960
COST AND ECONOMIC IMPACT ANALYSIS OF - ^
i^PD DISPOSAL RESTRICTIONS FOE
NEWLY LISIED WASTES AND CONTAMINATE!! DEBRIS
(PHASE 1LDR) £••
FINAL RULE
June 30, Wfl ••
Office of Solid Waste
B,, D.C. 20460
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Table of Contents . , Page i
TABLE OF CONTENTS
EXECUTIVE SUMMARY ES-1
ES.1- -Cost Impacts ; -.'..." ES-1
\ ' .
C" ' ES.2 Economic Impacts •....' ES-7
' . %
ES.3 Limitations . ES-9
CHAPTER L — INTRODUCTION ...'... .^.,.,..—1-U
V
1.1 , Regulatory History of the LDRs 1-2
1.2 Wastes Affected by the Phase 1 Rule 1-3
1.2.1 Petroleum Refining Wastes .'. 1-4
. 1.2.2 Newly Listed Organic Wastes 1-8
1.2.3 Hazardous Debris '. 1-12
1.2.4 Previously Regulated Wastes . 1-13
1.3 Containment Buildings 1-14
1.3.1 Background . 1-15
1.3.2 Industries and Wastes Potentially Using . ,
.. Containment Buildings for Management of Wastes 1-16
CHAPTER 2 — COST METHODOLOGY f. ^ 2-1
^ 2.1 Methodology for Wastes Affected by the Phase 1 Rule 2-1
^ 2.1.1 General Methodology •'...• 2-1
3 2.1^ Approach for Petroleum Refining. Wastes :....:. ....:.. 2-2
2.1.3 Newty Listed Organic Wastes : 2-5
2.1.4 Hazardous Debris ...'. '...• ......;..;...;... 2-6
2.1.5 Previously Regulated Wastes .-, 2-14
US EPA Headquarters Library - . .
40lMSt.,SW - (3404).
: 'Washington, DC 20460 . . .
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Table of Contents
2.2 Methodology for Assessing Potential Cost Savings of
Using Containment Buildings ... .................. . ....... - - . 2-jl§_
2.2.1 Background Information on the Facilities Considered . . . . ' ..... 2-16
2.2.2 Approach for Costing Containment Building ' "" •—-'-, —
Requirements ............. ........ . . . , ............... 2-18
2.2.3 Approach for Calculating Potential Cost Savings ............. 2-22
CHAPTER 3 - RESULTS OF COST ANALYSIS . . ........ -.-••:•: _____ ...... 3'1
3.1 Incremental Annual Costs for Wastes Affected
by the Phase 1 Rule . ........ ,: ........ ......... ---- . ......... 3-1
3.1.1 Petroleum Refining Wastes ............. . . . . i ......... ... 3-1
3.1.2 Newly Listed Organic Wastes ..... . ......... ............. 3-3
3.1.3 Newly Regulated Hazardous Debris ....;. ................ . . 3-4
3.1.4 Previously Regulated Hazardous Debris ..... . ---- ....... . . 3-13
3.1.5 Previously Regulated Wastes .......... ---- ........... ... 3-13
3.2 Potential Cost Savings from Storage and Treatment
in Containment Buildings - - - ........ -. ..... ............ - ....... 3-14
. 3.Z1 Overall Cost Savings from Containment Buildings ....... ...... 3-14
3.2.2 Costs of Containment Building Construction
and Operation and Maintenance ...... .................. - 3-18
3.2.3 Costs of Secondary Containment and
Fugitive Dust Abatement Equipment . . . . ...... . ........... 3-18
3.2.4 Costs of Recordkeeping . ..................... . ........ 3-18
i
3.2J Costs of Corrective Action ............ ......... ....... . 3-23
CHAPTER 4 — ECONOMIC IMPACTS ..... V ---- - - • - ........ : ...... : ---- -4-1
4.1 Petroleum Refining Wastes .......... . ........... .. .. ---- . ; ---- 4-1
4.2 Other Wastes ........ ..... ......... .............. '. ........ .4-2
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Table of Contents • '_ ] Page
CHAPTER 5 — LIMITATIONS TO THE COST AND
ECONOMIC IMPACT ANALYSIS 5-1
5.1 Limitations to the Cost Analysis .l '......*... 5-1
5.1.1 Process Wastes , :. - 5-1
5.1.2 Hazardous Debris ; 5-2 __.^
5.1.3 Containment Buildings 5-3
5.2 Limitations to the Economic Impacts Analysis 5-5
APPENDICES
A Calculation for P037 and P038 Volumes
B Costs and Benefits of Dredging and Closure Options for Petroleum Refining Surface
Impoundments . . .
C Unit Cost Data Gathered for Hazardous Debris Treatment Technologies
D: Guide for Structured Interviews Conducted for the Cost Analysis of Newly Regulated
Hazardous Debris . '
E Line Item Expense Projections Generated for Costing Containment Building Design and
Operating Requirements
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.Executive Summary . . Page ES-1
EXECUTIVE SUMMARY
Executive Order No. 12291 requires that regulatory agencies determine whether a new
regulation constitutes a major rulemaking, and, if so, it requires that the agency conduct a Regulatory
Impact Analysis (RIA). An RIA is the quantification of the potential'costs, economic impacts, and
benefits of a major rule. A major rule is defined in Executive Order No. 12291 as a regulation likely
to result in:
. • An annual effect to the economy of $100 million or more;
• A major increase in costs or prices for consumers, individuals, industries,
Federal, State, and local government agencies, or geographic regions; or
• Significant adverse effects on competition, employment, investment,
productivity, innovation, or on the ability of United States based enterprises
to compete with foreign based enterprises in domestic or export markets. •
, EPA estimated the costs of the final rule for the Land Disposal Restrictions.(LDRs)JJM\.
Phase 1 Newly Listed Wastes and Hazardous Debris (herein referred to as the Phase 1 rule) to
determine if it is a major regulation as defined by Executive Order 12291. EPA expects the final rule
to have an incremental annual cost below $100 million. EPA does not believe the rule will
significantly increase costs for consumers, individuals, industries, Federal, State and local government
\
agencies, or geographic regions; or have significant adverse effects on competition, employment,
investment, innovation, or international trade. EPA did not conduct a full RIA for this rulemaking.
ES.1 COST IMPACTS ' . ;
EPA has performed a Cost and Economic Impact Analysis, focusing its analyses on the costs
and economic impacts of the rule. EPA's cost analysis indicates the annual incremental costs of the
rule .will be between $57 million and $65 million per year. Exhibit ES-1 indicates the volumes of
waste affected by the rule; The cost of compliance with the rule for each waste is presented in
Exhibit ES-2.
F037 and F038 Petroleum Wastes
For F037 and F038 petroleum nonwastewaters, EPA estimates that the total annual
incremental cost of regulation will be between $40 million and $47 million. This figure is based on
an annual volume of 130,000 tons of F037 and F038 requiring additional treatment before disposal.
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Page £5-2
Executive Summajy
,'.„;_ _™,_^_ Exhibit ES-1
Summary of Annual Quantities of Wastes Affected by the Phase 1 Rule
- ;-<-- - ,\ ••' S'
* WA^fE: -
Petroleum Refining Sludge
(F037 and F038)
Unsymmetrical
-Dimethylhydrazine Production
Wastes~(K107-K110)
2-Ethoxyethanol Waste (U359)
Dinitrotoluene and
Toluenediamine Production
Wastes (Kill and K112, U328
and U353)
Ethylene Dibromide Production
Wastes (K117, K118, and K136)
and Methyl Bromide
Production Waste (K131 and
K132)
Ethylenebisdithiocarbamic Acid
Production Wastes (K123-
K126)
Debris Contaminated with
Newly Listed Wastes
Previously Regulated
Hazardous Debris
Electric Arc Furnace Dust
(K061)
>*••. X" ' •." ' \
DISPOSAL RATE
130,000 tons
No longer
produced
<500tons
3400 tons - Kill
Otons-K112
<500 tons of
U328andU353
< 100 tons K118
< 100 tons K132
< 100 tons K125
33,000 tons
1,000,000 tons
67,000 tons of low
zinc KQ61*
FORM OF WASTE
- -' '
Dewatered Sludge
•
Wastewater
Nonwastewater
Nonwastewater
Nonwastewater
i
Solid
Solid
Solid
GENERATION
- TSBHB
Routine
Routine
, Routine
Routine
Routine
Routine and
Intermittent
Routine and
Intermittent
Routine
a/ Of the set of wastes potentially affected by the new high temperature metal* recovery (HTMR) BDAT (i.e^ K061, K062,
and P006), EPA is considering K061 only. The quantity given for KD61 is baaed on the generation quantity instead of on
the quantity that will require additional treatment before land disposal.
This volume estimate does not include F037 and F038 nonwastewaters generated in California
because that State already has equivalent F037 and F038 land disposal standards. The estimate also
excludes the costs associated with the treatment of aqueous residuals from dewatering.
Hazardous Debris ,
There are two groups of hazardous debris regulated by this rule. The first group includes
hazardous debris regulated under previous LDR rules (Le,, the Solvents and Dioxins, California list,
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Executive Summary
PageES-3
.^-Exhibit ESr2^_
Summary of Annual Costs of LDiTPifas
WASTE
Petroleum Refining Sludge (F037 and
FQ38)&
Unsymmetrical Dimethylhydrazine
Production Wastes (K107-K110)
2-Ethoxyethanol Waste (U359)
Dinitrotoluene and Toluenediamine
Production Wastes (Kill and K112,
U328 and U353)
Ethylene Dibromide Production Wastes
(K117, K118, and K136) and Methyl
Bromide Production Waste (K131 and
K132)
Ethylenebtsdithiocarbamic Acid.
Production Wastes (K123-K126)
Debris Contaminated with Newly Listed
Wastes^
TOTAL FOR NEWLY LISTED WASTES
m^^^iti^&^i&^S^
Previously Regulated Hazardous
Debris^
Electric Arc Furnace Dust (K061)
POST-REGULATORY
COSTS
- " ;^T^*^'>?*'
58 to 66
6
0.4
1
03
0.2
, 15
81 to 89
970
19
BASELINE
COSTS
INCREMENTAL^
COSTS
iX^^U^.c -"'
18
0
0.1
1
'<«,
0.1
5
24
1,600
30
-40 to 47
0
0.3
6
03
0.2
10
57 to 65
J"^,v*"K^1*^">n> /* * v /
Y*.«: * <> v
(560)
(11)
:of
Note: Incremental cost sometimes doet not equal the difference between total posHxpilatoiy and total baseline coat* be
rounding. .
a/ The range of costs for F037 and F038 result from the range in unit costs assumed for reuse as fuel
in cement kilns (i.e., $700 per ton to $1200 per ton). This range is reflected in the total costs
shown for each column as well. •-
b/ Figures presented are median estimates obtained using probabilistic modeling.
£/ Incremental costs do not equal the difference between post-regulatory and baseline costs as
reported because of rounding. Results assume that all debris contaminated with organics (either
alone or in combination with inorganics) could be treated more cheaply as a result of the Phase 1
rule. .
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Page ES-4
Executive Summary
First Third, Second Third, and Third Third rules). The second group includes debris contaminated
with wastes newly regulated .underjhe^PhaseU..rule (e.g., F037 and F038). In its analysis of
raefifis, EPA sought to evaluate both the costs of compliance with the rule and the sources
of uncertainty surrounding this cost estimate. A lack in understanding of the future debris volumes
requiring treatment and the treatment approaches to be used for these volumes make up the main
sources ^f uncertainty in the debris analysis.
EPA based its analysis of previously regulated hazardous debris on information supplied by
EPA and contractor staff familiar with the cost and capacity determination analyses performed for
the Phase 1 rule. EPA based its analysis of newly regulated hazardous debris on the quantified
judgments of highly experienced environmental management personnel at facilities affected by this
rule. Structured interviews were conducted to obtain volume and cost information from experts.
EPA then developed a weighting scheme to extrapolate data gathered during interviews to the
universe of facilities generating newly regulated hazardous debris. For both previously and newly
regulated hazardous debris, EPA developed volume and cost estimates using a probabilistic model
involving a standard Monte Carlo simulation.
The cumulative frequency distributions that EPA generated for previously regulated hazardous
debris volumes and costs are presented in Exhibits ES-3 and ES-4, respectively. EPA estimates that
an annual volume of previously regulated hazardous debris between 750,000 tons and 3 million tons
will require additional treatment.before disposal The median estimate is 1 million tons, and the
mean estimate is 1.4 million tons. (All estimates are probabilistic and are not the products of
calculations.) The impact of the Phase 1 rule on the cost of treating previously regulated hazardous
debris is expected to fall between a cost savings of $3 billion and a cost of $300 million.1 The
.median estimate is a cost savings of $560 million, and the mean estimate is a cost savings of $780
minion. EPA believes that because of the skewed distribution, the median is a better predictor of
"central value."
The cumulative frequency distributions that EPA generated for newly regulated hazardous
debris volumes and costs are presented in Exhibits ES-5 and ES-6, respectively. The volume of newly
regulated hazardous debris is believed to fall within the range of 18,000 tons to 120,000 tons per year,
with the median estimate being 33,000 tons per year. The incremental cost of treatment of debris
contaminated with newly regulated wastes has an estimated 98 percent credible interval ranging from
a lower bound estimate of about $4 million per year to an upper bound estimate of $120 million year.
1 In actuality, the wont case scenario for total incremental cost would be SO million since the new standards allow
toe old standards to be used if'they are lest costly.
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Executive Summary
Page £5-5
Exhibit ES-3
Estimated Cumulative Probability Distribution of Volume
, of Previously Regulated Hazardous Debris
Cumulative probability
1 i
0.75
0.5-
0.25-
500K 1M 1.5M 2M 2.5M 3M
> Estimated Volume of Previously Regulated Hazardous Debris (tons/year)
The estimated median incremental annual cost is $10 million and the estimated mean incremental
annual cost is $18 million.
Containment Buildings ,
The Phase 1 rule includes a provision for the design and operating standards for containment
«*
buildings, which are a new hazardous waste management unit Given the data available, EPA was
not able to calculate the national level cost savings associated with the containment building
provision. Instead, EPA conducted an analysis to assess the potential cost savings of using a
containment building at generic facilities of several sizes managing hazardous debris and at typical
facilities in three industries that generate process waste which potentially could be managed in
containment buildings. Exhibits ES-7 and ES-8 show the results of EPA's analysis of the potential
costs savings from the containment building provision, assuming three and seven percent social
discount rates, respectively. For. a three percent discount rate, the calculations indicate that the use
of containment buildings designed to store the typical waste quantities associated with the three
industries considered and to treat hazardous debris could result in significant cost savings. Aluminum
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Page ES-6
Executive .Summary
Exhibit ES-4
Estimated Cumulative Probability Distribution of Incremental Annual Cost
-PreYioilsJy Regulated Hazardous Debris
0.75
0.5
0.25
•6 -4 -2 0 ' . • 2
Estimated Cumulative Probability Distribution of Incremental Annual Cost
of Treating Previously Regulated Hazardous Debris ($billion/year)
reduction facilities may save approximately $700,000 per facility annually; lead smelting facilities may
save approximately $15,000 per facility annually, and primary* steel production and high temperature
metals recovery (HTMR) faculties may save approximately $2 million per facility annually. Savings
for managers of hazardous debris could range from approximately $60,000 to $11 million per facility
annually, depending on the size of the containment building assumed and the corresponding volumes
of hazardous debris managed. For a seven percent social discount rate, aluminum reduction facilities
may save approximately $500,000 annually per facility. Lead smelters may lose $30,000 per facility
annually. Primary steel production and high temperature metals recovery (HTMR) facilities may save
approximately $1.9 million annually per facility. Savings for managers of hazardous debris could range
from approximately $40,000 to $10 million annually per facility. For a three percent discount rate,
the aggregated potential national annual cost savings for the three main industries expected to benefit
from the containment building provision could .range from $4.5 million to $325 million. Potential
national annual cost savings for managers of hazardous debris range from $9 million per year to $1.6
billion per year (depending of the amount of debris assumed,to be managed in containment
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Executive Summary
Page ES-7
Exhibit ES-5
Estimated Cumulative Probability Distribution off Volume
. of Newly Regulated Hazardous Debris^~—~*-*_
Cumulative probability
0.75-
0.5-
0.25-
0 • ~ :\ . •' 50K 100K 150K
Estimated Volume of Newly Regulated Hazardous Debris (tons/year)
buildings). For a seven percent discount rate, the aggregated potential national annual cost savings
for the three main industries could range from a loss of $45 million to a savings of $285 miOion per
year. Potential national savings for managers of hazardous debris range from a loss of $6 million to
a savings of $1.6 billion per year. • < .
ES.2. Economic Impacts ..-..- , .
For the First Third and Third Third Land Disposal Restrictions RIAs, data existed to evaluate
economic impacts on a facility-specific basis, aggregated by SIC sector. This level of detail is beyond
the scope of the analysis performed for the Phase 1 rule. , Rather, EPA performed a qualitative
analysis of economic impacts. ' , '
To analyze the economic impacts associated with regulating F037 and F038, EPA compared
the incremental costs associated with the Phase 1 LDR rule to the costs and economic impacts
identified in the regulatory impact analysis for the listing of F037 and F038 (referred to as the Listing
RIA), which prospectively analyzed the impacts from the land disposal restriction of F037 and F038.
