EPA-450/3-91-003
Air Pollutant Emission
Standards and Guidelines for
Municipal Waste Combustors:
Revision and Update of
Economic Impact Analysis and
Regulatory Impact Analysis
Emission Standards Division
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina
November 1990
U.S. Envifowtientat Section Agency
Region 5,Library {«*«» im f|OQ-
77 West Jackson Boulevard, I2tti Flo*
Chicago, !L 60604-3590
-------
This report is issued by the Emission Standards Division of the Office of Air
Quality Planning and Standards of the Environmental Protection Agency. It presents
technical data of interest to a limited number of readers. Copies are available free
of charge to Federal employees, current contractors and grantees, and non-profit
organizations—as supplies permit—from the Library Services Office (MD-35), U.S.
Environmental Protection Agency, Research Triangle Park, NC 27711, phone 919-
541-2777 (FTS 629-2777), or may be obtained for a fee from the National Technical
Information Service, 5285 Port Royal Road, Springfield, VA 22161, phone 703-487-
4650 (FTS 737-4650).
^
Publication No. EPA-450/3-91-003
NOTICE: This report addresses air pollutant emission standards and
guidelines for municipal waste combustor (MWC) plants that have design
capacities (aggregated over all combustors at each site) to combust 35 or
more Mg of municipal solid waste per day. Subsequent to the analysis,
the U.S. Congress passed the Clean Air Act Amendments of 1990. The
Amendments distinguish between MWC units (individual combustors)
with capacities greater than 225 Mg per day, and those smaller, without
regard to aggregate plant capacity. Pursuant to the intent of the Amend-
ments, EPA modified the emission standards and guidelines so that they
pertain only to MWC units greater than 225 Mg per day in capacity. This
action removes from the purview of the standards and guidelines about
15 percent of the total national combustion capacity analyzed in this re-
port. Consequently, most impact estimates in this report (national costs,
emission reductions, etc.) are higher than is likely to be the case. The
Preambles to the promulgated standards and guidelines contain revised
impact estimates. (See Docket A-89-08, entry IV-B-23 for an explanation
of the revised impact estimates.)
The Amendments direct EPA to promulgate standards and guidelines
for MWC units with capacities greater than 225 Mg per day now, supple-
mentary standards and guidelines for these same units within one year,
and standards and guidelines for MWC units with capacities equal to or
less than 225 Mg per day within two years. Most of the impact estimates
in this report now serve as preliminary estimates for the complete set of
standards and guidelines.
In addition to changing the lower size cutoff, EPA deleted the proposed
materials separation requirements. EPA no longer anticipates that such
requirements will be a part of the complete set of standards and guidelines.
In this report all discussion and impact estimates associated with the
initially-proposed materials separation requirements are separable, and
should be disregarded.
u
-------
CONTENTS
Chapter page
Conversions and Definitions[[[ ................................................ xi
Assumptions and Conventions[[[ ................................ xiii
1 Introduction and Summary [[[ 1.1
1.1 Background Information [[[ 1-1
1.2 Impacts of the Regulation [[[ 1-2
1.2.1 Cost Increases and Emission Reductions ............................................... 1-3
1.2.2 Sensitivity Analysis: Materials Separation Costs and High
Capacity Utilizatioa [[[ 1_6
1.3 Small Facility Impacts [[[ 1_7
1.3.1 Profile of Small Facilities: Ownership and Severity of
Impacts [[[ 1-7
1.3.2 Substitution Across the Small Size Cutoffs ........................................... 1-8
2 Background Information ____ .. ___________ . ______ .. ____ ... ____ . _______________ .. _____ ..... ............................ 2-1
-------
CONTENTS (continued)
Chapter Page
3 Methodology Used to Calculate Impacts of the Regulation ......................... ............. 3.1
3.1 Methods Used to Calculate the No Substitution Scenario Impacts ..................... 3-1
3.2 Methods Used to Calculate the Substitution Scenario Impacts ........................... 3-6
3.2.1 NSPS Substitution Scenario [[[ 3.5
3.2.2 Guidelines Substitution Scenario [[[ 3-1 1
4 Impacts of the Regulation.... ______ . ___ ...... _____ . ___________ . _____ ............................................... 4. j
4.1 Model Plant Impacts [[[ 4_1
4.2 National-Level Impacts. [[[ 4_2
5 Sensitivity Analysis.
5.1 Materials Separation Sensitivity Analysis [[[ 5-1
5.1.1 Methods Used to Calculate Costs of the Materials Separation
Requirements.. [[[ . ........ 5_1
5.1.2 Model Plant Impacts of the Materials Separation
Requirements. [[[ 5,7
5. 1.3 National-Level Impacts of the Materials Separation
-------
CONTENTS (continued)
Chapter page
6.3 Economic Impact on Small Entities 6-7
6.3.1 Analysis of Impacts on Governments 6-7
6.3.2 Analysis of Impacts on Private Firms 6-11
6.3.3 Analysis of Household Impacts. 6-14
6.3.4 Conclusion. 6-16
7 Substitution Across the Emissions Cutoff....... ... 7-1
7.1 Analytical Framework 7.2
7.1.1 Cost Estimation .' 7.4
7.1.2 Cost Comparisons 7.5
7.2 Impact of the Cutoff on Facility Investments 7.5
7.3 Additional Considerations 7_6
-------
-------
TABLES
Number Page
1-1 NSPS National Cost Impacts 1-4
1-2 Guidelines National Cost Impacts 1-5
2-1 Characteristics of NSPS Model Plants 2-4
2-2 Characteristics of Guidelines Model Plants 2-5
2-3 Emission Reduction Requirements for MWC Plants Subject to NSPS and
Guidelines 2-7
2-4 Materials Separation Requirements for MWC Plants Subject to NSPS and
Guidelines 2-9
3-1 Baseline Scaling Factors, Plant Capacity, and Waste How Estimates for
MWC Plants Subject to NSPS 3_2
3-2 Baseline Scaling Factors, Plant Capacity, and Waste Flow Estimates for
MWC Plants Subject to Emission Guidelines 3.3
3-3 Estimated Baseline Waste Flows Subject to Disposal Choice by
Technology 3_g
3-4 Estimated Downsizing of NSPS Model Plants Due to the Materials
Separation Requirement. 3.9
3-5 Waste Flow Shares Estimated by the Discrete Choice Model 3-10
3-6 Estimated Waste Flows Subject to Disposal Choice by Technology and
Regulatory Alternative 3.12
3-7 National Waste Flows and Scaling Factors by Model Plant Category Under
the NSPS Substitution Scenario 3.13
3-8 Guidelines Substitution Scenario: Baseline Substitution, 3-15
4-1 Annualized Enterprise Costs of Control for Publicly Owned NSPS Model
Plants 4_3
4-2 Annualized Enterprise Costs of Control for Publicly Owned Guidelines
Model Plants A 4.4
VI
-------
TABLES (continued)
Number
Page
4-3 Annualized Enterprise Costs of Control per Mg MSW Combusted for
Publicly Owned NSPS Model Plants by Size Classification 4.5
4-4 Annualized Enterprise Costs of Control per Mg MSW Combusted for
Publicly Owned Guidelines Model Plants by Size Classification 4.5
4-5 Annualized Enterprise Costs and Percentage Increase in Costs for Publicly
Owned NSPS Model Plants 4.6
4-6 Annualized Enterprise Costs and Percentage Increase in Costs for Publicly
Owned Guidelines Model Plants ; 4.7
4-7 NSPS National Cost Impacts 4.8
4-8 Guidelines National Cost Impacts 4.9
4-9 Percentage Price Increases Based on Full Pass-Through of Estimated NSPS
Enterprise Costs of Control per Mg of Municipal Solid Waste 4-io
4-10 Percentage Price Increases Based on Full Pass-Through of Estimated
Guidelines Enterprise Costs of Control per Mg of Municipal Solid Waste 4-10
4-11 NSPS National Baseline Emissions and Emissions Reductions 4-H
4-12 Guidelines National Baseline Emissions and Emissions Reductions 4-12
4-13 NSPS National Energy Impacts 4.^3
4-14 Guidelines National Energy Impacts 4_13
5-1 Estimated Waste Flows Subject to Disposal Choice by Technology: With
Materials Separation 1 and Materials Separation 2 Costs 5.5
5-2 National Waste Flows and Scaling Factors by Model Plant Category Under
the NSPS Substitution Scenario: With Materials Separation 1 and Materials
Separation 2 Costs... , 5.5
5-3 Annualized Enterprise Costs of Control for Publicly Owned NSPS Model
-. Plants: With Materials Separation 1 and Materials Separation 2 Costs. 5-8
VII
-------
TABLES (continued)
Number Page
5-4 Annualized Enterprise Costs of Control for Publicly Owned Guidelines
Model Plants: With Materials Separation 1 and Materials Separation 2
Costs. 5.9
5-5 Annualized Enterprise Costs of Control per Mg for Publicly Owned NSPS
Model Plants by Size Classification: With Materials Separation 1 and
Materials Separation 2 Costs 5-10
5-6 Annualized Enterprise Costs of Control per Mg for Publicly Owned
Guidelines Model Plants by Size Classification: With Materials Separation
1 and Materials Separation 2 Costs 5-11
5-7 Annualized Enterprise Costs and Percentage Increase in Costs for Publicly
Owned NSPS Model Plants: With Materials Separation 1 Costs 5-12
5-8 Annualized Enterprise Costs and Percentage Increase in Costs for Publicly
Owned NSPS Model Plants: With Materials Separation 2 Costs 5-13
5-9 Annualized Enterprise Costs and Percentage Increase in Costs for Publicly
Owned Guidelines Model Plants: With Materials Separation 1 Costs 5-14
5-10 Annualized Enterprise Costs and Percentage Increase in Costs for Publicly
Owned Guidelines Model Plants: With Materials Separation 2 Costs 5-15
5-11 NSPS National Cost Impacts: With Materials Separation 1 and Materials
Separation 2 Costs. 5.17
5-12 Guidelines National Cost Impacts: With Materials Separation 1 and
Materials Separation 2 Costs 5_lg
5-13 Percentage Price Increases Based on Full Pass-Through of Estimated NSPS
Enterprise Costs of Control per Mg of Municipal Solid Waste: With
Materials Separation 1 and Materials Separation 2 Costs 5-19
5-14 Percentage Price Increases Based on Full Pass-Through of Estimated
Guidelines Enterprise Costs of Control per Mg of Municipal Solid Waste:
With Materials Separation 1 and Materials Separation 2 Costs 5-19
5-15 High Capacity Utilization Scaling Factors, Plant Capacity, and Waste Row
Estimates for MWC Plants Subject to NSPS 5-21
5-16 High Capacity Utilization Scaling Factors, Plant Capacity, and Waste Flow
Estimates for MWC Plants Subject to Emission Guidelines 5-22
vm
-------
TABLES (continued)
Number
Page
5-17 NSPS National Cost Impacts Under the No Substitution Scenario:
High Capacity Utilization [[[ 5.23
5- 1 8 Guidelines National Cost impacts Under the No Substitution Scenario:
High Capacity Utilization [[[ 5_24
5-19 NSPS National Baseline Emissions and Emissions Reductions:
High Capacity Utilization [[[ .9
5-20 Guidelines National Baseline Emissions and Emissions Reductions:
High Capacity Utilization
6- 1 Distribution of MWCs by Facility Capacity and Size and Type of
Ownership .................
-------
FIGURES
Number Page
2-1 Solid Waste How Projections, 1986 through 1996 2-2
6-1 Distribution of MWCs with Capacities of 18 to 90 Mg per Day, by
Capacity 6-4
6-2 Distribution of MWCs with Capacities of 18 to 90 Mg per Day, by Type of
Ownership 6-5
6-3 Distribution of Publicly Owned MWCs with Capacities of 18 to 90 Mg per
Day, by Ownership Population 6-6
6-4 Distribution of Government Impacts Under Guidelines for MWC Plants
with Capacities of 35 to 90 Mg per Day, by Service Area Population:
Index 2 6-10
6-5 Distribution of Government Impacts Under Guidelines for MWC Plants
with Capacities of 35 to 90 Mg per Day, by Service Area Population:
Index 3 6-12
6-6 Distribution of Household Impacts Under Guidelines for MWC Plants with
Capacities of 35 to 90 Mg per Day, by Service Area Population: Index 1 6-15
6-7 Distribution of Household Impacts Under Guidelines for MWC Plants with
Capacities of 35 to 90 Mg per Day, by Service Area Population: Index 2 6-17
-------
CONVERSIONS AND DEFINITIONS
This report uses metric units, as well as acronyms and terms that may not be familiar to
all readers. Following is a short guide to conversions and definitions for a selection of the units,
acronyms, and terms.
CONVERSIONS
To Approximate
Mg
(megagram)
As
Ton
(2,000 Ib)
Multiply by
1.1025
Examples from Text
35 Mg
•225 Mg
39 tons
250 tons
g/dscm
(grams/dry standard
cubic meter)
TJ
(terajoule)
TJ
(terajoule)
gr/dscf 0.44 0.02 g/dscm
(grains/dry standard 0.18 g/dscm
cubic foot)
K^Btu 948 8.54 TJ
(million British 34.2 TJ
Thermal Units)
MWh 278 4.32 TJ
(megawatt 13 TJ
hours)
0.01 gr/dscf
0.08 gr/dscf
8,100 106Btu
32,400 106Btu
1,200 MWh
3,600 MWh
OTHER MEASURES
dscm
ng
mg
ppmv
103; 106
POLLUTANTS
CDD/CDF
CO
HC1
NOX
Pb
PM
S02
Dry standard cubic meter
Nanogram-one billionth of a gram
Normal cubic meter (A normal cubic meter is at 0°C, while a standard
cubic meter is at 20°C; both at 1 atmosphere of pressure.)
Milligram-one thousandth of a gram
Parts per million by volume
Thousands; Millions
Polychlorinated dibenzo-p-dioxins and dibenzofurans
Carbon monoxide
Hydrogen chloride
Nitrogen oxides
Lead
Paniculate matter
Sulfur dioxide
GENERAL ACRONYMS
APCD Air pollution control device
FBC Fluidized bed combustion
MSW Municipal solid waste
MWC Municipal waste combustor
RDF Refuse-derived fuel
XI
-------
ECONOMIC TERMS
National
enterprise
cost
National
social cost
1987$
Tipping fee
Unit cost
The sum of the regulatory costs incurred by each MWC, discounted and
annualized at market interest rates
The sum of the regulatory costs incurred by each MWC, discounted and
annualized at interest rates reflecting society's opportunity costs for capital
and consumption
Constant (real) dollars at their fourth quarter 1987 value
The charge for incinerating or landfilling MSW, usually $/Mg, imposed by
MWCs or landfill operators on MSW collectors. Tipping fees, where they
are charged, do not reflect the cost of collecting and transporting MSW to
the disposal site and often fail to reflect the full cost of incineration or
landfilling
The cost per Mg of waste combusted
REGULATORY AND LEGISLATIVE TERMS
Baseline
Conditions that would exist were there to be no new Clean Air Act
§ 11 l(b) and (d) regulation of MWCs
Clean Air Act §11 l(d) emission standards for existing sources
Model plant A hypothetical MWC representative of a class of MWCs; used to analyze
impacts of regulation
Clean Air Act §11 l(b) new source performance standards
Resource Conservation and Recovery Act
Regulatory Flexibility Act; also regulatory flexibility analysis, a study of
the impact of regulations on small entities (businesses, governments, and
organizations)
Economic Impact Analysis; Used to refer to the Economic Impact of Air
Pollutant Emission Standards for New Municipal Waste Combustors
(EPA, 1989b), Economic Impact of Air Polutant Emission Guidelines for
Existing Municipal Waste Combustors (EPA, 1989a), or this report unless
otherwise specified
RIA Regulatory Impact Analysis; Used to refer to the Regulatory Impact
Analysis of Air Pollutant Emission Standards and Guidelines for
Municipal Waste Combustors (EPA, 1989f) unless otherwise specified
§ 111 (b) Clean Air Act section governing emission standards for new sources
(NSPSs)
§ 111 (d) Clean Air Act section governing emission standards for existing sources
Subtitle D RCRA subtitle governing sanitary landfills
Guidelines
NSPS
RCRA
RFA
EIA
xu
-------
ASSUMPTIONS AND CONVENTIONS
Myriad assumptions, analytical conventions, and underlying calculations form the basis
for projecting the economic impacts of EPA regulations. This page summarizes the principal
assumptions, conventions, and calculated values used in this report. Chapter 5 describes how
projected impacts would be different if some of these assumptions, conventions, and values are
changed.
• Effective date for the §lll(b) NSPS and §lll(d) Guidelines: December 20, 1990
• Affected MWCs:
- NSPS: MWCs over 35 Mg per day capacity placed under construction on or after the
effective date
- Guidelines: MWCs over 35 Mg per day capacity placed under construction before the
effective date
• Lifetimes of physical facilities:
- Planned MWCs: 30 years after incurring initial compliance costs
- Existing MWCs: Depending on age of MWC, 15 or 30 years after incurring initial
compliance costs
- APCDs: 15 years
• % utilization of daily capacity (There are some exceptions. These percents remain constant
over time.):
- Mass burn: 84.7%
- RDFandFBC: 82.7%
- Modular: 81.7%
• Monetary units: Constant (real) 1987 dollars, usually for the 4th quarter
• Capital costs for each MWC and APCD:
- Incurred only at the outset of operation of the MWC or APCD
- Amortized over the lifetime of the MWC or APCD when included in annualized costs
• Annual operating costs and revenues for each MWC or APCD:
- Invariant over the lifetime of the MWC or APCD
- Proportional to MWC capacity utilization (for analysis purposes when alternative
capacity utilization rates are introduced)
• Materials separation costs: negligible
• Market discount rates for computing accounting costs:
- 8% real WACC for private MWCs
- 4% real municipal revenue bond rate of interest for public MWCs
• Social discount rates for computing social costs:
- 10% for capital costs
- 3% for operating costs
xiu
-------
CHAPTER 1
INTRODUCTION AND SUMMARY
The U.S. Environmental Protection Agency (EPA) proposed New Source Performance
Standards (NSPS) and Guidelines for air emissions from new and existing municipal waste
combustors (MWCs) on December 20,1989. Subsequent to proposal, EPA made several
changes in the requirements of the regulation in response to new technical information and to
public comments by MWC owners and operators, government officials, vendors of plants and
equipment, and other interested parties. This report presents the revised and updated economic
impacts of the NSPS and Guidelines prepared for promulgation.
Three reports published prior to the proposal date contain much of the background
information pertinent to this update. In August of 1989, EPA published the Economic Impact of
Air Pollutant Emission Standards for New Municipal Waste Combustors (EPA, 1989b) and the
Economic Impact of Air Pollutant Emission Guidelines for Existing Municipal Waste
Combustors (EPA, 1989a). These economic impact analysis (EIA) reports present the economic
impacts of five regulatory alternatives considered for proposal. In addition, EPA published the
Regulatory Impact Analysis of Air Pollutant Emission Standards and Guidelines for Municipal
Waste Combustors (EPA, 1989f). The regulatory impact analysis (RIA) combined the findings
of the EIA reports with other analyses of the proposed regulation. This report updates elements
of the three reports cited above and incorporates the impacts reported in the Air Pollutant
Emissions Standards and Guidelines for Municipal Waste Combustors: Economic Analysis of
Materials Separation Requirement (EPA, 1990a).
1.1 BACKGROUND INFORMATION
Chapter 2 contains background information regarding the affected waste flows, the
characteristics of planned and existing model plants, the economic impact scenarios used to
estimate impacts for this analysis, and the requirements of the regulation to be promulgated.
Based on data reported in the Characterization of Municipal Solid Waste in the United States:
1990 Update (EPA, 1990b), this report presents revised waste flow projections for landfilling and
materials recovery. Because the projected waste flow to combustion reported in the
Characterization of Municipal Solid Waste in the United States: 1990 Update approximates the
projected waste flow to combustors used in the 1989 EIA and RIA reports, the projected waste
flow to combustors has not been revised for this update.
1-1
-------
For plants subject to NSPS, the emission reduction requirements apply to MWCs placed
under construction after December 20,1989, and above the 35 Mg per day cutoff. For plants
subject to Guidelines, the emission reduction requirements apply to MWCs operating or under
construction before December 20,1989, and above the 35 Mg per day cutoff. Facilities affected
by the materials separation requirement are those plants over 100 Mg per day excluding existing
plants located in states with 25 percent mandatory recycling requirements.
A model plant approach is used to estimate economic impacts. Characteristics of these
"representative" plants, including a revised size classification for plants subject to Guidelines, are
presented in Chapter 2. With the exception of the change in size classification, the model plants
used for this analysis are identical to those used in the earlier EIA and RIA reports.
Impacts are estimated under two economic impact scenarios similar to those used to
estimate impacts in the 1989 EIA and RIA reports. In the first scenario, called the "No
Substitution" Scenario, the impacts of the regulation are estimated under the assumption that
MWC owners do not substitute other forms of waste disposal for combustion in response to the
regulation. This No Substitution Scenario is equivalent to Scenario I in the earlier EIA and RIA
reports. Under the second scenario, called the "Substitution" Scenario, the impacts of the
regulation are estimated under the assumption that MWC owners may substitute away from
combustion in response to the regulation.1 This Substitution Scenario is referred to as Scenario
II for Guidelines and Scenario IE for NSPS in the 1989 EIA and RIA reports.
Several changes in the requirements have occurred since proposal:
• a size cutoff for the emission reduction requirements,
• a size cutoff for the materials separation requirements,
• a new definition of the size classification for large and very large existing plants, and
• the addition of NOX to the list of regulated pollutants.
These changes in the requirements of the regulation as well as others are outlined in Chapter 2.
1.2 IMPACTS OF THE REGULATION
Chapter 3 describes the methods and assumptions used to estimate the revised economic
impacts, and Chapter 4 presents the results of the revised cost and emission impact analyses.
1 Some existing combustor facilities will be replaced even without the Guidelines. This change is also incorporated
in the Substitution Scenario.
-------
Impacts for planned and existing facilities are estimated at the model plant and the national level
under both the No Substitution and Substitution Scenarios. Chapter 5 presents the results of a
sensitivity analysis performed to estimate the impacts of using alternative estimates of materials
separation costs and capacity utilization.
