of a
DSI-based control system. All three classes would also be required to install ESP or FF for
metal and particulate matter controls, and CI for mercury control.7 Class A units would also
need to install SNCR for the control of NOX.

Under Regulatory Alternative I*, the stringency of Class B control requirements are
increased such that both Class A and B units would be required to implement control
technology with the performance characteristics of a SD based control system. Class C
control requirements and CI and SNCR requirements are the same as under Alternative I.
Under Regulatory Alternative n, the stringency of Class C control requirements are
increased such that Class A, B, and C units would be required to implement control
^e elasticity of the demand for waste disposal services is not widely explored in the economics
literature. Although studies agree that the demand for solid waste disposal is inelastic, they do not agree on the
exact magnitude (Goddard, 1975; Hockett, Lober, and Pilgrim, 1995). The assumption of perfectly inelastic
demand for combustion services, while not too far from the truth for solid waste in general, simplifies the
computations and is a conservative assumption.

7Refuse-derived fuel facilities do not require Hg control by carbon injection, because they have
sufficient unburned carbon in the fly ash in the flue gases to control Hg and they meet the Hg emission limits.

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technology with the performance characteristics of a SD based control system. CI and SNCR
requirements are the same as under Alternative I.

This EIA assumes that all capital costs of control for each model plant are incurred on
the effective date of compliance and are amortized over the remaining plant life. Annual
operating and maintenance expenditures and annual recovery credits stay unchanged over the
remaining life of the equipment, and salvage value at the end of the cycle equals the cost of
removing the wom-out equipment and restoring the site. This EIA assumes that the
remaining plant life on the date of compliance is 20 years for existing plants and that the
pollution control equipment life cycle equals remaining plant life. Even though APCDs last
on average longer than 20 years, it was assumed that they will not be used beyond the
remaining life of the combustor. The cost inputs used in this EIA, reported in Tables 5-1
through 5-8 in Economic Impact Analysis for Proposed Emission Standards and Guidelines
for Municipal Waste Combustors (EPA, 1994), reflect the assumption of remaining plant and
APCD life of 20 years.

The interest rates used to compute the annualized capital costs of the regulation in real
terms are 4 percent for units owned by the government and nonprofit organizations and
7 percent for business-owned entities. These rates represent the real cost of borrowing
money to acquire financial capital.

3.1 Costs

To calculate the compliance costs of the regulation for individual MWCs, the model
plants were first mapped into the 1998 inventory: each actual facility was related to one
model plant developed by EPA.8 Control costs estimates developed for the model plants
were then scaled for their corresponding actual facility based on capacity ratios between the
two.

Affected entities incur two major types of control costs because of the regulation:
capital and operating costs. The capital cost is an initial lump sum associated with
purchasing and installing pollution control equipment. Operating costs are the annually
recurring costs, including costs associated with operating and maintaining the control
equipment, personnel training costs, and emission monitoring costs. Annual control costs
See Tables 3-4 and 3-6 in Economic Impact Analysis for Proposed Emission Standards and
Guidelines for Municipal Waste Combustors (EPA, 1994).

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consist of capital recovery costs and operating costs. Capital recovery costs are the costs of
installing the APCD annualized over the remaining plant life.

Based on Municipal Waste Combustion Study (EPA, 1987) and Municipal Waste
Combustors—Background Information for Proposed Standards: Cost Procedures (EPA,
1989), it was determined that the capital costs should be adjusted for capacity differences
between model plant units and real units using the six-tenths rule to reflect that, with
increasing capacity, capital costs, K, increase at a slower rate (i.e., economies of scale exist).
The six-tenths rule computes the capital cost for a given MWC unit from the appropriate
model plant as follows:
K
Actual Facility
CapacityActuaI Facility
CaPacityModel Plant
K,
'Model Plant
Operating costs include operating, maintenance, and supervision labor; electricity;
water and chemicals; waste disposal; overhead; and emissions monitoring costs, as well as
taxes, insurance, and general administration costs. Again, based on Municipal Waste
Combustion Study (EPA, 1987) and Municipal Waste Combustors—Background Information
for Proposed Standards: Cost Procedures (EPA, 1989), it was determined that operating,
maintenance, and supervision labor and overhead, which together account for 30 percent of
operating costs, do not vary with changes in capacity. The cost of electricity, chemicals,
water, and waste disposal, which together account for 30 percent of operating costs, vary
linearly with capacity. The costs of taxes, insurance, and general administration, which
together account for 40 percent of operating costs, vary similarly to capital costs except that
they follow the seven-tenths rule. The adjusted operating costs, OP, become
OPActua. Facmty = °'30 ' OPMode. PUnt
plant
CapacityActual Facmty
CaPacityM
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The total annual compliance costs of the regulation, AC, for a given MWC unit are
calculated as follows:
AC =
K OP
where

AC = annual control cost, including annual capital recovery and annual operating
components;

K = capital cost of the required control option, incurred at the beginning of
period t;

r = real rate of discount (r = 7 percent for business-owned entities and
r = 4 percent for government-owned entities or entities owned by nonprofit
organizations) (see text in this section for a discussion of these
parameters);

t = estimated remaining life of the plant on the date of compliance (20 years);
and

OP = operating costs of the required control option less a credit for any avoided
operating costs associated with baseline APCD supplanted by more
stringent controls required under the regulation.