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Page £5-5
Executive Summary
Exhibit ES-6
Estimat^jCumulative Probability Distribution of Incremental Annual Cost
of treating Newly Regulated Hazardous Debris
1 i
0.75:
0.5
0.25-
0 . ...... 50 ... 100 _ 150
Estimated Cumulative Probability Distribution of Incremental Annual Cost ,
of Treating Newly Regulated Hazardous Debris ($million/year)
The Listing RIA estimated that the annual cost of treating F037 and F038 before land disposal would
Tall between $37 and $71 million (adjusted to 1992 dollars). In the analysis for the Phase 1 rule, EPA
.estimated the compliance costs incurred by the petroleum refining industry, including costs for both
nbnwastewater and hazardous debris, to be approximately $43 million to $50 million per year.
Assuming, that revenues reported in the Listing RIA are relatively stable over time, the analysis for
the Phase 1 rule suggests that any significant impacts anticipated in the Listing RIA are likely to be
no more severe in terms of the number of affected facilities or the level of financial impact than
those estimated in the Listing RIA. Impacts on small entities were not determined because of limited
n t *
financial data. .
The total incremental cost associated with non-F037 and F038 waste and debris is estimated
at $14 million annually. (This figure does not include potential regulatory relief that may be obtained
by facilities generating previously regulated hazardous debris and K061 formerly contained in the low-
zinc subcategory.) Based on an analysis of the net .income of the facilities currently land disposing
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Executive Summary . Page ES-9,
these wastes and debris, it is unlikely that any facility would be significantly^affected.by.reguiatioirbf"
these wastes. . . . . . • ' -
ESJ LIMITATIONS « . .
"l . ' r
EPA notes the following primary limitations to its analysis:
• EPA assumed that the compliance scenario for F037 and F038 would
involve dewatering sludge to 35 percent solids and oil for solvent
' extraction and 70 percent solids and oil for other treatmenT
technologies. EPA did not consider the cost of dewatering in its cost
analysis. Also, EPA did not consider the costs of associated with
managing aqueous residuals from the dewatering of F037 and F038.
F038 may be separated before the sludge form of the waste is EPA
believes that as much as two-thirds of the water in F037 and treated.
EPA did not consider on-site treatment technologies for any process
wastes except F037 and F038. Because the costs of on-site treatment
are typically less than that of off-site treatment, EPA may have
overestimated treatment costs in some instances.
EPA based the cost analysis for K061 on the quantity of this waste
being generated. Because EPA did not have adequate data on waste
characterization, the extent to which HTMR is currently being used,
and the efficiency of non-HTMR treatment technologies, it could not
quantify the volume of K061 that would be treated differently as a
result of the rule. Therefore, the cost savings for this waste may be
an overestimate.
EPA obtained its results for the incremental compliance cost of
treating both previously and newly regulated hazardous debris on
information gathered from experts. For previously regulated
hazardous debris, EPA solicited information from a minimal number
of in-house sources. For newly regulated hazardous debris, EPA
relied on structured interviews with environmental managers in the
industries affected by the Phase 1 rule. The limited quantity of data
that EPA collected resulted in volume and cost estimates with a large
degree of uncertainty. The information gathered regarding the costs
of treating previously regulated hazardous debris considered only
physical extraction (i.e., washing), incineration, and immobilization,
solely or in combination. ' .
The analysis of the potential savings associated with containment
buildings was limited by uncertainty of containment building
dimensions, uncertainty of number of facilities within each industry
that may use containment buildings, disregard for economies of scale
hi the management of transportation and management of waste, and
lack of consideration of existing storage areas that may only need to
perform minor retrofitting to meet or exceed EPA standards for
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Page ES-10
Executive Summary
Exhibit ES-7
Annualized Coats'and Potential Savings Associated with ContaJnment Buildings
(assuming • 3 percent social discount rate)*'.
Contain
Building
For the Aluminum ^y&&*
l«doctf on. Lead: Smetting, i
Production/imtt Facilities
:'Ai»iaitt:gee;ieMrti'!':':-:''::-:i;:^"-&0'; •'; V .
Off -Site lH«pc**l/l^.
Pf f *
Contaiment Bot td
Amuat Potential
Sminos Resulting
>;;. frOtUM Of
: ContairBent , .'
'
50' X 30'^
$100.000
$74:000
$15.000
160' X 100'*7
$1.900.000
$1.200.000
$670.000
340' X 200'i/
$5.900.000
$3.700,000
$2.200.000
For Facf I iti w
Contaminated
CofMafment Buildf
:| Potent i«"l*
:::- Savings : Resuiti nf-
''
50' X.30'
$320.000
$250.000
$59.000
160' X 100'.
$8.200.000
$5.000.000
$3.200,000
340' X 200'
$26.000.000
$15.000.000
$11.000,000
, a/ • Costs shown are annual coat* incurred for 20 years, assuring a 3 percent social discount rate.
, Potential savings nay vary aignificantly fro» results shown here due to.uncertainties in the market
and infrequent waste generation. Annualized estfnates consist of capital cost of containment
building construction (including secondary containment and fugitive dust abatement equipment) and
yearly operation and •aintsnance cost of building. Operation and Maintenance costs are assumed to
be 10 percent of capital -coats. Costs for certified professional engineer assumed four weeks of
time billed at $120 par hour. Coats of recordkeeping have been subtracted from savings.
by EPA assumes that the three industries considered dispose of their waste through mineral processing
or recycling facilities and would not opt for the more expensive option of waste treatment. Off-
site disposal costs assume a generic transportation coats to thermal treatera (i.e., principal- units
of recycling and recovery facilities). Off-site disposal without a containment building U assumed
; to necessitate more frequent trips to recycling facilities, thereby resulting in higher costs than
- with the use of containment buildings. Because of lack of data, there is considerable uncertainty
associated with EPA's estimates of economies of scale that facilities with containment buildings nay
enjoy. ' ' ,
c/ Annual savings are calculated by subtracting off-site disposal costs for facilities with containment
;-- buildings from off-site disposal costs for facilities without containment buildings.
d/ Dimension is typical of a containment building that would be used by a lead smelting facility.
e/ , Dimension is typical of a containment building 'that would be used by an aluainum reduction facility.
f/ Dimension is typical of a containment building that would be used by a facility producing K061. ,
a/ EPA has little data about the size of containment buildings used to store hazardous debris. Thus,.
.it cannot specify a typical storage dimension.
h/ Off-site treatment costs are calculated by multiplying a weighted average of immobilization and
extraction off-site costs for hazardous debris by an annual quantity of waste treated.
I/ On-site treatment costs are calculated by multiplying.a weighted average of immobilization and
extraction en-site costs for hazardous debris by an annual quantity of waste treated.
j/ Annual savings.are calculated by subtracting on-site treatment costs for facilities with containment
buildings from off-site treatment coats for facilities without containment buildings.
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Executive Summary
Page ES-ll
Exhibit ES-8
Annualized Costs and Potential Savings Associated with Containment Buildings
(assuming a 7 percent social discount rate)
Containment Building
Dimensions
For the Aluminum ,-.^\-\:'-l--
Reduction, Lead Smelting.
and' Primary Steel • •••:Vi:-.'».. ••'.:•::
Production/NIMt Facf tftle*
Annuallied
•..' c • • -•
Off-Site Disposal/lkr • ':?.
Containaent Buf Lding&T J
Disposal/Increased ! V
::.Stor«ge-«ftli;*;--::;,;av!':^i
Containaent Suildlhg^
Annual Potential
Savings Resulting
fraausaot
50' X 'SO'*'
$100.000
$115.000
160' X 100'27
$1.900.000
$1.370.000
$490,000
340' X 200'
-'
$5,900,000
$3.900.000
$1.900.000
For Fact If tie*
Hazardous
Cttrtainient Buildi
Savings Resulting
'
50' X 30'
$320.000
$270.000
$40.000
160' X 100'
$8.200.000
$5.300.000
$2.900.000
340' X 200'
$26,000,000
$16,000,000
$10,000,000
a/
b/
£/
d/
e/
f/
a/
h/
y
\J
k/
Costs show are annual costs Incurred for 20 years, assuming a 7 percent social discount rate.
Potential savings nay vary significantly from results shown here due to uncertainties in the market
and infrequent waste generation. Amualized estimates consist of capital cost of containment
building construction (including secondary containment and fugitive dust abatement equipment), and
yearly operation and maintenance cost of building. Operation and maintenance costs are assumed to
be 10 percent of capital costs. Costs for certified professional engineer assumed four weeks of
time billed at $120 per hour. Costs of recordkeeping have been subtracted fro* savings.
EPA assumes that the three industries considered dispose of their waste through Mineral processing
or recycling facilities and would not opt for the more expensive option of waste treatment. Off-
site disposal costs assume a generic transportation casts to thermal treaters (i.e., principal units,
of recycling and recovery facilities). Off-site disposal without a containment building is assumed
to necessitate more frequent trips to recycling facilities, thereby resulting in higher costs than
with the use of containment buildings. Because of lack of data, there is considerable. uncertainty •
associated with EPA' s estimates of economies of scale that facilities with containment buildings may
enjoy. , '
Annual savings are calculated by subtracting off -site disposal costs for facilities with containment
buildings from off-site disposal costs for facilities without containment buildings.
Dimension is .typical of a containment bui Iding-that would be used by a lead smelting facility.
Dimension' is typical of a containment building that would be used by an aluminum reduction facility.
Dimension is typical of a containment building that would be used by a facility producing K061.
Negative savings result primarily from relatively large construction cost of building for small
storage capacity of building. -Note, however, that building site is typical of lead smelting
industry. , '
EPA has little data about the size of containment buildings used to store hazardous debris. Thus,
it cannot specify a typical- storage dimension.
Off-site treatment costs are calculated by multiplying a weighted average of immobilization and
extraction off-site costs for hazardous debris by an annual quantity of waste treated.
On- site treatment costs are calculated by multiplying a weighted average of immobilization and
extraction on-sita costs for hazardous debris by an annual quantity of waste treated.
Annual savings are calculated by subtracting en-site treatment costs for facilities with containment
buildings from off-site treatment coats for facilities without containment buildings.
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PageES-12 • • - . __ " __ _ _ Executive Summary
.containment buildings. In addition, the Agency's analysis does not
fully capture the benefits of the provision for industries that may have
Few, if any, options to containment buildings. For example, many lead
smelters crack batteries and store waste on-site. Staging feed
materials in furnace feed areas is a necessary and integral step in the
production of secondary lead. The practice is required for safety and
production efficiency. Attempts to handle furnace feed materials
differently have proven unsuccessful and to date, remain unfeasible.
HTMR facilities are similarly affected by the containment building
provision. In this case, the containment building provision may be
necessary to keep these facilities in business. Last, the Agency's
analysis does not capture potential savings that may result from use of
innovative technologies made more feasible by the containment
building provision.
EPA did not use a facility-specific approach for analyzing economic
impacts of the Phase 1 rule. Furthermore, EPA did not collect any
financial data on industries affected by the Phase 1 rule. Also, EPA
has not considered the potential beneficial impacts of the Phase 1 rule
on managers of K061 and. previously regulated hazardous debris.
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Introduction Page 1-1
CHAPTER 1
INTRODUCTION
Executive Order No. 12291 requires that regulatory agencies.determine whether a new
regulation constitutes a major nilemaking, and, if so, it requires that the .agency conduct a Regulatory
Impact Analysis (RIA). An RIA is the quantification of the potential costs, economic impacts,_and_
benefits of a major rule. A major rule is defined in Executive Order No. 12291 as a regulation likely
to result in:
• An annual effect to the economy of $100 million or more; ,
• A major increase in costs or prices for consumers, individuals, industries,
Federal, State, and local government agencies, or geographic regions; or
» Significant adverse effects on competition, employment, investment, .
productivity, innovation, or on the ability of United States based enterprises
to compete with foreign based enterprises in domestic or export markets.
EPA estimated the costs of the final rule for the Land Disposal Restrictions (LDRs) for
Phase 1 Newly Listed Wastes and Hazardous Debris (herein referred to as the Phase 1 rule) to
t >
" determine if it is a major regulation as defined by Executive Order 12291. EPA expects the final rule
to have an incremental annual cost below $100 million. EPA does not believe the .rule will
significantly increase costs for consumers, individuals, industries, Federal, State and local government
agencies, or geographic regions; or have significant adverse effects on competition, employment,
investment, innovation, or international trade. EPA did not conduct a full RIA for this nilemaking.
EPA has performed a Cost and Economic Impact Analysis. EPA focused its analyses on
estimating the incremental costs of the rule, as well as qualitatively describing the distribution of
economic impacts attributable to the rule.
The remainder of this chapter is divided into three sections. Section 1.1 reviews the
regulatory history of the LDRs. Section 12 characterizes the wastes affected by the Phase 1 rule,
and Section 1.3 discusses the industries and wastes potentially using containment buildings, a new
hazardous waste management unit for which design and operating standards are being promulgated
under the Phase 1 rule.
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Page 1-2
Introduction
1.1. REGULATORY HISTORY OF THE LDRs
The Hazardous and Solid Waste Amendments (HSWA), enacted on November 8, 1984,
prohibit the land disposal of untreated hazardous wastes. Specifically, the amendments prohibit from
land disposal specified particular groups of untreated hazardous wastes unless "...it has been
demonstrated to the Administrator, to a reasonable degree of certainty, that there will be no
migration of hazardous constituents from the disposal unit or injection zone for as long as the wastes
are. hazardous" (RCRA Sections 3004(d)(l)). The amendments also required EPA to set "...levels
or methods of treatment, if any, which substantially diminish the toricity of the waste or substantially
* .
reduce the likelihood of migration of hazardous constituents from the waste so that short-term and
long-term threats to human health and the environment are minimized" (RCRA Section 3004(m)( 1)).
'•- ^
Wastes that meet the treatment standards established by EPA may be disposed of in or on the land.
' * *
Treatment standards may be technology-based (i.e., specified treatment methods that must
employed before land disposal) or concentration-based (ie., specified concentration levels that must
be attained before land disposal). EPA's preference, whenever possible, is to establish concentration-
based treatment standards, because they allow the regulated community greater flexibility, which
subsequently reduces costs, in complying with the LDRs in most instances.
EPA's rulemaking activities have been in accordance with the schedule set forth in HSWA.
As required in RCRA Section 3004(g)(l), EPA submitted a schedule for promulgating LDR
regulations for scheduled wastes to Congress off May 28,1986 (51 FR 19300).
On November 7,1986, EPA promulgated the LDR rule that is referred to as the "framework"
rule (51 FR 40572). Thus rule set forth much of EPA's LDR policy as well as set treatment standards
and effective dates for spent solvents and dioxrn-containing hazardous wastes.
On July 8, 1987, EPA promulgated the "California List* land disposal restrictions (52 FR
25760). In this rule, treatment standards were established for liquid and non-liquid hazardous wastes
containing halogenated organic compounds (HOCs) and for liquid hazardous waste containing
polychlorinated biphenyls (PCBs). Also, the statutory prohibitions on the land disposal of corrosive
wastes and dilute HOC wastewaters were codified, and the "hard hammer" provisions1 took effect
for free cyanides and California List metals.
The First Third scheduled wastes rule was promulgated on August 8, 1988 (54 FR 26594).
Treatment standards and effective dates for relatively high volume, intrinsically hazardous wastes were
1 HSWA specified that EPA promulgate treatment standards for hazardous wastes according to a statutory schedule.
If no treatment standards for a waste were promulgated by a specified date, then land disposal of such wastes became
absolutely prohibited (ue., disposal was stopped by the "hard hammer* regulatory provision).
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Introduction ' • • ' Page 1-3
established in that rule. The Second third scheduled wastes rule was promulgated on June 23,1989
' N
(54 FR 26594), and the Third Third schedule wastes rule was promulgated about a year later on June
1, 1990 (55 FR 22520). . " '
In addition to the above rules, for which specific deadlines were enacted in HSWA, Congress
directed EPA to promulgate standards for each newly listed and identified waste (i.e., a waste brought
into the RCRA system after the enactment of HSWA in 1984) six months after promulgating a listing
rule. Newly identified and listed wastes are being addressed in groupings, or phases.
This analysis addresses the first phase, which was proposed on January 9,1992 (57 FR 958).
Additional proposed rulemakings, to be published later in 1992 and 1993, will develop LDR treatment
i , ,-
standards for those wastes recently listed under the Toricity Characteristic rule (D018-D043);
characteristic wastes from mining and mineral processing; spent potliners from aluminum
manufacturing (K088); listed wastes from wood preserving operations (F032, F034, and F035); and
all other .wastes listings promulgated between the enactment of HSWA and June 1991.
1.2 WASTES AFFECTED BY THE PHASE 1 RULE .. -
The Phase 1 LDRs rule establishes treatment standards for
(1) Petroleum refining waste (i.e., F037 and F038)
(2) Five groups of newly listed organic wastes:
• production wastes from un§vmmetrical dimethylhydrazine
(K107, K108, K109, K110, K137, and K138)
• 2-Ethoxyethanol wastes (U359) •
• wastes from the production of dinitrotoluene and
toluenediamine (Kill and K112, U328 and U3S3)
* wastes from ethylenedibromide production (Kl 17, Kl 18, and
K136) and wastes from the production of methyl bromide
(K131 and K132)
• etbylenebisdithiocarbamic acid production wastes (K123-
K126).
(3) Hazardous debris, and
(4) ..Three groups of previously regulated wastes:
• K061 (low zinc subcategory) K062 and F006
. ' . • F001-FOOS spent solvents
• 24 K- and U-wastes with wastewater treatment standards
based on scrubber waters.
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Pag* 1-4
Introduction
This section provides background on each of these groups of wastes, including an overview
1 , '
of the generating industries and waste generation rates. In addition, Exhibit 1-2, presented at the end
of this section, summarizes the wastes and the annual quantities affected by the Phase 1 rule.