1.2.1 Cost Increases and Emission Reductions
Tables 1-1 and 1-2 present the national-level impacts of the regulation under two
economic impact scenarios. The unit costs presented in this report, including national-level
average compliance cost per Mg, are based on the waste combusted at facilities affected by the
regulation. Total social costs are 1.7 to 2.5 times higher for existing facilities than for planned
facilities. This difference in total cost is attributable to the higher estimated waste flow subject to
Guidelines. Annualized social costs per Mg of waste combusted average 14 to 20 percent lower
for existing facilities than for planned facilities reflecting the less stringentlequirements for
MWCs subject to Guidelines.
In addition to cost impacts, the national emission reductions and national energy impacts
due to the regulation are estimated. These impacts do not include any change in emissions or
energy usage due to the materials separation requirements. The estimates of emission reductions
include the new pollutant, NOX, covered by the regulation.
1-3
-------
TABLE 1-1. NSPS NATIONAL COST IMPACTS (1987 $)«
Annualized
Social Costsb
Scenario ($106/yr)
Annualized
Social Costs
perMg
MSWM
"($/Mg)
Annualized
Enterprise
Costsc
($106/yr)
=====
Annualized
Enterprise
Costs per
M:g MSWC'd
($/Mg)
No Substitution
PM and Acid Gas control 168
NOX control 26.7
Materials Separation6 negligible
Total 194
11.20
1.79
negligible
13.00
145
22.3
negligible
167
9.69
1.49
negligible
11.20
Substitution
Total
107
13.50
91
11.50
a Costs are calculated using average capacity utilization based on the annual operating hours
reported in Table 2-1. Costs calculated for higher capacity utilization are presented in
Chapter 5. Estimates have not been adjusted to exclude plants under the 35 Mg per day cutoff
for the emission reduction requirement. Plants under 35 Mg per day account for less than 1
percent of the waste flow to planned plants in this analysis.
•b Annualized social costs are the sum of capital costs, annualized at 10 percent, and annual
operating costs for MWC facilities or operators of materials separation programs.
c Annualized public enterprise costs arc the sum of capital costs, annualized at 4 percent, and
annual operating costs for MWC facilities or operators of materials separation programs.
d Computed by dividing the total annualized cost by the estimated annual waste combusted at
MWC facilities affected by the regulation.
e Materials separation costs are assumed to be negligible (EPA, 1990c). Quantitative estimates
of materials separation costs are presented for the sensitivity analysis discussed in Chapter 5.
1-4
-------
TABLE 1-2. GUIDELINES NATIONAL COST IMPACTS (1987 $)*
Annuaiized
Social Costsb
Scenario ($10«/yr)
Annuaiized
Social Costs
perMg
MSWM
($/Mg)
Annuaiized
Enterprise
Costsc
(SlOtyr)
Annuaiized
Enterprise
Costs per
Mg MSWc>d
($/Mg)
No Substitution
GCP, PM, and Acid Gas control 328
Materials Separation6 negligible
Total 328
Substitution
Total
265
11.20
negligible
11.20
10.40
272
negligible
272
222
9.27
negligible
9.27
8.69
a Costs are calculated using average capacity utilization based on annual operating hours reponed
in Table 2-2. Costs calculated for higher capacity utilization are presented in Chapter 5.
Estimates have not been adjusted to exclude plants under the 35 Mg per day cutoff for the
emission reduction requirements. Plants under 35 Mg per day account for less than 1 percent
of the waste flow to existing plants in this analysis and represent only a portion of the actual
population of existing plants under 35 Mg per day.
b Annuaiized social costs are the sum of capital costs, annualized at 10 percent, and annual
operating costs for MWC facilities or operators of materials separation programs.
c Annuaiized public enterprise costs are the sum of capital costs, annualized at 4 percent, and
annual operating costs for MWC facilities or operators of materials separation programs.
d Computed by dividing the total annualized cost by the estimated annual waste combusted at
MWC facilities affected by the regulation.
e Materials separation costs are assumed to be negligible (EPA, 1990c). Quantitative estimates
of materials separation costs are presented for the sensitivity analysis discussed in Chapter 5.
1-5
-------
1.2.2 Sensitivity Analysis: Materials Separation Costs and High Capacity Utilization
Two estimates of materials separation costs based on costs presented in the Air Pollutant
Emissions Standards and Guidelines for Municipal Waste Combustors: Economic Analysis of
Materials Separation Requirement (EPA, 1990a) are incorporated in the sensitivity analysis in
Chapter 5. The estimate of materials separation costs referred to as materials separation 1
reflects a net cost savings. Assumptions used to estimate materials separation 1 result in
revenues and avoided costs that exceed annualized capital and operating costs associated with
materials separation. The estimate of materials separation costs referred to as materials
separation 2 in this analysis reflects assumptions that result in costs rather than cost savings.
National-level cost impacts are estimated for both the No Substitution and Substitution
Scenarios with these alternative estimates of materials separation. Under the No Substitution
Scenario for planned plants affected by the regulation, estimated social costs are $154 million
with materials separation 1 and $329 million with materials separation 2. This represents an
estimated cost savings of $40.2 million with materials separation 1 and an estimated cost of $135
million with materials separation 2. Under the No Substitution Scenario for existing plants
affected by the regulation, estimated social costs are $274 million with materials separation 1 and
$551 million with materials separation 2 costs. This reflects an estimated cost savings of $53.9
million with materials separation 1 and an estimated cost of $223 million with materials
separation 2.
The Substitution Scenario social costs for planned plants are $114 and $125 million with
materials separation 1 and materials separation 2, respectively. For plants subject to Guidelines,
estimated social costs are $219 million with materials separation 1 and $470 million with
materials separation 2 under the Substitution Scenario.
Chapter 5 also provides an analysis of the sensitivity of costs to changes in capacity
utilization. The impacts reported in Chapter 4 of this analysis are estimated using average
capacity utilization reported in the 1988-89 Resource Recovery Yearbook (Gould, 1988).
Section 5.2, however, presents national costs and emission reductions calculated using higher
capacity utilization reported in the Municipal Waste Combustors—Background Information for
Proposed Standards: lll(b) Model Plant Description and Costs of Control (EPA, 1989d) and
the Municipal Waste Combustors—Background Information for Proposed Guidelines for
Existing Facilities (EPA, 1989c).
1-6
-------
Cost impacts calculated using high capacity utilization averaged 2 to 4 percent lower than
those calculated using average capacity utilization for both planned and existing facilities.
Emission reductions at planned plants calculated using higher capacity utilization are identical to
those calculated using average capacity utilization. For Guidelines plants, however, emission
reductions estimated using higher capacity utilization are higher for some pollutants and lower
for others. This is due to the change in the mix of facilities used to estimate these high capacity
utilization impacts for existing plants.
13 SMALL FACILITY IMPACTS
The regulation includes a cutoff for very small facilities below 35 Mg per day capacity.
There is, however, concern that small facilities above the cutoff may be more affected by the
regulation than larger facilities. Chapter 6 presents a profile of small facilities including a
description of the facility characteristics such as plant capacity and type of ownership as well as a
discussion of the distribution of economic impacts on small facilities.
Chapter 7 examines the potential for, and possible magnitude of, substitution of small
combustors (< 35 Mg per day) that are exempt from the emission standards for planned modular
facilities.
13.1 Profile of Small Facilities: Ownership and Severity of Impacts
The analysis of impacts in Chapter 6 focuses on small MWCs with capacities between 35
and 90 Mg per day. There are 32 existing and 3 planned MWCs with design capacities between
35 and 90 Mg per day identified for this analysis. Of these, 17 percent are privately owned and
83 percent are publicly owned.
The requirements of the Regulatory Flexibility Act (RFA) are used to help structure the
analysis of impacts on small facilities. Impacts on governments, private firms, and households
are examined in Section 6.3 of this analysis. Small governments are defined in the RFA as those
with a population of 50,000 or less, and small businesses are defined by the Small Business
Association general size standard definition as those averaging $6 million or less in annual
revenue over the most recent three fiscal years. Based on these size definitions, 26 facilities
owned by small entities and 9 owned by large entities are identified for this analysis.
Three indexes are used to measure impacts on government entities. Under one of the
three indexes, 14 of the 25 entities examined will likely suffer severe impacts due to the
1-7
-------
regulation. Data were insufficient to determine whether severe impacts are indicated under the
other two indexes of government impacts.
Six privately owned plants are identified for this analysis. Of these, three are owned by
small firms and three by large firms. The impact of regulation on these private firms was
calculated based on EPA guidance (1982) that impacts may be significant when the "compliance
costs are greater than 5 percent of production cost." Because EPA guidance does not define
production costs in this context, three definitions are discussed in this section. Compliance costs
are estimated to range from 20 to 25 percent of production costs for planned plants and from 15
to 65 percent of production costs for existing plants based on the broadest definition of
production costs.
Increased costs of waste disposal due to the regulation will likely be passed to the
customers served by small MWCs. To estimate the additional burden on households associated
with the regulation, two indexes are used. Under the first index impacts for 30 communities
were calculated. Severe impacts are indicated for households in three communities using this
index. Under Index 2, impacts for 28 communities were calculated. No severe impacts are
indicated for households in this analysis using this measure.
As these measures of severity indicate, some of the small communities and small owners
identified for this analysis will likely suffer severe impacts due to the regulation. EPA, however,
has already taken measures to help mitigate impacts at small plants. Specific mitigation
measures include
• a cutoff of 35 Mg per day for emission reduction requirements built into the regulatory
structure,
• a cutoff of 100 Mg per day for materials separation requirements built into the
regulatory structure,
• less stringent emission reduction requirements for small plants subject to the
regulation, and
• latitude for states to make case-by-case judgments on schedule and stringency under
the Guidelines.
1.3.2 Substitution Across the Small Size Cutoffs
Chapter 7 analyzes the possible impact of the Standards on substitution across the
emissions size cutoff of 35 Mg per day. The finding of that analysis is that the cutoff provides a
significant financial incentive for communities to revise plans for those combustors with
1-8
-------
capacities less than approximately 100 Mg per day. This incentive ranges from $46 per Mg of
waste combusted for facilities just larger than 35 Mg per day capacity down to $9 per Mg of
waste combusted for facilities nearing 100 Mg per day capacity.
The quantitative analysis of substitution across the emissions cutoff results in such
substitution for 11 planned facilities combusting approximately 335,000 Mg of waste annually.
The communities making these substitutions are estimated to reduce the cost by just over $2
million dollars per year.
1-9
-------
-------
CHAPTER 2
BACKGROUND INFORMATION
2.1 BASELINE PROJECTIONS
Baseline projections of waste flows to MWCs, landfills, and materials recovery were
developed in the Economic Impact Analyses and Regulatory Impact Analysis (EIA and RIA)
reports (EPA, 1989a; EPA, 1989b; EPA, 1989f). To estimate those waste flows, data from
Office of Solid Waste (OSW), Franklin Associates, Radian, Kidder-Peabody, GBB, and Frost &
Sullivan were used. For this updated analysis, the estimates of total amount of waste generated,
waste flows to materials recovery, and waste flows to landfilling are revised based on data
contained in the Characterization of Municipal Solid Waste in the US.: 1990 Update (EPA,
1990b). The estimates of waste flows to combustion reported in the 1989 EIA and RIA reports
are unchanged for this revised analysis. Figure 2-1 shows the revised baseline waste flows.
In the 1989 EIA and RIA reports, it was projected that waste flows to landfilling would
remain unchanged at 188.1 million Mg per year from 1986 through 1996. The revised projection
shows waste flows to landfills dropping from 120 million Mg in 1986 to 95 million Mg in 1996.
There are two reasons for the differences in these projections. First, the earlier projection was
based on the estimated waste flow to landfills in 1986 as reported in the OSW Subtitle D Landfill
Regulatory Impact Analysis (Temple, Barker, and Sloan, Inc. et al., 1989), which includes some
wastes that are not MSW by definition, such as small generator hazardous waste, construction
wastes, and waste from industrial and commercial sources. The revised projection includes only
waste defined as MSW. In addition, the projected growth rate used to calculate the earlier
estimate of waste flows to landfills did not reflect shrinking landfill capacity in the U.S. The
OSW Subtitle D Landfill Regulatory Impact Analysis (Temple, Barker, and Sloan, Inc. et al.,
1989) projects that landfill capacity will be reduced to 45 percent of the 1986 level by 1996. The
revised baseline waste flow projection for this report reflects this trend away from landfilling.
The earlier projection for recovery of MSW reflected recovery rates that changed very
slowly or not at all. When such factors as state deposit laws and recycling laws, increasing costs
of conventional waste disposal, the trend toward banning certain yard wastes in landfills, and
increased public access to recovery options are accounted for, however, the projected materials
recovery rate increases 159 percent over the period 1986 to 1996 (EPA, 1990b).
2-1
-------
10° Mg/yr
17.0
1986
P
29.9
44.1
1991
1996
Combustion
Materials Recovery
Landfilling
Figure 2-1. Solid Waste Flow Projections, 1986 through 1996
2-2
-------
2.2 MODEL PLANT APPROACH
Representative MWCs called model plants are used to estimate the impacts of the
regulation on MWCs nationwide. Tables 2-1 and 2-2 provide a list of the model plants and the
corresponding capacity, size classification, energy recovery capability, and annual operating
hours. This characterization of the model plants is identical to that used for the 1989 EIA and
RIA reports with the exception of the size classification for the Guidelines model plants. All
existing MWCs were classified as small or large for the 1989 EIA, and as small, large, or very
large (over 2000 Mg per'day capacity) for the 1989 RIA. For this updated analysis, existing
MWCs over 1000 Mg per day capacity are classified as "very large." Emission requirements
discussed in Section 2.4 are assigned to model plants according to the size classification.
23 SCENARIO APPROACH
It is difficult to predict how public and private decision makers constrained by
institutional considerations will respond to the regulation. Faced with increased costs of waste
disposal due to the regulation, decision makers may respond by making expensive modifications
to existing MWCs, adding control equipment in their plans for new MWCs, or restructuring their
entire waste management program. Because of the uncertainty surrounding the response to the
regulation, two economic impact scenarios are examined.
Under the first scenario, called the "No Substitution" Scenario, it is assumed that decision
makers make the necessary modifications to existing and planned MWCs to meet the
requirements of the regulation with no substitution away from baseline MWCs. In other words,
it is assumed that the amount of waste combusted at MWCs and the number of MWCs will
remain constant. In the 1989 EIA and RIA this scenario is called Scenario I.
Impacts are estimated based on the assumption that MWC owners will respond to the
regulation by employing APCD modification and establishing materials separation programs. In
this scenario planned facilities are not downsized and capacity utilization at planned or existing
facilities is unchanged. It is assumed that the increased waste flows to materials separation will
result in a decrease in the amount of waste landfilled, not a decrease in the amount of waste
combusted.
Under the second scenario, called the "Substitution" Scenario, decision makers may
choose to substitute away from baseline MWCs to a more cost-effective waste disposal
technology. Referred to as Scenario II in the 1989 EIA and RIA, the Guidelines Substitution
Scenario reports the impact of replacing Guidelines MWC plants with new MWC plants based
2-3
-------
TABLE 2-1. CHARACTERISTICS OF NSPS MODEL PLANTS
Model
Plant
Number
Abbreviated
Term
Definition of Term
Model Model
Plant Plant Annual
Capacity Size Energy Operating
(Mg/day) Category8 Recovery Hours
1 MB/WW (small)
2 MB/WW (mid-size)
3 MB/WW (large)
4 MB/REF
5 MB/RC
6 RDF
7 RDF/CF
8 MOD/EA
9 MOD/SA (small)
10 MOD/SA (mid-size)
11 FBC/CB
12 FBC/BB
Mass Burn/Waterwall (small) 180
Mass Burn/Waterwall (mid-size) 730
Mass Burn/Waterwall (large) 2,040
Mass Burn/Refractory Wall 450
Mass Burn/Rotary Combustor 950
Refuse Derived Fuel 1,810
Refuse Derived Fuel/Co-fired 1,810
Modular/Excess Air 220
Modular/Starved Air (small) 45
Modular/Starved Air (mid-size) ' 90
Fluidized Bed Combustion (Circulating Bed) 820
Fluidized Bed Combustion (Bubbling Bed) 820
S
L
L
L
L
L
L
S
S
S
L
L
steam
electric
electric
electric
electric
electric
electric
electric
none
electric
electric
electric
5,000
7,420
7,420
7,420
7,420
7,245
3,622
7,157
5,000
7,157
7,271
7,271
a Model Plants with design capacity less than or equal to 225 Mg per day are classified as small and plants with capacity greater than
225 Mg per day are classified as large. Specified control technologies (except materials separation) are assigned to model plants
according to this size classification.
-------
TABLE 2-2. CHARACTERISTICS OF GUIDELINES MODEL PLANTS
tn
Model
Plant Abbreviated
Number Term
1
2
3
4
5
6
7
8
9
10
11
12
' 13
14
15
16
17
MB/REF/TG
MB/REF/RG
MB/REF/RK
MBAVW(large)
MBAVW(mid-size)
MBAVW(small)
RDF (large)
RDF (small)
MOD/SA/TR
MOD/SA/G
MOD/EA
MB/RWW
TRANS MOD/EA
TRANS MB/WW
TRANS RDF (large)
TRANS RDF (small)
TRANS MB/RWW
Definition of Term
Mass Burn/Refractory Wall/Travelling Grate
Mass Burn/Refractory Wall/Rocking Grate
Mass Burn/Refractory Wall/Rotary Kiln
Mass Burn/Waterwall (large)
Mass Burn/Waterwall (mid-size)
Mass Burn/Waterwall (small)
Refuse Derived Fuel (large)
Refuse Derived Fuel (small)
Modular/Starved Air/TransferRams
Modular/Starved Air/Grates
Modular/Excess Air
Mass Burn/Rotary Waterwall
Transitional Modular/Excess Air
Transitional Mass Burn/Waterwall
Transitional Refuse Derived Fuel (large)
Transitional Refuse Derived Fuel (small)
Transitional Mass Burn/Rotary Waterwall
Model Model
Plant Plant
Capacity Size Energy
(Mg/day) Category3 Recovery
680
220
820
2,040
980
180
1,810
540
140
45
180
450
380
180
1,810
540
450
L
S
L
VL
L
S
VL
L
S
S
S
L
L
S
VL
L
L
none
none
none
electric
electric
electric
electric
electric
steam
none
steam
electric
electric
electric
electric
electric
electric
Annual
Operating
Hours
6,500
6,200
7,420
7,420
7,420
7,420
7,245
7,245
4,772
6,500
7,157
7,420
7,157
7,420
7,245
7,245
7,420
— — ^— —
225
or InS tg i SS i? ?3 °r efa-r° P Mg Per day are Classified as sma11' Plants with caPacy ««•««•
and less than or equal to 1,000 Mg per day are classified as large, and plants with greater than 1,000 Mg per day capacity are
classified as very large. Specified control technologies (except materials separation) are assigned to model plants according to this
size classification. •
-------
on a cost-minimizing choice criterion. In the NSPS Substitution Scenario, the impact of
substituting landfills or alternative MWCs for baseline MWCs, using a discrete choice model
based on historical patterns of choice, is estimated. This scenario was referred to as Scenario III
in the earlier analyses.
2.4 REQUIREMENTS OF THE REGULATION
In the 1989 EIA and R1A reports, five regulatory alternatives for the planned MWC
plants and five regulatory alternatives for existing plants were presented. The proposed
regulation appeared in the December 20,1989, Federal Register. In response to comments by
MWC owners and operators, equipment vendors, environmental organizations, government
officials, and other interested individuals, several changes were made in the regulation including
the addition of maximum emission limits for NOX, a cutoff for very small plants, and changes in
the size classification for existing plants. Table 2-3 outlines the maximum emission levels
allowed for the various types of pollutants controlled under the regulation. The proposed
materials separation requirements have also been revised to include a 100 Mg per day size cutoff.
2.4.1 Emission Reduction Requirements
The most significant change in the regulation since proposal involves a cutoff exempting
very small facilities. The regulation as proposed in the Federal Register covered all existing and
planned plants that burn MSW without regard to capacity, including medical waste incinerators
(MWIs) that combust MSW. Because MWIs will be controlled under separate regulation now
under consideration, however, EPA set a 35 Mg per day cutoff that exempts virtually all MWIs
(over 7,000 units) (White, 1990b). This cutoff also exempts MWCs under 35 Mg per day from
the emission requirements.
Despite the introduction of a size cutoff, the baseline waste combusted or number of
plants subject to regulation has not been changed. Even though the profile of existing facilities
does include a few MWCs below 35 Mg per day, these'plants constitute less than one percent of
baseline capacity. Furthermore, it is now believed that small MWCs with capacities between 35
and 100 Mg per day were underrepresented in the baseline data bases. Continued use of the
original baseline compensates to some degree for this shortcoming. Very small MWCs between
25 and 35 Mg per day must submit a report to qualify for the exemption. Very small MWCs
below 25 Mg per day capacity qualify without submitting a report.
2-6
-------
TABLE 2-3. EMISSION REDUCTION REQUIREMENTS FOR MWC PLANTS SUBJECT TO NSPS AND GUIDELINES
Control Technology
Basis
Emission Limits
CDD/CDF
CO
PM
S02
HC1
NOX
NSPS
Small Plants
(35 to 225 Mg/day)
GCP
DSI
FF
75 ng/dscm
50tol50ppmv
(Varies by technology)
34 mg/dscm
50% reduction or
30 ppmv
80% reduction or
25 ppmv
No Standards
NSPS
Large Plants
(> 225 Mg/day)
GCP
SD
FF
30 ng/dscm
50 to 150 ppmv
(Varies by technology)
34 mg/dscm
80% reduction or
30 ppmv
95% reduction or
25 ppmv
180 ppmv
Guidelines
Small Plants
(35 to 225 Mg/day)
GCP
ESP
500 ng/dscm
50 to 250 ppmv
(Varies by technology)
69 mg/dscm
No Guidelines
No Guidelines
No Guidelines
Guidelines
Large Plants
(225 to 1000 Mg/dity)
GCP
DSI
ESP
125 ng/dscm
(250 ng/dscm for RDF)
50 to 250 ppmv
(Varies by technology)
69 mg/dscm
50% reduction or
30 ppmv
50% reduction or
25 ppmv
No Guidelines
Guidelines
Very Large Plants
(>1000 Mg/day)
GCP
SD
ESP
60 ng/dscm
50 to 250 ppmv
(Varies by technology)
34 mg/dscm
70% reduction or
30 ppmv
95% reduction or
25 ppmv
No Guidelines
Key:
good combustion practices (GCP), dry sorbent injection (DSI), fabric filter (FF), spray dryer (SD), electrostatic precipitator (ESP), polychlorinated
dibenzo-p-dioxins and dibenzofurans (CDD/CDF), carbon monoxide (CO), paniculate matter (PM), sulfur dioxide (SOa), hydrogen chloride (HC1)
nitrogen oxides (NOx), nanograms (ng), dry standard cubic meter (dscm), parts per million by volume (ppmv), and milligrams (mg)
-------
New Size Classification
Plants are subject to different levels of emission control depending on their size
classification and the emission measure. Small plants between 35 and 225 Mg per day capacity
are subject to less stringent emission reduction requirements than large or very large plaints for
selected emissions (see Table 2-3). Similarly, for selected emissions, large Guidelines MWCs
with capacities between 225 and 1000 Mg per day are subject to less stringent emissions
requirements than verylarge Guidelines MWCs with capacities greater than 1000 Mg per day.