The aggregate costs of the regulation were then computed by summing across all the
individual affected MWC facilities in the 1998 inventory.

There is a lot of debate in the economics literature on which discount rate to use when
analyzing government programs. The general view is that whenever it is believed that the
mandated capital outlays displace other productive capital9 the proper rate of discount is the
one reflecting the opportunity cost of capital rather than the cost of consumption (Lind,
1990). Given the uncertainty about whether the required air pollution control equipment will
"implicit in this is the assumption that capital is in fixed supply, so investing in air pollution control
equipment crowds out investments in other sectors.

11
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displace capital or consumption expenditures, we assumed that it will displace investment
expenditures, which, if anything, will again overestimate the cost of regulation. The private
real discount rate of 7 percent was used to annualize the capital cost for private entities. It
reflects the real marginal pre-tax rate of return of an average private-sector investment and
the private cost of capital. This rate is recommended by OMB in "evaluating federal
programs whose benefits and costs are distributed over time" (OMB, 1992). The OMB
circular also allows for modification of the 7 percent rate when justified by certain
characteristics of the specific industry. Given the lack of data about rates of return on
investment in the industries operating MWCs, no such modification was undertaken in this
analysis. This rate differs from the one in Economic Impact Analysis for Proposed Emission
Standards and Guidelines for Municipal Waste Combustors (EPA, 1994), reflecting recent
developments in the economics literature discussed above. The public real discount rate of 4
percent reflects the cost of capital to government and nonprofit organizations. It is
approximated by the real municipal bond rate. This rate is the same as the one used in
Economic Impact Analysis for Proposed Emission Standards and Guidelines for Municipal
Waste Combustors (EPA, 1994).

Some costs were not quantified for this analysis:

• Operator training: Operator training and certification is essential to ensure proper
operation of MWCs in accordance with good combustion practices (GCP). The
annual cost of operator training is expected to be minor.
• Governmental administration and enforcement: Federal, state, and local
governments incur costs to issue permits, monitor performance, and enforce
compliance with current environmental regulations for new and existing MWCs.
The additional costs associated with administering and enforcing the regulations
were not quantified in this EIA but are addressed in the Information Collection
Request (ICR) for this rulemaking.
• Adjustment costs for displaced resources: Three types of costs may occur while
the economy adjusts to new regulations: underutilization of resources from lost
output, resource reallocation costs (such as moving to a new location), and the
operation of programs to help the unemployed. These costs were not quantified.
• Paperwork: No paperwork burden costs were estimated in this analysis beyond
the testing, reporting, and recordkeeping costs (see Tables 5-7 and 5-8 in
Economic Impact Analysis for Proposed Emission Standards and Guidelines for
Municipal Waste Combustors [EPA, 1994]).
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• Costs of controlling fugitive emissions: The costs to control fugitive emissions
were not included in this analysis.
3.2 Emissions
Emission factors (EPA, 1995) (expressed as emission per ton of MSW combusted
basis) based on the type of combustor, APCD at baseline, and APCD after retrofit were used
in conjunction with the annual amount of MSW combusted at each facility to compute the
baseline emissions and emission reductions. Aggregate emission reductions were then
calculated by summing across all of the facilities in the 1998 inventory.