Is,
1.2.1 Petroleum Refining Wastes (F037 and F038)
In October 1990, EPA analyzed the cost and economic impacts of listing F037 and F038; the
regulatory impact analysis is referred to in this analysis as the Listing RIA,2 In the Listing RIA,
EPA assessed compliance costs by using a compliance scenario that included LDR treatment before
jjand disposal. Hie LDR treatment scenario of dewatering of the waste followed by either
\incineration (on-site or off-site) or solvent extraction (on-site). EPA developed treatment costs for
-the F037 and F038 treatment technologies based on previous work done for the K048-K052 LDRs,3
because F037 and F038 have similar chemical and physical characteristics compared with these wastes.
For the analysis for the Phase 1 LDRs, the most pertinent information given in the Listing RIA was
used, as well as additional, more recent information gathered by EPA's Capacity Programs Branch
(CPB).4
Indnstrv Overview
At the beginning of 1989, there were 204 petroleum refineries in the United States (excluding
U.S. territories) with a total crude oil distillation capacity of 15.7 million barrels per calendar day
(BPCD).5 These refineries were spread across the country in 35 States, but 88 refineries (or 43
percent) were concentrated in three States—Texas, Louisiana, and California. Although crude oil
distillation capacity generally is an indicator of refinery size, seven of the 204 refineries did not have
any operating crude capacity. These seven refineries had only downstream charge capacity, which
was capacity for re-distillation of unfinished petroleum products. Of the 197 refineries with crude
* Regulatory Tmmct Analysis for tl*g T J«ting of Primary and SecomTaiv Oil/Water^oiids Separation Sludges from the
Treatment of Petroleum Refinery Wastewaters. prepared Ear U.S. EPA, Office of Solid Waste, Economic Analysis Staff,
by DPRA, October 1990.
3 EPA promulgated the LDRs for K048-K052 in the HSWA scheduled waste rules (First Third and Third Third
LDRs).
fo t New T i*"** Waste and Contaminated Debris to Support 40
4 Background Document for Capacity A
CFR 268 Land Disposal Restrictions fFinal Rulel. ILS. EPA, Office of Solid Waste, Capacity Programs Branch, June
1992.
5 Energy Information Administration (EIA), 1989. Much of the information in the following paragraphs comes from
this source. . '
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Introduction . . , ' Page M
distillation units, 11 had distillation units that were completely idle, at the beginning of 1989.
Refineries varied in size and complexity, from less than 5,000 BPCD to over 400,000 BPCD of crude
oihdistillation capacity.
The 204 refineries existing at the beginning of 1989 were owned by 106 companies. Ten
companies possessed over half (57 percent) of the crude distillation capacity, and .another 21
companies controlled an additional 30 percent The remaining 75 companies accounted for only 13
percent of the total U.S. capacity. Of these 75 companies, most had less than 50,000 BPCD capacity
and each typically owned only one refinery. In addition, these 75 companies generally were non-
integrated; that is, they purchased oil from other companies directly (i.e., they did not produce their
own crude oil), or they did not market their products. In contrast, the 31 largest companies were
mainly integrated companies, with the largest 24 being exclusively integrated companies.
i* ' • •*
Waste Generation
Virtually all refineries generate a variety of oily wastewaters, including process wastewaters,
wastewaters associated with the storage and shipment of crude oil and products, wash waters, and
cooling system wastewaters. These oily wastewaters are commingled, sometimes along with oil-free
stormwater runoff, and are either treated in an on-site wastewater treatment system and discharged
to surface waters, or pretreated on-site and discharged to an off-site wastewater treatment facility.
Discharges to surface waters are controlled under the National Pollutant Discharge Elimination
System (NPDES), while releases, to publicly owned treatment works (POTWs) are subject to local,
i
State, and Federal pretreatment standards. .
Although there is considerable variability in the configuration of wastewater treatment systems
from one refinery to the next, Exhibit 1-1 presents a simplified flow diagram of the common
treatment steps. As shown, the wastewater "influent" usually enters a series of oil/water/solids
separation steps collectively referred to as primary treatment
Primary treatment can be broken down into primary and secondary separation. Primary
separation is generally characterized by gravitational separation, during which solids settle to the
bottom and oil floats to the top and is skimmed off. Secondary separation is intended to remove
suspended solids and emulsified oils that are not readily separated by gravity. After secondary.
separation, the wastewater undergoes additional treatment and is then discharged.
Based on the listing descriptions for K048, K049, and K051, these three wastes encompass
only certain sludges generated in specific units in the primary wastewater treatment process. In
particular, K048 is dissolved air flotation (DAF) float, K049 is slop oil emulsion solids, and K051 is
-------
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Introduction . , Page 1-7
l "
API separator sludge. The newly listed wastes, P037 and F038* effectively include all other primary
and secondary oil/water/solids separation sludges that are not already generated as either K048 and
KOS1. The listing descriptions for these wastes are as follows:
. • F037: Any sedimentation sludge, except KOS1, generated from the
, - - ~ ~ gravitational separation of oil/water/solids during the storage or treatment of
process and oily cooling wastewaters from petroleum refineries. Such sludges
include those generated in oil/water/solids separators, tanks and
impoundments, ditches and other conveyances, sumps, and stormwater units
. receiving dry weather flow. Sludges exempt from this listing include sludges
generated in stormwater units that do not receive dry weather flow and
sludges generated from aggressive biological treatment units.
biological'treatment units include the following four types of units: (i)~
activated sludge, (ii) high-rate aeration, (iii) trickling filter, and (hr) rotating
biological contactor.
• F038: . Any sludge or float generated from the physical or chemical separation
of oil/water/solids in process and oily cooling wastewaters from petroleum
refineries, including all sludges and floats generated in DAF units, IAF units,
tanks, and impoundments, except for the following sludges or floats: F037,
K048, and K051 sludges generated in stormwater units that do not receive dry
weather flow, and sludges generated from aggressive biological treatment
units.
-.-'•"'
r - ' " " • t '
Before the listing of F037 and F038, most wastewaters from petroleum refineries were
managed in surface impoundments. EPA's F037 and F038 volume estimates for the Listing RIA and
this analysis took into account wastewater treatment system modifications being undertaken in
response to promulgation of the listing and LDR treatment standards. EPA estimated in the Listing1
RIA that 470,000 tons of F037 and F038 nonwastewater (with an average water content-of-55-
. percent) would be generated annually after the effective date of the LDRs. This volume included
F037 and F038 waste which also would be characteristically hazardous under the tenacity characteristic
(TC) rule. EPA has updated the F037 and F038 volume estimates, used in the Listing RIA based on
x •
additional generation information obtained as part of the capacity determination. (See the
background document for the capacity determination for more information.) Based on this updated
, • ' ' • • 'i .
information, EPA estimated that 230,000 tons (rounded) of F037 and F038 nonwastewater would be
generated annually (with an average water content of 30 percent).6
* This analysis generally is consistent with the capacity determination mmhiftfd for the final rule by EPA's Capacity
Program Branch (CPB). Hie capacity determination did not consider, however, some of the volume that this analysis
assumes will be subject to the LDRs. Specifically, this cost analysis includes in the affected waste volume approximately
50,000 toes per year of F037 and PQ38 wastes that will be generated in tanks that replace existing surface impoundments.
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Page 1-8
Introduction
Of the 230,000 tons of P037 and F038, EPA estimated that roughly 70,000 tons (i.e., 30
percent of the 230,000 tons) would be generated in Califoraia._CaIifornia-has its-own LDR program,
under which F037 and F038 waste will be restricted from land disposal as of January 1993. Since the
economic impact analysis focuses on long-term costs associated with treatment, EPA did not consider
the period before restrictions, that is, the period before January 1993. The California land ban
standards are substantively equivalent to those standards in the final rule. Thus, even if the Federal
treatment standards are not promulgated, F037 and F038 waste will be restricted in California. Of
the 160,000 tons generated annually, EPA estimated that 30,000 tons currently is managed using
cokers. Therefore. EPA estimated that only 130.000 tons annually of F037 and FQ38 would require
- additional treatment before land disposal as a result of the final rule. For the EIA analysis, EPA is
not considering the effect of the one-year national capacity variance being granted for F037 and F038.
EPA has not analyzed the effect of the final rule in effectively requiring surface impoundment
retrofitting to occur by June 1994 rather than November 1994. The effect of this change in timing
is not expected to be significant Appendix B presents an analysis of the costs and benefits of surface
impoundment dredging and closure alternatives that EPA considered during the development of
treatment standards for F037 and F038 wastes. ,
" ' ' '! '
1.2.2 Newly Listed Organic Wastes
The Phase 1 rule addresses five groups of newly listed organic wastes:
(1) Production wastes from unsymmetrical dimethylhvdrazine (K107,
K108, K109, K110, K137, and K138),
• - *
(2) 2-Ethoxyethanol wastes (U359),
wyr (3) Wastes from the production of dinitrotoluene and toluenediamine
,' * (Kill and K112, U328 and U353),
< .1
(4) Wastes from ethylene dibromide production (K117, K118, and K136)
and wastes from the production of methyl bromide (K131 and K132),
and
(5) EthylenebisditMocarbamic acid production wastes (K123-K126).
Each group is discussed below. . - ,
The capacity i
i did not consider this quantity of F037 and F038 because it is assumed that this volume would
be generated after the capacity variance period has ended. See Appendix A for more detail.
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Introduction • . Page'l-9,
Four wastes generated in the production of unsymmetrical dimetbylhydrazine (UDMH) salts
^fromarboxylic acid hydrazides—K107-K110-^were listed as hazardous on May 2,1990 (55 FR18496).
The listing description for these wastes are as follows:
'• CK107; Column bottoms from product separation from the production of 1.1-
dimethylhydrazine from carboxylic acid hydrazides.
K108: Condensed column overheads from product separation and condensed
reactor vent gases from the production of 1,1-dimethylhvdrazine from
carboxylic acid hydrazides.
K109; Spent filter cartridges from product purification from the production
of 1,1-dimethylhydrazides from carboxylic acid intermediates.
K110; Condensed column overheads from intermediate separation from the
production of 1,1-dimethylhydrazine from carboxylic acid hydrazide
intermediates. >
K107-K110 wastes are generated only when UDMH is produced using a specific production
process. Uniroyal holds a proprietary right to this process, and as of May 1990 they had ceased
production of UDMH.7 Since these wastes are no longer produced, they would only be subject to
LDRs through remediation of *hg TJniroal site. '
2-Ethoxvethanol Wastes (U359>
U359, 2-ethoxyethanol, is generated in the printing, organic chemical manufacturing, and
leather and tanning industries. It becomes a waste after it is used in various removers, cleansing
solutions, and dye baths; as a solvent for inks, duplicating fluids, nitrocellulose, lacquers and other
substances; as a chemical intermediate in 2-ethocyacetate manufacture; and in the process of leather
-' f
finishing. EPA expects Urn waste to be co-treated and co-disposed with F005 wastes listed for 2-
ethoxyethanoL
EPA's preliminary contacts with industry indicate that only two facilities generate U359. One
reports generating .U359 as minimal spills and other losses during handling and also as 100 gallons
a year of laboratory waste. The facility sends these wastes off-site for treatment and disposal. The
7 See 55 FR 18504. In addition, information describing how UDMH wastes were previously managed is available in
Listing Background Document for l.l.Dimethvlhvdraane fUDMm Production from Carbmvlic Arid Hydrazides. EPA
Office of Solid Waste, May 1990. ,
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Page 1-10
Introduction
other reports generating unspecified quantities of U3S9 from spill cleanups and other sources. These
wastes are treated by incineration and biological treatment depending on water content. EPA has
assumed for its analysis that an upper bound of 500 tons per year of U359 wastewaterswould require"
treatment as a result of the LDRs.
Wastes from the Production of Dinitrotoluene and Toluenediamine (Kill and K112. U328
andU3S3>
On October 23, 1985, six wastes (Kill through K116) generated in the production of
dinitrotoluene (DNT), toluenediamine (TDA), and toluene diisocyanate (TDI) were listed as
hazardous (50 FR 42936).8 Treatment standards.for four of the six wastes, K113 through K116,
V " • • •'''
were promulgated in the Second Third final rule (54 FR 26623). The Phase 1 rule addresses
treatment standards for Kill and Kl 12. .
Kill, which is product wash waste from'the production of dinitrotoluene via nitration of
toluene, is generated at facilities engaged in manufacturing inorganic chemicals, dyes and pigments,
explosives, and organic chemicals in the course of organic synthesis operations. K112, reaction by-
product water from the drying column in the production of toluenediamine via hydrogehation of
dinitrotoluene, occurs in intermediate processes at facilities engaged in manufacturing photographic
chemicals, plastics and resins, organic chemicals, and textiles and poiyurethane, as well as in the
production of toluenediamine as an end product
Characterization information indicates that Kill wastes are aqueous liquids with significant
quantities of sulfuric and nitric acids, and that these wastes are likely to be corrosive. Other organic
K- . - '
components that could be present and potentially used as surrogates for concentration-based
standards are dinitrotoluenes, nitrocresols, nitrophenols, and nitrobenzoic acid. K112 is an aqueous
liquid with small quantities of toluenediamines. Kill and K112 wastes also may include metals such
as nickel from catalysts. Recent data gathered for the capacity determination indicate that •
approximately 3.500 tons of Kill and no K112 are land disposed annually •*
Ortho-toluidine (o-toluidine) and para-toluidine (p-toluidine), which become U328 and U353,
respectively, when discarded, are manufactured, from processes similar to those manufacturing
dinitrotoluene and toluenediamine. Thus, U328 and U353 may be similar to wastes identified as
Kill and K112. The textiles industry and the dye and pigment industry generate o-toluidine and
p-toluidine as intermediates and reagents for printing textiles and for making colors fast to acids in
1 For a detailed description of the wastes and the localities of their generation, refer to the final rate listing these
wastes as hazardous. .
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Introduction ' , ' . Page 1-11
\ ' • ' •
/
the dyeing process. Both compounds are also components in ion exchange column preparation, used
as antioxidants in rubber manufacturing, and used as reagents in medical glucose analyses.
EPA's preliminary contacts with industry indicate that less than 500 tons of U328 and U353
are land disposed annually. EPA has assumed for its analysis that an upper bound of 500 tons per
year of U328 and U353 wastes would require treatment as a result of the LDRs.
Wastes from Ethvlene Dibromide Production (K117. Kllg. and K136> and Wastes from the
Production of Methyl Bromide (K131 and K132) . '^.^
Three wastes generated in the production of ethylene dibromide (EDB) were listed as
hazardous on February 13, 1986 (51 PR 532T).9 Although EPA banned the use of EDB in the
United States, EPA believes that EDB wastes still may be generated by pesticide manufacturers who
sell EDB overseas.
K117 is a liquid stream containing EDB, bromoethane, bromochloroethane, 1,1,2-
tribromoethane, and chloroform. Kl 18 is a solid-form waste consisting of spent adsorbents saturated
with ethylene dibromide, bromochloroethane, bromomethane and bis (2-bromo) ethyl ether. K136
is an organic liquid high in ethylene dibromide. ' • '
In the revised background document for the listing, EPA estimated that 24,000 tons of K117
and 130 tons of K118 were generated annually, based on 1982 production data. Tnfnrmatinn now
available to EPA suggests that only one facility generates K118. disposing of 100 tons annually in a
hazardous waste permitted landfill. This facility reports recycling its K117 stream, a brinv high-
bromine stream that returns to the bro*"'"e production unit.
Two wastes generated during the production of methyl bromide were listed as hazardous on
October 6, 1989 (54 FR 41402).10 K131 wastes are acidic aqueous liquids containing methyl
.bromide, dimethyl sulfate, and sulfuric acid, plus other brominatedethanes and methane- and ethane-
based alcohols and ethers. K132 wastes consist of adsorbent solids saturated with liquids containing
methyl bromide. '
K131 is an acidic aqueous liquid containing methyl bromide, dimethyl sulfate and sulfuric acid,
plus other brominated ethanes and also small alcohols and ethers. K132 is a solid waste consisting
of an adsorbent solid saturated with a,liquid phase containing methyl bromide. EPA's preliminary
contacts with industry indicate that two facilities generate K131 and K132. One facility steam-strips
9 Foe a detailed description of K117, K118, and K136, refer to the final rate listing these wastes as hazardous.
10 For a more detailed description of wastes K131 and K132, refer to the final rule fat the listing of these wastes and
.the listing background documents. . . , t
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Page 1-12 . . Introduction
both streams and ships the residue off-site, where it is recycled or incinerated. The other facility uses
a similar management strategy, except that a limited quantity of K132, less than 100 tons annually,
is land disposed off-site without prior treatment Thus. EPA has assumed for its analysis that an
upper bound of 100 tons per year of K132 waste would require treatment as a result of the LDRs.
EthylenebtsdithiocarfaaiBic Acid Production Wastes (K123-K126)
Four wastes generated in the production and formulation of the fungicide
-ethylenefaisdithiocarbamic acid (EBDG) and its salts were listed as hazardous on October 24, 1986
(51 FR 37725).11 . . . .
In general, waste characterization information indicates that K123 wastes are aqueous liquids,
K124 wastes are caustic aqueous liquids, K125 wastes are filtration and distillation solids, and K126
wastes are dry, dust-like solids. Ethylene thiourea appears .to be the primary organic component of
all four wastes. Zinc may also be present in' these four wastes.
EPA's recent contacts with industry indicate that one remaining facility generates EBDC
wastes; this facility sends wastes to a publicly owned treatment works (POTW) after neutralization
to an appropriate pH. EPA believes that a minimal amount of K125 residues, less than 100 tons
annually, may still be land disposed. Thus, EPA has assumed for its analysis that an upper bound of
i
100 tons per year of K125 waste would require treatment as a result of the T.DRs
, i
*
1.2J Hazardous Debris
EPA is establishing treatment standards for debris contaminated with listed hazardous waste
included in 40 CFR 261, Subpart D and debris that exhibit a hazardous waste characteristic. For this
EIA, EPA considered two groups of hazardous debris:1?