Estimates of economic impact arc based on the control technologies that would achieve emission
requirements for each plant size.
New Pollutant Included in Emission Requirements
This revised analysis includes a requirement covering NOX emissions for NSPS plants.
As shown in Table 2-3, NOX requirements are included for large NSPS plants only.
2.4.2 Materials Separation Requirements
Materials separation requirements covering both Guidelines and NSPS plants an;
included in the MWC regulations and have been incorporated into this revised EIA and RIA.
The materials separation requirements are summarized in Table 2-4 and apply only to MWCs
with capacities greater than 100 Mg per day. In addition, the materials separation requirements
have special provisions that relax these requirements somewhat for plants whose local markets
for secondary materials do not develop as anticipated.
The materials separation component of the revised EIA and RIA is based on the cost
analysis of materials separation programs contained in Air Pollutant Emission Standards and
Guidelines for Municipal Waste Combustors: Economic Analysis of Materials Separation
Requirement (EPA, 1990a). Cost estimates derived from this report are applied to model plants
with capacities greater than 100 Mg per day to obtain the cost components for the materials
separation requirements used in Chapter 5 (Byrd, 1990).
2-8
-------
TABLE 2-4. MATERIALS SEPARATION REQUIREMENTS FOR MWC PLANTS
SUBJECT TO NSPS AND GUIDELINES
Plant Size
(Mg per Day) Materials Separation Requirements
0 to 100 "
Over 100 • Annual percent weight reduction (separation) requirement prior to
combustion:
- 15 percent reduction in MSW by 1993 or first year of MWC
operation,
- 20 percent reduction in MSW by 1994 or second year of MWC
operation, and
- 25 percent reduction in MSW by 1995 or third and subsequent years.
• Credit is given for the separation of the following items: paper, metal,
glass, plastic, household batteries, vehicle batteries, tires, used oil,
household hazardous waste, and yard waste.
• Credit for yard waste separation is limited to a maximum of 10 percent.
• A program to remove lead-acid batteries from the MSW stream prior to
combustion is required.
2-9
-------
-------
CHAPTER 3
METHODOLOGY USED TO CALCULATE IMPACTS OF THE REGULATION
3.1 METHODS USED TO CALCULATE THE NO SUBSTITUTION SCENARIO
IMPACTS
Under the No Substitution Scenario, the cost of meeting the emission reduction
requirements and the materials separation requirements for planned and existing facilities is
calculated. Under this scenario, current and projected owners and operators of MWCs respond to
the regulation by adopting the control equipment identified in Table 2-3 and current and
projected owners and communities served by MWCs respond by implementing a materials
separation program.
Under this scenario three basic assumptions are made regarding the affected waste flow,
including the MSW combusted and the MSW diverted to a materials separation program:
1. Waste flows combusted do not change as communities implement separation
programs in response to the regulation. In other words, there is no change in capacity
utilization at existing plants and no downsizing of planned facilities.
2. Communities implement a materials separation program that ultimately results in 25
percent of the waste flow being diverted to a materials separation program.
3. The service area must be increased to account for the additional 25 percent of total
waste processed due to materials separation.
Tables 3-1 and 3-2 contain the estimated number of plants (scaling factors), estimated
MWC capacity, and estimated affected waste flow combusted for NSPS and Guidelines model
plant categories, respectively.
The model plant costs and national-level costs associated with meeting the emission
reduction requirements are calculated using the same methods and assumptions outlined in the
1989 EIA and RIA reports (EPA, 1989a; EPA, 1989b; EP^A, 1989c). These costs are based on
engineering cost estimates for model plants (EPA, l989c; EPA, 1989d; White, 1990a; Soderberg,
1990) and include the cost of retrofitting existing plants or installing control equipment at new
plants. Materials separation costs are assumed to be negligible for this analysis (EPA, 1990c).
Compliance costs do not include any baseline cost of building or operating the plants. Using
these input costs, the enterprise costs—the costs to the firm or entity that owns the MWC—and
the social costs of the regulation are estimated.
3-1
-------
TABLE 3-1. BASELINE SCALING FACTORS, PLANT CAPACITY, AND WASTE
FLOW ESTIMATES FOR MWC PLANTS SUBJECT TO NSPS3
Model Plant Model Plant
Number Description
1
2
. 5
4
5
6
1
8
9
10
11
12
MB/WW (small)
MB/WW (mid-size)
MB/WW (large)
MB/REF
MB/RC
RDF
RDF/CF
MOD/EA
MOD/SA (small)
MOD/SA (mid-size)
FBC/BB
FBC/CB
TOTAL
Individual
Model Plant
Capacity
(Mg/day)
180
730
2,040
450
950
1,810
1,810
220
45
90
820
820
Scaling
Factorsb
16.81
7.28
8.49
3.24
3.24
5.39
3.31
3.35
1.80
7.13
2.06
4.54
66.64
National National
Capacityc Waste Flow*1
(106 Mg/yr) (106 Mg/yr)
i.n
1.9?
6.33
0.54
1.12
3.57
2.19
0.27
0.03
0.24
0.61
1.35
19.29
0.64
1.63
5.36
0.45
0.95
2.95
0.91
0.22
0.02
0.19
0.51
1.12
14,95
a Details may not add to totals due to rounding.
b These scaling factors are based on the annual operating hours reported in Table 2-1, total
projected waste flows subject to NSPS, and the distribution of MWCs reported in the
Municipal Waste Combustors—-Background Information for Proposed Standards: lll(b)
Model Plant Description and Costs of Control (EPA, 1989d). These scaling factors are used
to estimate the number of MWC plants subject to NSPS under the No Substitution Scenario.
c National capacity estimates are calculated based on model plant capacity, an assumed 365-day
operating year, and model plant scaling factors reported in this table.
d Waste flow estimates are calculated based on the annual operating hours reported in Table 2-1
and the scaling factors presented in this table.
3-2
-------
TABLE 3-2. BASELINE SCALING FACTORS, PLANT CAPACITY, AND WASTE
FLOW ESTIMATES FOR MWC PLANTS SUBJECT TO EMISSION
GUIDELINES3
Model Plant Model Plant
Number Description
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
MB/REF/TG
MB/REF/RG
MB/REF/RK
MB/WW (large)
MB/WW (mid-size)
MB/WW (small)
RDF (large)
RDF (small)
MOD/SA/TR
MOD/SA/G
MOD/EA
MB/RWW
TRANS MOD/EA
TRANS MB/WW
TRANS RDF (large)
TRANS RDF (small)
TRANS MB/RWW
Assigned
Unassigned
TOTAL
Individual
Model Plant
Capacity Scaling
(Mg/day) Factors^
680
220
820
2,040
980
180
1,810
540
140
45
180
450
380
180
1,810
540
450
—
5.53
22.75
4.78
11.05
17.51
9.30
5.00
14.10
19.56
46.60
8.38
2.43
2.11
2.91
4.22
2.64
4.27
183.14
15.93
199.07
National National
Capacity* Waste Flowd
(106 Mg/yr) (106 Mg/yr)
1.37
1.81
1.42
8.23
6.26
0.62
3.31
2.80
0.97
0.77
0.55
0.40
0.29
0.19
2.79
0.53
0.71
33.04
2.84
35.87
1.02
1.28
1.21
6.97
5.30
0.52
2.74
2.32
0.53
0.57
0.45
0.34
0.24
0.16
2.31
0.43
0.60
27.00
2.35
29.35
a Details may not add to totals due to rounding.
b These scaling factors are based on the annual operating hours reported in Table 2-2, total
projected waste flows subject to Guidelines, and the distribution of MWCs reported in the
Municipal Waste Combustors—Background Information for Proposed Guidelines for Existing
Facilities (EPA, 1989c). These scaling factors are used to estimate the number of MWC
plants subject to Guidelines under the No Substitution Scenario.
c National capacity estimates are calculated based on model plant capacity, an assumed 365-day
operating year, and model plant scaling factors reported in this table.
d Waste flow estimates are calculated based on the annual operating hours reported in Table 2-2
and the scaling factors presented in this table.
3-3
-------
Chapter 3 of the 1989 EIA reports presents a cash flow model for calculating the net
present value of model plant costs and the parameters used to calculate these costs. These
parameters include the discount rate, tax rate, rate of inflation, length of investment period, and
depreciation method. For this update, these same parameters and assumptions are used to
calculate annualized enterprise costs of meeting the emission reduction requirement. To compute
annualized costs per Mg, the total control costs for the model plant are divided by the estimated
amount of waste combusted per year at the model plant
To calculate national-level costs, the costs for each model plant are multiplied by the
corresponding "No Substitution" scaling factor (see Tables 3-1 and 3-2). The scaling factors are
derived by dividing the estimated total waste combusted by plants in each model plant category
by the waste combusted by each model plant. Scaling factors roughly estimate the number of
plants represented by each model plant category. After multiplying the model plant cost by its
corresponding scale factor, these scaled costs are then summed across all the model plant
categories to compute national-level costs.
Table 3-2 shows that the national cost impacts for Guidelines plants include costs for
plants in an unassigned technology category. These are plants that do not match well with a
model plant category, size, and technology. An additional factor is used to adjust for this
problem. This factor is calculated as the ratio of total plant capacity affected by the regulation,
including the capacity represented by the unassigned technology, to the total affected capacity
assigned to a model plant category. Using the resulting factor, 1.087, the final estimate of
national costs is adjusted for existing plants. This factor reflects the implicit assumption that the
average compliance cost per Mg of waste combusted is the same for the unassigned plants as that
estimated for the assigned plants.
Estimates of national-level social costs are also presented. A different discounting
procedure from that used in computing enterprise costs was used to compute social costs (EPA,
1989a). Although this measure does attempt to account for the difference between social and
private rates of time preference, it is not quite an ideal estimate of social costs. In particular,
these elements of social cost due to the regulation as a whole are missing from the No "
Substitution Scenario:
• credit for the substitution of other, now less costly, forms of waste disposal for
combustion;
• credit for those MWCs that can already meet the emission requirements or that can do
so using technical or management methods that are less expensive than those identified
by EPA;
3-4
-------
• credits for the health and welfare benefits of emission reductions due to the
regulations;
• additions to cost for mandatory materials separation programs that require firms and
households to devote additional time and resources to processing and storing wastes
before collection;
• adjustment costs associated with shifting resources to meet the requirements of the
regulations;
• additional administrative costs borne by government entities and private organizations
associated with enforcing the regulations; and
• net credits or costs for increasing the size of the combustor service area.
3-5
-------
3.2 METHODS USED TO CALCULATE THE SUBSTITUTION SCENARIO
IMPACTS
The 1989 EIA and RIA reports (EPA, 1989a; EPA, 1989b; EPA, 1989f) contained a
substitution scenario for existing and planned plants called Scenario II and Scenario III
respectively. The methods used to calculate impacts under these substitution scenarios; are
described in detail in the 1989 EIA reports. With a few modifications the same descriptions
apply to the substitution scenarios presented in this update of the EIA and RIA reports. The
methods used to calculate impacts for planned MWCs have been modified to include the impacts
of downsizing plant capacity in response to the materials separation requirement. The methods
used to calculate impacts for existing plants have been modified to exclude control costs
attributable to so-called "baseline" substitution.
3.2.1 NSPS Substitution Scenario
For the NSPS Substitution Scenario, impacts are calculated under the assumption that
projected owners of MWC plants may respond to the regulation by substituting one combustion
technology for another or by substituting away from combustion to landfilling, resulting in fewer
combustors being built The steps outlined in order below are used to estimate impacts under the
NSPS Substitution Scenario:
1. Compute baseline waste flow shares subject to disposal choice for each disposal
technology including landfilling, mass burn combustion, modular combustion,
RDF/FBC combustion, and materials separation.
2. Compute revised waste flow shares subject to disposal choice for combustion and
materials separation assuming that MSW decision makers respond to the materials
separation requirement by downsizing planned MWC plant capacity.
3. Compute the incremental change in waste flow shares subject to disposal choice in
response to increased costs of combustion with the regulation.
4. Project the post-regulatory waste flow shares to each disposal technology keeping
total waste flow constant.
5. Calculate Substitution Scenario model plant scaling factors, national capacity, and
national waste flows based on the post-regulatory waste flow shares to combustion
technologies and downsized model plant capacity.
6. Multiply the model plant impacts at downsized plants by the Substitution Scenario
scaling factors to estimate national-level impacts.
Steps 3 through 6 are identical to those outlined in the 1989 EIA report (EPA, 1989b)
describing the methods used to calculate Scenario DI impacts. Steps 1 and 2 address the
3-6
-------
modifications in methodology to account for downsizing planned MWCs in response to the
materials separation requirement.
Table 3-3 reports the estimated baseline waste flows and waste flow shares subject to
disposal choice before and after downsizing. In Step 1, the "before downsizing" waste flow
shares subject to disposal choice are estimated. The combustion component of this total is based
on the projected waste flow to planned MWCs reported in Table 3-1. Specifically, the total
waste flow subject to disposal choice at mass bum facilities is estimated by summing the
national-level waste flows to planned mass burn model plants. This method is repeated for
modular and RDF/FBC facilities in turn. The landfilling and materials separation components of
estimated waste flow subject to disposal choice are based on the difference between the
respective 1991 waste flows and the respective 1996 projected waste flows reported in the
Characterization of Municipal Solid Waste in the United States: 1990 Update (EPA, 1990b).
In Step 2, the "after downsizing" waste flows subject to disposal choice are estimated.
Table 3-4 shows the revised capacity and waste flow projections for planned MWCs in each
model plant category based on the estimated percent reduction in plant capacity reported in Air
Pollution Emission Standards and Guidelines for Municipal Waste Combustors: Economic
Analysis of Materials Separation Requirement (EPA, 1990a). No change in plant capacity is
projected for model plants 9 and 10 because these plants are below the cutoff for the materials
separation requirement. Based on these percentage reductions in plant capacity, it is estimated
that 2.47 million Mg of waste is diverted from planned MWCs to materials separation in
response to the regulation. In Table 3-3,2.47 million Mg of MSW is subtracted from the "before
downsizing" combustion total and added to the "before downsizing" materials separation total to
compute the "after downsizing" waste flows. The waste flow to landfilling is unchanged.
In Step 3, the incremental change in waste flow shares is estimated as described in the
1989 EIA report using the Mathtech discrete choice model (Bentley and Spitz, 1989). First, the
waste flow shares after the inclusion of Subtitle D Costs for landfills are estimated using the
discrete choice model (see Table 3-5). These shares are the basis from which incremental
changes in waste flow shares are calculated. Next, estimated costs of control at downsized mass
bum, modular, and RDF/FBC MWCs are added to the model. This yields new estimates of
waste flow shares to each of the combustion technologies as well as landfilling. Using these
waste flow share estimates and the estimates reported in Table 3-5 (after inclusion of Subtitle D),
incremental changes in the waste flows are estimated.
3-7
-------
TABLE 3-3. ESTIMATED BASELINE WASTE FLOWS SUBJECT TO DISPOSAL
CHOICE BY TECHNOLOGY
Before Downsizing
Technology
Mass Burn
Modular
RDF/FBC
Landfill
Material Separation
TOTAL
10* Mg/yr
9.03
0.43
5.49
13.84
14.25
43.05
Share (%)
20.99
0.99
12.75
32.16
33.11
100.00
After Downsizing
106 Mg/yr
7.53
0.35
4.60
13.84
16.72
43.05
Share (%)
17.49
0.82
10.69
32.16
38.84
10000
3-8
-------
TABLE 3-4. ESTIMATED DOWNSIZING OF NSPS MODEL PLANTS DUE TO THE
MATERIALS SEPARATION REQUIREMENT
Model
Plant
Number
1
2
3
4
5
6
7
8
9
10
11
12
O T~»
Model Plant Description
MB/WW (small)
MB/WW (mid-size)
MB/WW (large)
MB/REF
MB/RC
RDF
RDF/CF
MOD/EA
MOD/SA (small)
MOD/SA (mid-size)
FBC/BB
FBC/CB
Model Plant
Capacity
Before
Downsizing
(Mg/day)
180
730
2,040
450
950
1,810
1,810
220
45
90
820
820
Estimated
Percent
Reduction in
Plant Size
(%)
18.01
16.26
16.62
16.68
16.68
16.23
16.31
17.25
Ob
Ob
15.88
15.88
Model Plant
Capacity
After
Downsizing
(Mg/day)
150
610 •
1,700
380
790
1,520
1,520
180
45
90
690
690
a For an explanation of percent reduction in plant size see Table 3-4 in Air Pollution Emission
Standards and Guidelines for Municipal Waste Combustors: Economic Analysis of Materials
Separation Requirement (EPA, 1990a).
b Model plants 9 and 10 are not downsized because plants below 100 mg per day capacity are not
subject to materials separation requirements.
3-9
-------
TABLE 3-5. WASTE FLOW SHARES ESTIMATED BY THE DISCRETE CHOICE
MODEL3
Technology
Mass Burn
Modular
Refuse-Derived Fuel
Landfill
TOTAL
Before Inclusion
of Subtitle D Costs
13.79%
5.94%
8.02%
72.25%
100.00%
After Inclusion
of Subtitle DCostsb
16.34%
6.91%
9.60%
67.15%
100.00%
a See A Model of the MSW Choice Decision (Bentley and Spitz, 1989) for an explanation of the
model used to estimate waste flow shares.
b Based on costs reported in the OSW Landfill RIA (Temple, Barker, and Sloan, Inc. ei al
1989).
3-10
-------
In Step 4, the incremental waste flow changes are applied to the "after downsizing"
shares reported in Table 3-3 to estimate the post-regulatory waste flows reported in Table 3-6.
As indicated in the table, an additional adjustment is made to keep total waste flows subject to
disposal choice constant.
Table 3-7 presents the Substitution Scenario model plant scaling factors and
corresponding national capacity and national waste flows estimated in Step 5. To compute these
scale factors, the total waste flow to a particular combustion technology reported in Table 3-6 is
allocated to the NSPS model plants using that same technology. This allocation is made in
proportion to the No Substitution waste flows to model plants using that combustion technology.
For example, estimated post-regulatory waste flows to mass burn MWCs are 5.29 million Mg per
year. There are 5 mass burn model plants. In the No Substitution Scenario, model plant 1
receives 7 percent of the waste flow processed at mass burn MWCs. Likewise, in the
Substitution Scenario, model plant 1 receives 7 percent of the waste flow processed at mass burn
facilities.
In Step 6, the scaling factors are used to calculate national level costs and emission
reductions under the Substitution Scenario. The scaling factors are multiplied by model plant
costs and emission reductions estimated for downsized facilities. These scaled impacts are then
summed across all model plant categories to compute national totals.
3.2.2 Guidelines Substitution Scenario
The Guidelines Substitution Scenario estimates the impacts of the regulation under the
assumption that MWC owners may respond to the regulation by substituting new MWC plants
for existing ones based on a cost-minimizing criterion. In addition, it is assumed that existing
plants are not downsized or operated at reduced capacity utilization in response to the materials
separation requirement. Rather, it is assumed that the service area must be increased to account
for the additional waste that must be collected to meet the materials separation requirement.
The methods used to describe Scenario H in the 1989 EIA report (EPA, 1989a) are
identical to those used to calculate the Substitution Scenario impacts reported in this update with
one exception. In the earlier report, control costs associated with meeting the NSPS at
replacement plants were attributed to the Guidelines regardless of whether the substitution was
due to normal baseline plant closure or the costs of the regulation. In this analysis, it is assumed
3-11
-------
TABLE 3-6. ESTIMATED WASTE FLOWS SUBJECT TO DISPOSAL CHOICE BY
TECHNOLOGY AND REGULATORY ALTERNATIVE (10* Mg/yr)
Baseline After F'ost-
Technology Downsizing Regulatory
Before Adjustment for Constant Total Waste Flow
Mass Burn 7.53 . 493
Modular 0.35 0.29
RDF/FBC 4.60 2.22
Landfill 13.84 16.28
Materials Separation 16.72 16.72
TOTAL 43.05 40.48
After Adjustment for Constant Total Waste Flow
Mass Burn 7.53 5 29
Modular 0.35 0.30
RDF/FBC 4.60 2.36
Landfill 13.84 17.31
Materials Separation 16.72 17.78
TOTAL 43.05 43.05
3-12
-------
TABLE 3-7. NATIONAL WASTE FLOWS AND SCALING FACTORS BY MODEL
PLANT CATEGORY UNDER THE NSPS SUBSTITUTION SCENARIO3
Model Plant Model Plant
Number Description
1
2
3
4
5
6
7
8
9
10
11
12
MB/WW (small)
MB/WW (mid-size)
MB/WW (large)
MB/REF
MB/RC
RDF
RDF/CF
MOD/EA
MOD/SA (small)
MOD/SA (mid-size)
FBC/BB
FBC/CB
TOTAL
Individual
Model Plant
Capacity
(Mg/day)
150
610
1,700
380
790
1,520
1,520
180
35
75
690
690
National National
Scaling Capacity0 Waste Flowd
Factorsb (10<> Mg/yr) (106 Mg/yr)
11.81
5.12
5.97
2.27
2.27
2.76
1.70
2.89
1.55
6.14
1.06
2.33
45.88
0.64
1.13
3.71
0.31
0.66
1.53
0.94
0.19
0.02
0.17
0.27
0.58
10.16
0.37
0.96
3.14
0.27
0.56
1.27
0.39
0.16
0.01
0.14
0.22
0.48
7.96
a Model plant capacity reflects downsizing. See Table 3-3 for estimated percent reduction in
plant size due to downsizing.
b These scaling factors are used to estimate the number of MWC plants subject to NSPS under
the substitution scenario.
c National capacity estimates are calculated based on model plant capacity, an assumed 365-day
operating year, and model plant scaling factors reported in this table.
d Waste flow estimates are calculated based on the annual operating hours reported in Table 2-1
and the scaling factors presented in this table.