4. Costs and Emissions Reduction: Emission Guidelines
The number of units, by type of ownership, that will be affected by each type of
emission control device is summarized in Table 3 for Regulatory Alternative I, in Table 4 for
Regulatory Alternative I*, and in Table 5 for Regulatory Alternative EL The annual control
costs for these units were computed using the model plant cost inputs listed in Tables 5-1,
5-3, and 5-4 in the Economic Impact Analysis for Proposed Emission Standards and
Guidelines for Municipal Waste Combustors (EPA, 1994). These costs are incremental to the
baseline levels. Figures 1, 2, and 3 show the distribution of all MWCs in the 1998 inventory
based on the increase in the cost per ton of waste combusted under Regulatory Alternatives I,
I*, and n, respectively. Table 6 provides the aggregate costs of the standard, about
$50 million annually for Regulatory Alternative I. As shown in Table 7, under Regulatory
Alternative I* the aggregate costs are $68 million. Table 8 indicates the aggregate costs of
Regulatory Alternative n are about $89 million. These costs are presented as the social cost
of the regulatory alternatives. However, as explained above, they represent a worst-case
(highest-cost) scenario because substitution (facility closure) was not evaluated. These costs
are distributed across the three ownership categories: business-owned units, government-
owned units, and units owned by nonprofit organizations.
4.1 Impacts on Business-Owned Units
Eleven private entities owning 26 MWCs are subject to regulation. Under Regulatory
Alternative I, business-owned units will incur about $17.1 million, or 34 percent, of the total
annual cost of the regulation. This cost averages to $17.97 per ton of waste combusted by
these sources. Under Regulatory Alternative I*, they will incur $21.3 million, or 32 percent,
of the total annual cost of the regulation. This is a cost of $22.35 per ton of waste combusted.
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Table 3. Distribution of Affected Units: Regulatory Alternative I (Existing MWCs)
Control System
Acid Gas/PM/Metals
Hg
NO,
Total Number of Units
Table 4. Distribution
Control System
Acid Gas/PM/Metals
Hg
NOX
Total Number of Units
TableS. Distribution
Control System
Acid Gas/PM/Metals
Hg -
NO,
Total Number of Units
Business
11
22
6
26
of Affected Units:
Business
15
• 22
6
26
of Affected Units:
Business
19
22
6
26
Government
38
58
4
62
Nonprofit
Organization
2
2
0
2
Total
51
82
10
90
Regulatory Alternative I* (Existing MWCs)
Government
45
58
4
62
Nonprofit
Organization
2
2
0
2
Total
62
82
10
90
Regulatory Alternative II (Existing MWCs)
Government
50
58
4
62
Nonprofit
Organization
2
2
0
2
Total
71
82
10
90
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Figure 1. Distribution of Annual Compliance Cost Per Ton of Waste Combusted for
Existing Small MWCs: Regulatory Alternative I
35 •,
30
40 45
$1997/ton
SO 55 60 65 70 75
Figure 2. Distribution of Annual Compliance Cost Per Ton of Waste Combusted for
Existing Small MWCs: Regulatory Alternative I*
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20 25 30 35 40 45 50 55 60 65 70 75 80
5 10 15
Figure 3. Distribution of Annual Compliance Cost Per Ton of Waste Combusted for
Existing Small MWCs: Regulatory Alternative II
Under Regulatory Alternative n, they will incur $27.0 million, or 30 percent of the total
annual cost of the regulation. This is $28.30 per ton of waste combusted by these sources.

Two general options are available to the operators of these facilities—pay these costs
out of revenues or pass them along to suppliers of inputs or purchasers of the commodity
produced at the facility. No formal attempt was made in this analysis to assess whether and
to what degree operators may be able to shift costs upstream to suppliers or downstream to
consumers. However, costs are expressed as a share of tipping fees. If a facility provides its
services for a fee, tipping fees are the price charged. The national average tipping fee is $57
in 1993 dollars (Berenyi and Gould, 1993), or $57.95 when expressed in 1997 dollars. The
average control cost represents 31 percent of tipping fees for business-owned units under
Regulatory Alternative I, 38 percent under Regulatory Alternative I*, and 49 percent under
Regulatory Alternative n. If there were full-cost pass through, which would require a
perfectly inelastic demand curve for waste combustion services, this would be the price
increase, obviously a very large amount.
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Table 6. Aggregate Costs: Regulatory Alternative I (Existing MWCs)
Ownership/Type
of Control
Business
Acid
Gas/PM/Metals
Control
Hg Control
NO, Control
Total Business
Percentage of
Total Annual
Regulatory Costs
Government
Acid
Gas/PM/Metals
Control
Hg Control
NOX Control
Total Government
Percentage of
Total Annual
Regulatory Costs
Nonprofit
Organization
Acid
Gas/PM/Metals
Control
Hg Control
NO, Control
Total Nonprofit
Organization
Percentage of
Total Annual
Regulatory Costs
Grand Total
Total
Capital Cost
($1997)

$70,528,076

$1,453,984
$9,053,560
$81,035,620

$110,441,464

$3,362,191
$4,360,142
$118,163,798

$2,101,438

$101,371
$0
$2,202,810

$201,402,227
Annual
Operating
Costs ($1997)

$7,334,187

$814,417
$1,333,349
$9,481,953

$19,708,494

$3,108,600
$694,233
$23,511,327

$443,966

$78,975
$0
$522,941

$33,516,221
Total Annual
Costs ($1997)

$13,991,539

$951,663
$2,187,941
$17,131,142
34.25%

$27,834,970

$3,355,996
$1,015,060
$32,206,026
64.38%

$598,593

$86,434
$0
$685,027

1.37%

$50,022,196
Annual Average
Enterprise
Costs
($1997/ton)