**.*» ' ' .
(1) Newly Regulated Hazardous Debris —Debris contaminated with wastes newly
regulated in the Phase 1 rule; and
(2) Previously Regulated Hazardous Debris — Debris contaminated with wastes
regulated in previous rules (i.e., debris contaminated with wastes regulated
under the Solvents and Dioxins; California List Wastes; and First, Second, and
Third Third rules).
11 For a detailed description of K123 through K126, refer to the final rule listing these wastes as hazardous.
12 A third group of ccmtamiiMted debris, debreconsklctedta
current or proposed LDR treatment standards, is unaffected by th°t rule.
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Introduction . - * Page \.\ j
Based on information gathered for the EIA from experts in the environmental field, EPA
estimates the total quantity of land disposed hazardous debris to be appro»mately_l million tons
annually, of which 33,000 tons per, year are newly regulated hazardous debris. The case-by-case.
national variance extension for hazardous debris is listed in the May IS, 1992, Federal Register (57
FR at 20766).
5 . '
1.2.4 Previously Regulated Wastes .
The Phase 1 rule sets treatment standards for three sets of wastes regulated under previous
LDR rules: """* ~-~~-^ ———
(1) K061 (low zinc subcategory), K062, and F006;
(2) F001-P005 spent solvents; and
(3) 24 K- and U-wastes with wastewater treatment standards based on
scrubber waters.
The Phase 1 rule eliminates the low zinc subcategory for K061 wastes and establishes numeric
treatment standards for all K061 based on high temperature metals recovery, (HTMR). Wastes
previously included in the high zinc subcategory of K061 already had to meet treatment standards
based on HTMR, and they are unaffected by this change. Wastes previously included in the low zinc
subcategory of K061 had to meet numeric treatment standards based on stabilization, although in
some cases HTMR was being used. EPA believes that an upper bound of 67.000 tons of low and
K061 will be affected bv the revised treatment standards in the Phase 1 rule. This quantity is based
on the generation quantity for low zinc K061 instead of on the quantity that is land disposed.
The Phase 1 rule sets alternative treatment standards based on HTMR for K062 and F006
nonwastewater with recoverable amounts of metal It also excludes nonwastewater residues from
HTMR treatment of F006 and K062 from regulation as hazardous waste, providing the residues meet
designated generic exclusion levels and providing they are disposed of in a Subtitle D unit
The Phase 1 LDRs also set revised treatment standards for two groups of wastes previously
regulated under the LDRs. These two groups of waste are F001-P005 spent solvents and 24 K- and
U-wastes with wastewater treatment standards based on scrubber waters. EPA has regulated these
wastes previously and is revisiting them only to modify the basis for concentration standards. The
modifications are for the purpose of: (IV standardization in testing procedures and in the basis for
treatment standards, and (2} for the nuroose of clarification to ensure appropriate placement in the
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Page 1-14
Introduction
Code of Federal Regulations. These modifications will not change the required management practices
for
•?,"
*~Exhibit-l-2 summarizes the wastes and the annual .quantities affected by the Phase 1 rule.
Exhibit 1-2
Summary of Annual Quantities of Wastes Affected by the Phase 1 Rule
1 ' '
*Petf oleum Refining Sludge
(F037 and F038)
Unsymmetrical
Dimethylhydrazine Production
Wastes (K107-K110)
2-Ethoxyethanol Waste (U3S9)
Dinitrotoluene and
Toluenediamine Production
Wastes (Kill and K112, U328
and U353)
Ethylene Dibromide Production
Wastes (K117, K118, and K136)
and Methyl Bromide
Production Waste (K131 and
K132)
Ethylenebisditbiocarbamic Acid
Production Wastes (K123-
K126)
Debris Contaminated with
Newly Listed Wastes
Previously Regulated
.Hazardous Debris ' •
Electric Arc Furnace Dust .
(K061)
130,000 tons
No longer
produced
<500 tons
3,500 tons - Kill
0 tons - K112
<500 tons of
U328 and U353
<100 tons K118
< 100 tons K132
< 100 tons Kl 25
33,000 tons
1,000,000 tons
67,000 tons of low
FOfiM OF WASTE
?, -'•wfF^CflS|Kv>'
Dewatered Sludge
i
Wastewater
Nonwastewater
Nonwastewater
Nonwastewater
Solid
Solid
Solid
GENERATION
Routine
Routine
. Routine
Routine
Routine
Routine and
Intermittent
Routine and
Intermittent
Routine
cub
ay (HTMR) BOAT (i.e., K061,
a/ , Of the «et of wastes potentially affected by the new high tempenta
K062, and POOS), EPA to oouiderini K061 only. Tlie quantity pvea for KM11* bawd on the generation quantity
instead of on the quantity that will require additiooal tnatmort before, land disposal.
13 ' CONTAINMENT BUILDINGS
This section provides general background information on containment buildings, a new
hazardous waste management unit for which design and operating standards are being promulgated
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Introduction ' . • . Page 1-15
\ .
under the Phase 1 rule. In addition, this section details the industries and wastes potentially using
containment buildings for storage or treatment of wastes.
U.I Background • ~
Currently, EPA regulations implementing the LDRs consider most forms of temporary storage
of wastes to be "land disposal" and prohibit storage of materials subject to the LDRs other than in
tanks and containers (40 CFR 268.50(a)). Hazardous waste prohibited from land disposal must, in
•\
some cases, be stored or treated for short periods of time to facilitate recycling, recovery, treatment,
or transport off-site to meet BDAT-derived treatment standards. However, some wastes are bulky
or have other physical characteristics that make their management in tanks or containers impractical.
Because the wastes are not amenable to management in RCRA tanks and containers, they are stored
or treated on concrete pads inside buildings. EPA currently classifies such units as indoor waste piles
and prohibits the placement of waste in these units that do not meet LDR treatment standards, A
generator managing wastes in a tank or container, on the. other hand, may accumulate waste on-site
for 90 days or less without a permit or without having interim status. Tanks and containers are
exempt from the 40 CFR 268.50 storage prohibition, which prohibits storage of hazardous wastes
f ' .
restricted from land disposal.
Facilities managing wastes not amenable to tanks or containers have argued to EPA that
compliance with current LDR regulations is extremely difficult because of the physical characteristics
of their wastes. The industries argue that temporary storage of the wastes is necessary prior to
treatment or recovery because the viability of these processes depends on the accumulation of the
waste. •'•,... . •
. ' - S
'- EPA believes that hazardous wastes managed in buildings that are properly designed and
operated to contain wastes within the unit do not pose the types of potential harm that Congress
sought to address in enacting the LDRs. Consequently, EPA is promulgating design and operating
standards for a new hazardous waste management unit, the containment building, that will provide
new flexibility for managing wastes not amenable to storage in tanks and containers. EPA is allowing
both storage and treatment of hazardous waste within containment buildings.
Containment buildings must be permitted under 40 CFR 264 or 265 unless they are eligible
under 40 CFR 26234 for, the 90-day generator exemption from permitting. Units that are not
permitted must meet the same design and operating standards as permitted containment buildings.
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Page 1-16
Introduction
:'&
13.2 Industries and Wastes Potentially Using Containment Buildings for Management
-^-^^of Wastes^. ^,—'._.
_—,._JTo assess the implications for industries potentially using containment buildup for storage
of waste, EPA first reviewed public comments and industry documentation to identify industries and
types of wastes potentially affected by the provision. EPA believes containment buildings will be used
to store or treat bulky wastes that cannot be managed in tanks or containers, since' containment
buildings will not provide managers of wastes any additional regulatory advantages relative to these
^two-types of units. EPA believes that facilities in the mineral processing or metal recycling sectors
are the most likely of facilities to use containment buildings because these types of facilities often
manage large volumes of waste that are potentially difficult to manage in tanks or containers. EPA
also expects some generators of large amounts of hazardous debris to benefit from the containment
building provision, since much debris is not amenable to storage or treatment in tanks or containers.
EPA has identified the primary industries it believes would use containment buildings to
manage process wastes.13 For the most part, these industries are mineral processing and metal
recycling operations generating large volumes of bulky wastes. EPA also includes information on
facilities that treat wastes using incinerators or industrial furnaces, since they might manage wastes
in a manner not conducive to using tanks or containers. EPA does not try to characterize the
universe of facilities that manage large volumes of hazardous debris, as this set of facilities is diverse
and difficult to define. , .
AlufMnff Production and Aln>M^<*nro Reduction Facilities. The aluminum industry generates
spent aluminum potliners, a waste consisting of a used reduction cell with adsorbed mineral residue.
Periodically, potiiners must be replaced because of physical failure. Because spent potliners are
concrete-like and bulky, they are not amenable to storage in confined units like tanks and containers.
Data indicate that there are five alumina production facilities and 24 aluminum reduction facilities.
The national production of spent potiiners is approximately 130,000 tons per year.
Anrtmnnv Electrolytic anA Antimony Smelting and Refining Facilities. Lead, silver, copper,
and mercury processing generate a large amount of antimony waste. Antimony is recovered either
through electrolytic processes or through smelting and refining, which, in turn, may generate slag and
furnace residues. There are two antimony electrolytic facilities and eight antimony smelting and
refining faculties. These facilities generate over 36,000 tons per year that potentially could be
managed in containment buildings.
0 Unless otherwise noted, profiles of industries are taken from a memorandum prepared fat Bill Kline and Lcs
Otte, U.S. EPA, by ICF Incorporated, February 12,1991. . '
-------
Introduction , " "\" " ' Page 1-17
* '
Coal Gasification Facilities. Coal gasification converts low grade coal and lignite to synthetic
natural gas of pipeline quality. There is one commercial coal gasification facility in full operation in
•, • * • ' •
the United States. This facility generates approximately 270,000 tons of gasifier ash annually that
potentially could be managed in containment buildings.
Copper Smelting and Refining Facilities. Copper smelting applies heat'to copper ore to
separate copper from iron and other impurities. Refining follows1 smelting and removes any
remaining sulfur and other impurities. Copper smelting and refining processes generate several dry,
solid wastes, including converter slag, furnace brick, furnace slag, and air pollution control dusts.
' There are 12 facilities in this sector that collectively generate approximately 1.8 million tons per year
of waste that potentially could be managed in containment buildings.
Elemental Phosphorus Production Facilities. In elemental phosphorus production, phosphate
rock is mixed and heated with coke and silica in an electric arc furnace.. The process frees
' / .... < • ,
phosphorous in the ore and generates dust from off-gas separation and stag. Off-gas solids may either
be recycled or -disposed of. There are five facilities in this sector that may generate these wastes.
Together, the industries generate approximately 2.9 million tons per year of waste that potentially
could be managed in containment buildings.
Primary Steel Production/High Temperature Metals Recovery Facilities Managing K061.
Some primary steel producers generate EPA hazardous waste K061 (i.e., emission control dust and
sludge from the primary production of steel in electric arc furnaces). Large volumes of K061 wastes
are treated by HTMR before land disposal HTMR facilities may store K061 wastes in order to
accumulate the most efficient mixture of volume of waste for treatment Approximately 85 facilities
have the potential to generate K061. In addition, six facilitates currently have HTMR capacity..
Current estimates of the volume of K061 managed annually by these industries range from 300,000
to 550,000 tons that potentially could be managed in containment buildings.
Commercial Facilities Using Incinerators and Industrial Furnaces. Some facilities burning
wastes may store wastes to facilitate proper blending and preprocessing to achieve greater throughput
efficiency. There are 13 commercial incinerators currently in operation. These facilities process
420,000 tons, of waste per year that potentially could be managed in containment buildings. EPA *
believes, however, that a large proportion of this waste is already managed in tanks or containers,
which would permit the same kind of storage and preprocessing as containment buildings.
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Page 1-18
Introduction
Lead Smelting and Refining Facilities. Secondary lead smelters use lead from batteries as
feedstock for their smelting operations.14 When the batteries arrive at the facility, they are
"cracked" (i.e., sawed or crushed), the acid is drained and collected, and the lead is removed. The
acid is then either disposed of or put up for resale. The lead in the form of plates (lead grids) or
groups (several plates held together by lead oxide paste) are put into storage in a waste pile for a
week to several weeks and then removed to the furnace for smelting as needed. Thirty facilities
generate approximately 260,000 tons per year of lead smelting waste that potentially could be
managed in containment buildings.
t ' i - -
Tin Smelting Facilities. Tin is reduced from cassiterite, a major tin-containing metal, by
heating the cassiterite with carbon. There is one tin smelting facility that generates slag. This facility
generates approximately 17,000 tons per year of waste that potentially could be managed in
containment buildings. *
Titanium TetracMoride Production Facilities. Production of titanium tetrachloride involves
the chlorination of a titanium concentrate. The processing of titanium tetrachloride generates waste
solids. There are nine facilities that may generate these wastes. These facilities generate
approximately 510,000 tons per year of waste that potentially could be managed in containment
buildings. ;
Zinc Smelting and Refining nr Electrolytic Refining Facilities. There are three electrolytic
zinc faculties. There is one zinc smelting facility which generates ferrosilicon, refractory brick, and
slag. The zinc smelting and refining or electrolytkalry refining faculties generate approximately
120,000 tons per year of waste that potentially could be managed in containment buildings.
for U.S. EPA Office of Solid Waste by Midwest Research Institute, August 26,1988.
.prepared
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Cost Methodology , •. • ', Page 2-1
•\ - • ' •
1 ' , f l
'•'';'... " CHAPTER! ; .,'/-,-
COST METHODOLOGY •'.
This chapter describes the methodology used to estimate the incremental costs of the Phase
1 rule. The cost methodology is divided into two major sections:.
, * Section 2.1 discusses the methodology for estimating the incremental costs of
treatment standards for wastes affected by the Phase 1 rule; and
• Section 2.2 describes the methodology for assessing the potential cost savings
associated with the containment building provision.
2.1"• METHODOLOGY FOR WASTES AFFECTED BY THE PHASE 1 RULE
To assess the costs of the Phase .1 rule on the wastes affected, EPA developed analytic
approaches for each of the four main categories of wastes: (1) petroleum refining wastes, (2) newly
-listed organic wastes, (3) hazardous debris, and (4) previously regulated wastes.1 Section 2.1.1
provides a background to the general methodology that applies to each of the categories and Sections
2.1.2 to 2.1.5 discuss each of the categories, respectively, in detail. In addition, Exhibit 2-1, presented
at the end of this section, summarizes the assumed management methods.
' % x • ..'.'•'''
2.1.1 General Methodology
The incremental cost of the Phase 1 rule is composed of two main costs:
/ - •„ '
h . . • /
• The difference between the cost of the management method in the baseline
and that assumed in the post-regulatory scenario; and ,
• The difference between transportation costs in the baseline and the post-
regulatory scenario. ,
Incremental costs are computed by subtracting baseline transportation, treatment (if
applicable), and disposal costs for management and residuals from the corresponding post-regulatory
transportation, treatment, and disposal costs. In determining the post-regulatory treatment options,
1 The analysis only addresses nonwastewater covered "under the Phase 1 rate. Negligible compliance costs are J
expected from treatment of wastewaters because wastewaters are typically discharged to publicly owned treatment works
(POTW) or to coastal and inland waters under National Pollution Discharge Elimination System (NPDES) permit
provisions. When wastewaters are discharged in this manner, they are not subject to toe treatment standards required by
the LDRs under RCRA.
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Page 2-2
Cost Methodology
the treatment alternative with the lowest cost was used to determine the incremental cost for each
waste. This is the typical practice for regulatory analyses.
Commercial transportation prices were developed using DPRA's Transportation Cost
Model.2 This cost model calculates the price (or. cost for noncommercial applications) of
transporting various types, of hazardous waste including bulk liquids, bulk sludge and solids, and
containerized wastes based on user specified waste types, quantities, and transportation distances.
Landfilling and reuse as fuel at cement kilns, two of the management methods considered in EPA's
analysis, are assumed to be fairly common and thus available relatively close to the point of
generation. For these two disposal alternatives, the associated transportation distance is assumed to
' • ' •
be 200 miles. Incineration, a technology assumed to be used for managing much waste in the post-
regulatory scenario, is far less common, and the transportation distance associated with it is assumed
to be 500 miles. .-'':'•
The cost of transport is assumed to be $0.236 per ton per mile for incineration and $0.265
per ton per mile for commercial landfilling or reuse as fuel at cement kilns. Based on the distances
traveled and this unit cost, the transportation prices used in the analysis are $118 per ton for
incineration and.$53 per ton for landfilling and reuse as fuel at cement kilns.
2.1.2 Approach for Petroleum Refining Wastes (F037 and F038)
The baseline and post-regulatory treatment technologies used for F037 and F038 primarily
i
are based on information from the Listing RIA and the Phase 1 capacity analysis.
Baseline Management Practices
, EPA estimates that treatment of 130,000 tons per year of F037 and F038 wastes will require
•?*•' • ' , *
•fK •*> •
a modification from current baseline management practices to comply with treatment standards being
established in the Phase 1 Rule. It is estimated that an additional 100,000 tons per year of F037 and
F038 wastes currently are being treated to meet the Phase 1 standards in the baseline (either because
they are generated in California or because they currently are being sent to cokers). Therefore, EPA
considers this latter quantity of waste to incur no incremental costs as a result of the Phase 1 rule.3
Three baseline practices are assumed for F037 and P038: commercial landfilling, on-site
* DPRA Transportation Cost Model, DPRA, St. Paul, Minnesota.