3-13
-------
that control costs at new plants that substitute for existing MWCs in the baseline are included in
the costs of NSPS. Only those costs associated with substitution beyond the baseline axe
attributed to the Guidelines.
Using a cost-minimizing criterion it is estimated that substitution in the baseline will
occur for the three model plants listed in Table 3-8. No substitution beyond the baseline will
occur. These model plants represent older less cost-effective MWCs. It is assumed that the
existing plants represented by model plants 1, 2, and 3 would have been phased out and replaced
by new plants without the regulation. Therefore, Guidelines Substitution Scenario impacts
include costs and emission reductions for plants represented by model plants 4 through 17 only.
3-14
-------
TABLE 3-8. GUIDELINES SUBSTITUTION SCENARIO: BASELINE
SUBSTITUTION
Model Plant Cost per
p'ant Capacity Mg/MSW
Number (Mg/day) ($/Mg)
Before Substitution in the Baseline: Model Plant Costs0
1 680 46.40
2 . 220 63.30
3 820 36.20
After Substitution in the Baseline: New Plant Costs*
1 680 22.90
2 220 51.60
3 820 25.80
a Baseline costs are computed from operating costs only.
b Baseline costs are computed from capital costs annualized over 30 years, with a real discount
rate of 4 percent, plus operating costs.
3-15
-------
-------
CHAPTER 4
IMPACTS OF THE REGULATION
This chapter presents the model plant and national-level impacts of the regulation for
NSPS and Guidelines facilities. For the national-level impacts, the "No Substitution" impacts as
well as the "Substitution" impacts are presented. In addition, emission reductions and energy
impacts due to the regulation are presented.
4.1 MODEL PLANT IMPACTS
Tables 4-1 and 4-2 show the annualized enterprise costs of the regulation for publicly
owned model plants. For planned plants subject to NSPS, estimated compliance costs per Mg
combusted range from $8.83 to $47.40. Estimated compliance costs for existing plants range
from $0 to $20.40 per Mg combusted
Tables 4-3 and 4-4 present the annualized enterprise costs per Mg by MWC size
classification for publicly owned planned and existing plants, respectively. The emission
reduction requirements and the technology basis for each size classification are presented in
Chapter 2, Table 2-3. For both planned and existing plants, small plants are subject to less
stringent control than large plants. Under the Guidelines, large facilities are subject to less
stringent control than very large facilities. However, the NSPS plants over 1,000 Mg per day
capacity have the same requirements as those between 225 and 1,000 Mg per day capacity.
There is no regulatory distinction between "large" and "very large" planned plants.
In absolute terms, the estimated costs of compliance are lower for smaller plants with less
stringent requirements and higher for larger plants with more stringent requirements. The costs
per Mg do not reflect this because the larger plants are able to spread these costs over a greater
annual waste flow combusted.
Tables 4-5 and 4-6 present the baseline and post-regulatory enterprise costs for publicly
owned NSPS and Guidelines model plants, respectively. These tables also report the percentage
increase over the baseline associated with the post-regulatory costs. Post-regulatory costs range
from 22.4 to 314 percent over the baseline for NSPS plants. Impacts range from 0 to 270 percent
for Guidelines model plants.
4-1
-------
4.2 NATIONAL-LEVEL IMPACTS
Tables 4-7 and 4-8 show the national-level costs for MWC plants subject to NSPS and
Guidelines, respectively, under both the No Substitution and Substitution Scenarios. Under the
No Substitution Scenario, total waste flow to existing plants is approximately 2 times the
projected waste flow to planned plants. However, total annualized social cost for existing plants
is only 1.7 times the total cost/for planned MWCs because the requirements for planned facilities
are more stringent and, therefore, more costly to implement than the requirements for existing
plants. As a result, annualized social costs per Mg of waste combusted are about 14 percent
lower for existing facilities ($11.20) than for planned facilities ($13.00) under the No
Substitution Scenario.
Under the Substitution Scenario, the difference in total waste flow to planned versus
existing facilities is even greater. Under this Scenario existing plants combust over 3 times as
much waste as planned plants, while total annualized social costs for existing plants are less than
2.5 times the cost for planned plants. Annualized social costs per Mg combusted at existing
plants are about 20 percent lower than costs per Mg at planned plants.
Under the No Substitution Scenario, annualized enterprise costs for planned MWCs
average $11.20 per Mg combusted for plants subject to NSPS and $9.27 for plants subject to
Guidelines. Based on a full pass-through of these estimated enterprise control costs by the
MWC, this represents price impacts of 26 percent at NSPS plants and 22 percent at Guidelines
plants (see Tables 4-9 and 4-10). Impacts under the Substitution Scenario are 27 percent for
NSPS plants and 20 percent for Guidelines plants. An average tipping fee of $47.20 per Mg
(Pettit, 1988) at MWC facilities was used as the basis for calculating price impacts.
Tables 4-11 and 4-12 present the baseline emissions and emission reductions for planned
MWC plants subject to the NSPS and existing plants subject to the Guidelines, respectively.
Tables 4-13 and 4-14 present the energy impacts incremental to the baseline for NSPS and
Guidelines plants. These impacts do not reflect any emission reductions or energy impacts due
to materials separation.
4-2
-------
TABLE 4-1. ANNUALIZED ENTERPRISE COSTS OF CONTROL FOR PUBLICLY
OWNED NSPS MODEL PLANTS (1987$)«
Model
Plant
Number
1
2
3
4
5
6
7
8
9
10
11
12
Model
Plant
Description
MB/WW (small)
MB/WW (mid-size)
MB/WW (large)
MB/REF
MB/RC
RDF
RDF/CF
MOD/EA
MOD/SA (small)
MOD/SA (mid-size)
FBC/BB
FBC/CB
Model Plant
Capacity
(Mg/day)
180
730
2,040
450
950
1,810
1,810
220
45
90
820
820
Annualized
Enterprise
Compliance Costs
($l
-------
TABLE 4-2. ANNUALIZED ENTERPRISE COSTS OF CONTROL FOR PUBLICLY
OWNED GUIDELINES MODEL PLANTS (1987$)»
Model
Plant
Number
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
Model
Plant
Description
MB/REF/TG
MB/REF/RG
MB/REF/RK
MB/WW(large)
MBAVW(mid-size)
MB/WW(small)
RDF (large)
RDF (small)
MOD/SA/TR
MOD/SA/G
MOD/EA
MB/RWW
TRANS MOD/EA
TRANS MB/WW
TRANS RDF (large)
TRANS RDF (small)
TRANS MB/RWW
Model Plant
Capacity
(Mg/day)
680
220
820
2,040
980
180
1,810
540
140
45
180
450
380
180
1,810
540
450
Annualized
Enterprise
Compliance Costs
($103/yr)b
2,250
987
2,370
5,180
2,270
275
5,520
2,190
155
250
0
1,280
805
0
4,000
1,570
1,290
Annualized
Enterprise
Compliance Costs
($/Mg)c
12.20
17.60
9.39
8.22
7.51
4.90
10.10
13.30
5.73
20.40
0.00
9.1 [
7.09
0.00
7.30
9.56
9.17
Control costs are costs over the baseline model plant costs. These costs are incurred to meet the requirements of
the Guidelines.
b Total annualized costs based on a 15-year APCD life and a real discount rate of 4 percent
c Computed by dividing total annualized cost by the estimated amount of MSW combusted per year at the model
plant
4-4
-------
TABLE 4-3. ANNUALIZED ENTERPRISE COSTS OF CONTROL PER Mg MSW
COMBUSTED FOR PUBLICLY OWNED NSPS MODEL PLANTS BY
SIZE CLASSIFICATION (1987 $)a
MWC Plant Capacity
Small— Large— Very Large—
< 225 Mg/day 225-1000 Mg/day > 1000 Mg/dav
($/Mg) ($/Mg) . ($/Mg) "
Total 8.83 - 47.40 9.50 -18.20 9.26 - 14.10
a Costs are calculated using average capacity utilization based on the annual operating hours
reported in Table 2-1. Costs calculated on higher capacity utilization are presented in
Chapter 5. Estimates have not been adjusted to exclude plants under the 35 Mg per day cutoff
for the emission reduction requirement. Plants under 35 Mg per day account for less than 1
percent of the waste flow to planned plants in this analysis. Materials separation costs are
assumed to be negligible (EPA, 1990c). Quantitative estimates of materials separation costs
are presented for the sensitivity analysis discussed in Chapter 5.
TABLE 4-4. ANNUALIZED ENTERPRISE COSTS OF CONTROL PER Mg MSW
COMBUSTED FOR PUBLICLY OWNED GUIDELINES MODEL
PLANTS BY SIZE CLASSIFICATION (1987 $)*
_ MWC Plant Capacity
Small— Large— Very Large—
35-225 Mg/day 225-1,000 Mg/day > 1,000 Mg/dav
($/Mg) ($/Mg) ($/Mg) *
Total 0.00-20.40 7.09-13.30 7.30-10.10
a Costs are calculated using average capacity utilization based on the annual operating hours
reported in Table 2-2. Costs calculated on higher capacity utilization are presented in
Chapter 5. Estimates have not been adjusted to exclude plants under the 35 Mg per day cutoff
for the emission reduction requirement. Plants under 35 Mg per day account for less than 1
percent of the waste flow to planned plants in this analysis. Materials separation costs are
assumed to be negligible (EPA, 1990c). Quantitative estimates of materials separation costs
are presented for the sensitivity analysis discussed in Chapter 5.
4-5
-------
TABLE 4-5. ANNUALIZED ENTERPRISE COSTS AND PERCENTAGE INCREASE
IN COSTS FOR PUBLICLY OWNED NSPS MODEL PLANTS (1987$)"
Model
Plant
Number
1
2
3
4
5
6
7
8
9
10
11
12
Model
Plant
Description
MB/WW (small)
MB/WW (mid-size)
MB/WW (large)
MB/REF
MB/RC
RDF
RDF/CF
MOD/EA
MOD/SA (small)
MOD/SA (mid-size)
FBC/BB
FBC/CB
Baseline
Cost per
Mg MSWb
($/Mg)
75.40
20.70
9.40
44.00
21.30
3.69
17.70
30.50
54.20
30.10
13.20
13.20
Post-Regulatory
Cost
per
MgMSWC
($/Mg)
92.30
32.80
18.70
62.20
32.10
15.30
31.80
39.30
102.00
47.20
22.70
22.70
Percentage
Change
over
Baseline
22.4
58.7
98.6
41.4
50.9
314
79.3
29.0
87.4
56.5
72.3
72.3
a Materials separation costs are assumed to be negligible (EPA, 1990c). Quantitative estimates
of materials separation costs are presented for the sensitivity analysis discussed in Chapter 5.
b Baseline costs are computed from capital costs annualized over 30 years, with a real discount
rate of 4 percent, plus operating costs.
c Post-regulatory costs are baseline costs plus the cost of control.
4-6
-------
TABLE 4-6.
ANNUALIZED ENTERPRISE COSTS AND PERCENTAGE INCREASE
IN COSTS FOR PUBLICLY OWNED GUIDELINES MODEL PLANTS
(1987$)*
Model
Plant
Number
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
=5^^^^^=
Model
Plant
Description
MB/REF/TG
MB/REF/RG
MB/REF/RK
MBAVW(large)
MBAVW(mid-size)
MB/WW(small)
RDF (large)
RDF (small)
MOD/SA/TR
MOD/SA/G
MOD/EA
MB/RWW
TRANS MOD/EA
TRANS MB/WW
TRANS RDF (large)
TRANS RDF (small)
TRANS MB/RWW
Baseline
Cost per
Mg MSWb
($/Mg)
46.40
63.30
36.40
-3.13
5.08
24.40
-19.70
-4.94
5.17
23.80
3.39
10.50
14.20
24.40
14.20
27.40
10.50
Post-Regulatory
Cost
per
Mg MSWC
($/Mg) .
58.60
80.90
45.80
5.09
12.60
29.30
-9.66
8.39
10.90
44.10
3.39
19.60
21.30
24.40
21.50
36.90
19.60
Percentage
Change
over
Baseline
26.3
27.7
25.8
262
148
20.1
51.1
270
111
85.6
0
87.1
49.8
0
51.4
34.9
87.8
SB^ -—
Materials separation costs are assumed to be negligible (EPA, 1990c). Quantitative estimates
of materials separation costs are presented for the sensitivity analysis discussed in Chapter 5.
b Baseline costs are computed from operating costs only.
c Post-regulatory costs are baseline costs plus the cost of control.
4-7
-------
TABLE 4-7. NSPS NATIONAL COST IMPACTS (1987 $)»
Annualized
Social Costsb
Scenario ($10«/yr)
Annualized
Social Costs
perMg
MSWM
($/Mg)
Annualized
Enterprise
Costsc
($10«/yr)
Annualized
Enterprise
Costs per
Mg MSWc'd
($/Mg)
No Substitution
•
PM and Acid Gas control ' 168 11.20 145
NOX control 26.7 1.79 22.3
Materials Separation6 negligible negligible negligible
Total 194 13.00 167
9.69
1.49
negligible
11.20
Substitution
Total
107
13.50
91
11.50
a Costs are calculated using average capacity utilization based on the annual operating hours
reported in Table 2-1. Costs calculated for higher capacity utilization are presented in
Chapter 5. Estimates have not been adjusted to exclude plants under the 35 Mg per day cutoff
for the emission reduction requirement. Plants under 35 Mg per day account for less than 1
percent of the waste flow to planned plants in this analysis.
b Annualized social costs are the sum of capital costs, annualized at 10 percent, and annual
operating costs for MWC facilities or operators of materials separation programs.
c Annualized public enterprise costs are the sum of capital costs, annualized at 4 percent, and
annual operating costs for MWC facilities or operators of materials separation programs.
d Computed by dividing the total annualized cost by the estimated annual waste combusted at
MWC facilities affected by the regulation.
e Materials separation costs are assumed to be negligible (EPA, 1990c). Quantitative estimates
of materials separation costs are presented for the sensitivity analysis discussed in Chapter 5.
4-8
-------
TABLE 4-8. GUIDELINES NATIONAL COST IMPACTS (1987 $)«
Annualized
Social Costs5
Scenario (SlOVyr)
Annualized
Social Costs
perMg
MSWM
($/Mg)
Annualized
Enterprise
Costsc
($10*/yr)
Annualized
Enterprise
Costs per
Mg MSWc>d
($/Mg)
No Substitution
GCP,PM, and Acid Gas control 328
Materials Separation6 negligible
Total 328
11.20 272 9.27
negligible negligible negligible
11.20 272 9.27
Substitution
Total
265
10.40
222'
8.69
a Costs are calculated using average capacity utilization based on annual operating hours reported
in Table 2-2. Costs calculated for higher capacity utilization are presented in Chapter 5.
Estimates have not been adjusted to exclude plants under the 35 Mg per day cutoff for the
emission reduction requirements. Plants under 35 Mg per day account for less than 1 percent
of the waste flow to existing plants in this analysis and represent only a portion of the actual
population of existing plants under 35 Mg per day.
b Annualized social costs are the sum of capital costs, annualized at 10 percent, and annual
operating costs for MWC facilities or operators of materials separation programs.
c Annualized public enterprise costs are the sum of capital costs, annualized at 4 percent, and
annual operating costs for MWC facilities or operators of materials separation programs.
d Computed by dividing the total annualized cost by the estimated annual waste combusted at
MWC facilities affected by the regulation.
e Materials separation costs are assumed to be negligible (EPA, 1990c). Quantitative estimates
of materials separation costs are presented for the sensitivity analysis discussed in Chapter 5.
4-9
-------
TABLE 4-9. PERCENTAGE PRICE INCREASES BASED ON FULL PASS-
THROUGH OF ESTIMATED NSPS ENTERPRISE COSTS OF
CONTROL PER Mg OF MUNICIPAL SOLID WASTE3
Percentage
Scenario Increase
No Substitution 26
Substitution 27
a Based on average resource recovery facility tipping fee for 1988 of $43.96 per Mg (Pettit,
1989), converted to last quarter 1987$ to an average $42.70 per Mg.
TABLE 4-10. PERCENTAGE PRICE INCREASES BASED ON FULL PASS-
THROUGH OF ESTIMATED GUIDELINES ENTERPRISE COSTS OF
CONTROL PER Mg OF MUNICIPAL SOLID WASTE*
Percentage
Scenario Increase
No Substitution 22
Substitution 20
a Based on average resource recovery facility tipping fee for 1988 of $43.96 per Mg (Pettit,
1989), converted to last quarter 1987$ to an average $42.70 per Mg.
4-10
-------
TABLE 4-11. NSPS NATIONAL BASELINE EMISSIONS AND EMISSIONS REDUCTIONS (Mg per Yr)»
Scenario
No Substitution
Baseline Emissions
Emissions Reductions
from Baseline
Percent Reductions
from Baseline
Substitution
Baseline Emissions
Emissions Reductions
from Baseline
Percent Reductions
from Baseline
==^====^=^=5^====
CDD/CDF
0.031
0.030
97.8
0.015
0.014
97.5
CO
5,470
0
0
2,810
0
0
PM
7,540
5,270
69.8
4,076
2,870
70.5
==^=^=
SO2
42,000
36,400
86.7
21,700
18,700
86.0
HCI
49,300
47,200
95.8
26,200
25,100
95.6
Pb
127
123
97.5
71
69.4
97.6
NOX
27,700
9,340
33.7
•
14,700
4,920
33.4
Solid
Waste
Residuals'*
3,700,000
-332,000
-8.96
2,680,000
-167,000
-8.04
« \ A , . e vaues reporte er
baseline ""* emiSS1°n reductlon due to materials separation. MWCs subject to NSPS are assumed to have GCP in the
rcSidUal qUCnCh Waten Negative Values reflect increases in ash emissions relative to the
r >;dioxins and dibenzofurans (CDD/CDF), carbon monoxide (CO), paniculate matter (PM) sulfur
dioxide (S02), hydrogen chloride (HCI), lead (Pb), and nitrogen oxides (NOX). pdnituiaie matter (I'M), sulfur
-------
TABLE 4-12. GUIDELINES NATIONAL BASELINE EMISSIONS AND EMISSIONS REDUCTIONS (Mg per Yr)»
Scenario
CDD/CDF
CO
PM
SO2
HCI
Pb
Solid
Waste
Residuals1*
No Substitution
Baseline Emissions 0.213
Emissions Reductions 0.198
from Baseline
Percent Reductions 92.9
from Baseline
25,600
10,700
41.6
11,300
6,210
54.9
86,200
48,200
55.9
108,000
78,200
72.5
247
154
62.3
7,360,000
-214,000
-2.91
Substitution
Baseline Emissions
Emissions Reductions
from Baseline
Percent Reductions
from Baseline
0.126
0.115
15,500
3,560
5,340
1,240
76,700
45,500
94,300
72,800
124
•55:1
5,970,000
-446,000
91.6
22.9
23.2
59.3
77.2
44.4
-7.47
a Based on average capacity utilization reported in the 1988-89 Resource Recovery Yearbook (Gould, 1988). The values reported here
do not include any emission reduction due to materials separation.
b Includes bottom ash and fly ash with some residual quench water. Negative values reflect increases in ash emissions relative to the
baseline.
KEY: polychlorinated dibenzo-p-dioxins and dibenzofurans (CDD/CDF), carbon monoxide (CO), paniculate matter (PM) sulfur
dioxide (SO2), hydrogen chloride (HCI), and lead (Pb).
-------
TABLE 4-13. NSPS NATIONAL ENERGY IMPACTS3
Electrical Gas
Use Use
Scenario (Tj/yr) (Tj/yr)
No Substitution 951 0
Substitution '516 0
1 Energy impacts for air pollution control equipment only.
TABLE 4-14. GUIDELINES NATIONAL ENERGY IMPACTS3
Electrical Gas
Use Use
Scenario (Tj/yr) (Tj/yr)
No Substitution 760 809
Substitution 698 31 7
1 Energy impacts for air pollution control equipment only.
4-13
-------
-------
CHAPTER 5
SENSITIVITY ANALYSIS
In the 1989 EIA reports, a sensitivity analysis was performed to show how alternative
views of discounting affect the estimated impacts of the regulation. Additionally, impacts
calculated using a higher capacity utilization were reported in the earlier analysis. The purpose
of the sensitivity analysis in this update is to show the effect of changing the assumptions related
to materials separation costs and capacity utilization. •
Impacts reported elsewhere in this report are calculated under the assumption that costs
associated with the materials separation requirement are negligible (EPA, 1990c). Section 5.1
provides a sensitivity analysis of these results by presenting two alternative estimates of materials
separation costs. Section 5.1.1 outlines the methods used to calculate materials separation costs,
and Sections 5.1.2 and 5.1.3 present the model plant and national-level results of the sensitivity
analysis for materials separation costs, respectively. Both the No Substitution Scenario impacts
and the Substitution Scenario impacts are presented in Section 5.1.3.
Average capacity utilization estimates reported in the 1988-89 Resource Recovery
Yearbook (Gould, 1988) are used to calculate impacts reported throughout this report
Section 5.2 provides a sensitivity analysis using higher capacity utilization estimates to calculate
national-level costs and emission reductions.
5.1 MATERIALS SEPARATION SENSITIVITY ANALYSIS
5.1.1 Methods Used to Calculate Costs of the Materials Separation Requirements
It is assumed that the costs of meeting the materials separation requirement vary with the
municipality served by the MWC. The materials separation costs estimated for this sensitivity
analysis are based on those reported in the Air Pollution Emission Standards and Guidelines for
Municipal Waste Combustors: Economic Analysis of Materials Separation Requirement (EPA,
1990a). There are, however, several differences in the methods used in the Materials Separation
study and those used to estimate the costs of materials separation for this analysis. For example,
the Materials Separation study uses a model community/model program approach rather than a
model plant approach. The estimates of total waste flow and number of MWC plants affected by
the regulation also differ between the two studies. Outlined below are the adjustments and
methods used for this analysis.