$14.67

$1.00
$2.29
$17.97

$16.45

$1.98
$0.60
$19.03

$26.64

. $3.85
$0.00
$30.49

$18.75
Projected
Avg.
Tipping Fee
Increase

30.93%

32.77%

52.50%

32.28%
17
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Table 7. Aggregate Costs: Regulatory Alternative I* (Existing MWCs)
Ownership/Type
of Control
Business
Acid
Gas/PM/Metals
Control
Hg Control
NO, Control
Total Business
Percentage of Total
Annual Regulatory
Costs
Government
Acid
Gas/PM/Metals
Control
Hg Control
NO, Control
Total Government
Percentage of Total
Annual Regulatory
Costs
Nonprofit
Organization
Acid
Gas/PM/Metals
Control
Hg Control
NOX Control
Total Nonprofit
Organization
Percentage of Total
Annual Regulatory
Costs
Grand Total
Total Capital
Cost ($1997)

$92,994,827.87

$1,453,984.42
$9,053,559.78
$103,502,372

$192,124,588

$3,362,191
$4,360,142
$199,846,922

$2,101,438

$101,371
$0
$2,202,810

$305,552,104
Annual
Operating
Costs ($1997)

$9,392,894.59

$814,416.78
$1,333,348.61
$11,540,660

$26,999,548

$3,108,600
$694,233
$30,802,381

$443,966

$78,975
$0
$522,941

$42,865,982
Total Annual
Costs ($1997)

$18,170,948.47

$951,663
$2,187,941
$21,310,552
31.57%

$41,136,411

$3,355,996
$1,015,060
$45,507,468
67.42%

$598,593

$86,434
$0
$685,027

1.01%

$67,503,047
Annual Average
Enterprise
Costs
($1997/ton)

$19.06

$1.00
$2.29
$22.35

$24.31

$1.98
$0.60
$26.89

$26.64

$3.85
$0.00
$30.49

$2530
Projected
Avg.
Tipping Fee
Increase

38.48%

46.30%

52.50%

43.56%
18
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Table 8. Aggregate Costs: Regulatory Alternative II (Existing MWCs)
Ownership/Type
of Control
Business
Acid
Gas/PM/Metals
Control
Hg Control
NO, Control
Total Business
Percentage of
Total Annual
Regulatory Costs
Government
Acid
Gas/PM/Metals
Control
Hg Control
NO, Control
Total Government
Percentage of
Total Annual
Regulatory Costs
Nonprofit
Organization
Acid
Gas/PM/Metals
Control
Hg Control
NO, Control
Total Nonprofit
Organization
Percentage of
Total Annual
Regulatory Costs
Grand Total
Total
Capital Cost
($1997)

$121,293,761
$1,453,984
$9,053,560
$131,801,305

$307,088,205
$3,362,191
$4,360,142
$314,810,539

$3,939,795
$101,371
$0
$4,041,166
$450,653,011
Annual
Operating
Costs ($1997)

$12,394,490
$814,417
$1,333,349
$14,542;255

$34,019,870
$3,108,600
$694,233
$37,822,704

$562,428
$78,975
$0
$641,403
$53,006,362
Annual Average
Enterprise
Total Annual Costs
Costs ($1997) ($1997/ton)

$23,843,763
$951,663
$2,187,941
$26,983,366
30.35%

$56,615,958
$3,355,996
$1,015,060
$60,987,014
68.59%
$852,325
$86,434
$0
$938,759
1.06%
$88,909,139

$25.00
$1.00
$2.29
$28.30

$33.46
$1.98
$0.60
$36.04

$37.94
$3.85
$0.00
$41.79
$33.32
Projected
Avg.
Tipping Fee
Increase

48.72%

62.05%

71.94%
57.37%
19
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4.2 Impacts on Government Entities

Twenty-nine government entities owning 62 MWCs that meet the 35 to 250 tpd size
criteria are subject to regulation under both scenarios. Under Regulatory Alternative I,
government-owned units will incur annual incremental costs due to the regulation in the
amount of $32.2 million, or 64 percent of the total annual compliance costs. This is an
increase of $19.03 per ton of waste combusted. Under Regulatory Alternative I*, the cost of
compliance for government units is $45.5 million, or 67 percent of the aggregate compliance
costs. This represents an increase of $26.89 per ton of waste combusted at these facilities.
Under Regulatory Alternative n, the cost of compliance for government units is
$61.0 million, or 69 percent of the aggregate compliance costs. This represents an increase of
$36.04 per ton of waste combusted at these facilities. The cost increases faced by
government units are higher than the increases business-owned MWCs will face because a
larger proportion of public MWCs will require a retrofit of their PM/acid gas/metals controls.
The tipping fee increase for government MWCs needed to cover these costs, analogous to the
one for business-owned units, is 33 percent under Regulatory Alternative I, 46 percent under
Regulatory Alternative I*, and 62 percent under Regulatory Alternative n.