3 Some portion of the 130,000 torn of P037 and F038 being considered presently may be treated to meet treatment
standards. EPA's baseline ignores the treatment of this portion of FD37 and F038, however, because EPA believes that
this treatment is being undertaken solely in anticipation of the LDRs. \
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Cost Methodology ' • ' • Page 2-3
landOlling, and on-site land treatment4 Data submitted to EPA by 29 facilities, generating 25
.percent of F037 and F038 waste, indicated that, in the baseline, 64 percent (i.e., 83,000 tons per year)
of the F037 and F038 waste requiring additional treatment is managed on-site, and the remaining 36
percent (i.e., 47,000 tons per year) is sent off-site. Of the waste managed oh-site, the data show that
95 percent (i.e., 79,000 tons per year) is managed using land treatment, and 5 percent (i.e., 4,000 tons
per year) is landfilled. All wastes disposed off-site are assumed to go to commercial landfills.
. EPA assumed the following commercial and average on-site costs for baseline management
methods:5 v .
i ' . • . ^ , '
• Commercial Landfill — $200 per ton
- • On-Site Landfill — $ 75 per ton
• , On-Site Land Treatment — $ 75 per ton
Post-Regulatory Scenario ' •.'•",
EPA is assuming that the post-regulatory scenario for F037 and F038 will consist of
dewatering the waste followed by either incineration, (on-site or off-site), solvent extraction (on-site)
or coking (on-site). To simplify the cost analysis, EPA made assumptions concerning dewatering of
waste prior to treatment, the percentage of waste being treated on-site versus off-site, and the types
of treatment used both for on-site and off-site management For the residuals of treatment, EPA
- * "*
assumes disposal in Subtitle C landfills. EPA believes that these assumptions, which are described
below, reflect probable compliance activities based on reasonable (i.e., least cost) economic choices.
Dewatering serves to minimize the waste volume that needs to be treated. Solvent extraction
is not efficient for solid and oil concentrations above 35 percent, so EPA used this technological limit
as an estimate for the extent of dewatering for wastes assumed to be treated using solvent extraction.
EPA assumes that F037 and F038 managed using other technologies will be dewatered to 70 percent
' * ' -
solids and oil. ;
* ' i * ', •
EPA believes that there is a push toward on-site management due to the high costs associated
with off-site treatment The Listing RIA estimated that if all F037 and F038 wastes were incinerated,
4 EPA used data collected by its Capacity Programs Branch (CPU) as a basis for constructing the F037 and F038
baseline. .
'• . - <
'
5 On-site landfill costs are from Technical Background Document Baseline and Alternative Waste
Estimates for Third Third land Dkonsal Restrictions, prepared for the Office of Solid Waste by DPRA Incorporated,
May 1990. On-site land treatment costs are from the Listing RIA. Both costs were updated to 1992 dollars for .this
analysis. Commercial landfiU costs were based on vendor contacts. .
-------
Page 2-4 " . • ' _ Cost Methodology
87 percent of waste would be treated on-site, and the remaining 13 percent of waste would be treated
off-site.6 Assuming that these percentages are still accurate, EPA employed this breakdown as the
basis for its assumptions regarding on-site and off-site management Thus, of the 130,000 tons of
waste requiring additional treatment before land disposal, EPA assumes that 113,000 tons would be
treated on-site and 17,000 tons would be treated off-site.
For waste treated on-site, the Listing RIA did not project any volume of waste going to on-
site cokers. Recent information indicates, however, that in the post-regulatory scenario 26 percent
(i.e., 29,000 tons per year) of the F037 and F038 volume managed on-site would be disposed of in
such a manner. • Of the two remaining treatment methods considered—solvent extraction and
incineration—solvent extraction is the cheaper to perform. Not all wastes are amenable to solvent
extraction, however, so EPA assumed that half of the remaining volume would go to each technology:
37 percent (i.e., 42,000 tons per year) would be treated using solvent extraction, and 37 percent (Le.,
42,000 tons per year) would be treated using incineration. EPA's assumed waste characterization for
F037 and F038 implies that these wastes may not contain enough water for them to be pumpable.
For the purposes of this analysis, it was assumed that the volume of sludge sent to solvent extraction
would be doubled to 84,000 tons per year to account for the required" liquid content to make the
sludge pumpable. .
Average on-site costs for treatment of petroleum wastes were used for incineration, solvent
extraction, and coking unit costs applied to F037 and F038. The on-site cost for incineration was
developed from the Listing RIA and updated from 1989 dollars to 1992 dollars. The average solvent
extraction cost was based on discussions with vendors that supply solvent extraction equipment The
coking cost used in this analysis was based on best engineering judgment to estimate necessary
process equipment modifications and labor requirements.
• On-Site Incineration — $400 per ton
• Solvent Extraction — $500 per ton .
* x ' • /
• Coking — . . $200 per ton
\ • .
EPA assumed that 13 percent of the volume of F037 and F038 requiring additional treatment
before land disposal (Le. 17,000 tons per year) would be treated off-site. EPA does not recognize
* These figures are based on the Listing RIA, Tables B-l, B-2, and B-3 in Appendix B, as weB as on unpublished
information provided ty DPRA to the US. EPA Omce of Solid Waste, Economic Analysis Staff.
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Cost Methodology , . Page 2-5
any significant technological differences between the two off-site treatments it considered -
f ' ' r s-
incineration and reuse as fuel in cement kilns. Certain factors (i.e., generation quantity below that
commonly accepted by cement kQns) may continue to lead a limited volume of F037 and F038 to be
treated using incineration. EPA assumes that 10 percent (i.e., 2,000 tons per year) of the volume of .
F037 and F038 treated off-site would go to incineration, and the remaining 90 percent (i.e., 15,000
tons per year) would go to cement kilns. The average commercial prices for the these two types-of
treatment are as follows: . ^
• Incineration — $1,600 per ton (based on price for sludge)
• Cement Kiln— $700 to $1,200 per ton
1 •
EPA expects that the latter technology will soon be the cheaper alternative because of an increase
in the acceptability, of F037 and F038 at cement kilns and hence, that most of these wastes will
eventually be disposed of using this management method. A number of circumstances, however,
could reduce the capacity of cement kilns to treat these wastes. These circumstances include
v'
difficulty meeting the 20 ppm hydrocarbon emission limit being set under the Boiler and Industrial
Furnaces rule and operational complications due to the heating value or viscosity of F037 and F038.
If this is the case, then the 15,000 tons per year assumed to be.treated at cement kilns would be
treated at commercial incinerators at the $1,600 per ton figure, which would represent an increase
of $400 per ton over the upper bound cost for treatment at cement kilns.
2.13 Newly Listed Organic Wastes
All newly listed organic wastes affected by the Phase 1 rule—unsymmetrical dimethylhydrazine .
(UDMH) production wastes; 2-ethoxyethanol, dinitrotoluene, and toluenediamine production wastes;
ethylene dibromide (EDB) production wastes, and methyl bromide production wastes; and
ethylenebisdithiocarbamic acid (EBDC) production wastes-pare land disposed in relatively small
quantities. , . \
\ " • . • « '
Baseline Management Practices ~ '','•'..
EPA assumed that the baseline for all newly listed organic wastes was continued land disposal
in landfills meeting minimum technological requirements. (EPA assumed this scenario for U359
wastewaters because of the lack of information on the cost of baseline, management of U359.)
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Page 2-6
Cost Methodology
• Post-Regulatorv Scenario, -
For the Phase 1 rule, EPA is basing treatment standards on samples obtained from thermal
treatment EPA lacked site-specific waste generation data for this analysis. Accordingly, it developed
costs for post-regulatory scenario assuming off-site commercial incineration for these wastes, even
though off-site incineration may not be used by all generators, since it generally is more expensive
than incineration on-site.
EPA is regulating wastes from the production of unsymmetrical dimethylhydrazine by using
incineration as a specified-method standard. EPA, however, does not expect any cost or economic
impacts since this waste is no longer produced.
Current commercial prices and unit costs were used in.estimating the post-regulatory
treatment costs for newly listed organic wastes. EPA considered both incineration and chemical
oxidation and carbon adsorption for treatment of U359 wastewaters in the post-regulatory scenario.
The unit costs for these technologies, including transportation, approximately were $1,000 per ton
for incineration and $750 for carbon. oxidation and carbon adsorption. The only technology
considered for the treatment of newly listed organic nonwastewateis in the post-regulatory scenario
was incineration. The average commercial price for used for this technology was $1,600 per ton.
; ' i . \
This price was based on vendor contacts made during June and July 1991. Several vendors were
contacted and an average price was developed based on waste characterization data and information
provided by the vendors. The commercial price included all necessary pretreatment and residual
disposal (i.e., treatment of scrubber waters and stabilization and disposal of ash as appropriate).
2.1.4 Hazardous Debris
The data available for both previously and newly regulated hazardous debris analysis did not
provide EPA with the level of detail desired for a reliable point-estimate determination of compliance
costs for the debris regulations. The lack of knowledge about the volume estimates and types of
debris, the treatment practices available and the costs of sorting and treating debris lead EPA to
modify its standard costing approach. • ,
In order to develop a characterization of the costs and uncertainty of the newly regulated
hazardous debris standards, EPA adopted an approach which tied probabilities to estimates of
volumes and treatment costs solicited from experts. For previously regulated hazardous debris, EPA
relied on two EPA contractors, one an expert in the volume of hazardous debris -generation and the
other an expert in the cost of treating hazardous debris. For newly regulated hazardous debris, EPA
conducted its analysis based, oh the quantified judgments of experienced and qualified environmental
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Cost Methodology . • Page 2-7
management personnel at facilities affected by this rule. Using information gathered in structured
interviews, EPA obtained volume and cost information from experts and then developed weighting
schemes to apply data gathered during interviews to the universe of facilities generating hazardous
debris. EPA's approach has the following advantages:
/ • , . ' •
• Impacts of key uncertainties were quantified and corresponding assumptions
documented;
• For newly regulated hazardous debris, estimates for the quantities EPA was
considering were based on the actual experience of facilities affected,
including uncertainties relevant to their operations; .and )
• EPA obtained aggregate probabilistic estimates in a relatively short time frame
(e.g., less than three months). This quick turnaround was possible, in part,
v • - because of the availability of software that allows for the rapid development
of probabilistic models in which experts1 judgments are integrated.
Previously Regulated Hazardous Debris
To estimate, the incremental annual cost of treating previously regulated hazardous debris,
EPA constructed probabilistic distributions of both the volume of previously regulated hazardous
debris and the unit costs of treating various subsets of this volume before and after the rule takes
effect EPA relied on the expert judgment of its technical staff to collect the data necessary for this
step. EPA considered three sources of generation of previously regulated hazardous debris: routinely
generated debris (approximately 20 percent of all previously regulated hazardous debris), debris
generated at remedial actions required by Federal and State regulations (approximately 30 percent),
A - . ' •'
and debris generated at demolition and construction sites (approximately SO percent). The volumes
associated with each of these sources were further divided based on other considerations that would
determine the type and cost of the technology used to treat the debris.
EPA's approach for previously regulated hazardous debris did not focus on volume and cost
estimates for specific wastes or facilities. For this set of debris, estimates of total volumes and costs
were apportioned to sets of facilities with different debris generation characteristics and different
, treatment patterns. EPA assumed that in the baseline, incineration would always be used for debris
contaminated with organic wastes (estimated to be 20 percent of previously regulated hazardous
debris, on average, for all sets of facilities); immobilization always would be used for debris
contaminated with inorganic wastes (estimated to be 20 percent of previously regulated hazardous
debris, on average, for all sets of facilities); and incineration followed by immobilization always would
i •
be used for debris contaminated with both organic and inorganic wastes (estimated to be 60 percent
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Page 2-8
Cost Methodology
of previously regulated hazardous debris, on average, for ail sets of facilities). In the post-regulatory
scenario, EPA assumed that debris contaminated with organics would be treated using incineration
20 percent of the time and washing the remaining ,80 percent of the time, debris contaminated with
inorganics always would be treated using immobilization (i.e., no change from the baseline treatment),
and debris contaminated with both organics and inorganics would be treated using incineration
followed by immobilization 20 percent of the time and washing followed by immobilization 80 percent
of the time. EPA assumed that in both the baseline and post-regulatory scenario industry would use
the same treatment technologies on-site and off-site. Thus/in the baseline, 80 percent of previously
s . . "
regulated hazardous debris is either incinerated or incinerated and immobilized. In the post-
regulatory scenario, debris incinerated or incinerated and immobilized drops to 16 percent of die
total. . EPA gathered cost information, presented in Appendix C, based on industry contacts and
professional judgment The ranges used for the costs of washing and immobilization reflected that
the uncertainty of where debris would be disposed after treatment (Le., Subtitle C or Subtitle D
disposal units). The range used for incineration was always based on Subtitle C disposal of residuals,
because EPA believes that incinerated debris almost always would be commingled with other waste
that would not be exempted from Subtitle C. More information on the cost impact on disposal
assumptions is presented in Appendix C.
••-•-. .. • . • •
- . ^
- . Newly Regulated Hazardous Debris •
For newly regulated hazardous debris, EPA gathered cost and volume information at the
facility-specific level and1 extrapolated (i.e., scaled up) estimates to get totals. In the discussion which
follows, EPA describes the methodology it used for the cost analysis of newly regulated hazardous
debris in detail. EPA describes the probabilistic estimation model used to develop the aggregate
estimate of newly regulated hazardous debris volumes and incremental annual compliance for the
long-term (i.e., 5 to 25 year) time frame. Much of the discussion also applies to EPA's probabilistic
modeling of previously regulated hazardous debris. . .
Judgments of Debris Volumes and Treatment Costs. EPA constructed a methodology.
based on solicitation of experts' estimates for the main cost factors under different uncertainty
scenarios. Developing an aggregated estimate using expert judgments involved several steps. The
first step was to structure the factors of interest, to identify key variables that would require subjective
estimates from experts.
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Cost Methodology " . . Page 2-9
i . • • _
As a starting point for its analysis of the volumes of newly regulated hazardous debris being
generated, EPA reviewed the information that had been collected for the capacity determination.
EPA then focused on large debris contributors. The reason for focusing on only the largest
/ ^ . • '
contributors to Phase 1 debris, that is, those associated with the largest waste volumes, was modelling
simplicity. The volumes for the excluded wastes are so small that their contribution to the total
should be insignificant and indistinguishable from the uncertainty hi estimates of debris associated
with the larger-volume wastes.
Since these wastes are essentially generated by different industries, each expert could address
no more than one* type of waste. EPA considered it more important to the quality of the analysis
to obtain several experts' estimates for the largest-volume waste types than to assure that every waste
type, no matter how small, be covered in the survey. Using this criteria for inclusion hi the analysis,
the effort focused on debris contaminated with four categories of wastes: P037 and F038 wastes;
U359 wastes; Kill and 112 wastes; and K118, 131, and 132 wastes. Probabilistic estimates for the
volumes of debris and costs of these waste, which are generated independently in different industries,
were combined hi an additive model.
Having narrowed the set of variables to be estimated, the second step of EPA's analysis
involved identifying sources of expertise for each type of waste. Earlier data collection conducted
for the capacity determination provided the names of individuals who worked as environmental
managers hi the relevant industries and who had the credentials needed to qualify as participants in
the judgment elicitation process. EPA identified environmental managers at facilities in the organic
. . i %
chemicals and petroleum refining industries who would provide expert judgment on the cost of
treating newly regulated hazardous debris: four experts from the organic chemical industry and five
• t*
from the petroleum refining industry.
The experts EPA contacted at the facilities were typically hi charge of waste management and
compliance with environmental regulations. These individuals had access to the most accurate and
timely information concerning their facility's operations, and baseline levels of hazardous debris
generation. Furthermore, they were hi the best position both to assess their facility's response to the
Phase 1 rule, and to gauge the impact of future uncertainties associated with potential changes hi
. . : v-
production, waste treatment technologies, market conditions hi their industry, and changes in
regulatory requirements. : . ..-•'••
> v ' -*' ,
.An interview protocol was developed. • The protocol addressed important sources of
uncertainty associated with each /variable, which would be probed in each interview. The protocol
used for EPA's structured interviews is provided in Appendix D. .
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Page 2-10
Cost Methodology
In the next step, EPA conducted structured interviews with the identified experts. The
interviews were conducted by telephone and were typically one hour long. > Experts were asked to
describe current day-to-day operations and activities, and to identify any other modes of hazardous
debris generation at their facility. Volumes of debris that would likely be generated were then
discussed according to the type of treatment that would be applied. For each distinct type of
, , »s
treatment, or mix of treatment technologies that would be applied to hazardous debris at their facility,
the experts were asked to provide an estimate of the volume of hazardous debris using an
accompanying distribution of volumes (e.g., the volume associated with 10 percent certainty, .50
percent certainty, 99 percent certainty); this produces a subjective probability distribution (SPD).
Experts were asked to estimate the volume of debris generated that would be treated with each
technology; they were also, asked to produce a SPD for the cost per unit volume of treating that
hazardous debris with the specified technologies. .-•••',
For each set of estimates, experts were asked to consider uncertainties that could cause the
levels to be significantly higher, or lower, than what was currently generated. In general, they were
asked to consider changes in technology, market fluctuations, and regulatory factors that could affect
the. quantities being estimated. When estimating values within an SPD for each uncertain quantity,
whether a volume estimate or cost estimate, experts were asked to describe the scenario or set of
assumptions on which each estimate was based. Given the degree of uncertainty associated with most
of the quantities discussed in the structured interviews, and the rather limited interview time available,
EPA obtained no more than three estimates per quantity, corresponding to the first, fiftieth, and
ninety-ninth percentiles of the expert's SPD. The information gathered from the interviews was then
used as input for the probabilistic model.