5-1
-------
Costs presented in the Materials'Separation study vary by the type of materials; separation
program implemented and type of community served. The study presents 21 possible cost
combinations resulting from seven model communities based on population and population
density and three model programs based on the degree of curbside separation, the imposition of
mandatory participation ordinances, the application of unit pricing incentives, and the type of
post-collection processing.
Because of the uncertainty surrounding the type of separation program communities may
choose to implement, the effecnhe regulation will have on secondary materials markets, and the
variation in costs associated with landfilling and waste collection from community to
community, two estimates of materials separation costs using differing assumptions were
developed for the Materials Separation study. This effectively doubles the number of possible
cost combinations. These parallel cost estimates are identified in this analysis as materials
separation 1 and materials separation 2.
To estimate the materials separation 1 and materials separation 2 costs for the model
plants used in this analysis, the model program costs associated with each planned and existing
MWC facility in the Materials Separation study were identified (Byrd, 1990). Then the model
plant number corresponding to each plant was identified. The inventory of 67 planned plants in
the Materials Separation study is identical to the inventory used for this update. But the
inventory of existing plants (and the estimated waste flow to these plants) is different from the
inventory used for this update. This analysis includes approximately 200 existing plants, and the
Materials Separation study identified 213 existing plants. A model plant number for 156 of the
213 plants was identified based on lists contained in the Municipal Waste Combustors—
Background Information for Proposed Guidelines for Existing Facilities (EPA, 1989c). Of the
remaining 57 plants, 24 are in the unassigned technology category (Radian, 1988) and 33 are not
identified for the model plant analysis used to estimate impacts in the 1989 EIA and Rl A reports
and this update. Therefore, only cost data for the 156 plants were used for this analysis.
The components of the materials separation 1 and material separation 2 costs include
annualized capital costs, annual operating costs, avoided landfill costs, avoided transportation
costs, and materials recovery revenue. With the 67 planned plants and 156 existing plants, a
weighted average cost per Mg of waste combusted was calculated for each model plant category
using the formula below:
(I[(Kij + QJ) - (Lij + Try + Ry)])
WAG; = -*
5-2
-------
where
ij = The 1th MWC plant in the j* model plant category;
WACj = weighted average materials separation cost per Mg of waste combusted for the
jto model plant category;
K = annualized capital costs (Assumes a 4 percent discount rate for enterprise costs
and a 10 percent discount rate for social costs. Length of investment period
varies with the type of plant and equipment. These costs are the same for
materials separation 1 and 2.);
C = annual operating costs (Assumes these costs are the same each year over the
life of the MWC. Materials separation 1 costs are lower than materials
separation 2 costs. See the Air Pollution Emission Standards and Guidelines
for Municipal Waste Combustors: Economic Analysis of Materials Separation
Requirement (EPA, 1990a) for an explanation of these costs.);
L = avoided landfill costs (based on $45.64 per Mg of waste diverted for materials
separation 1 and $23.30 per Mg of waste diverted for materials separation 2);
Tr = avoided transportation costs (Avoided costs are higher in absolute value for
materials separation 1 and lower for materials separation 2. See the Air
Pollution Emission Standards and Guidelines for Municipal Waste
Combustors: Economic Analysis of Materials Separation Requirement (EPA
1990a) for an explanation of these costs.);
R = credits from the sale of recovered materials (Revenues are higher in absolute
value for materials separation 1 and lower for materials separation 2. See the
Air Pollution Emission Standards and Guidelines for Municipal Waste
Combustors: Economic Analysis of Materials Separation Requirement (EPA
1990a) for an explanation of these costs.); and
Q = the total amount of waste combusted per year at affected facilities.
Materials separation 1 and materials separation 2 costs per Mg are calculated in this way
for each model plant category above the 100 Mg per day cutoff for materials separation. For
those model plants below the cutoff, it is assumed that materials separation costs are zero. These
weighted average costs per Mg are used to calculate the national-level materials separation costs
for planned plants subject to NSPS and existing plants subject to Guidelines.
NSPS
For planned plants subject to NSPS, the weighted average cost per Mg is multiplied by
the estimated annual waste combusted at the corresponding model plant to compute the
annualized cost of materials separation for each model plant Then the annualized model plant
5-3
-------
cost is multiplied by its coiresponding scaling factor and summed over all the model plant
categories to compute NSPS national-level materials separation costs.
The scaling factors for the NSPS No Substitution Scenario are identical to those used for
calculating impacts assuming negligible materials separation costs (see Tables 3-1 and 3-2).
Consistent with the assumptions used to calculate impacts under the No Substitution Scenario, no
change in the waste flow or number of MWCs is projected with the alternative estimates of
materials separation costs.
For the NSPS Substitution Scenario, however, revised scaling factors are calculated for
model plants using the steps outlined in Chapter 3. Control costs including materials
separation 1 and materials separation 2 are inserted in the discrete choice model (Bentley and
Spitz, 1989) to estimate incremental changes in the waste flow shares. Using these costs in the
model results in a different projected waste flow share and, thus, a different incremental change
in the waste flow than that computed using negligible (or zero) costs for materials separation.
Table 5-1 reports the estimated waste flows to combustion, materials recovery, and landfilling
with materials separation 1 and. materials separation 2. The waste flow share to combustion is
then used to calculate revised scaling factors using the method described in Chapter 3. Table 5-2
reports the scaling factors, national capacity, and national waste flows estimated using materials
separation 1 and materials separation 2.
Guidelines
Model plant costs for existing plants subject to Guidelines are also computed by
multiplying the weighted average cost per Mg by the estimated annual waste combusted at the
corresponding model plant The scaling factors reported in Table 3-2 are the basis for calculating
national impacts under both the No Substitution and the Substitution Scenarios for Guidelines
plants. Before multiplying the model plant annualized costs by the scaling factors, however,
these scaling factors are adjusted to account for baseline recycling. It is estimated that
combustors in states with baseline recycling—excluding plants under 100 Mg per day capacity
account for 37 percent of the waste flow to existing MWC plants (Byrd, 1990). Therefore, those
existing plants in states with baseline recycling are excluded by multiplying the scaling factors in
Table 3-2 by 63 percent (100 percent less 37 percent). It is assumed that the distribution of plant
capacity and technology in states with recycling requirements is equivalent to the distribution of
MWC capacity and technology nationwide.
-------
TABLE 5-1. ESTIMATED WASTE FLOWS SUBJECT TO DISPOSAL CHOICE BY
TECHNOLOGY (10« Mg/Yr): WITH MATERIALS SEPARATION 1 AND
MATERIALS SEPARATION 2 COSTS
Technology
Baseline
Including
Subtitle D
Post-
Regulatory
with
Materials
Separation 1
Post-
Regulatory
with
Materials
Separation 2
Before Adjustment for Constant Total Waste Flow
Mass Burn 7.53
Modular . 0.35
RDF/FBC 4.60
Landfill 13.g4
Materials Separation 16.72
TOTAL
43.05
5.74
0.44
3.42
14.78
16.72
41.11
3.40
0.22
1.71
17.46
16.72
39.51
After Adjustment for Constant Total Waste Flow
Mass Burn
Modular
RDF/FBC
Landfill
Materials Separation
TOTAL
7.53
0.35
4.60
13.84
16.72
43.05
6.01
0.46
3.58
15.48
17.51
3.70
0.24
1.87
19.02
18.22
43.05
5-5
-------
TABLE 5-2. NATIONAL WASTE FLOWS AND SCALING FACTORS BY MODEL
PLANT CATEGORY UNDER THE NSPS SUBSTITUTION SCENARIO:
WITH MATERIALS SEPARATION 1 AND MATERIALS SEPARATION 2
COSTS3
Model Plant Model Plant
Number Description
Individual
Model Plant
Capacity
(Mg/day)
Scaling
Factor1*
National National
Capacity Waste FIowd
(106 Mg/yr) (10* Mg/yr)
With Materials Separation 1
1 MB/WW (small) 150
2 MB/WW (mid-size) 610
3 MB/WW (large) 1,700
4 ' MB/REF 380
5 MB/RC 790
6 RDF 1,520
7 RDF/CF 1,520
8 MOD/EA 180
9 MOD/SA (small) 35
10 MOD/SA (mid-size) 75
11 FBC/BB 690
12 FBC/CB 690
TOTAL
With Materials Separation 2
16.81
7.28
8.49
3.24
3.24
5.39
3.31
3.35
1.80
7.13
2.06
.4.54
66.64
13.42
5.81
6.78
2.58
2.58
4.19
2.58
4.42
2.37
9.39
1.61
3.54
59.27
0.52
1.37
4.47
0.38
0.79
2.47
0.76
0.18
0.01
0.16
0.43
0.94
12.48
1
2
3
4
5
6
7
8
9
10
11
12
MB/WW (small)
MB/WW (mid-size)
MB/WW (large)
MB/REF
MB/RC
RDF
RDF/CF
MOD/EA
MOD/SA (small)
MOD/SA (mid-size)
FBC/BB
FBQCB
TOTAL
150
610
1,700
380
790
1,520
1,520
180
35
75
690
690
16.81
7.28
8.49
3.24
3.24
5.39
3.31
3.35
1.80
7.13
2.06
4.54
66.64
8.26
3.58
4.17
1.59
1.59
2.18
1.34
2.32
1.24
4.92
0.84
1.84
33.87
0.52
1.37
4.47
0.38
0.79
2.47
0.76
0.18
0.01
0.16
0.43
0.94
12.48
scenario.
b These scaling factors are based on the annual operating hours reported in Table 2-1, total projected waste flows
subject to NSPS, and the distribution of MWCs reported in the Municipal Waste Combustors—Background
. Information for Proposed Standards: lll(b) Model Plant Description and Costs of Control (EPA, 1989d)
These scaling factors are used to estimate the number of MWC plants subject to NSPS under the No Substitution
Scenario.
c National capacity estimates are calculated based on model plant capacity, an assumed 365-day operating year, and
model plant scaling factors reported in this table.
d Waste flow estimates are calculated based on the annual operating hours reported in Table 2-1 and the scaling
factors presented in this table.
5-6
-------
The emission reduction values do not reflect any impact due to materials separation
requirements. Removing the target materials listed in Table 2-4 will likely have an impact on
emission factors. Nevertheless, no change in these factors resulting from a change in the
composition of waste combusted has been estimated. It should also be noted that the energy
impacts, similarly, do not reflect any impacts due to a change in the composition of waste
combusted.
5.1.2 Model Plant Impacts of the Materials Separation Requirements
Assumptions regarding materials recovery revenue, avoided landfill costs, and avoided
transportation costs lead to an estimated cost savings for most model plant categories with
materials separation 1. For materials separation 2, expenses outweigh avoided costs and
revenues. Therefore, estimated impacts calculated using materials separation 1 and materials
separation 2 bracket the impacts calculated using negligible costs for materials separation.
Tables 5-3 and 5-4 show the enterprise costs of the regulation for publicly owned model
plants with materials separation 1 and materials separation 2 costs. For planned plants subject to
NSPS, estimated compliance costs per Mg combusted range from $4.69 to $47.40 with materials
separation 1 costs and from $16.90 to $47.40 with materials separation 2 costs. Estimated
impacts for existing model plants with materials separation 1 costs range from negative $1.09
(reflecting cost savings due to materials recovery revenue) to $20.40 per Mg of waste combusted;
and impacts using materials separation 2 costs range from $13.70 to $28.90 per Mg combusted.
Tables 5-5 and 5-6 present the annualized enterprise costs per Mg by MWC size classification for
publicly owned planned and existing plants, respectively. Costs per Mg for the small plants vary
widely because this classification includes some plants with materials separation costs (those
above the 100 Mg per day materials separation cutoff) and some with no materials separation
costs (those below the cutoff).
Tables 5-7 and 5-8 present the NSPS baseline and post-regulatory enterprise costs for
publicly owned model plants with materials separation 1 costs and materials separation 2 costs,
respectively. These tables also report the percentage increase over the baseline associated with
the post-regulatory costs. Post-regulatory costs, including materials separation 1 costs, range
from 25.9 to 217 percent over the baseline. Impacts range from 44.1 to 542 percent with
materials separation 2 costs.
Tables 5-9 and 5-10 present the cost impacts with materials separation 1 and 2 for
publicly owned Guidelines model plants. Impacts range from 6.88 to 189 percent with materials
separation 1 costs and from 44.3 to 569 percent with materials separation 2 costs.
5-7
-------
TABLE 5-3. ANNUALIZED ENTERPRISE COSTS OF CONTROL FOR PUBLICLY OWNED NSPS MODEL PLANTS
(1987$): WITH MATERIALS SEPARATION 1 AND MATERIALS SEPARATION 2 COSTS*
Annualized Enterprise
Compliance Costs
Model
Plant
Number
1
2
3
4
5
6
7
8
9
10
11
12
Model Plant
Description
MB/WW (small)
MB/WW (mid-size)
MB/WW (large)
MB/REF
MB/RC
RDF
RDF/CF
MOD/EA
MOD/SA (small)
MOD/SA (mid-size)
FBC/BB
FBC/CB
Model Plant
Capacity
(Mg/day)
180
730
2,040
450
950
1,810
1,810
220
45
90
820
820
($io-y
Including
Materials
Separation 1
Costs
737
1,760
2,960
1,910
1,840
4,380
3,260
564
447
460
1,700
1,380
Annualized Enterprise
Compliance Costs
yr)b>d ($/Me)">,c,d
Including
Materials
Separation 2
Costs
1,260
4,460
10,800
3,660
5,510
11,000
4,910
1,400
447
460
4,790
4,180
Including
Materials
Separation 1
Costs
19.50
7.83
4.69
13.60
6.23
8.00
11.90
8.69
47.40
17.00
6.86
5.57
Including
Materials
Separation 2
Costs
33.30
19.90
17.10
26.10
18.70
20.00
18.00
21.61
47.40
17.00
19.35
16.90
—— ———•-•"— •••«*—»•• I'uuu. v^.ou. i ii\^>v< i.i*ju» cuw iiiwuiii/u lu mcci uic mjuirciiicnis 01 me INoro.
b Total annualized costs based on a 30-year plant life, 15-year APCD life, and a real discount rate of 4 percent.
c Computed by dividing total annualized cost by the estimated amount of MSW combusted per year at the model plant.
d For an explanation of the assumptions used to calculate materials separation 1 and 2, see the Air Pollution Emission Standards and Guidelines for Municipal Waste
Combustors: Economic Analysis of Materials Separation Requirement (EPA, 1990a). Materials separation costs do not include any allowance for costs to
hnimphnlsfc that J*rv* r^nnir^H tr\ c^noralA u»iof»o T*ha^a ^noto nff* «,-.* <-*f Is.nr4r:ii -,„-„-!. • ....
— as ...A 1, v—„ \,«oi»,o. >.,^ v»ow «r^ ...^ u. .oiidihi i,usis anu iransporiaiion cosis avoiaea because ot separation, and include credit for
the sale of materials recovered. The No Substitution costs do not include downsizing credits and were calculated based on the inventory of plants and projected
waste combusted by MWCs reported in Table 3-1.
-------
TABLE 5-4.
ANNUALIZED ENTERPRISE COSTS OF CONTROL FOR PUBLICLY OWNED GUIDELINES MODEL
PLANTS (1987$); WITH MATERIALS SEPARATION 1 AND MATERIALS SEPARATION 2 COSTS"
Annualized Enterprise
Compliance Costs
($iQ3/yr)M
Annualized Enterprise
Compliance Costs
Model
Plant
Number
1
2
3
4
5
6
9
10
14
1
12
13
14
15
16
17
====
A S*\ „ _ _ •
Model Plant
Description
MB/REF/TG
MB/REF/RG
MB/REF/RK
MBAVW(large)
MBAVW(mid-size)
MB/WW(small)
RDF (large)
RDF (small)
MOD/SA/TR
MOD/SA/G
MOD/EA
MB/RWW
TRANS MOD/EA
TRANS MB/WW
TRANS RDR (large)
TRANS RDF (small)
TRANS MB/RWW
Model Plant
Capacity
(Mg/day)
680
220
820
2,040
980
180
1,810
540
140
45
180
450
380
180
1,810
540
450
Including
Materials
Separation 1
Costs
1,610
737
632
2,280
921
506
2,720
1,540
245
250
-59.2
982
602
232
955
394
467
Including
Materials
Separation 2
Costs
3,790
1,650
7,300
11,300
5,490
1,430
10,500
3,960
675
250
742
3,460
2,310
1,160
9,250
3,270
2.660
*
\TW P
Including
Materials
Separation 1
Costs
8.74
13.10
2.51
3.61
3.04
9.03
4.97
9.37
907
•r *\J 1
20.40
-1.09
7.00
5.30
4.13
1.74
2.40
3.33
^ ••••••M^^— j^^^^^^^—
u.
Including
Materials
Separation 2
Costs
20.50
29 30
•** *r • ~t\J
28 90
<£rl)» S\J
nKO
• \J\J
18 10
1 CJ* 1 \J
25.50
19.30
24.10
25 00
£*+j .\J\J
20.40
1370
M. *J • 1 \J
2470
**~. / \J
2030
^*\jf *j\j
2060
*i\J,\J\J
1690
i \Jt *r\J
19 90
M. «?. X\-/
19.00
, ihe baseline model plant costs. These costs are incurred to meet the requirements of the Guidelines
Total annualized costs based on a 15-year APCD life and a real discount rate of 4 percent.
c Computed by dividing total annualized cost by the estimated amount of MSW processed per year at the model plant
For an expJanauon of the assumptions used to calculate materials separation 1 and 2, see the Air Pollution Emission Standards and Guidelines for Municipal
Waste Combustors: Economtc Analysts of Materials Separation Requirement (EPA, 1990a). Materials separation costs do not include any allowance for
costs to households that are required to separate wastes. These costs are net of landfill cosls and transportation costs avoided because of separation and
inctuaecredit tor the sale of materials recovered. The No Substitulion costs were calculated based on the inventory of plants and projected waste flows
-------
TABLE 5-5. ANNUALIZED ENTERPRISE COSTS OF CONTROL PER Mg FOR
PUBLICLY OWNED NSPS MODEL PLANTS BY SIZE
CLASSIFICATION (1987 $): WITH MATERIALS SEPARATION 1 AND
MATERIALS SEPARATION 2 COSTS3
MWC Plant Capacity
Small— Large— Very Large—
< 225 Mg/day 225-1000 Mg/day > 1000 Ms/day
($/Mg) ($/Mg) ($/Mg)
With Materials Separation131 8.69 - 47.40 5.57 -13.60 4.69 - 11.90
With Materials Separation13 2 17.00-47.40 16.90-26.10 17.10-20.00
a Costs are calculated using average capacity utilization values reported in the 1988-89 Resource
Recovery Yearbook (Gould, 1988). Cost per Mg based on a real discount rate of 4 percent.
Estimates have not been adjusted to exclude plants under the 35 Mg per day cutoff. Plants
under 35 Mg per day account for less than 1 percent of the waste flow to planned plants in this
analysis.
b For an explanation of the assumptions used to calculate materials separation 1 and 2, see the Air
Pollution Emission Standards and Guidelines for Municipal Waste Combustors: Economic
Analysis of Materials Separation Requirement (EPA, 1990a). Materials separation costs do
not include any allowance for costs to households that are required to separate wastes. These
costs are net of landfill costs and transportation costs avoided because of separation, and
include credit for the sale of materials recovered. The No Substitution costs do not include
downsizing credits and were calculated based on the inventory of plants and projected waste
combusted by MWCs reported in Table 3-1.
5-10
-------
TABLE 5-6. ANNUALIZED ENTERPRISE COSTS OF CONTROL PER Mg FOR
PUBLICLY OWNED GUIDELINES MODEL PLANTS BY SIZE
CLASSIFICATION (1987 $): WITH MATERIALS SEPARATION 1 AND
MATERIALS SEPARATION 2 COSTS3
MWC Plant Capacity
Small— Large— Very Large—
35-225 Mg/day 225-1,000 Mg/day > 1,000 Mg/day
($/Mg) ($/Mg) ($/Mg)
With Materials Separation15 1 (1.09)-20.40 2.40-9.37 1.74-4.97
With Materials Separation15 2 13.70-29.30 18.10-28.90 16.90-19.30
a Costs are calculated using average capacity utilization values reponed in the 1988-89 Resource
Recovery Yearbook (Gould, 1988). Cost per Mg based on a real discount rate of 4 percent.
Estimates have not been adjusted to exclude plants under the 35 Mg per day cutoff. Plants
under 35 Mg per day account for less than 1 percent of the waste flow to existing plants in this
analysis and represent only a portion of the actual population of existing plants under 35 Mg
per day.
b For an explanation of the assumptions used to calculate materials separation \ and 2, see the Air
Pollution Emission Standards and Guidelines for Municipal Waste Combustors: Economic
Analysis of Materials Separation Requirement (EPA, 1990a). Materials separation costs do
not include any allowance for costs to households that are required to separate wastes. These
costs are net of landfill costs and transportation costs avoided because of separation, and
include credit for the sale of materials recovered. The No Substitution costs were calculated
based on the inventory of plants and projected waste flows reported in Table 3-2.
5-11
-------
TABLE 5-7. ANNUALIZED ENTERPRISE COSTS AND PERCENTAGE INCREASE
IN COSTS FOR PUBLICLY OWNED NSPS MODEL PLANTS (1987$):
WITH MATERIALS SEPARATION 1 COSTS3
Model
Plant
#
1
2
3
4
5
6
7
8
9
10
11
12
Model
Plant
Description
MB/WW (small)
MB/WW (mid-size)
MB/WW (large)
MB/REF
MB/RC
RDF
RDF/CF
MOD/EA
MOD/SA (small)
MOD/SA (mid-size)
FBC/BB
FBC/CB
Baseline
Cost per
MgMSWb
($/Mg)
75.40
20.70
9.40
44.00
21.30
3.69
17.70
30.50
50.20
30.10
13.20
13.20
Post-Regulatory
Cost
per
Mg MSWC
($/Mg)
94.90
28.50
14.10
57.60
27.50
11.70
29.60
39.10
102.00
47.20
20.00
18.70
Percentage
Change
over
Baseline
25.9
37.9
49.9
30.9
29.4
217
67.2
28.6
87.4
56.5
52.2
42,4
a For an explanation of the assumptions used to calculate materials separation 1, see the Air
Pollution Emission Standards and Guidelines for Municipal Waste Combustors: Economic
Analysis of Materials Separation Requirement (EPA, 1990a). Materials separation costs do
not include any allowance for costs to households that are required to separate wastes. These
costs are net of landfill costs and transportation costs avoided because of separation, and
include credit for the sale of materials recovered. The No Substitution costs do not include
downsizing credits and were calculated based on the inventory of plants and projected waste
combusted by MWCs reported in Table 3-1.
b Baseline costs are computed from capital costs annualized over 30 years, with a real discount
rate of 4 percent, plus operating costs.
c Post-regulatory costs are baseline costs plus the cost of control.