Governments may finance regulatory compliance costs by borrowing, rasing taxes,
diverting revenue from other services, or, where they exist, raising user fees (i.e., tipping
fees). This analysis focuses on the use of revenue bonds as a means of financing MWC
retrofits. It estimates the impacts of the regulation on government entities by projecting the
government entity's ability to issue revenue bonds to finance the capital control costs
imposed by the regulation. Revenue bonds are generally repaid through user fees assessed to
individuals that directly benefit from the investment. Thus, the ability to issue revenue bonds
depends on the ability of the government entity to increase user charges assessed to
households in the service area of the MWC. For this analysis, the ability of government
entities to issue revenue bonds was projected based on a threshold criterion established in
Municipalities, Small Businesses, and Agriculture—The Challenge of Meeting Environmental
Responsibilities (EPA, 1988). Specifically, if the annual cost per household due to the
regulation exceeds 1 percent of annual household income, then the community is projected to
have potential difficulty issuing revenue bonds.

Household impacts were computed using the median household income and number
of households in the county where the MWC facility is located (Department of Commerce,
1994). Household income was converted to 1997 dollars (Department of Labor, 1998). The
20
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aggregate costs were combined with demographic and income data to compute the cost per
household and the cost per household as a percentage of pre-tax household income. The total
annual cost (including the annualized capital cost and the annual operating cost) was divided
by the number of households to calculate the cost of each regulatory alternative per
household.10 Then the annual cost per household was expressed as a percentage of household
income to determine whether the community will have financial difficulty issuing revenue
bonds. The results of the analysis were broken down into four groups of facilities based on
the size of the population of the county in which they are located.

Tables 9, 10, and 11 show, for Regulatory Alternatives I, I*, and n, respectively, the
number of facilities and units, the average cost per household, median household income,
average household cost as a percentage of median household income, and the number of
government entities whose annual compliance costs exceed the threshold criterion under the
regulation, all broken down by population size of the county where the MWC facility is
located. No government entities are projected to have difficulty issuing revenue bonds as a
result of the regulation under Regulatory Alternative I or Regulatory Alternative I*. Under
Regulatory Alternative n, one small government entity exceeds the 1 percent criterion.
Government entities that, for some reason, are unable to issue bonds to cover the costs of the
regulation may decide to use other financing mechanisms or other waste disposal options.

4.3 Impacts on Nonprofit Organizations
One nonprofit organization owns two MWCs that will be affected by the regulation.
These two units will incur annual incremental compliance costs of approximately
$0.7 million, or 1 percent of the total annual compliance costs under Regulatory Alternatives
I and I*. These costs equate to an annual average cost increase of $30.49 per ton of waste
combusted, which is 53 percent of the pre-regulation average fee. Under Regulatory
Alternative n, the two units will incur annual incremental compliance costs of $0.9 million,
or 1 percent of the total compliance costs of the regulation. Under Regulatory Alternative n,
compliance costs result in a cost increase of $41.79 per ton of waste combusted, which is
72 percent of the average tipping fee.

Data were not sufficient to determine the ability of units owned by the nonprofit
organization to meet the regulation requirements (e.g., annual operating expenditures or
assets).
number of households is used as an estimator of the service area population.

21
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Table 9. Impacts on Publicly Owned Units: Regulatory Alternative I (Existing MWCs)
Country Population

Facilities
Units
Annual Avg. Compliance Cost
Per Household
Annual Household Income
Annual Avg. Compliance Cost
Per Household as a Share of
Household Income (%)
Government Facilities
Projected to Have Difficulty
with Financing
Table 10. Impacts on Publicly
MWCs)
OtoSO
8
14
$58.17
$25,551.27
0.2277%
0
Owned Units:
50 to 100
5
12
$17.69
$29,905.72
0.0591%
0
Size (in thousands)
100 to 250
10
23
$12.29
$37,145.15
0.0331%
0
Regulatory Alternative I*
Country Population

Facilities
Units
Annual Avg. Compliance Cost
Per Household
Annual Household Income
Annual Avg. Compliance Cost
Per Household as a Share of
Household Income (%)
Government Facilities
Projected to Have Difficulty
with Financing
OtoSO
8
14
$58.17
$25,551.27
0.2277%
0
50 to 100
5
12
$17.69
$29,905.72
0.0591%
0
Over 250
6
13
$1.11
$41,030.44
0.0027%
0
(Existing
Size (in thousands)
100 to 250
10
23
$15.55
$37,145.15
0.0419%
0
Over 250
6
13
$6.98
$41,030.44
0.0170%
0
22
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Table 11. Impacts on Publicly Owned Units: Regulatory Alternative II (Existing
MWCs)
Country Population