"••' Debris Volume and Cost Estimation Models. The probabilistic model used to estimate average
total values and treatment costs associated with hazardous debris was a weighted sum of the estimates
obtained for the nine facilities surveyed.
The estimated volume of Phase 1 hazardous debris, denoted by Vol^ debris, was thus defined
as • • •
Vol.
• EL
(1)
where:
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Cost Methodology _ ' _ ; _ ' _ Page 2-11
w/debris | = a probabilistic estimate of the annual average volume of debris contaminated with
waste group i, where / was one of the following sets of waste newly regulated under the Phase
1 rule: (F037 and P038), (U359), (Kill and KlllXand (K118, K131 and K132).
The wastes within each of the above groupings typically are generated by the same facilities,
and the wastes are often intermixed. Debris contaminated with these wastes would thus be likely to
be contaminated with some combination of them. Treatment approaches described by facility experts
generally addressed all of the hazardous debris in the waste code grouping that applied to a particular
facility's operations.
The aggregated volume of hazardous debris generated within each waste group i was defined
as: • • ."' • '
where: • •• i ' -','"'•."
Debris^ = a probabilistic estimate of the annual average volume of debris contaminated with
wastes in group i, generated by facility/. " .
wtt = the population weight for facility;', with wfj * 1. .This population weight was essentially
a multiplier reflecting the share of all facilities in the industry producing wastes in group i,
* y
for which facility /s estimated volumes and treatment costs used as a basis for extrapolation.
The nine experts contacted for this survey represented only one facility each. To extrapolate
estimates from the facility represented by one expert to the universe of facilities generating newly
, regulated debris, EPA had to develop population weights. EPA identified the best available basis for
population weights as the type and scale of facilityoperations relative to others in the waste grouping.
The measures EPA used, though somewhat crudei had the virtue of being readily available for the
analysis and provided a consistent approach to weighting facility estimates.
For the relatively small number of facilities in industries generating debris contaminated with
newly regulated organic chemicals, EPA used estimates of the total yearly production of Phase 1
wastes at each facility as a basis for determining weights for each facility relative to the waste
grouping. The weights assigned to the interviewed facilities were set equal to the ratio of total Phase
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Page 2-12 . Cost Methodologr
1 waste generation for all facilities in the same size class and industry relative to the volume of Phase
1 waste generated by the facility interviewed.
For facilities in the petroleum industry, the only reliable measure readily available for EPA's
analysis was the level of product output Refineries were classified as small (95,250 barrels per day
or less), medium (95,251 to 299,250 barrels per day) or large (over 299,250 barrels per day). The
facilities EPA surveyed in each of these size classes were assigned multipliers equal to the ratio of
total industry output hi that size class relative to the interviewed faculty's output When there was
more than one facility surveyed in a given size class, the industry output for that size class was divided
equally among the interviewed facilities. One exception to this approach involved a small facility that
was planning to change its production sequence in ways that were considered to be unusual for the
industry as a whole, including other facilities in that size range. In this case, consultations with
engineers familiar with the petroleum industry were used to develop a reduced weighting factor,,
corresponding to the output of the total number of facilities that would be likely to implement similar
changes.
The hazardous debris contaminated by waste group i generated by facility/ in Equation 3 was
defined as the sum of all separate volumes of debris to which a distinct technology or mix of
technologies would be applied. It is defined as follows:
where:
debris^ ^0 = the probabilistic estimates of average annual volumes of hazardous debris
contaminated by waste group i at facility/ that will be treated with a specified technology (or
mix of technologies) kind. These estimates were provided by the expert at facility / who
participated in EPA's survey;' estimates were specified as a 98 percent credible interval,
defined by the expert's evaluation of the first ninety-ninth, and fiftieth percentiles.
Using a similar approach, EPA estimated the total average annual cost of treating hazardous
debris. Here, the experts, using their estimates of the size and weight of their debris, would consider
the steps involved in each treatment process. Thus, they would develop unit costs particular to the
type of debris generated. For example, the unit cost (per ton) of hydroblasting would differ for
-------
Cost Methodology . . . . Page 2-13
concrete slab debris and for pipes, since the cost of hydroblasting depends on surface area. The
aggregate cost estimate, Cosrall debris, is defined as:
CosffliiAfcrfc - yy cost (4)
where: • ' ' .
costi = the aggregate probabilistic estimate of the total average cost per year of treating
* debris contaminated with wastes in grouping i.
This quantity is a weighted sum of the individual (ue., total facility) treatment cost estimates
provided by the facilities EPA contacted in the industry that generate grouping /.wastes, and is
defined as: *
costt = 5^ Totaly wtj <5)
•••-.'
where:' , , .
TotaL - a probabilistic estimate of the total incremental annual compliance cost of treating
debris contaminated with waste group i at facility /. This total cost is the sum of estimated
costs of treating each of the separate "streams" of debris generated at facility/ that will be
treated with a distinct technology or mix of technologies.
I
The population weight wt. is the same as that applied in the estimation of total volume,
described above. ;
, > Each facility's total estimated incremental annual compliance cost of treatment under the
Phase 1 rule is defined as the sum of the cost for each separate volume of debris that must be treated
with a distinct treatment approach with correspondingly different costs per unit volume. Thus,
where: ' • '• ' _ . . /. •' • •./ ;• ' '
* debris^: Hua = the probabOistic estimates of average annual volumes of debris contaminated
by waste grouping i at facility ; that will be treated with a specified technology or mix of
technologies kind. This estimate was provided by the expert at facility /, who participated hi
-------
Page 2-14 . Cost Methodology
'. EPA's survey. Estimates were specified as a 98 percent credible interval, defined by the
expert's evaluation of the first, ninety-ninth and fiftieth percentiles.
S "
/ '. .
tota/j: jjjjjjj = the probabilistic estimate of cost per unit volume of treating debris contaminated
with waste i at facility), using technology or specified mix of technologies kind. Estimates for
the first, fiftieth and ninety-ninth percentiles provided the 98 percent credible interval
provided by the expert EPA interviewed at facility/.
6| j £,„} = the "baseline" or current cost of treating debris{ j ^ prior to implementation of the
Phase 1 rule. This information was supplied by the experts.
These volume and cost models were implemented with a decision modeling software package,
DEMOS,7 using a standard Monte Carlo simulation with a specified sample size of 500.
' • x
• \ • . r - ' _ ./-...-
2.L5 Previously Regulated Wastes
The Phase 1 rule eliminates the low zinc subcategory for electric arc furnace dust (K061)
wastes and establishes numeric treatment standards for all K061 based on high temperature metals
recovery (HTMR). Wastes previously included in the high zinc subcategory of K061 already had to
meet treatment standards based on HTMR; they are unaffected by this change. Wastes previously
included in the low zinc subcategory of K061 had to meet numeric treatment standards based on
stabilization, although in some cases HTMR was being used.
EPA's cost analysis for the regulatory changes to K061 -considered only the low zinc
subcategory since wastes in the high zinc subcategory are not affected by the rule. EPA assumed the
baseline for wastes previously included in the low zinc subcategory K061 was stabilization. EPA
. \
assumed that in the post-regulatory scenario managers of these wastes would use HTMR.
The Phase 1 rule also establishes numeric treatment standards based on HTMR as an
alternative treatment standard for K062 and F006. EPA did not quantify the cost impact of the rule
for these two wastes; it believes that any operator using HTMR for K062 and F006 will be using this
technology only because it is more cost-effective than current management practices.
Exhibit 2-1 summarizes the assumed post-regulatory treatment methods for each of the wastes
affected by the Phase 1 rule. .
Macintosh DEMOS, Version l.Tbl, developed by Lumina Decision Systems, Inc.', 125 California Avenue, Suite 200,
Palo Alto, CA, , "-• .
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Cost Methodology
Page 2-15
Exhibit 2-1
Summary of Assumed Management Methods in the Post-Regulatory Scenario
for Wastes Affected by the Phase 1 Rule
/''- -vV -sv^'S : *;^. &*'-&
Petroleum Refining Sludge (F037 and F038)
Unsymmetrical Dimethylhydrazine Production Wastes
(K107-KUO)
2-Ethoxyethanol Waste (U359)
Dinitrotoluene and Toluenediamine Production Wastes
(Kill and Kill, U328 and U353J
Ethylene Dibromide Production Wastes (K117, K118, and
K136) and Methyl Bromide Production Waste (K131 and
K132)
Ethylenebisdithiocarbamic Add Production Wastes (K123-
K126)
Debris Contaminated with Newly Listed Wastes
Previously Regulated Debris
Electric Arc Furnace Dust (K061) -
^^OTBSS?^"."'
_ Solvent Extraction
Incineration
Reuse as Fuel hi Cement Kilns
No Longer Produced
Carbon Oxidation and Carbon
Adsorption
Incineration
. Incineration ,
Incineration
Methods Specified hi Expert
Interviews
Extraction
Destruction
Immobilization
- . Ml
Recovery
2.2 METHODOLOGY FOR ASSESSING POTENTIAL COST SAVINGS OF Usmc CONTAINMENT
1 BUILDINGS ,
For this analysis, EPA assessed the potential cost savings of using containment buildings.
EPA did not have sufficient industry- or facility-specific information to estimate precisely the national
cost savings attributable to the provision. EPA focused its efforts on selected industries by calculating
how much money typical faculties in these industries might save if they were to manage their wastes
in containment buildings in the post-regulatory scenario. EPA chose to consider typical facilities from
,'." • ~ j • • • '
three industries—alumina production and aluminum reduction, lead smelting, and primary steel
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Page 2-16' . • '^ ' ' Cost Methodology
production and HTMR—in its analysis. EPA also considered treatment of hazardous debris at generic
facilities of several sizes.
EPA focused its analysis on three industries and generic facilities generating hazardous debris
3 * • ,
for two reasons. First, of the industries potentially using containment buildings to manage process
waste, the three industries analyzed each handle large quantities of solid-form waste not amenable
1 • x
to management in tanks or containers, thus making containment buildings a very attractive
management option. EPA believes that hazardous debris is also difficult to manage in tanks and
containers. Second, EPA received extensive comments on the difficulty of treating hazardous debris;
it.also received more requests for further analyses from representatives within the three industries
being considered than from the other industries identified as potentially affected by the containment
building provision (see Section 13). EPA believes that analysis of the potential effects of the
containment building provision for the three industries considered, along with a generic facility
generating a large volume of hazardous debris, provides an understanding of the magnitude of the
•* '
potential cost savings for facilities in other industries:
i
2.2.1 Background Information on the Facilities Considered . .
Alumina Production and Aluminum Reduction Facilities. Spent potliners are generated as
part of the process in which alumina is electrolytically reduced to aluminum. A reduction ceil, or pot,
contains a strongly reinforced steel box lined with heat insulation. Periodically, the potliner must be
replaced because of physical failure. Each potliner remains hi operation for approximately 76 months
before the carbon liner becomes spent and must be disposed of. Industry representatives indicate
that facilities may generate approximately five to six potliners each month, and dispose of them at
a mineral processing facility every two or three months. Shipment of spent potliners is often over
large distances, commonly by rail. As a result, shipment is not continuous but is made only after a
sufficient number of pots have been accumulated. .
EPA is assuming that aluminum facilities already have Subtitle C storage permits since
potliners are stored on-site in waste piles pending shipment off-site. Although K088 currently is not
subject to the LDRs, treatment standards are scheduled to be promulgated for this waste in 1994.
Once treatment standards are established, managers of K088 will be unable to store potliners in waste
piles without first meeting treatment standards. EPA believes that if there were no containment
building provision, facilities would have to send potliners off-site at the time of generation, at a higher
transportation cost The containment building provision allows generators of spent aluminum
potliners to continue their present management methods even after treatment standards are set for
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Cost Methodology
Page 2-17 v
K088. Using containment buildings, aluminum potliners could be stored pending sufficient
accumulation for economical shipment < • . ,
( Secondary Lead Smelting Facilities. Waste from the recycling of lead batteries is generated
by three interrelated and continuous steps of the" reclamation process. The Grst step is battery
"cracking," the second step is smelting, and the third step is refining and casting. Each of these three
steps necessitates storage of material that EPA considers hazardous waste.
EPA is assuming that brokers of lead batteries (i.e., firms that collect batteries for distribution
to lead smelters) and recyclers of lead acid batteries would be the primary parties affected by the
containment building provision. It is EPA's understanding that some brokers may perform "cracking"
operations to facilitate preprocessing of batteries and reduce size and, therefore, costs of shipment
to smelters. Recycling operations of lead smelters necessitate the storage of wastes in staging areas,
and thus smelters are likely to be also affected by ttie containment building provision. EPA does not
believe the provision will affect generators of used whole batteries (e.g., commercial auto stores) since
no cracking or dismantling of the batteries has occurred and the .wastes, by RCRA .regulation, are
considered a solid, not,hazardous, waste.
On average, batteries are stored for one to three months. The storage sites for these batteries
. . " ,. \ .
include trailer beds; concrete or asphalt pads inside buildings, some with leachate coUectioRsystems;
!,
and outdoor waste piles, some of which are covered. Over 80 percent of lead smelters have roofed
storage areas.8 EPA's interviews with industry representatives indicate that most brokers and
smelters of lead batteries do not yet have RCRA hazardous waste storage permits.9 Because EPA .
.considers the management of cracked batteries and their component parts in land based units as land
disposal of hazardous waste, such management is prohibited because the national capacity variance
for D002 and D008 expired'on May 8, 1992. According to EPA's understanding, if brokers and
recyclers are not able to manage lead batteries, more generators of lead batteries will have to seek .
treatment alternatives, such as off-site stabilization, that may be more expensive than lead recycling
'. ^ : ' . .
and do not promote resource recovery. The containment building provision would allow brokers and
* Background
prepared for U.S. EPA Office of Solid Waste by Midwest Research Institute, August 26,1988.
* Industry representatives, in feet, have challenged toe Agency's application of the LDRi to their waste. Hie
industries argue tha.t the LDRs are not triggered by the staging of furnace feed- materials in the furnace area because'
they believe the furnace feed materials are not solid waste and therefore cannot be hazardous waste; and even if the
waste is classified as solid and hazardous, the industries maintain that the act of staging the furnace feed materials in the
furnace feed areas is not a form of prohibited land disposal, but of recovery. • '"".,•
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Page 2-78
Cost Methodology
secondary smelting facilities to manage lead batteries and recycling by-products in a manner that
would allow for efficient processing.
Primary Steel Production/HTMR Facilities Managing K061. Steel production facilities using
electric arc furnaces generate K061 and may store this waste for a period of time in order to lower
the cost of shipping the waste off-site for treatment Large quantities of K061 and other wastes are
treated by HTMR before land disposal. HTMR facilities may store K061 wastes to accumulate an
efficient mixture or volume of waste for treatment In the absence of the containment building
provision, these management practices would have to change to less efficient (and often unfeasible)
approaches, as storage of this waste without treatment will be prohibited. Therefore, as containment
buildings would allow both steel production and HTMR operations • to continue storing their waste
in the current manner, they would experience a cost savings from this provision.
Generic Facilities Generating HnTnrdous Debris. Because of the site-specific nature of the
volumes and characteristics of the hazardous debris generated at a site, EPA assessed the effects of
the containment building provision based on generic facilities of several sizes generating hazardous
debris. While facilities could use containment buildings for both storage and treatment of hazardous
debris, EPA focused its analysis on facilities considering containment buildings for treatment EPA
assumed that containment buildings primarily would be used for hazardous debris treated with
/ '•-•,•
extraction and immobilization technologies. EPA does not believe that destruction technologies (e.g.,
incineration) would be used with containment buildings.
2.2.2 Approach for Costing Containment Building Requirements
To determine the potential cost savings associated with the containment building provision,
EPA estimated costs of containment building construction, including operation and maintenance, and
analyzed specific costs of secondary containment and fugitive dust abatement equipment
recordkeeping, and corrective action. EPA's approach and assumptions are discussed below.
ntainment Building Coi
To estimate the costs of constructing and operating containment buildings at facilities in the
three industries and treating hazardous debris at generic facilities, EPA developed engineering models
representing containment buildings suitable for handling the waste produced by each industry.
Because EPA's analysis did not reveal any significant design requirements unique to any one of the
three industries or the hazardous debris facility, EPA varied the model containment building by size ,
only, estimating a typical amount of waste that would be managed in containment buildings in each
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Cost Methodology . .- • Page 2-19
case. EPA bad no data on the typical size of containment buildings that storers and treaters of
hazardous debris might use; therefore, EPA used facility dimensions from the analysis of the three
industries to infer potential costs savings for managers of hazardous debris.
EPA used the ICF Kaiser Engineers Interactive Estimating System to compute costs of
containment buildings built to EPA design specifications. Appendix E shows typical printouts of line-
item costs obtained from this model. After reviewing industry documentation, EPA concluded that
the following containment building sizes are typical:
• Generators of aluminum potliners typically need a 160 ft. x 100 ft.
containment building, able to store approximately 4,000 tons of waste;
* A battery recycler may need a 50 ft. x 30 ft. building, able to process
approximately 5,400 cubic feet of batteries.
• A facility storing or processing K061 waste may need a,340 ft. x 200
ft. containment building, able to store approximately 12,500 tons of
. waste. .
EPA calculated the total annualized costs of containment buildings by first estimating the
present value of the capital and recurring costs incurred by facilities over an assumed 20-year
operating life. The present value costs were then annualized over 20 years to arrive at equal annual
payments. Implicit in this approach is the assumption that facilities will be able to smooth out
anticipated costs with some form of financing over a 20-year period EPA used a three percent and
seven percent social discount rate, assumed constant for 20 years, to calculate the annualized costs.