5-12
-------
TABLE 5-8. ANNUALIZED ENTERPRISE COSTS AND PERCENTAGE INCREASE
IN COSTS FOR PUBLICLY OWNED NSPS MODEL PLANTS (1987$):
WITH MATERIALS SEPARATION 2 COSTS3
Model
Plant
Number
1
2
3
4
5
6
7
8
9
10
11
12
SS^^^H
Model
Plant
Description
MB/WW (small)
MB/WW (mid-size)
MB/WW (large)
MB/REF
MB/RC
RDF
RDF/CF
MOD/EA
MOD/SA (small)
MOD/SA (mid-size)
FBC/BB
FBC/CB
Baseline
Cost per
Mg MSWb
($/Mg)
75.40
20.70
9.40
44.00
21.30
3.69
17.70
30.50
50.20
30.10
13.20
13.20
^••^••i^MHB^BB
Post-Regulatory
Cost
per
Mg MSWC
($/Mg)
109.00
40.60
26.50
70.00
40.00
23.70
35.70
' 52.10
102.00
47.20
32.50
30.10
Percentage
Change
over
Baseline
44.1
96.1
182
59.3
88.1
542
101
71.0
87.4
56.5
147
129
B«^^M^=^^^=^=?—
1 For an explanation of the assumptions used to calculate materials separation 2, see the Air
Pollution Emission Standards and Guidelines for Municipal Waste Combustors: Economic
Analysis of Materials Separation Requirement (FJ>A, 1990a). Materials separation costs do
not include any allowance for costs to households that are required to separate wastes These
costs are net of landfill costs and transportation costs avoided because of separation and
include credit for the sale of materials recovered. The No Substitution costs do not include
downsizing credits and were calculated based on the inventory of plants and projected waste
combusted by MWCs reported in Table 3-1.
b Baseline costs are computed from capital costs annualized over 30 years, with a real discount
rate of 4 percent, plus operating costs.
c Post-regulatory costs are baseline costs plus the cost of control.
5-13
-------
TABLE 5-9. ANNUALIZED ENTERPRISE COSTS AND PERCENTAGE INCREASE
IN COSTS FOR PUBLICLY OWNED GUIDELINES MODEL PLANTS
(1987$): WITH MATERIALS SEPARATION 1 COSTS3
^— ^^BBa^B
Model
Plant
#
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
=^^==
Model
Plant
Description
MB/REF/TG
MB/REF/RG
MB/REF/RK
MB/WW(large)
-MB/WW(mid-size)
MB/WW(small)
RDF (large)
RDF (small)
MOD/SA/TR
MOD/SA/G
MOD/EA
MB/RWW
TRANS MOD/EA
TRANS MB/WW
TRANS RDF (large)
TRANS RDF (small)
TRANS MB/RWW
Baseline
Cost per
Mg MSWb
($/Mg)
46.40
63.30
36.40
-3.13
5.08
24.40
-19.70
-4.94
5.17
23.80
3.39
10.50
14.20
24.40
14.20
27.40
10.50
Post-Regulatory
Cost
per
Mg MSWC
($/Mg)
55.10
76.40
38.90
0.48
8.12
33.40
-14.80
4.42
14.20
44.10
2.29
17.50
19.50
28.50
16.00
29.80
13.80,
SSSSBS^S&^SS^S^SSS^SSSSSSSSSZ
Percentage
Change
over
Baseline
18.8
20.7
6.88
115
59.9
37.0
25.2
189
17.5
85.6
32.3
67.0
37.3
16.9
12.3
8.76
31.9
^^^B^^^gg^^^Bii"^»»»—^— -
a For an explanation of the assumptions used to calculate materials separation 1, see the Mr
Pollution Emission Standards and Guidelines for Municipal Waste Combustors: Economic
Analysis of Materials Separation Requirement (EPA, 1990a). Materials separation costs do
not include any allowance for costs to households that are required to separate wastes These
costs are net of landfill costs and transportation costs avoided because of separation, and
include credit for the sale of materials recovered. The No Substitution costs were calculated
based on the inventory of plants and projected waste flows reported in Table 3-2.
b Baseline costs are computed from operating costs only.
c Post-regulatory costs are baseline costs plus the cost of control.
-------
TABLE 5-10. ANNUALIZED ENTERPRISE COSTS AND PERCENTAGE INCREASE
IN COSTS FOR PUBLICLY OWNED GUIDELINES MODEL PLANTS
(1987$): WITH MATERIALS SEPARATION 2 COSTS*
Model
Plant
Number
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
Model
Plant
Description
MB/REF/TG
MB/REF/RG
MB/REF/RK
MB/WW(large)
MBAVW(mid-size)
MBAVW(small)
RDF (large)
RDF (small)
MOD/SA/TR
MOD/SA/G
MOD/EA
MB/RWW
TRANS MOD/EA
TRANS MB/WW
TRANS RDF (large)
TRANS RDF (small)
TRANS MB/RWW
Baseline
Cost per
Mg MSWb
($/Mg)
46.40
63.30
36.40
-3.13
5.08
24.40
-19.70
-4.94
5.17
23.80
3.39
10.50
14.20.
24.40
14.20
27.40
10.50
Post-Regulatory
Cost
per
MgMSWC
($/Mg)
66.90
92.60
65.30
14.70
23.20
49.90
-0.48
19.10
30.10
44.10
17.10
35.10
34.50
45.00
31.10
47.30
29.40
Percentage
Change
over
Baseline
44.3
46.2
79.4
569
357
105
97.6
487
483
85.6
405
236
143
84.6
119
72.7
181
TTTT ni
a For an explanation of the assumptions used to calculate materials separation 2, see the Air
Pollution Emission Standards and Guidelines for Municipal Waste Combustors • Economic
Analysis of Materials Separation Requirement (EPA, 1990a). Materials separation costs do
not include any allowance for costs to households that are required to separate wastes These
costs are net of landfill costs and transportation costs avoided because of separation and
include credit for the sale of materials recovered. The No Substitution costs were calculated
based on the inventory of plants and projected waste flows reported in Table 3-2.
b Baseline costs are computed from operating costs only.
c Costs of the regulation are baseline costs plus the cost of control.
5-15
-------
5.13 National-Level Impacts of the Materials Separation Requirements
Tables 5-11 and 5-12 show the national-level costs for MWC plants subject to NSPS and
Guidelines, respectively, under both the No Substitution and the Substitution Scenarios. Under
the No Substitution Scenario, annualized social costs per Mg of waste combusted are about
21 percent lower for existing facilities ($8.19) than for planned facilities ($10.30) using materials
separation 1 costs. Under the Substitution Scenario, average social costs per Mg combusted are
about 33 percent higher for planned facilities than for existing facilities using materials
separation 1 costs. Annualized social costs calculated using materials separation 2 estimates
average $22 to $23 per Mg of waste combusted for both planned and existing plants under both
economic impact scenarios.
Materials separation 1 annualized enterprise costs for planned MWCs average $7.48 per
Mg combusted for plants subject to NSPS and $5.00 for plants subject to Guidelines under the
No Substitution Scenario. Based on a full pass-through of these estimated enterprise control
costs by the MWC, this represents price impacts of 18 percent at NSPS plants and 12 percent at
Guidelines plants (see Tables 5-13 and 5-14). An average tipping fee of $47.20 per Mg (Pettit,
1988) at MWC facilities was used as the basis for calculating price impacts. Materials
separation 2 annualized enterprise costs at both planned and existing facilities average from $19
to $20 per Mg of waste combusted under the No Substitution Scenario. This represents price
impacts of slightly less than 50 percent Price impacts under the Substitution Scenario with
materials separation 1 are 19 percent and 11 percent for planned and existing plants, respectively.
Price impacts estimated using materials separation 2 under the Substitution Scenario are
approximately 40 to 50 percent for both planned and existing facilities
5.2 HIGH CAPACITY UTILIZATION SENSITIVITY ANALYSIS
For impacts reported elsewhere in this report, we adopted average capacity utilization
values reported in the 1988-89 Resource Recovery Yearbook (Gould, 1988) to calculate the waste
flows combusted at most of the model plants. (Capacity utilization values at some model plants
. were adjusted to reflect co-fired capacity, increased downtime at older or smaller plants, or a
stand-by unit) However, capacity utilization values reported in the Municipal Waste
Combustors—Background Information for Proposed Standards: lll(b) Model Plant
Description and Costs of Control (EPA, 1989d) and Municipal Waste Combustors—Background
Information for Proposed Guidelines for Existing Facilities (EPA, 1989c) average as much as
8 percentage points higher than those used in this report.
-------
TABLE 5-11. NSPS NATIONAL COST IMPACTS (1987 $): WITH MATERIALS
SEPARATION 1 AND MATERIALS SEPARATION 2 COSTS3
Annualized
Social Costsb
Scenario (SlO^/yr)
Annualized
Social Costs
per Mg
MSWM
($/Mg)
Annualized
Enterprise
Costsc
($10«/yr)
Annualized
Enterprise
Costs per
Mg MSWc'd
($/Mg)
No Substitution
PM and Acid Gas control 168
NOX control 26.7
Materials Separation le -40.2
Materials Separation 2e 135
Total with Materials Separation 1 154
Total with Materials Separation 2 329
11.20
1.79
-2.72
9.17
10.30
22.20
145
22.3
-54.7
121
113
288
9.69
1.49
-3.71
8.19
7.48
19.40
Substitution
Total with Materials Separation 1 114
Total with Materials Separation 2 125
11.30
21.50
82.1
106
8.16
18.30
a Costs arc calculated using average capacity utilization values reported in the 1988-89 Resource
Recovery Yearbook (Gould, 1988). Estimates have not been adjusted to exclude plants under
the 35 Mg per day cutoff. Plants under 35 Mg per day account for less than 1 percent of the
waste flow to planned plants in this analysis.
b Annualized social costs arc the sum of capital costs, annualized at 10 percent, and annual
operating costs for MWC facilities or operators of materials separation programs.
c Annualized public enterprise costs are the sum of capital costs, annualized at 4 percent and
annual operating costs for MWC facilities or operators of materials separation programs.
SSS?^ *? &vidinS me total annualized cost by the estimated annual waste combusted at
MWC facilities affected by the regulation.
6 F2r ^ exPlanation of *e assumptions used to calculate materials separation 1 and 2 see the Air
Pollution Emission Standards and Guidelines for Municipal Waste Combustors: Economic
Analysis of Materials Separation Requirement (EPA, 1990a). Materials separation costs do
not include any allowance for costs to households that are required to separate wastes These
costs are net of landfill costs and transportation costs avoided because of separation and
include credit for the sale of materials recovered. The No Substitution costs do not include
downsizing credits and were calculated based on the inventory of plants and projected waste
combusted by MWCs reported in Table 3-1. Total costs and average costs per Mg reflect the
assumption that all planned plants over 100 Mg are affected by the materials separation
requirement.
5-17
-------
TABLE 5-12.
GUIDELINES NATIONAL COST IMPACTS (1987 $): WITH
MATERIALS SEPARATION 1 AND MATERIALS SEPARATION 2
COSTS3
Annuaiized
Social Costsb
Scenario (SlOfyyr)
Annuaiized
Social Costs
perMg
MSWM
($/Mg)
Annuaiized
Enterprise
Costsc
(SlOVyr)
Annuaiized
Enterprise
Costs per
Mg MSWc'd
($/Mg)
No Substitution
GCP.PM, and Acid Gas control 328
Materials Separation le -53.9
Materials Separation 2e 223
Total with Materials Separation 1 274
Total with Materials Separation 2 551
11.20
-2.98
12.30
8.19
23.50
272
-77.4
200
195
472
9.27
-4.27
11.00
5.00
20.30
Substitution
Total with Materials Separation 1
Total with Materials Separation 2
219
470
7.53
23.10
157
406
4.62
20.10
_„-.„ __ „....., ^w..«,x» u»u»g urwAugw wu£/awAi.jr UUU&AUVS11 icpui ICU Ul LUC lyOO-Qy KSSOUfCS
Recovery Yearbook (Gould, 1988). Estimates have not been adjusted to exclude plants under
the 35 Mg per day cutoff. Plants under 35 Mg per day account for less than 1 percent of the
waste flow to existing plants in this analysis and represent only a portion of the actual
population of existing plants under 35 Mg per day.
b Annuaiized social costs are the sum of capital costs, annualized at 10 percent, and annual
operating costs for MWC facilities or operators of materials separation programs.
c Annuaiized public enterprise costs are the sum of capital costs, annualized at 4 percent, and
annual operating costs for MWC facilities or operators of materials separation programs.
d Computed by dividing the total annualized cost by the estimated annual waste combusted at
MWC facilities affected by the regulation.
e For an explanation of the assumptions used to calculate materials separation 1 and 2, see the Air
Pollution Emission Standards and Guidelines for Municipal Waste Combustors • Economic
Analysis of Materials Separation Requirement (EPA, 1990a). Materials separation costs do
not include any allowance for costs to households that are required to separate wastes. These
costs are net of landfill costs and transportation costs avoided because of separation, and
include credit for the sale of materials recovered. The No Substitution costs were calculated
based on the inventory of plants and projected waste flows reported in Table 3-2. Total costs
and average costs per Mg for materials separation are adjusted to exclude MWCs located in
states with mandatory recycling requirements and MWCs below 100 Mg per day capacity.
-------
TABLE 5-13. PERCENTAGE PRICE INCREASES BASED ON FULL PASS-
THROUGH OF ESTIMATED NSPS ENTERPRISE COSTS OF
CONTROL PER Mg OF MUNICIPAL SOLID WASTE: WITH
MATERIALS SEPARATION 1 AND MATERIALS SEPARATION 2
COSTS3
Percent
Scenario Increase
No Substitution
With Materials Separation 1 18
With Materials Separation 2 45
Substitution
With Materials Separation 1 19
With Materials Separation 2 43
a Based on average resource recovery facility tipping fee for 1988 of $43.96 per Mg (Pettit
1989), converted to last quarter 1987$ to an average $42.70 per Mg.
TABLE 5-14. PERCENTAGE PRICE INCREASES BASED ON FULL PASS-
THROUGH OF ESTIMATED GUIDELINES ENTERPRISE COSTS OF
CONTROL PER Mg OF MUNICIPAL SOLID WASTE: WITH
MATERIALS SEPARATION 1 AND MATERIALS SEPARATION 2
COSTS3
Percent
Scenario Increase
No Substitution
With Materials Separation 1 12
With Materials Separation 2 48
Substitution
With Materials Separation 1 11
With Materials Separation 2 47
Bfnol°n averageiresource recovery facility tipping fee for 1988 of $43.96 per Mg (Pettit
1989), convened to last quarter 1987$ to an average $42.70 per Mg.
5-19
-------
Tables 5-15 and 5-16 present the scaling factors and estimated waste flow combusted
calculated using the estimates of higher capacity utilization. Note that total waste flows subject
to NSPS and Guidelines are unchanged from the values calculated in Chapter 3, Tables 3-1 and
3-2. Keeping total affected waste flows constant results in a decrease in the estimated scaling
factor (number of model plants) as the amount of waste combusted at each plant increases. The
distribution of waste flows to existing model plants changes slightly because the scaling factors
are adjusted for model plant categories that contain transitional model plants only (EPA, 1989c).
The distribution of waste flows to NSPS facilities is not affected by the adjustments for higher
capacity utilization.
Tables 5-17 and 5-18 report the national social costs and national enterprise costs of the
regulation for plants subject to NSPS and Guidelines using the higher capacity utilization
estimates. These costs are 2 to 4 percent lower than the corresponding costs reported in
Tables 4-7 and 4-8. Using a higher capacity utilization results in no change in baseline emissions
or emission reductions for NSPS plants reported in Table 5-19. However, these values do change
slightly for existing facilities (Table 5-20) due to a change in the mix of facilities subject to
Guidelines.
-------
TABLE 5-15. HIGH CAPACITY UTILIZATION SCALING FACTORS, PLANT
CAPACITY, AND WASTE FLOW ESTIMATES FOR MWC PLANTS
SUBJECT TO NSPSa
Model Plant Model Plant
Number Description
1
2
3
4
5
6
7
8
9
10
11
12
MB/WW (small)
MB/WW (mid-size)
MB/WW (large)
MB/REF
MB/RC
RDF
RDF/CF
MOD/EA
MOD/SA (small)
MOD/SA (mid-size)
FBC/BB
FBC/CB
Model Plant
Capacity
(Mg/day)
180
730
2,040
450
950
1,810
1,810
220
45
90
820
820
Scaling
Factors5
16.81
6.75
7.88
3.00
3.00
4.88
3.00
3.00
1.80
6.38
1.88
4.13
Capacity0 Waste Flow<*
(10* Mg/yr) (106 Mg/yr)
1.11
1.79
5.87
0.50
1.04
3.23
1.99
0.24
0.03
0.21
0.56
1.23
0.64
1.63
5.36
0.45
0.95
2.95
0.91
0.22
0.02
0.19
0.51
1.12
TOTAL
62.50
17.79
14.95
a Details may not add to totals due to rounding.
b These scaling factors are based on the model plant annual operating hours and distribution of
MWCs reported in the Municipal Waste Combustors—Background Information for Proposed
Standards: lll(b) Model Plant Description and Costs of Control (EPA, 1989d) and the total
projected waste flows subject to NSPS reported in Table 3-1. These scaling factors are used to
estimate the number of MWC plants subject to NSPS assuming high capacity utilization.
c Capacity estimates are calculated based on model plant capacity, an assumed 365-day operatic
year, and model plant scaling factors reported in this table. ~
*Waste Combustors—Background Information for Proposed Standards: lll(b) Model Plant
Description and Costs of Control (EPA, 1989d) and the model plant scaling factors presented
in this table.
5-21
-------
TABLE 5-16.
HIGH CAPACITY UTILIZATION SCALING FACTORS, PLANT
CAPACITY, AND WASTE FLOW ESTIMATES FOR MWC PLANTS
SUBJECT TO EMISSION GUIDELINES3
Model Plant Model Plant
Number Description
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
MB/REF/TG
MB/REF/RG
MB/REF/RK
MB/WW (large)
MB/WW (mid-size)
MB/WW (small)
RDF (large)
RDF (small)
MOD/SA/TR
MOD/SA/G
MOD/EA
MB/RWW
TRANS MOD/EA
TRANS MB/WW
TRANS RDF (large)
TRANS RDF (small)
TRANS MB/RWW
Total Assigned
Unassigned
TOTAL
Model Plant
Capacity Scaling
(Mg/day) Factors^
680
220
820
2,040
980
180
1,810
540
140
45
180
450
380
180
1,810
540
450
—
5.53
22.75
4.78
10.13
15.39
9.30
5.00
14.10
18.75
46.50
8.38
2.43
1.64
2.34
3.31
2.08
3.44
183.14
15.93
199.07
Capacity* Waste Flow*1
(10* Mg/yr) (106 Mg/yr)
1.37
1.81
1.42
7.54
5.50
0.62
3.31
2.80
0.93
0.77
0.55
0.40
0.23
0.15
2.19
0.41
0.57
30.60
2.76
33.36
1.02
1.28
1.30
6.89
5.03
0.56
3.03
2.56
0.57
0.57
0.51
0.37
0.21
0.14
2.00
0.38
0.52
26.92
2.43
29.35
a Details may not add to totals due to rounding.
b These scaling factors are based on the model plant annual operating hours and distribution of
MWCs reported in the Municipal Waste Combustors—Background Information for Proposed
Guidelines for Existing Facilities (EPA, 1989c) and the total projected waste flows subject to
Guidelines reported in Table 3-2. These scaling factors are used to estimate the number of
MWC plants subject to Guidelines assuming high capacity utilization.
c Capacity estimates are calculated based on model plant capacity, an assumed 365-day operating
year, and model plant scaling factors reported in this table.
d Waste flow estimates are calculated based on the annual operating hours reported in Municipal
Waste Combustors—Background Information for Proposed Guidelines for Existing Facilities
(EPA, 1989c) and the model plant scaling factors presented in this table.
-------
TABLE 5-17.
NSPS NATIONAL COST IMPACTS UNDER THE NO SUBSTITUTION
SCENARIO (1987 $): HIGH CAPACITY UTILIZATION*
Annualized
Social Costs Annuaiized
PM and Acid Gas control
NOX control
Materials Separation6
Total
Annualized
Social Costsb
($10«/yr)
162
25.6
negligible
187
perMg
MSWM
($/Mg)
10.80
1.71
negligible
12.50
Enterprise
Costsc
($10«/yr)
141
21.6
negligible
163
B^^— »
Annualized
Enterprise
Costs per
Mg MSWc>d
($/Mg)
9.43
1.44
negligible
10.90
a Costs are calculated using high capacity utilization values reported in the MWCs—Background
,2&7U£™for Pr°P°sed Standards: lll(b) Model Plant Description and Costs of Control
(EPA, 1989d). Estimates have not been adjusted to exclude plants under the 35 Mg per day
cutoff for the emission reduction requirements. Plants under 35 Mg per day account for less
than 1 percent of the waste flow to planned plants in this analysis.
b Annualized social costs are the sum of capital costs, annualized at 10 percent, and annual
operating costs for MWC facilities or operators of materials separation programs.
c Annualized public enterprise costs are the sum of capital costs, annualized at 4 percent and
annual operating costs for MWC facilities or operators of materials separation programs.
SfJSSS1?1 & ?™®?tme total annualized cost by the estimated annual waste combusted at
MWC facilities affected by the regulation.
e Materials separation costs are assumed to be negligible (EPA, 1990c). Quantitative estimates
ot materials separation costs are presented for the sensitivity analysis discussed in Chapter 5.
5-23
-------
TABLE 5-18.