50 to 100
5
12
$31.21
$29,905.72
0.1044%

Size (in thousands)
100 to 250
10
23
$18.73
$37,145.15
0.0504%

Over 250
6
13
$8.13
$41,030.44
0.0198%

4.4 Household Impacts
If the MWC facilities are not institutional (i.e., they serve customers other than their
owners/operators), some or all of the increase in costs will be passed onto their customers.
Because household waste comprises the majority of MSW, this analysis estimated the impact
of the regulation on households in the facilities' service areas. Household impacts apply to
all communities served by MWCs, regardless of their form of ownership. Therefore, the
methods used to compute average cost per household and average cost per household as a
percentage of income for government-owned MWCs also applies to business-owned MWCs
and facilities owned by nonprofit organizations. Community size is based on the population
of the county where the facility is located.
Tables 12,13, and 14 show the average annual compliance cost per household under
the regulation and the average annual cost as a percentage of median household income for
Regulatory Alternatives I, I*, and n, respectively. They report the average cost increase due

23
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Table 12. Household Impacts: Regulatory Alternative I (Existing MWCs)

Country Population Size (in thousands)
OtoSO 50 to 100 100 to 250 Over 250
Facilities 11 8 14 8

Units 20 18 34 18

Annual Avg. Compliance Cost $48.80 $25.72 $9.46 $2.09
Per Household

Annual Household Income $29,250.07 $32,928.15 $37,321.44 - $40,973.82

Annual Avg. Compliance Cost .0.17% 0.08% 0.03% 0.01%
Per Household as a Share of
Household Income (%)
Table 13. Household Impacts: Regulatory Alternative I* (Existing MWCs)

Country Population Size (in thousands)
OtoSO 50 to 100 100 to 250 Over 250
Facilities 11 8 14 8

Units 20 18 34 18

Annual Avg. Compliance Cost $48.80 $25.72 $13.68 $6.33
Per Household

Annual Household Income $29,250.07 $32,928.15 $37;321.44 $40,973.82

Annual Avg. Compliance Cost 0.17% 0.08% 0.04% 0.02%
Per Household as a Share of
Household Income (%)
to the regulation if all the cost increases are passed on to households in the form of increased
user fees or increased taxes. As already discussed, the actual burden on a given household
may be larger or smaller depending on the method by which the jurisdiction passes costs
along to its customers. The values reported in Tables 12,13, and 14 indicate that, on
24
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Table 14. Household Impacts: Regulatory Alternative II (Existing MWCs)
Country Population

Facilities
Units
Annual Avg. Compliance Cost
Per Household
Annual Household Income
Annual Avg. Compliance Cost
Per Household as a Share of
Household Income (%)
OtoSO
11
20
$71.78
$29,250.07
0.25%

50 to 100
8
18
$35.75
$32,928.15
0.11%

Size (in thousands)
100 to 250
14
34
$17.09
$37,321.44
0.05%

Over 250
8
18
$7.16
$40,973.82
0.02%

average, the cost per household, both as an absolute value and as a share of median
household income, is highest for entities with populations below 50,000, and it is inversely
related to population size.
5. National Emissions Reductions (Emission Guidelines)
Tables 15,16, and 17 describe expected national aggregate emissions and emissions
reductions for dioxins (CDD/CDF), cadmium (Cd), Hg, lead (Pb), PM, sulfur dioxide (SO2),
hydrogen chloride, and NOX under Regulatory Alternatives I, I*, and n, respectively. The
tables also report the expected percentage change in the emissions of each pollutant.
6.
Cost and Emissions Reductions: NSPS
The proposed regulation of MWCs includes New Source Performance Standards
(NSPS) to be imposed on new facilities. New MWCs subject to the NSPS will be required to
install air pollution control technologies with the performance characteristics of an SD-based
control system. Additionally, units located at MWC plants with an aggregate capacity greater
than 250 tons of MSW per day would also be required to install NOX control systems with the
performance characteristics of SNCR.
25
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Table 15. Aggregate Emissions Reductions: Regulatory Alternative I (Existing MWCs)
Baseline Emissions
(Ibs per year)
PM
Cd
Hg
Pb
S02
HC1
CDD/CDF
NO,
CO*
Table 16. Aggregate
MWCs)
1,058,149
806
9,427
30,909
5,347,111
6,167,873
6
9,042,433
1,958,682
Emissions Reductions Percent Reduction
(Ibs per year) (%)
771,878
680
8,987
28,044
2,630,931
5,258,472
6
845,717
0
Emissions Reductions: Regulatory Alternative I*
Baseline Emissions
(Ibs per year)
PM
Cd
Hg
Pb
SO2
HC1
CDD/CDF
NOX
CO*
1,058,149
806
9,427
30,909
5,347,111
6,167,873
6
9,042,433
1,958,682
73%
84%
95%
91%
49%
85%
97%
9%
0%
(Existing
Emissions Reductions Percent Reduction
(Ibs per year) (%)
812,958
683
8,998
28,503
3,014,954
5,414,007
6
845,717
0
77%
85%
95%
92%
56%
88%
97%
9%
0%
26
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Table 17. Aggregate Emissions Reductions: Regulatory Alternative II (Existing
MWCs)