EPA's calculations incorporated costs of containment building construction (including
secondary containment, fugitive dust abatement equipment, and oversight by a professional engineer)
and yearly operation and maintenance cost of building, but did not include cost for land purchase or
permitting. Given the lack of data, the Agency assumed annual operation and maintenance costs to
be 10 percent of the capital cost of the containment building, in accordance with standard engineering
assumptions. ' „
In addition to estimating construction costs for typically sized containment buildings for the
three industries considered, EPA estimated costs for two other building sizes. These latter estimates
, were intended to provide insight into the variation and magnitude of annualized costs that may be
incurred if facilities construct building sizes different than the ones presented.
EPA did not estimate annualized costs of containment buildings smaller than 50 ft x 30 ft
•v ' ' „ * '- .
After a review of comments and interviews with industry representatives, EPA concluded that
facilities not needing the capacities of storage of at least 50 ft x 30 ft building are unlikely to build
-------
Page 2-20
Cost Methodology
a containment building at all because their waste storage needs could be met using storage
mechanisms such as roll-off bins or small concrete bins.10
Secondary Containment and Fugitive Dust Abatement Equipment •
p i • *
Because some facilities may only need to retrofit an existing structure to meet design
/
standards, EPA's approach included separating the cost of secondary containment and fugitive dust
abatement equipment from the complete costs of constructing a containment building. To determine
the cost of these systems for existing buildings of various dimensions, EPA calculated costs of
purchasing and installing secondary containment and fugitive dust abatement equipment according
to conservative "worst case" costs. For example, the system used upper bounds of labor installation
costs and market prices.
To estimate cost implications of recordkeeping requirements, EPA relied on telephone
conversations with industry representatives of the three key industries and on an analysis .of the
number of man-hours necessary to fulfill the following requirements:
• Establishment of an inspection program that ensures maintenance of the structural
integrity of the unit and prompt detection of releases. The Agency requires that
' facility personnel inspect leak detection equipment, the containment building, and the
area surrounding the containment building at least once each Operating day to ensure
that the unit is being properly operated and that no releases have occurred. These
' observations must be recorded in the facility's operating log. Records from automated
monitoring systems, such as electronic monitoring of fluid captured by a secondary
containment system or of (he air pressure differential between the inside and outside
of the unit, are acceptable in completion of the Agency requirements.
• Documentation that the containment building is emptied every 90 days. Facilities
> must maintain records in their operating log that verify that no waste remains in the
containment building for more than 90 days. Records of waste shipments are
acceptable supporting .documentation.
During interviews with industry representatives, EPA discussed the potential burden of the
recordkeeping requirements for containment buildings with industry representatives. These interviews
provided qualitative understanding of the potential recordkeeping costs:
18 Concrete bin are regulated as RCRA tanks and require secondary containment A concrete sump is located in
one comer, of the bin to collect liquid within the tank; and the bin is open-topped. (Interim Final Report: Analysis of
Proposed Statutory Changes to RCRA that Redefine Solid Wastes and Define and Authorize Specific Controls for
Recycling, prepared for U.S. EPA, Office of Solid Waste by ICF Incorporated, January 1990).
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Cost Methodology
Page 2-21
To estimate recordkeeping costs, EPA used a inan-hour costing approach. In its quantitative
estimation of the cost of recordkeeping, the EPA estimated the number of hours that would be
needed to fulfil the requirements for buildings of varying sizes. Specifically, the Agency assumed
• half an hour of daily recordkeeping would be needed for a 50 ft by 30 ft. building;
• one hour of daily recordkeeping .would be needed for a 65 ft by 40 ft. building;
• one and one half hour of daily recordkeeping would be needed for a 100 ft. by 60 ft.
building;'
* two hours of daily recordkeeping would be needed for a 160 ft. by 100 ft. building;
and
• two and one half hours of daily recordkeeping would be needed for a 340 ft by 200.
ft ."-..-• ;
All calculations assumed 365 inspections (i.e., one for each day of the year). EPA also
assumed that facility inspection personnel are paid at a rate of $60 per hour in wages, benefits, and
overhead. The Agency believes that this hourly rate is higher than the rate likely of inspection
personnel and therefore believes its use is conservative. To estimate the costs of the inspection
recordkeeping requirements, EPA first multiplied by 365 the number of hours a containment
building's required daily inspections were estimated to require. EPA then multiplied this number by
$60 per hour.
To estimate the cost of completing documentation that verifies the emptying of the
containment building every 90 days, EPA assumed one hour is needed by facility personnel to
complete appropriate forms each time the building is emptied. EPA assumed the buildings would
be emptied four times each year and that the facility personnel are paid at a rate of $60 per hour.
To estimate the total yearly costs of recordkeeping, EPA then summed the costs for documentation
of daily inspection and periodic emptying.
Corrective Action _
Under the containment building provision, corrective action authority will be extended to
permitted containment buildings; corrective action authority will not be extended to non-permitted
containment buildings (i.e., those under the 90-day generator exemption from permitting). EPA
assumed that only facilities that already have RCRA permits will choose to construct permitted
containment buildings and that any containment buildings constructed at facilities without existing
RCRA permits will be non-permitted and, therefore, will not be affected by the corrective action
provisions in the Phase 1 rule.' EPA did not calculate the additional costs of corrective action to
permitted facilities. " - : •:..'.
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Page 2-22
Cost Methodology
2.23 Approach for Calculating Potential Cost Savings
EPA assessed the potential regulatory effects associated with the containment building
provision by comparing post-regulatory costs based on the use of containment buildings with the costs
of current, or baseline, conditions. For the three industries it considered, EPA compared the cost
of off-site recycling and recovery with and without the use of containment buildings. To calculate
the regulatory effects associated with the containment building provision with regard to hazardous
debris, EPA compared the cost of off-site treatment with the cost of treating hazardous debris on-site
in a containment building. > - .
To determine off-site waste recycling and recovery costs with the use of containment
buildings, EPA researched potential recovery and transportation costs. According to the Agency's
interviews with industry representatives, recycling and recovery costs at mineral processing and other
recycling plants are low and often negligible. In many cases, generators incur only the costs of
transporting wastes to recovery or recycling facilities. Therefore, EPA used a generalized
transportation cost for ail three industries it considered. EPA assumed a standard transportation
distance of 500 miles cost (at a cost of $118 per .ton)11 because mineral processing and recycling
facilities are often located far from the site of waste generation. In estimating the economies of scale
for transportation costs that storers of wastes might enjoy through the use of containment buildings,
EPA assumed that facilities using containment buildings would incur only 50 percent of the standard
transportation cost per ton of waste that facilities not using containment buildings would incur. This
cost reduction includes both the lower cost of transportation per unit waste volume and of fewer trips
to recovery and recycling facilities as a result of using containment buildings for waste storage. Thus,
using this conservative assumption, facilities storing waste in containment buildings might incur a cost
of $59 per ton of waste. .
EPA multiplied this transportation cost by the annual quantities of waste assumed to be
generated by the typical facilities in each of the three industries it considered and added these costs
to the annualized costs of the containment buildings. EPA assumed that the facilities considered
would empty containment buildings four times a year, because of the 90-day storage exemption, and
thereby decrease the number of individual shipments to recovery facilities. Applying this assumption,
EPA estimated that the annual waste quantity affected by the containment building provision at a
typical facility would be four times the capacity of the containment building.
11 "1991 Commercial Prices for Extraction, Immobilization, and Incineration of Contaminated Debris," revised,
memorandum to Paul Balserak, U.S. EPA, Office of Solid Waste, Regulatory Analysis Branch, from Barb Dean-
Hcndricks, DPRA, St. Paul, Minnesota, April 7, 1992.
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Cost Methodology . v Page 2-23
1 ' i •
To determine treatment costs for the three industries without the use of containment
buildings, EPA assumed that the cost of treatment (i.e., recovery) would be insignificant and that the
only cost would be for transportation of waste to the treatment facility. EPA used a standard cost
of $118 per ton for transportation. EPA multiplied this transportation cost by the annual quantities
of waste assumed to be generated by the industries when emptying out containment buildings four
times per year. Waste generation quantities were assumed to be the same as those stored annually
in containment buildings.
To assess the regulatory effects associated with the containment building provision with regard
to hazardous debris, EPA compared the cost of off-site treatment with the cost of treating hazardous
debris on-site in a containment building. EPA used a weighted average of commercial on-site and
off-site extraction and immobilization costs; it did not include incineration costs in this average
because it believes that staging of wastes prior to incineration would not be done in a containment
building. EPA assumed that the volumes of waste managed annually corresponded to the sizes of
the containment buildings it assumed (i.e., the sizes used for the analysis of the three industries).
In these calculations, EPA assumed that 75 percent of hazardous debris stored in containment
buildings .would be treated by immobilization, and 25 percent would be treated by extraction.12 The
typical cost for on-site immobilization was estimated to be $280 per ton. EPA estimated the costs
of on-site extraction to be $340 per ton.13 The resulting weighted average estimate of cost for on-
site treatment of hazardous debris waste was estimated to be $300 per ton. In a similar manner, EPA
calculated the cost of off-site treatment for hazardous debris stored in containment buildings. EPA
estimated the cost of off-site extraction to be $380 per ton. Cost for off-site immobilization was
estimated to.be $560 per ton. The resulting weighted average estimate of cost for off-site treatment
of hazardous debris waste was estimated to be $520 per ton.
* . *
National Level Cost ,
To determine the potential national cost savings for each of the .three industries, EPA
multiplied the savings estimated for an individual facility by the number of facilities in each industry.
B EPA projects that after promulgation of the final rule 21 percent of the entire universe of debris (Le., stored in
containment buildings or not) will be treated using an extraction technology, 63 percent will be treated using an
immobilization technology, and the remaining 16 percent win be treated using a destruction technology.
0 Costs for treatment of hazardous debris based on "1991 Commercial Prices for Extraction, immobilization, and
Incineration of Contaminated Debris," revised memorandum to Paul Bateerak, U.S. EPA, from Barb Dean-Hendricks,
DPRA, April 7,1992, and personnel communication between Barb Dean-Hendricks of DPRA and Steve Williams of ICF
Incorporated, Fairfax, Virginia.
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Page 2-24
Cost Methodology
Similarly, to estimate the potential cost savings for storers and treaters of hazardous debris, the
Agency multiplied estimates of individual facility cost savings by 150, EPA's estimate of the number
of such facilities that may use containment buildings for managing debris.
14 EPA has determined (througjj a review of Superfund RODs, demolition records, industry reviews, and RCRA
records) that approximately 300 fccffities managed hazardous debris in 1991. Tne Agency assumes 150 out of 300
facmties poten^ would te affected ty the containmem
geoerateVenr small quantities of hazardous debris, or desire to ship debris ofMte relatively quickly. Because of the
scarcity of data for hazardous debris, EPA has attempted to be conservative.
-------
Results of Cost Analysis Page 3-1
\ > '
CHAPTER 3
RESULTS OF COST ANALYSIS
This chapter summarizes the total costs of the Phase 1 rule. Cost results are divided into two
major sections: ' i
'" : '
• Incremental annual costs estimated for the wastes affected by the Phase 1
rule, and
• Assessment of the potential cost savings attributable to the containment
building provision. • • ,
'3.1 INCREMENTAL ANNUAL COSTS FOR WASTES AFFECTED BY THE PHASE l RULE
As shown in Exhibit 3-1, the estimate for the total incremental annual cost of the standards
promulgated in the Phase 1 rule is $57 million to $65 million.1 In addition, incremental annual
savings of about $570 million may be realized by industries generating previously regulated hazardous
debris and electric arc furnace dust (K061),
The following sections summarize the incremental costs by the four major waste groups:
• Section 3.1.1: Petroleum Refining Wastes,
. • Section 3.1.2: Newly Listed Organic Wastes,
* Section 3.13: Newly Regulated Hazardous Debris,
: • Section 3.1.4: Previously Regulated Hazardous Debris, and
• Section 3.1.5: Previously Regulated Wastes.
3.1.1 Petroleum Refining Wastes (F037 and F038)
EPA estimates the total incremental annual cost for treatment of F037 and P038 wastes to
range between $40 million and $47 million. This figure is based on an annual F037 and F038 land
disposed volume of 130,000 tons per year in States other than California.'
1 Wastcwaters account for a negligible portion of the cost of the Phase 1 rule. No compliance costs are expected for
treatment of wastewaters because wastewaters are typically discharged to publicly owned treatment works (POTWs) or to
coastal and inland waterways under. National Pollution Discharge Elimination System (NPDES) permit provisions. When
wastewaters are discharged in this manner, they are not subject to the treatment standards required by the LDRs under
RCRA. In addition, total costs do not take into account the effect of the rote on F001 through POOS spent solvents or
the 24 K- and U-wastes. EPA believes that the rule win have a negligible effect on the management of these wastes.
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Page 3-2
Results of Cost Analysis
Exhibit 3-1
Summary of Annual Costs of LDR Phase 1 Rule
Waste
Wastes wltblDwefflefittl fc^^£P^
Petroleum Refining Sludge (P037 and
FD38)^
Unsymmetrical Dimethylhydraztne
Production Wastes (K107-K110)
"-2-Etnoxyethanol Waste (U359)
Dinitrotoluene and Toluenediamine
Production Wastes (Kill and K112,
U328 and U353)
Etbylene Dibromide Production Wastes
(K117, K118, and K136) and Methyl
Bromide Production Waste (K131 and
K132)
Ethylenebisdithiocarbamic Acid
Production Wastes (K123-K126)
, •
Debris Contaminated with Newly Listed
Wastes^
TOTAL FOR NEWLY LISTED WASTES
w**te*yt* iH^^^-tice^tm**
Previously Regulated Hazardous
Debris^
Electric Arc Furnace Dust (KQ61)
Post»Regulatory Costs
58 to 66
0
.0.4
- ' . 7
03
'0.2
15
81 to 89
•SS^S ^^fr"S^^&****^'r^fe^^fc^.*d*S>^C^S1^i> {:
'$-&?", vn""5
18
0
0.1
1
<0.1
0.1
5
24
*Mf? Jm«fr j$S$?j: A -^^KS*
1,600
30 ,
. incremental
Costs
v«a ^ ,„'..,. „,,
" «"• S? <• * \ s !"
f •, f \_ < r * J
40 to 47
(
0
0.3
6
03
0.2
10
57 to 65
S^ft^S^X^?-'" iXCff. >'*\
(560)
. (ii)
Note: Incremental costs sometime* do not equal the difference between post-regulatory and baseline costs because of rounding.
a/ The range of coata for F037 and P038 result from the range in unit costs assumed for reuse aa fuel in cement kilns (iA,
$700 per ton to $1200 per ton). This range is reflected in the total cost* shown for each column aaweU.
b/ - Figures presented are median estimate* obtained using probabilistic modeling. . _
cj Incremental con doe* not equal difference between post-regulatory and baseline costs because of probabilisUc modeling.
Results assume that all debria contaminated with organic* (either done or to c»Mnbmation with inorganics) could be treated
more cheaply aa a result of the Phase 1 rule. • . .
-------
Results of Cost Analysis . " • ;- Page 3-3
While only 13 percent of the total P037 and F038 waste (17,000 tons) would be treated off-
site, 25 percent to 33 percent of the post-regulatory scenario cost is from off-site treatment. The
upper bound cement kiln price used in EPA's analysis, $1,200 per ton, is expected to be an
overestimate of the long-term price for reuse as fuel in cement kilns. Presently, cement kilns appear
to be charging rates slightly below those charged by incinerators; as more cement kilns are able to
handle wastes, prices should decrease because of competition. - . _
3.1.2 Newly Listed Organic Wastes
Incremental costs are summarized for the five groups of newly listed organic wastes.
"* i
Wastes from the Production of Unsvmroetrical DimethvIhTdrazine (K107-K110>
Because these wastes are no longer generated, EPA did not calculate costs of treatment
standards for wastes from the production of unsymmetrical dimethylhydrazine (UDMH) (K107, K108,
K109,aridK110). ' ° •
2-Ethoxvethanol Wastes (U359) A , ,
EPA estimated an incremental annual cost of $700,000 for the standards developed for these
wastes. This cost is based on an upper bound assumption of incineration of 500 tons annually.
Wastes from Production of Dinitrotoluene and Toluenedlamine (Kill and.K112.U328 and
' ' U353) . •' . ' ';.. • ••'•;' ;••'.'
EPA estimated an incremental annual cost of $6 million for the standards developed for these
wastes. This figure is based on an annual land disposal estimate of 3,500 tons of Kill
nonwastewater, an upper bound assumption of 100 tons of K112 nonwastewater, and an upper bound
assumption of 500 tons of U328 and U353 combined.
_ • /
• • * •
Wastes from Production of Ethvlene Dlbromlde YK117. K118. and K136)
The standards for these wastes have an estimated incremental annual cost of $300,000. This
\
figure is based on upper bound assumptions of 100 tons of K118 nonwastewater and 100 tons of
K132 nonwastewater requiring incineration. .
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Page 3-4
Jtesults of Cost Analysis
Wastes from Production of Ethvlenebisdlthiocarbaiiric Acid fK123-K126)
The incremental annual cost estimated for these wastes is $150,000. This figure is based on
an upper bound assumption of 100 tons of K125 nonwastewater requiring incineration.