GUIDELINES NATIONAL COST IMPACTS UNDER THE NO
SUBSTITUTION SCENARIO (1987 $): HIGH CAPACITY
UTILIZATION*
Annualized
Social Costsb
($10«/yr)
Annualized
Social Costs
perMg
MSWM
($/Mg)
Annualized
Enterprise
Costsc
(SlOfyyr)
Annualized
Enterprise
Costs per
Mg MSWc»d
($/Mg)
GCP, PM, and Acid Gas control 319 10.90 266 9.07
Materials Separation^ negligible negligible negligible negligible
Total 319 10.90 266 9.07
a Costs are calculated using high capacity utilization reported in the Municipal Waste
Combustors—Background Information for Proposed Guidelines for Existing Facilities (EPA
1989c). Estimates have not been adjusted to exclude plants under the 35 Mg per day cutoff for
emission reduction requirements. Plants under 35 Mg per day account for less than L percent
of the waste flow to existing plants in this analysis.
b Annualized social costs are the sum of capital costs, annualized at 10 percent, and annual
operating costs for MWC facilities or operators of materials separation programs.
c Annualized public enterprise costs are the sum of capital costs, annualized at 4 percent, and
annual operating costs for MWC facilities or operators of materials separation programs.
d Computed by dividing the total annualized cost by the estimated annual waste combusted at
MWC facilities affected by the regulation.
e Materials separation costs are assumed to be negligible (EPA, 1990c). Quantitative estimates
of materials separation costs are presented for the sensitivity analysis discussed in Chapter 5.
-------
TABLE 5-19. NSPS NATIONAL BASELINE EMISSIONS AND EMISSIONS REDUCTIONS (Me per Yr)-
HIGH CAPACITY UTILIZATION"
Scenario
No Substitution
Baseline Emissions
Emissions Reductions
frr\m Rac*»lirn»
CDD/CDF CO
0.031 5,470
0.030 0
===s^
PM
7,540
5,270
SO2
42,000
36,400
HCI
49,300
47,200
Pb
127
124
NOX
27,700
9,340
Solid Waste
Residuals'*
3,700,000
-332,000
Percent Reductions
from Baseline
97.8
0
69.8
86.7
95.8
97.5
33.7
-8.96
Energy impacts for air pollution control equipment only.
qUCnCh Waten Negative Values reflect increases in ash emissions relative to the
Carb0"
«*»•
(PM), sulfur dioxide
-------
TABLE 5-20. GUIDELINES NATIONAL BASELINE EMISSIONS AND EMISSIONS REDUCTIONS (Mg per Yr)-
HIGH CAPACITY UTILIZATION"
Scenario
No Substitution
Baseline Emissions
Emissions Reductions
from Baseline
Percent Reductions from
Baseline
CDD/CDF
0.222
0.206
93.0
CO
26,400
11,200
42.6
PM
11,400
6,250
54.9
S02
86,600
48,300
55.8
HC1
108,000
77,400
71.7
Pb
248
153
61.9
Solid Waste
Residuals5
7,320,000
-212,000
-2.89
a Energy impacts for air pollution control equipment only.
b Includes bottom ash and fly ash with some residual quench water Negative values reflect increases in ash emissions relative to the
> carbon monoxide panicuuie matier (PM)- suifur
-------
CHAPTER 6
ANALYSIS OF ECONOMIC IMPACTS ON SMALL MWCs
Small MWCs in the context of this chapter include only those planned and existing
MWCs with capacities below 90 Mg per day. The requirements of the Regulatory Flexibility Act
(RFA) were used to help structure the analysis of impacts on small MWCs. Section 6.1 presents
an overview of the requirements of the RFA with regard to small businesses and small
governments. Section 6.2 describes the population of small MWCs identified. In Section 6.3 the
impacts of the regulation on the small MWCs affected by the regulation are analyzed.
6.1 REQUIREMENTS OF THE REGULATORY FLEXIBILITY ACT
The RFA requires that federal agencies consider whether regulations they develop will
have "a significant economic impact on a substantial number of small entities" (U.S. Small
Business Administration, 1982). Small entities may include nonprofit organizations, small
governmental jurisdictions, and small businesses. The RFA identifies small government
jurisdictions as those with populations less than 50,000. Small businesses are identified by the
Small Business Association general size standard definitions. For SIC code 4953, Refuse
Systems, small business concerns are those receiving less than $6 million dollars per year,
averaged over the most recent 3 fiscal years.
EPA (1982) provides guidelines for determining when a "substantial number" of these
small entities have been "significantly impacted." EPA suggests that a "substantial number" is
"more than 20 percent of these (small entities) affected for each industry the proposed rule would
cover." However, each office may develop its own criterion for defining a substantial number.
Impacts may be considered significant if any one of these conditions exist:
1. compliance costs are greater than five percent of production costs,
2. compliance costs, as a percent of sales, are at least 10 percent higher for small entities
than £>r other entities,
3. capital costs of compliance are a significant portion of capital available, or
4. the requirements are likely to result in closures of small entities.
6.2 PROFILE OF SMALL MWCs
A data base of small MWCs was constructed to determine whether the regulation will
have a significant economic impact on a substantial number of small entities. Current sources
including the following were consulted:
6-1
-------
• 1988-89 Resource Recovery Yearbook (Gould, 1988)
• City Currents
• Waste Age magazine (November 1987 and November 1989 issues)
• Kidder Peabody waste-to-energy industry analyses
• Municipal Waste Combustors—Background Information for Proposed Guidelines for
Existing Facilities (EPA, 1989c)
• Municipal Waste Combustors—Background Information for Proposed Standards •
lll(b) Model Plant Description and Costs of Control (EPA, 1989d)
The municipalities identified in the literature search were contacted to guarantee the
accuracy of the data. After excluding plants that were no longer in operation and planned plants
that had been cancelled, 45 MWCs with capacities of 18 to 90 Mg per day were identified.
Several sources containing financial data on small firms were also consulted to determine
the size of private firms identified as owners or operators of MWCs. These sources include the
following:
• Thomas Register of American Manufacturers Company Profiles
• Thomas Register of American Manufacturers Products and Services
• Moody's Industrial Manual
• Moody's Public Utility Manual
• Kelly's Business Directory
• Ward's Business Directory of US. Private and Public Companies
• Dunn and Bradstreet's Million Dollar Directory
• Dunn and Bradstreet" s Business Information Reports
For facilities where financial and operating information was unavailable or insufficient from
these sources, the MWC owners and/or operators, equipment vendors, and public officials were
contacted for supplementary data.
Data were collected for small MWCs with capacities of 18 to 90 Mg per day. Initially,
the«18 Mg per day lower limit was chosen in anticipation of a size cutoff designed to exclude
Medical Waste Incinerators (MWIs) from the regulation. [MWIs will be controlled under
separate regulation now under consideration, and roughly 90 percent of total MWI design
capacity and 99 percent of all MWI units are under 18 Mg per day (White, 1990b).] The cutoff
was subsequently set at 35 Mg per day, which exempted virtually all MWIs (over 7,000 units).
The 90 Mg per day upper limit was based on the assumption that a community with a population
of 50,000 would generate approximately 80 to 90 Mg of refuse per day. This calculation is based
on the 1988 estimated waste generation rate of 1.8 kg per person per day (EPA, 1990b).
Although a small community may own a MWC with a per-day capacity greater than 90 Mg, the
-------
facility probably serves more than 50,000 people. On the basis of population served, such a
community would not qualify as a small governmental jurisdiction (U.S. Small Business
Administration, 1982).
The 45 facilities identified for our analysis include 42 existing and 3 planned MWCs.
The small number of planned MWCs between 18 and 90 Mg per day capacity is due in pan to a
trend toward larger facilities. The 1988-89 Resource Recovery Yearbook (Gould, 1988) states
that the average design capacity for planned resource recovery plants is 790 Mg per day. This
represents a 19 percent increase in average facility size for planned units since 1986. There are
two possible explanations for this trend toward larger facilities. First, facilities are shifting away
from modular technology toward larger scale mass burn and RDF facilities (Gould, 1988).
Second, emission regulations further accentuate economies of scale that are already present in the
industry. As a result, an increasing number of communities are seeking to take advantage of
these economies of scale through regionalization.
Figure 6-1 shows the distribution of MWCs with capacities of 18 to 90 Mg per day. The
data indicate that MWCs are not concentrated toward either end of the spectrum, but that
modular units are commonly constructed in capacity increments of 23 Mg per day (25 TPD).
This accounts for the increased number of facilities within each range that encompasses multiples
of 23 Mg perday (e.g., 23 Mg per day falls in the 18-26 Mg per day category, 46 Mg per day
falls in the 45-53 Mg per day category). There are 35 facilities above and 10 below the 35 Mg
per day cutoff for emission reduction requirements. None of the facilities are subject to the
materials separation requirements.
Figure 6-2 shows the distribution of small MWCs by type of ownership. Only 6 of the
total 45 facilities identified are owned by private firms, with 3 of these 6 having small private
owners (as defined in Section 6.1). The remaining facilities are publicly owned—3 by the U.S.
military, 3 by states, and 33 by municipalities or counties. Figure 6-3 shows the distribution of
these publicly owned MWCs by ownership population. The critical value for the analysis of
ownership population is 50,000 because the RFA defines small government entities as those with
population below 50,000. Thirty small MWCs that are owned by local government entities have
populations below 50,000.
6-3
-------
10
8
Number 6
of Plants 4
2--
0--
8
18-26 27-35 36-44 45-53 54-63 64-72 73-81 82-90
Mg Per Day
Figure 6-1. Distribution of MWCs with Capacities of 18 to 90 Mg
per Day, by Capacity
N = 45
-------
Military
6.67%
Municipalities/
Counties
73.33%
13.33% Private
6.67% State
Figure 6-2. Distribution of MWCs with Capacities of 18 to 90 Mg
per Day, by Type of Ownership
N = 45
6-5
-------
Number of Publicly
Owned Plants
15T
10--
5--
0-4,999
12
8
5,000-
9,999
10,000-
24,999
25,000-
49,999
50,000-
99,999
over
•00,000
Ownership Population
Figure 6-3. Distribution of Publicly Owned MWCs with Capacities of
18 to 90 Mg per Day, by Ownership Population
N = 39
-------
63 ECONOMIC IMPACT ON SMALL ENTITIES
This analysis is limited to small MWCs above the 35 Mg per day cutoff; 32 existing and
3 planned MWCs with design capacities between 35 and 90 Mg per day were identified. Of
these, 17 percent are privately owned and 83 percent are publicly owned. Twenty-six facilities
are owned by small entities and 9 are owned by large entities. Table 6-1 presents these small
MWCs sorted by size of facility, size of owner, and type of ownership.
The 3 planned facilities include a 45 Mg per day publicly owned facility, a 68 Mg per day
privately owned facility, and a 64 Mg per day privately owned facility. Under the criteria cited
in Section 6.1, the publicly owned MWC is owned by a small entity and the privately owned
MWCs are owned by large entities. Given the low number of planned small facilities that exceed
the 35 Mg cutoff and the evidence of a trend toward larger facilities, the NSPS is not expected to
affect a substantial number of small planned MWCs. Therefore, this section focuses on existing
MWCs with capacities of 35 to 90 Mg per day when analyzing the economic impacts of the
regulation on small facilities. Indeed, as discussed in the next chapter, the regulation encourages
small facilities with capacities less than 35 Mg per day.
6.3.1 Analysis of Impacts on Governments
Plant-specific annual compliance costs for the small, publicly owned MWCs were
calculated as the first step in the analysis of impacts on governments. All of the plants in the
analysis of small MWCs are modular technology. Therefore, the costs for these facilities were
estimated based on the costs for Guidelines model plant 10, a modular plant with a capacity of
45 Mg per day. The costs for model plant 10 (based on the enterprise cost parameters for
publicly owned facilities) were scaled in proportion to the capacity of each plant in the data base.
It is assumed that the plants are just meeting federal standards for emissions in the baseline. This
assumption may tend to overestimate control costs for those plants with baseline controls in place
that remove more pollution than currently required by federal standards.
The assessment of the impact of the regulation on specific government entities used the
following three indexes designed to measure the entity's ability to meet the additional financial
obligations incurred due to the regulation:
1. the sum of the average sewerage and sanitation cost per household and the average
control cost per household as a percentage of median household income,
2. the sum of total debt service and additional debt service associated with the capital
cost of control as a percentage of total general revenues, and
3. control costs as a percentage of total general expenditures.
6-7
-------
TABLE 6-1. DISTRIBUTION OF MWCS BY FACILITY CAPACITY AND SIZE AND
TYPE OF OWNERSHIP
Plant Size (Mg per day)
and Type of Ownership
18-26
Public
Private
27-35
Public
Private
36-44
Public
Private
45-55
Public
Private
54 -63
Public
Private
64-72
Public
Private
73-57
Public
Private
52-90
Public
Private
Small
5
0
2
0
3
0
6
1
2
0
3
1
2
1
7
0
Size of Owner3
Large
3
0
0
0
1
0
1
0
1
0
1
2
1
0
1
1
B^BSSBB^MBSSS— — ===
Cumulative
Total
8
10
14
22
25
32
36
45
==^—
a For Standard Industrial Classification (SIC) 4953, Refuse Systems, small business concerns are
Uiose receiving less than $6 million per year averaged over the most recent 3 fiscal years
Small governmental jurisdictions are identified in the Regulatory Flexibility Act as those with
DODulations less than 50 OHO
populations less than 50,000.
-------
The first two indexes are adaptations of indexes used in Municipalities, Small Business,
and Agriculture (EPA, 1988) and are designed to measure each government's ability to issue
revenue bonds or obtain loans to finance the additional control costs. One percent is set as a
criterion for severity under Index 1; and 15 percent is set as a criterion for severity under Index 2.
It is noted, however, that severity under Indexes 1 and 2 is subject to a second criterion. Namely,
severity under both indexes must be indicated before a facility can be said to have a severe
impact due to the regulation.
The third index is used in the OSW Subtitle D Landfill RIA (Temple, Barker & Sloan, Inc.
et al., 1989) to measure the additional governmental cost burden associated with the regulation
relative to existing government expenditures. One percent is set as the criterion for severity
under this index.
Demographic and financial data were collected for each government entity identified in
the analysis using the 1988 County and City Data Book, Tennessee Statistical Abstract 1989, and
Virginia Statistical Abstract 1987. Local government officials supplied data that were
unavailable from these sources. All cost data were converted to last quarter 1987 dollars and
population data were projected to 1987 levels.
Impacts as measured by Index 1 could be calculated for only 3 of the MWCs in the
analysis due to data limitations. The measure of impacts using this index range from
1.08 percent to 7.39 percent. Impacts for all 3 facilities exceed the 1 percent criterion. However,
none of these 3 facilities exceed the 15 percent criterion for Index 2. Consequently, jointly
applying the second criterion indicates no severe impacts.
Figure 6-4 presents the distribution of impacts as measured by Index 2. Actual data on
debt service is not available for each of the communities, but, debt outstanding is available for 27
of the communities. To estimate the debt service for each community, a capital recovery factor
was first calculated based on an average municipal bond yield of 8.49 percent (calculated using
data from December 1983 through April 1990 for BAA rated municipal bonds in Moody's Bond
Guide) and a standard 20-year amortization period. This capital recovery factor was then applied
to the debt outstanding for each community to approximate the debt payments.
Impacts under Index 2 for individual communities range from 0.06 percent to
51.0 percent. Of the 27 communities, 7 have impacts exceeding the 15 percent criterion.
However, because of the limited data on sewerage and sanitation expenditures, it is impossible to
jointly apply the second criterion to identify whether these 7 facilities have severe impacts from
the regulation.
6-9
-------
Index 2a 10 4-
(median impact)
5 +
9.11
0-10,000 10,001-20,000 20,001-30,000 30,001-40,000 40,001-50,000 over 50 000
N»5 N»7 N»7 N»3 N*2 N=3
Service Area Population in 1987
Index 2 is the sum of total current debt service and additional debt service associated with
compliance to the regulation as a percent of total general revenues. The Municipal Sector
Study (U.S. EPA, 1988d) sets 15 percent as the criterion for severe impacts under this index.
Figure 6-4. Distribution of Government Impacts Under Guidelines for
MWC Plants with Capacities of 35 to 90 Mg per Day, by
Service Area Population: Index 2
N = 27
-------
Figure 6-5 shows the distribution of government impacts measured by Index 3. Data
were available to calculate impacts for 25 communities. Impacts range from 0.005 percent to
12.5 percent for these communities. Using the 1 percent criterion, it is estimated that 14 of the
25 facilities will suffer severe impacts.
6.3.2 Analysis of Impacts on Private Firms
Impacts of the regulation on private firms may be direct or indirect in nature. The owners
and operators of small MWCs who must install control equipment, train employees, or change
operating practices will have direct impacts. On the other hand, firms that supply services and/or
equipment to these small MWCs (but do not own a plant) will have indirect impacts and may
actually benefit from the regulation as the demand for air pollution control equipment and
technology increases.
In this section, the focus is limited to private firms that own small MWCs. Six privately
owned MWCs with capacities between 35 and 90 Mg per day are identified. Of these, 3 are
owned by small firms and 3 by large firms, based on the size classification for small businesses
(see Section 6.1). Four of these MWCs are existing and 2 are planned; the planned MWCs are
both owned by large firms.
Firm-specific data from which to compute impacts were unavailable from sources
containing financial data on small firms listed in Section 6.2. Small firms are not subject to the
same requirements regarding disclosure of costs and revenues as larger firms. Indeed, many
small firms regard these data as confidential business information. However, by contacting the
firms directly, limited data on annual revenues for 4 of the 6 firms were obtained. Two of the
firms only indicated that their annual sales exceeded $6 million criterion. To estimate
compliance costs at the existing plants, the compliance cost for Guidelines model plant 10 (based
on the enterprise cost parameters for privately owned facilities) was scaled in proportion to the
capacity of each plant. To estimate the compliance costs at the planned plants, the cost for NSPS
model plant 9 was scaled in proportion to the capacity of each plant.
Section 6.1 lists four measures for determining whether economic impacts are significant
for small entities. The first, third, and fourth measures apply absolute criteria, while the second
measure applies a criterion designed to show the adversity of the impact on small entities relative
to other, larger entities. Data were sufficient to calculate impacts under the first measure only
6-11
-------
4-r
3.92
Index 3
(median impact)
0-10,000 10,001-20,000 20,001-30,000 30,001-40,000 40,001-50000 over 50 000
N-4 N.7 N»7 N-2 N=2 N=3
Service Area Population in 1987
Index 3 measures control costs as a percent of total general expenditures. The OSW Landfill
RIA sets 1 percent as the criterion for severe impacts under this index
Figure 6-5. Distribution of Government Impacts Under Guidelines for
MWC Plants with Capacities of 35 to 90 Mg per Day,
by Service Area Population: Index 3
N = 25
-------
The first measure of economic impacts using EPA guidance outlined in Section 6.1 states
that when "compliance costs are greater than 5 percent of production costs" impacts may be
considered significant. EPA guidance does not define production costs in this context. However,
the following definitions are consistent with the intent of this measure of economic impacts:
1. Production costs include only the costs directly associated with operating the MWC
plant. &
2. Production costs include the costs directly associated with operating the MWC plant
plus the annualized capital costs of building the MWC plant.
3. Production costs include the costs directly associated with operating the MWC plant
the annualized capital costs of building the MWC plant, and costs associated with any
other business activities not directly related to combustion.
These definitions yield estimates of production costs in an increasing order of magnitude. As the
definition broadens, the likelihood of severe impacts declines.
To calculate impacts based on the first definition of production costs, we used baseline
operating and compliance costs for the model plants identified above. Compliance costs are
about 125 percent of production costs for planned plants and about 105 percent for existing
plants.
Calculating impacts based on the second definition is more complicated because data on
initial capital costs for existing facilities are not available. Consequently, annualized capital
costs were approximated using data from the cash flow analysis of NSPS model plant 9 for both
planned and existing plants. Compliance costs are about 90 and 66 percent of production costs
for planned and existing plants, respectively, based on the second definition of production costs.
Using the first two definitions of production costs to estimate compliance costs as a
percent of production costs will underestimate production costs and, thereby, overestimate
impacts for MWCs owned by firms that engage in business activities not directly related to
combustion. Because data on actual costs associated with these "non-combustion" activities are
not available, annual sales data were used to approximate production costs under definition 3
above. Using this method to approximate costs reflects the implicit assumption that the firms in
this analysis face perfectly competitive market structures. This assumption may tend to
overestimate production costs (and, thereby, underestimate impacts) for firms that do not operate
in perfectly competitive markets. Compliance costs are estimated to range from 20 to 25 percent
of production costs for planned plants and 15 to 65 percent of production costs for existing plants
based on the third definition of production costs.
6-13
-------
63.3 Analysis of Household Impacts
Increased costs of waste disposal due to the regulation will likely be passed on to
customers served by MWCs. Households generate most of the solid waste disposed of annually
and, as such, are one group of customers that will incur increased costs of waste disposal. To
estimate the additional burden on households associated with the regulation, demographic data
and annual compliance costs are used to calculate the following two indexes:
1. compliance cost per household, and
2. compliance cost per household as a percentage of median household income.
These two indexes are from the OSW Subtitle D Landfill RIA (Temple, Barker, and
Sloan, Inc. et al., 1989). The first index provides an absolute measure of additional household
burden while the latter provides a measure of the additional burden relative to a "representative"
household income specific to each community.
The methodology used to calculate plant-specific compliance costs and the sources used
to collect demographic data are the same as those described in Section 6.3.1 above. Where data
on the number of households were unavailable, the population was divided by the 1987 average
number persons per household reported in the 7990 Statistical Abstracts of the US.
Figure 6-6 presents the distribution of household impacts under the first index. Impacts
for 30 communities were calculated using this measure. Compliance costs per household range
from $5 to $329 per household per year for these communities. The OSW Subtitle D Landfill
RIA (Temple, Barker, and Sloan, Inc. et al., 1989) sets $220 as the criterion for severity. Under
this criterion, households in three communities will suffer severe economic impacts due to the
regulation.
Data on median household income were available for only four communities in the
analysis. Per capita income, number of persons per household, and the average ratio of mean to
median household income for the U.S. were used to estimate median household income for an
additional 24 communities. Average cost per household as a percent of median household
income ranged from 0.09 percent to 0.80 percent for these 28 communities. Household impacts
are defined as severe in the OSW Subtitle D Landfill RIA (Temple, Barker, and Sloan, Inc. et al.,
1989) if cost per household exceeds 1 percent of median household income. Under this criterion,
none of the households served by MWCs in the analysis will suffer severe economic impacts.