PM
Cd
Hg
Pb
SO2
HC1
CDD/CDF
NO,
CO*
Baseline Emissions*
(Ibs per year)
1,058,149
806
9,427
30,909
5,347,111
6,167,873
6
9,042,433
1,958,682
Emissions Reductions
(Ibs per year)
862,110
689
9,023
29,512
3,576,606
5,522,556
6
845,717
0
Percent Reduction
(%)
81%
85%
96%
95%
67%
90%
98%
9%
0%
It is projected that, in the absence of the NSPS, five new small MWC plants will be
constructed over the next 5 years, averaging one per year (Leatherwood, 1998). Furthermore,
it is projected that each of these new plants will have two combustor units each with capacity
of 50 tpd, for a total plant capacity of 100 tpd. For the new NSPS, the baseline performance
is assumed to be the 1971 NSPS for MWCs (Subpart E) (40 CFR Part 60), which only
regulates PM emissions. The model plant for the NSPS analysis would be required to
implement air pollution controls with the performance characteristics of SD/FF control
systems for PM, acid gas, and metals and of CI for Hg. NOX controls will not be required for
the projected model units, because the projected total capacity of each new facility is less
than 250 tpd.
The aggregate costs and emissions reductions at new MWCs were computed based on
the same assumptions and methodology as the ones for existing small MWCs. The only
difference is that the useful life of new small MWCs is assumed to be 30 years,11 and the cost
data used were extracted from Tables 5-2, 5-5, and 5-6 in Economic Impact Analysis for
Proposed Emission Standards and Guidelines for Municipal Waste Combustors (EPA, 1994).
This assumption is consistent with Economic Impact Analysis for Proposed Emission Standards and
Guidelines for Municipal Waste Combustors (EPA, 1994).

27
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Table 18. Aggregate Costs (New MWCs)a
Type of Control
Acid Gas/PM/
Metals Controls
Hg Control
NO, Control
Total
Annual
Total Capital Operating Costs
Cost ($1997) ($1997)
$34,600,503
$542,044
$0
$35,142,547
$5,126,064
$101,618
$0
$5,227,682
Total Annual Annual Average
Costs Enterprise Costs
($1997) ($1997/ton)
$7,914,394
$145,299
$0
$8,059,693
$50.73
$0.93
$0.00
$51.66
1 Fifth-year impacts.

6.1 Cost Impact

The costs of the NSPS in the fifth year after the regulation is imposed are expected to
be $8.1 million in the worst case, as shown in Table 18. These costs are taken to be the
social cost of the regulation. One projected small MWC plant, consisting of two units, will
incur additional costs due to the regulation in the amount of $1.6 million. In the fifth year, it
is projected that there will be five such new facilities in operation. The cost of the regulation
averages to about $51.66 per ton of waste combusted. These costs are relative to the 1971
NSPS for MWCs (Subpart E).

As explained in the EG analysis, the costs presented in Table 18 represent a worst-
case (highest-costs) scenario because substitution was not evaluated. If we did consider
landfilling as a substitution option for institutions planning to purchase a small MWC, we
would expect the number of new MWCs to be lower than in our worst-case scenario. This
results because, as the new standards require additional pollution control equipment to be
installed with the combustors, the cost of combustion increases. As the cost of combustion
increases, institutions that plan to use combustion as a method of waste disposal will
consume less of it. This effect will be even more pronounced further into the future, as the
institutions planning to purchase combustors will have more flexibility in choosing their
method of waste disposal.
28
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6.2 Emissions Reductions

In the fifth year after the NSPS are put into effect, the standards are expected to result
in a reduction of pollutants, as shown in Table 19. The table also reports the expected
percentage change in the emissions of each pollutant. These reductions are relative to the
1971 HSPS for MWCs (Subpart E).

Table 19. Emissions Reductions (New MWCs)a

CDD/CDF
Cd
Hg
Pb
PM
SO2
HC1
NOX
Baseline Emissions'*
(Ibs per year)
0.459
376
874
33,231
535,134
503,931
335,434
493,010
Emissions Reductions
(Ibs per year)
0.452
372
850
33,191
525,461
417,498
302,514
(c)
Percent Reduction
(%)
99%
99%
97%
99%
98%
83%
90%
0%
' Fifth-year impacts.
b Baseline emissions assume new MWCs are subject to 1971 NSPS (Subpart E).
c The model plant for new NSPS units was a unit of a plant with capacity less than 250 tpd and no NOX control
would be required. If the model plant had been a unit of a plant with capacity larger than 250 tpd, NOX
control would have been required. The projected NOX emissions reduction for such units is approximately
40 percent.
7.
References
Berenyi, E.B., and R.N. Gould. 1993. "Municipal Waste Combustion in 1993." Waste Age
(November):51-56.

Goddard, H.C. 1975. Managing Solid Wastes: Economics, Technology, and Institutions.
New York: Praeger Publishers.

Hockett, D., D. Lober, and K. Pilgrim. 1995. "Determinants of Per Capita Municipal Solid
Waste Generation in the Southeastern United States." Journal of Environmental
Management 45:205-217.

29
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Lind, R.C. 1990. "Reassessing the Government's Discount Rate Policy in Light of New
Theory and Data in a World Economy with a High Degree of Capital Mobility."
Journal of Environmental Economics and Management 18:S8-S28.

Memorandum from L. Cone, and C. Kane, Eastern Research Group, Inc. to Walt Stevenson,
EPA/Combustion Group (MD-13). July 7,1997. Large and Small MWCs in the
1995 MWC Inventory Database. (A-90-45; VI-B-2)

Memorandum from Chad Leatherwood, Eastern Research Group, Inc. to Walt Stevenson,
EPA/Combustion Group (MD-13). October 7,1998. Estimate for the Growth Rate
of New Small Municipal Waste Combustion (MWC) Units. (A-98-18; H-B-5)

Memorandum from J. Tucker, Eastern Research Group, Inc. to Walt Stevenson,
EPA/Combustion Group (MD-13). July 22,1998. Economic Impact Analysis
(ELA)—1998 National Inventory of Small Municipal Waste Combustion Units. (A-
98-18; H-B-3)

New Source Performance Standards for Municipal Waste Combustors. 1971. 40 CFR Part
60 Subpart E.

U.S. Court of Appeals. March 21, 1997. U.S. Court of Appeals Order on Petition for
Rehearing of December 6,1996 Decision. Case No. 95-161.

U.S. Department of Commerce, Bureau of the Census. 1994. County and City Databook.
Washington, DC: U.S. Department of Commerce.
.

U.S. Department of Labor, Bureau of Labor Statistics. May 14, 1998. Consumer Price Index.
Washington, DC: U.S. Department of Labor.
.

U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards. June
1987. Municipal Waste Combustion Study. Research Triangle Park, NC: U.S.
Environmental Protection Agency.

U.S. Environmental Protection Agency. 1988. Municipalities, Small Business, and
Agriculture: The Challenge of Meeting Environmental Responsibilities. Washington,
DC: Office of Policy, Planning, and Evaluation. EPA 230-09/88-037.
30
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U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards.
August 1989. Municipal Waste Combustors—Background Information for Proposed
Standards: Cost Procedures. Research Triangle Park, NC: U.S. Environmental
Protection Agency.

U.S. Environmental Protection Agency, Office of Air and Radiation. March 1994.
Economic Impact Analysis for Proposed Emission Standards and Guidelines for
Municipal Waste Combustors. Research Triangle Park, NC: U.S. Environmental
Protection Agency.

U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards. 1995.
Compilation of Air Pollution Emission Factors: Stationary Point and Area Sources.
Vol. 1, Section 2-1. Research Triangle Park, NC: U.S. Environmental Protection
Agency.

U.S. Office of Management and Budget. 1992. "Guidelines and Discount Rates for Benefit-
Cost Analysis of Federal Programs." Circular No. A-94, Revised. Memorandum for
Heads of Executive Departments and Establishments. Washington, DC.
.
31
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TECHNICAL REPORT DATA
(Please read Instructions on reverse before completing)
l. REPORT NO
EPA-452/R-00-001
3 RECIPIENT'S ACCESSION NO
4. TITLE AND SUBTITLE
Economic Impact Analysis (EIA): Small Municipal Waste
Combustors—Emissions Guidelines and New Source Performance
Standards
5 REPORT DATE
May 2000
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
Tayler H. Bingham, Peter Diakov, Virginia Perry
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS

Research Triangle Institute
Research Triangle Park, NC 27709
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
Research Triangle Institute, Economic
Analyses and Control Strategy Development
EPA Contract #68-D-99-024
12. SPONSORING AGENCY NAME AND ADDRESS

Office of Air Quality Planning and Standards
Office of Air and Radiation
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
13. TYPE OF REPORT AND PERIOD COVERED
Final Report
14. SPONSORING AGENCY CODE
EPA/200/04
15. SUPPLEMENTARY NOTES
16. ABSTRACT

This report describes the expected impacts of EPA's Emission Guidelines (EGs) on existing small municipal waste combustion
units (SMWCs) and the New Source Performance Standards on new SMWCs. The report compares three different regulatory
alternatives for existing facilities and reports the overall distribution of costs, the distribution of costs across ownership
structures, and the variation of costs across communities of different sizes. The report presents projected emissions
reductions associated with each of the regulatory alternatives. The report also describes expected fifth-year impacts of the
NSPS.
17. M ACT Rule Support
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b. IDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
Air pollution control, small municipal
waste combustors
18. DISTRIBUTION STATEMENT
Release unlimited
19.
Unclassified
j, ,
NO. OF PAGES
20. SECURITY CLASS (Page}
Unclassified
22. PRICE
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