-------
211
Compliance
Cost per
Household3- b- c
($)
21
0-10,000
10,001-20,00020,001-30,00030,001-40,000 40,001-50000 over 50 000
N»7 N=8 N=3 N=3 N=3
Service Area Population in 1987
Costs refer to control costs only; no baseline costs are included.
Household impacts were defined as "severe" if average cost exceeds $220 per
household per year.
c Where data were unavailable on the number of households this was calculated based
on the average number of persons per household as reported in the 1990 Statistical
Abstracts.
Figure 6-6. Distribution of Household Impacts Under Guidelines for
MWC Plants with Capacities of 35 to 90 Mg per Day,
by Service Area Population: Index 1
N = 30
6-15
-------
63.4 Conclusion
Thirty-two small existing MWCs subject to the Guidelines and 3 small planned MWCs
subject to NSPS were identified. Of these, only 22 existing and 1 planned MWC are owned by
small entities. In absolute terms, this represents a small number of small firms and municipalities
affected by the regulation. In addition, this number represents a very small percentage of all
small combustors (including MWIs). Therefore, the regulation is not expected to affect a
substantial number of small plants.
The measures of impacts on households, governments, and private firms indicate that
some of these small communities and small owners will suffer severe impacts due to the
regulation. Therefore, EPA has taken measures to provide greater regulatory flexibility for small
plants. Specific mitigation measures that address the needs of small plants include
• a cutoff of 35 Mg per day for emission reduction requirements built into the regulatory
structure,
• a cutoff of 100 Mg per day for materials separation requirements built into the
regulatory structure,
• less stringent emission reduction requirements for small plants subject to the
regulation, and
• latitude for states to make case-by-case judgments on schedule and stringency under
the Guidelines.
Raising the cutoff further would not only reduce the proportion of small entities affected,
it would also exempt more large entities from the standards and result in higher MWC emissions.
The regulation will likely have a significant impact on all MWC plants, regardless of size.
To ensure that small facilities do not suffer disproportionately more severe impacts than large
facilities, EPA designed the regulatory flexibility measures mentioned above to help mitigate
impacts at small plants.
-------
1 T
Compliance
Cost per
Household as a
Percent of
Median
Household
Income3-b-c-d
0.11
0-10,000 10,001-20,00020,001-30,000 30,001-40,00040,001-50,000 over 50,000
N.5 N»7 N=8 N=3 N=3 N=2
Service Area Population in 1987
a Costs refer to control costs only; no baseline costs are included.
b Household impacts were defined as "severe" if average costs per household per year
exceeds 1 percent of median household income.
0 Where data were unavailable on the number of households this was calculated based
on the average number of persons per household as reported in the 1990 Statistical
Abstracts.
d Where data were unavailable on median household income, this was estimated based on
per capita income, number of persons per household, and the average ratio of mean to
median household income in the U.S.
Figure 6-7. Distribution of Household Impacts Under Guidelines
for MWC Plants with Capacities of 35 to 90 Mg per Day,
by Service Area Population: Index 2
N = 28
6-17
-------
-------
CHAPTER 7
SUBSTITUTION ACROSS THE EMISSIONS CUTOFF
Introducing a cutoff for emission control requirements protects small facilities from
excessive control costs.1 The cutoff also provides an opportunity for communities and firms
planning to build MWCs to reduce plant costs by building combustors with capacities less than
35 Mg per day.2 This prospect, referred to here as substitution across the emissions cutoff, arises
because the NSPS would increase the control costs of plants with capacities > 35 Mg per day but
not those of plants with capacities of 35 Mg per day or less.
In general, constructing and operating large combustors appears to offer some economies
of scale. All other things equal, larger plants have lower costs per unit of waste combusted and
communities have a financial incentive to build plants as large as justified by the amount of
waste produced by their service area. This accounts, in part, for the trend toward the construction
of bigger, regional combustor facilities.
If, however, control costs required by the NSPS are large enough, smaller plants that are
not required to meet the same emissions limits could become financially attractive. Communities
and firms may find it attractive to revise their plans and build one or more smaller combustors
that fall below the emission standards cutoff. This might especially be the case if the smaller
plants can also be built at favorable locations within the service area and confer reductions in
transportation costs.
Assuming that the potential for substitution across the cutoff applies primarily to smaller
plants with capacities between 35 and 225 Mg per day, the cutoff could affect up to 20 planned
plants representing total capacity of about 540,000 Mg per year and total waste flows combusted
of about 370,000 Mg per year by 1995.3 If, because of the shorter lead time required for smaller
facilities, the baseline forecast underestimates the number of small plants that would be affected
by the NSPS, even more plants and MSW would be affected. Such substitution would reduce the
1 Since the costs of the materials separation requirements have been estimated as negligible, the effects of the
materials separation cutoff are not considered in this discussion.
2 Based on its analysis of relative costs (see Chapter 4) the Agency does not anticipate that the regulations will
result the closing of existing MWCs and their replacement by new MWCs. Thus, substitution across the cutoff is
not an issue for the Guidelines.
3 Analysis of substitution across the cutoff is limited to modular technology because most plants in the size range
!SS&Sf IT t f r^n^"^,1^ S?""* °f afltoBd Capacity » based on ««*** represented
by NSPS model plants 8,9, and 10 (see Table 3-1). The estimate of affected waste now is based on a capacity
utilizauon rate of 68 percent applied to the estimated capacity. This capacity utilization rate is lower than
average capacity utilization rates used to calculate impacts in earlier chapters and reflects data on capacity
utilization garnered for the analysis of small facility impacts in Chapter 6.
7-1
-------
cost and increase emissions relative to the economic impact estimates for NSPS provided in
Chapters 4 and 5.
The analysis of this chapter:
• gauges the magnitude of incentive to "build small" created by the regulation;
• provides rough estimates of the change in plans that would result; and
• discusses circumstances that would encourage and discourage such a revision in plans.
7.1 ANALYTICAL FRAMEWORK
To assess the potential for substitution across the small size cutoff for emission standards,
a comparative cost analysis is used. The costs that are compared are those for small modular
plants that are not required to meet the emission requirements of the NSPS (< 35 Mg per day)
and those larger modular plants affected by the NSPS. The cost of the larger plants, with
controls, are compared to the minimum cost combination of smaller plants costs providing
equivalent service. If the smaller plants are less costly, then the substitution is likely to occur.
These comparisons are made for a profile of waste flows and plant sizes drawn from the
"No Substitution" waste flow and model plant forecast of Chapters 2 and 3. Additional detail for
this profile was drawn from information collected on the sizes and number of existing modular
plants for the small facilities analysis, the listing of planned facilities (EPA, 1989d), and data on
existing and planned modular plants contained in City Currents (U.S. Conference of Mayors,
1989). This profile is shown in Table 7-1.
Plants were allocated to the profile in Table 7-1 in two steps. For plants between 0 and
90 Mg per day capacity, a database on existing small facilities was used. The total capacity of all
facilities in the database was added, and this total capacity was compared to the capacity for
model plant categories 9 and 10 found in Table 3-1. The distribution of facilities in the database
was then scaled by this ratio of capacities to provide the distribution in the profile. A similar
method, using a different database, was used in. allocating the plants in the profile of facilities
sized 90-225 Mg per day. The total capacity of plants iij a database of medium facilities was
compared to the total capacity of model plant category 8 found in Table 3-1. The distribution in
this database was then scaled. Thus, Table 7-1 contains a profile of plants whose capacities add
to the total capacity of model plant categories 8,9 and 10.
-------
TABLE 7-1. PROFILE OF MODEL PLANTS
Capacity (Mg/day) Number
0-90
2
2
1
1
1
3
1
1
2
2
Total 15
90-225
3
1
1
Capacity
72.6
68
63.5
54.4
52.5
45.3
43
36
22.7
19
180
108
92
Total Capacity
145
136
63.5
54.4
52.5
136
43
36
45.4
38
540
108
92
Total
740
7-3
-------
7.1.1 Cost Estimation
The baseline costs of modular facilities were obtained from capital cost data collected as
part of the small facilities analysis and operating cost data contained in the new facilities cost
report (EPA, 1989e). Capital costs were estimated to be proportional to plant capacity.
Operating costs were estimated as a function of plant capacity and capacity utilization. Adding
estimated expressions for average annualized capital costs and average annual operating costs
resulted in the baseline average cost expression shown in Equation (7.1), where Q is capacity in
Mg per day and U is capacity utilization rate,
Average Baseline Cost per Mg of Waste Combusted = 31'97 ~ °'23Q + 55.06 (7.1)
For example, using Equation (7.1) the average baseline cost, including baseline control
equipment, for a 25 Mg per day plant with a utilization rate of 0.65, is estimated to be $95 per ton
of waste combusted.
The control costs for those plants subject to the NSPS are based on a fixed capital cost
component and an operating component, which is a function of waste flow and capacity
utilization (EPA, 1989d). Equation (7.2) shows the estimated expression for control cost as a
function of both the plant capacity and its utilization rate. In this expression, Q is capacity of the
plant in Mg per day, and U is capacity utilization rate:
Control Cost = 2.563^ +
(7.2)
Adding the average baseline cost and the control cost gives an estimate of the average
annual cost per Mg of waste combusted for a plant with a capacity > 35 Mg per day. These
combined expressions estimate, for example, that a 50 Mg per day plant with a capacity
utilization rate of 0.68 has a cost of $124 per Mg of waste combusted.
Equation (7.2) highlights the fact that control costs needed to ensure compliance with the
emission standards are significant in both absolute value and relative to baseline costs, especially
for those facilities just above the cutoff. These magnitudes in themselves suggest a strong
incentive for substitution across the emissions cutoff.
Actual costs for any particular facility can vary substantially from these estimates
depending on such factors as the price of land, composition of the trash, local labor and material
costs, type and intensity of energy recovery, and baseline emission controls. The cost functions
7-4
-------
employed in this analysis are based on relationships fitted to available data and reflect for the
most part modular facilities equipped with steam recovery in the 25 to 200 Mg per day capacity
range. These data were often quite limited, and the data that were available often exhibit
considerable variation across the various components of baseline and control costs.
Consequently, these cost equations and the analysis based on them represent best estimates of
"average" conditions. Choices actually made for or against substitution across the baseline as a
result of the NSPS can vary considerably in either direction from those characterized below due
to variation in costs, especially for plant sizes outside the range of our data or for different energy
recovery options.
7.1.2 Cost Comparisons
The cost functions described above are used to compare costs based on the "planned"
facility profile. Using the baseline and control cost equations, the average cost per Mg of waste
combusted for each planned facility is computed using that facility's estimated capacity and
capacity utilization.
The cost of meeting the same combustion requirements using some mix of small plants
was estimated using a non-linear, numerical optimization program called GINO and marketed by
LINDO Systems (Liebman et ah, 1986). This procedure identified the least-cost combination of
sizes and capacity utilization rates a small facility would need to achieve the same capacity and
waste combustion as the larger plant.
7.2 IMPACT OF THE CUTOFF ON FACILITY INVESTMENTS
When comparing the cost data for the large planned and least-cost combination of small
(< 35 Mg per day) facilities, substitution (on average) is projected to occur for those large
facilities whose average cost per Mg of waste combusted is less than for the small facilities. The
results show that a combination of smaller facilities would provide the same combustion services
at lower cost for all planned facilities projected in the profile to have less than 100 Mg capacity.
The results for all such planned facilities are summarized in Table 7-2.
All plants under 100 Mg per day capacity would be able to reduce their average cost per
Mg combusted when used in a combination of smaller facilities. These savings range from $46
per Mg at a 48 Mg per day capacity to $9 per Mg at 80 Mg per day capacity. The total annual
cost savings would be $2.14 million. Of the plants in the profile of plants in Table 7-1,11 of the
7-5
-------
TABLE 7-2. DIFFERENCE BETWEEN AVERAGE COST PER MG OF WASTE
COMBUSTED WITH ONE PLANT AND OPTIMAL NUMBER OF
PLANTS AT A GIVEN CAPACITY AND UTILIZATION RATE
Average Cost
Facility
Capacity
(Mg)
36
43
45.3
52.5
54.4
63.5
68
72.6
92
(dollars per Mg)
Capacity
Utilization
.5
.5
.68
.68
.68
.68
.68
.68
.68
1
Facility
173
159
122
120
119
112
108
105
93
2
Facilities
103
105
92
92
91
90
90
Difference
3 in Average
Facilities Cost
— 60
— 54
— 28
— 30
— 27
— 22
— 18
90 15
91 2
Annual Rate
Savings
(103$)
394
424
945
391
364
347
608
541
46
20 would be built with a combination of smaller facilities. The capacity of these 11 is 570 Mg
per day out of a total of 1,330 Mg per day for all 20 plants. The waste flow of these 11 plants is
approximately 90,000 Mg per year.
73 ADDITIONAL CONSIDERATIONS
The comparative cost analysis described above provides quantitative estimates of the size
of the financial incentive to substitute across the emissions cutoff and the waste flows and
capacities of planned modular facilities affected by this substitution. This section discusses
analytical elements that were not quantified that would work to either further discourage or
encourage such substitution beyond the levels identified above.
First, the magnitude of financial incentives for substitution across the cutoff could well be
reduced if constructing several smaller facilities also entailed substantial expenses that are
primarily a function of the number of facilities rather than the size of the facility per se. The cost
of land, siting, permitting, designing and other such "up-front" expenses may have such
properties and may not be properly reflected in the cost functions employed in this analysis.
7-6
-------
As part of the small facility analysis, however, data were collected on such up-front costs.
For the most part these up-front expenses are negligible or quite small. Most of the facilities are
publicly owned and the land on which they were built is often either owned by the community or
donated to the community. Siting and permitting costs are seldom broken out separately
(suggesting, perhaps, that they were not major cost items) and when they are broken out they are
small or negligible. For example, the Galax, Virginia plant, a $2.3 million dollar facility,
reported siting costs of $26,000 and included regulatory and permitting cost in a design fee of
$42,000. These costs were included among the data used to estimate the baseline capital cost
equations discussed above.
The quantitative analysis may also overestimate cost advantage of multiple small plants if
these plants are required by state or local regulations or opinion to control beyond the "baseline"
level. The importance of this consideration is difficult to gauge in as much as it depends on both
current and future approaches to emission regulation adopted by state and local authorities.
On the other hand, two other components of cost may, in fact, add additional financial
incentive for substitution across the baseline. As noted above, substituting several facilities for
one larger facility may significantly reduce the cost of transporting MSW for combustion. In
addition, some combination of landfilling in combination with one or more smaller combustors
may provide an even less costly alternative to the planned facility. To the extent that such
possibilities arc common and significant, substitution across the cutoff would be both more
frequent and more attractive than characterized in the quantitative analysis.
Second, the number and size of planned combustor facilities affected by the NSPS may
have been over or underestimated in the quantitative analysis. As already noted, the two- or
three-year planning horizon for modular facilities makes identifying what would have happened
over the five-year planning horizon covered by the economic impact analysis more difficult.
Trends toward regional combustor facilities, encouraged by economies of scale in mass burn and
other combustion technologies fabricated on site, lend support to the notion that small
combustors will provide only a small fraction of future waste combustion. On the other hand, the
recent difficulty communities have experienced in obtaining approval for large combustor
facilities may ultimately encourage greater reliance on smaller, local combustors where the
community served is also the community that produces the MSW. These opposing
considerations have not been formally factored into the quantitative analysis developed above.
7-7
-------
-------
REFERENCES
Bentley, Jerome T. and William Spitz. 1989. A Model of the MSW Choice Decision.
Prepared for the U.S. Environmental Protection Agency. Princeton, NJ- Mathtech
Incorporated.
Byrd, Denise. 1990. Memorandum to Brenda Jellicorse, Research Triangle Institute
Research Triangle Park, NC. October 9.
Gould, Robert, M.S., M.P.H., ed. 1988. 1988-89 Resource Recovery Yearbook,
Directory and Guide. Governmental Advisory Associates.
Liebman, Judith, Leon Lasdon, Linus Schrage, and Allan Waren. 1986. Modeling and
Optimization with GINO. The Scientific Press: Palo Alto, CA.
Pettit, C.L. 1989. "Tip Fees Up More Than 30% In Annual NSWMA Survev " Waste
Age (March): 101-106.
Soderberg, Eric. 1990. Memorandum to Brenda Jellicorse, Research Triangle Institute
Research Triangle Park, NC. August 31.
Temple, Barker & Sloan, Inc.; ICF, Inc.; DPRA, Inc.; and American Management
Systems, Inc. 1989. Draft Final Regulatory Impact Analysis of Revisions to Subtitle
£ f^?forM^CJ?,arl Solid Waste Landfills- Prepared for the Economic Analysis
Staff, Office of Solid Waste, U.S. Environmental Protection Agency.
United States Conference of Mayors. "Resource Recovery Activities," City Currents
Volume 8, Number 3, October 1989.
U.S. Environmental Protection Agency. 1982. Memoranda to Administrators and Office
Directors on EPA implementation of the Regulatory Flexibility Act. February 9.
U.S. Environmental Protection Agency. 1988. Municipalities, Small Business and
nS7{?SrC; ™eCha"f "8* °f Mating Environmental Responsibilities. Washington,
DC: Office of policy Planning and Evaluation. EPA-230-09/88-037.
U.S Environmental Protection Agency. 1989a. Economic Impact of Air Pollutant
Emission Guidelines for Existing Municipal Waste Combustors. Office of Air Quality
Planning and Standards. EPA-450/3-89-005. v"«"uy
U.S Environmental Protection Agency. 1989b. Economic Impact of Air Pollutant
Emission Standards for New Municipal Waste Combustors. Office of Air Quality
Planning and Standards. EPA-450/3-89-006. v"«""y
U.S. Environmental Protection Agency. 1989c. Municipal Waste Combustors—
BackgroundInformation for Proposed Guidelines for Existing Facilities. Office of
Air Quality Planning and Standards. EPA-450/3-89-27. v^ui.cui
U.S Environmental Protection Agency. 1989d. Municipal Waste Combustors —
n/JS*irars*tj*isi /*»/Vi»-*«^*-i*^— ^ — D_ i r*. * » T i r/t i ».* t t
s: /11(b) Model Plant Description
R-l
-------
U.S. Environmental Protection Agency. 1989e. Municipal Waste Combustors—
Background Information for Proposed Standards: Cost Procedures. Office of Air
Quality Planning and Standards. EPA-450/3-89-27a.
U.S. Environmental Protection Agency. 1989f. Regulatory Impact Analysis of Air
Pollutant Emission Standards and Guidelines for Municipal Waste Combustors.
Office of Air Quality Planning and Standards.
U.S. Environmental Protection Agency. 1990a. Air Pollutant Emission Standards and
Guidelines for Municipal Waste Combustors: Economic Analysis of Materials
Separation Requirement. EPA-450/3-91-002.
U.S. Environmental Protection Agency. 19905. Characterization of Municipal Soiid
Waste in the United States: 1990 Update. Office of Solid Waste and Emergency
Response (OS-305). EPA/530-SW-90-042.
U.S. Environmental Protection Agency. 1990c. Forthcoming. A-89-08, IV-E-24.
U.S. Small Business Administration. 1982. The Regulatory Flexibility Act. October.
White, David M. 1990a. Memorandum to Brenda Jellicorse, Research Triangle Institute
Research Triangle Park, NC. August?.
White, David M. 1990b. Memorandum to Michael Johnston, U.S. Environmental
Protection Agency and Walt Stevenson, U.S. Environmental Protection Agency
April 18.
-------
1. REPORT NO.
EPA-450/3/91-003
TECHNICAL REPORT DATA
!Please read Instructions on the reverse before completing)
2.
I. TITLE AND SUBTITLE
Air Pollution Emission Standards and Guidelines for
Municipal Waste Combustors: Revision and Update of
Economic Impact Analysis and Regulatory Impact Analys
3. RECIPIENT'S ACCESSION NO.
. RE PORT DATE . _--
November 1990
5. PERFORMING ORGANIZATION CODE
Glenn E. Morris, Brenda L. Jellicorse,
and Rhythm Sarmiento
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Center for Economics Research
Research Triangle Institute
Research Triangle Park, NC 27709
8. PERFORMING ORGANIZATION REPORT NO
RTI Project Number
233U-4300-09-10-FR
10. PROGRAM ELEMENT NO
1A1153C003
11. CONTRACT/GRANT NO.
EPA Contract
68D80073
12. SPONSORING AGENCY NAME AND ADDRESS
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Research Triangle Park, Nq, 27711
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
53C
15. SUPPLEMENTARY NOTES ~~ " ~
A companion report is "Economic Analysis of Materials Separation Requirement,"
EPA-450/3-91-002 (November 1990).
16. ABSTRACT
EPA is preparing for promulgation under Clean Air Act §111(b) emission standards
for new MWCs and, under §111(d), emission guidelines for existing MWCs. The
standards and guidelines will apply to MWCs with a capacity to combust 35.or
more Mg of municipal solid waste per day. This report updates "Economic Impact
of Air Pollutant. Emission Standards for New Municipal Waste Combustors,"
EPA-450/3-89-006 (August 1989), "Economic Impact of Air Pollutant Emission
Guidelines for Existing Municipal Waste Combustors," EPA-450/3-89-005 (August
1989), and "Regulatory Impact Analysis of Air Pollutant Emission Standards and
Guidelines for Municipal Waste Combustors," EPA, October 1989. This update
describes baseline projections of MWCs, economic analysis methodology, national
costs and emission reductions attributable to the standards and guidelines, the
sensitivity of costs to assumptions about capacity utilization and about
materials separation requirements, and how the standards and guidelines may
change communities' choices of waste disposal technology.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
18. DISTRIBUTION STATEMENT
Release unlimited
EPA Form 2220-1 (R«v. 4-77) previous EDITION is OBSOLETE
b.lDENTIFIERS/OPEN ENDED TERMS
19. SECURITY CLASS (This Report)'
Unclassified
20. SECURITY CLASS (Thispage!
Unclassified
c. COSATI Field/Group
21. NO/OF PAGES
120
22. PRICE
-------
U S. Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12tn Floor
Chicago, IL 60604-3590
------- |