- • t ' \
'\ ' •
3.13 Newly Regulated Hazardous Debris
Estimates obtained using the models described in Chapter 2 were generated as probability
distributions of total volume and total incremental cost The estimated 98 percent credible interval
for newly regulated hazardous debris ranges'from 18,000 tons per year to 120,000 tons per year, with
a median of 33,000 tons per year. ,
The mean estimated volume of hazardous debris generated per year is 49,000 tons. As shown
in Exhibit 3-2, the large volumes at the upper end of the distribution cause the mean value to be
substantially higher than the median (i.e., the distribution is skewed); EPA is therefore using the
median as a better predictor of "central value." '
Exhibit 3-2
Estimated Cumulative Probability Distribution of Volume
of Newly Regulated Hazardous Debris
Cumulative probability
1 i
0.75-
0.25
0 50K 100K 150K
Estimated Volume of Newly Regulated Hazardous Debris (tons/year)
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Results of Cost Analysis
Page 3-5
. The estimated annual volume of newly regulated hazardous debris comprises two basic
categories of debris, debris contaminated with F037 and F038 and debris contaminated with newly
listed organic wastes. EPA discusses volume and cost estimates for each of these groups.
V • .
Estimated Volumes of Debris Contaminated with F037 and F038
The volume of debris contaminated with F037 and F038 has an estimated 98 percent credible
.interval ranging from 13,000 to 24,000 tons per year, with a median of 17,000 tons per year. The
mean estimated volume per year is 18,000 tons. As shown by the cumulative distribution function
for F037 and F038 (Exhibit 3-3), the uncertainty regarding the volume of these wastes is relatively
symmetric with respect to the median.
, Exhibit 3-3
Estimated Cumulative Probability Distribution of Volume
, of Debris Contaminated with F037 and F038
Cumulative probability
1 n
0.75
0.5 -
0.25
12.5K 15K 17.5K 20K 22.5K 25K
Estimated Volume of Debris Contaminated with F037 and F038 (tonsfyear) .
Several major sources of uncertainty were cited when the experts provided their estimates to
EPA. These sources included uncertainty about what would be defined as "hazardous debris" and the
implications of that definition for the type and extent of treatment Some experts were uncertain
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Page 3-
Results of Cost Analysis
about the fraction of debris they might generate that would be classified as hazardous debris. At one
facility, for example, there were plans to replace several concrete-lined ponds. The experts at this
facility were uncertain about the depth of the layer of concrete that EPA would classify as hazardous.
If only the surface of the concrete were classified as hazardous, the total volume was estimated to
be significantly smaller (i.e., less than half as much) than if all the concrete were classified as
contaminated and thus require treatment There was also uncertainty about the extent of renovation
' - ' ' " *
that would be undertaken at facilities in the long term and the timing of that work. For example, at
one of the facilities EPA interviewed, planned renovation work included the replacement of some
of the existing underground sewer with above ground pipe. The experts at the facility considered it
possible that extensive renovation might be done, including a plausible, though unlikely, replacement
of the entire sewer system. Related to this point was the uncertainty experts voiced about the
amount of personnel protective clothing and equipment that would be used and would subsequently
' , * -N. " ,
require treatment as hazardous debris.
Estimated Volumes of Debris Contaminated with Newly Regulated Organic Wastes
For the 'debris contaminated with newly regulated organic wastes, the estimated volume
generated per year had a 98 percent credible interval that ranged from a low of about 3,000 tons per
year to 98,000 tons per year, with a median of 13,000 tons per year. The mean estimated volume,
32,000 tons per year was distorted somewhat by the extremely high estimates at the upper end of this
distribution. This can be seen in Exhibit 3-4, which shows the cumulative probability distribution for
the estimated volumes of debris contaminated with newly regulated organic wastes.
The major sources of uncertainty associated with the estimates of the volumes of debris
, contaminated with newly regulated organic wastes were basically similar to those cited by facilities
generating F037 and F038. They included the extent of future facility maintenance and facility
upgrades and associated generation of personnel protective clothing and equipment contaminated
with newly regulated organic wastes. At one facility, for example, upper bound estimates of volumes
of hazardous debris corresponded to a major trench clean-out, or the occurrence of a major spill in
production. The lower bound estimate reflected the less significant impact of uncertainty for volumes
less than their nominal case, since the nominal value was relatively small and the lower bound was
realistically constrained to be nonzero. The lower bound estimate corresponded to a scenario where
facility personnel consciously work to reduce the volume of discarded material, resulting in an
, ' ~ *• " .
approximate SO percent reduction in the volume of generated hazardous debris. At another facility,
routine maintenance of piping and values was the primary source of hazardous debris. The upper
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Results of Cost Analysis
Page 3-7
Exhibit 3-4
Estimated Cumulative Probability Distribution of Volume
of Debris Contaminated with Newly Regulated Organic Chemical Waste
Cumulative probability
1
0.75-
0.5
0.25
25K 50K 75K 100K
Estimated Volume of Debris Contaminated with
Newly Regulated Organic Chemical Waste (tons/year)
125K
bound estimate in this case corresponded to a plausible but relatively unlikely scenario in which all,
or a large fraction, of the pipe at the facility had to be replaced The lower bound estimate for this
type of debris corresponded to the .possibility that no pipes or valves had to be replaced.
Uncertainties affecting high end estimates also included the potential extent of contamination
resulting from accidental spills of wastes. <
In order to characterize the uncertainty embedded in the calculation of the treatment costs
for newly regulated hazardous debris due to limited data availability, EPA employed an approach to
estimate the volume which would provide concomitant probability measures of its accuracy. This
~ ' i .'•".'
approach, however, and thus the resulting estimate, differ from that approach used in the capacity
analysis. The capacity analysis estimates this volume to be approximately 10,000 tons per year. The
,'-,.' '*
cost analysis results estimate the volume to range between 18,000 tons and 120,000 tons per year, with
a median of 33,000 tons per year. Although these estimates differ, it should be noted that, because
-------
Page 3-8
Results of Cost Analysis
the capacity analysis is granting a variance for newly regulated hazardous debris, no outcome is
affected by this difference. In addition, the cost analysis approach was designed for a specific purpose
relative to costs; its methodology was not fashioned with the capacity analysis in mind.
Estimated Cost off Treating Debris Contaminated with Newly Regulated Wastes
The incremental cost of treatment of debris contaminated with newly regulated wastes had
an estimated 98 percent credible interval ranging from a low of about $4 million per year to an upper
bound estimate of $120 million year. The estimated median yearly incremental cost is $10 million.
Since the range of uncertainty in the upper half of this distribution is considerably greater than the
range below the median, as shown in Exhibit 3-5, the mean estimated annual treatment cost of $20
million is much higher than the median. The median, therefore, is a better predictor of "central
value" for this skewed distribution. .
Exhibit 3-5
Estimated Cumulative Probability Distribution of Incremental Annual Cost
of Treating Newly Regulated Debris
0.75
0.5
0.25
50
100
150
Estimated Cumulative Probability Distribution of Incremental Annual Cost
of Treating Newty Regulated Debris (Smillionyyear)
-------
Results of Cost Analysis ' . " > Page 3-9
The major source of uncertainty cited by some facility experts regarding treatment costs of
newly regulated hazardous debris was the type of treatment that would be required by the' rule for
the types of debris they expect to generate, and for some types of debris, the extent to which
incineration, including special packaging and transportation prior to treatment, might be required.
' •
The highest unit costs of treatment were generally associated with incineration of personnel
protective equipment
The other method of treatment most often cited in interviews was hydroblasting, which can
i . '
be used to treat hazardous concrete and steel piping and tanks. Costs per unit for this method can
vary substantially on a per ton basis since costs are more directly related to the surface area requiring
treatment than to the weight of the debris. For example, the environmental managers cited costs
ranging from $20 per ton to $5,500 per ton, depending on the type of debris. In general, however,
treatment of the debris that is generated with hydroblasting will represent a net savings in treatment
costs per ton, compared to the current (i.e., baseline) treatment With few exceptions, hazardous
debris is currently being taken off-site for disposal in a Subtitle C landfill. Debris that had been
treated with an extraction technology, such as hydroblasting, would be exempted from Subtitle C
disposal, and accordingly a net savings may result for managers of such waste.
Estimated Incremental Cost of Treatment of Debris Contaminated with F037 and F038
. • Wastes :. '. • ' . ' • . \ . '
The estimated annual cost of treating debris contaminated with F037 and F038 ranges from
$1 million to $6 million.. The median and mean estimated cost per year are $3 million. (See
Exhibit 3-6.)
Among the issues and uncertainties discussed in interviews with experts at facilities generating
debris contaminated with F037 and F038 were the implications of the definition of hazardous debris
and how they would minimize their operating costs, including waste and debris treatment costs, given
a particular definition. With regard to personnel protective equipment, facility experts generally
indicated that methods cheaper than incineration would be used, since incineration often requires
labor intensive packaging prior to treatment as well as transportation to an incineration facility. At
one facility, for example, the upper bound estimate of costs per ton for treatment of protective
clothing corresponded to the need to pre-pack the debris, in steel drums with special labelling, and
then ship it off-site for incineration. The cost per ton in this case was about twice their median
estimate. The lower bound estimate corresponded to a treatment scenario in which bulk processing
was permissible, and the debris could be shipped in plastic bags without separate packing and
-------
Poge 3-10
Results of Cost Analysis
Exhibit 3-6
Estimated Cumulative Probability Distribution of Incremental Annual Cost
of Treating Debris Contaminated with F037 and F038
0.75-
0.25
Estimated Cumulative Probability Distribution of Incremental Annual Cost
of Treating Debris Contaminated with F037 and F038 ($million/year)
labelling. The cost of treatment in this scenario was about half of their median estimated cost per
ton. . .
. Treatment with extraction methods also presented some uncertainties. At one facility, for
example, upper bound cost estimates corresponded to a requirement that the work be done by
personnel trained to handle hazardous materials and that equipment be EPA contractor-certified..
This was estimated to increase the labor costs by 50 percent, compared to their median estimate. The
lower bound estimate corresponded to a scenario in which "contract laborers" without any special
training could be used to perform the work. In this case the cost of treatment, which is largely the
cost of the labor involved, was estimated to be 50 percent lower. At another facility EPA
interviewed, the upper bound estimate of costs of treating contaminated concrete and other debris
assumed that treatment and disposal off-site would be required, tins would cost an estimated $2,000
per ton. The nominal case, corresponding to their median estimate, assumed that the debris could
V ' .
be hydroblasted and kept in. place. The cost of this treatment approach was estimated to be about
-------
Results of Cost Analysis • • ' Page 3-11
$50 per ton. The lower bound estimate assumed that the replaced pipe could be left in place
underground, without any treatment, and thus, zero treatment cost ,
Another source of uncertainty is estimating extraction costs concerned the treatment of
residuals. If these are contaminated, the facility experts wondered whether special further treatment
would be required by EPA. In producing cost estimates for this analysis they assumed that the water
used can be put into their facility's wastewater treatment system. EPA did not consider the cost of
any permit modifications this might necessitate.
In terms of hazardous debris generated by capital improvements and renovation, different
approaches were being considered among the facilities that participated in these interviews. One
facility planned to take old pipe out of the ground, treat it, and dispose of it outside of Subtitle C.
Another planned to treat most of the old pipe in place and simply lay new pipe parallel to the old
pipelines. Another facility plans to redesign the production sequence to eliminate F037 and F038
wastes, according to the regulatory definitions. .„'•',..
Estimated Incremental Cost of Treatment of Debris Contaminated with Organic Chemical
Wastes . .
The annual cost of treating debris contaminated with the organic chemicals newly regulated
by the Phase 1 rule ranges from a first percentile estimate of $1 million to an upper bound estimate
of $120 million. The median estimated incremental annual cost is $7 million. Exhibit 3-7 presents
the cumulative probability distribution for this cost ' '
The extremely high estimated costs at the upper end of this distribution relative to the central
and lower bound estimates cause the mean, $18 million, to be considerably higher than the median
cost estimate. The main reason that estimated costs are so high relative to the volumes estimated
is that experts indicated that in the .upper bound a high percentage of wastes would have to be
incinerated. The costs associated with incineration, as described by the experts, included not only the
. fee per unit weight paid to the incinerator operator but the costs of separating, packaging, and
shipping the contaminated materials. For most of organic chemical facilities considered, no
incinerator was located nearby. :
Sources of uncertainty associated with treatment cost estimates included whether less
expensive treatment .alternatives, such as incineration, would increase in price as more facilities are
required to incinerate waste and debris and the supply of wastes with high heating value exceed the
kiln and furnace operators' need for fuel. The uncertainty ranges for treatment by incineration varied
according to the circumstances of .the facilities interviewed. At a facility with operating incinerators
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Page 3-12
of Cost Analysis
Exhibit^?
Estimated Cumulative Probability Distribution of Incremental Annual Cost
of Treating Debris Contaminated with Newly Regulated Organic Chemical Wastes
0.75-1
0.51
0.25-1
50
100
150
Estimated Cumulative Probability Distribution of Incremental
Annual Cost of Treating Debris Contaminated with
Newly Regulated Organic Chemical Wastes ($million/year)
on-site, for example, the upper bound estimate corresponded to a scenario where new air emissions
regulations required that new scrubbers be installed, and that their fuel costs increase. Their lower
bound estimate assumed that a delisting petition they submitted gets approved and that air emissions
restrictions are relaxed from the current standards. At another facility, it is currently planned that
high heating value debris would be treated off-site at a cement kiln, which is less expensive than use
of an incinerator facility. The upper bound estimate assumes that the construction industry is in a
recession, and that without demand for cement, kiln operators do not need a large volume of fuel.
In this case, the price of treatment approaches that quoted by incineration facilities. The lower
bound estimate corresponds to a change in technology at cement kilns, so that debris would not need
to be pre-packed for bucket-feeding into the kiln. This would reduce the cost per ton by almost half
' • ' . , ' ft
when compared with the nominal cost per unit weight. Other uncertainties included whether washing
could be used for personal protective clothing and equipment and glassware, and which material!
* ' . ,
could be recycled after washing to avoid their being classified as debris.
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Results of Cost Anafysis -- •.'• Page 3-13
'• ' ' ' '^ '
3.1.4 Previously Regulated Hazardous Debris
On May 8,1992, all of the national capacity variances for the debris regulated in the HSWA
land disposal restriction scheduled waste rules expired. EPA, however, issued a national case-by-case
variance (57 FR at 20766), which will extend until to May 8,1993. All previously regulated hazardous
debris would then be required to meet the existing standards for nonwastewaters established in the
scheduled waste rules. Since EPA is interested in long-term treatment costs, its analysis does not take
into account the effect of the national capacity variance on treatment of hazardous debris.
As presented in Exhibit 3-8, the results of EPA's analysis indicate that the volume of
previously regulated hazardous debris affected .by today's rule has a 98 percent likelihood of falling
between 750,000 tons and 3 million tons per year. Standards for debris established' in today's rule
allow considerably more flexibility in debris treatment than did the standards established in the LDR
scheduled waste rules. In addition, today's standards provide for the use of many more extraction
technologies for treatment then the HSWA standards; extraction technologies often can be cheaper
to use than the destruction and immobilization technologies that are required under current
regulations. Furthermore, today's treatment standards allow debris treated by destruction and
extraction technologies to be excluded from Subtitle C disposal Therefore, EPA believes that today's
standards for previously regulated debris will probably result in a potential regulatory relief to
industry. The cost impact of managing previously regulated hazardous debris in accordance with
debris treatment standards has a 98 percent likelihood of falling between a cost savings of S3 billion
i • • • - \
and a cost of $300 million per year. The median annual cost savings resulting from the rule for
treating previously regulated debris was $560 million, and the mean annual cost savings was $780
million. All results assume that debris contaminated with organics, either alone or in combination
with inorganics, can be treated more cheaply as a result of the Phase 1 rule. .
3.1.5 Previously Regulated Wastes (F006, K061, and K062)
The only previously regulated wastes revisited in the Phase 1 rule for which EPA developed
cost estimates are K061 low-zinc wastes. (As discussed above, the standards for F006 and K062 are
expected to have no incremental costs associated with them.) The standards for K061 wastes are
based on high temperature metals recovery (HTMR). These standards, as applied to K061; could
save industry up to approximately $11 million annually (Le., the standards in the Phase 1 rule could
be less costly than die existing standards.). This figure is based on an annual generation estimate of
67,000 tons. EPA has used a generation estimate rather than a land disposal estimate for this waste
because of a high level of uncertainty regarding the quantity of low zinc K061 that is currently treated
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Page 3-14
Results of Cost Analysis
Exhibit 3-8
Estimated Cumulative Probability Distribution of Volume
of Previously Regulated Hazardous Debris
Cumulative probability
1
0.75
0.5
0.25-
500K 1M 1.5M 2M 2.5M
T. Estimated Cumulative Probability Distribution of Volume
of Previously Regulated Hazardous Debris (tons/year)
3M
using HTMR. The effect of using a generation estimate of the K061 volume is that the cost saving
presented is likely to be an overestimate of the true cost saving resulting from these standards.
33, POTENTIAL COST SAVINGS FROM STORAGE AND TREATMENT IN CONTAINMENT BUILDINGS
3.2.1 Overall Cost Savings from Containment Building Provision
Exhibits 3-10 through 3-13 show the results of EPA's analysis of the potential savings from
the containment building provision. The calculations indicate that the use of containment buildings
designed to store the typical waste quantities associated with the three industries considered and to
treat hazardous debris could result in significant cost savings. For a three percent discount rate, the
calculations indicate that the use of containment buildings designed to store the typical waste
quantities associated with the three industries considered and to treat hazardous debris could result
in significant cost savings. As shown in Exhibit 3-10, aluminum reduction facilities may save
approximately $700,000 per facility annually, lead smelting facilities may save approximately $15,000
per facility annually, and primary steel production and high temperature metals recovery (HTMR)
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Results of Cost Analysis
Page 3-15
Exhibit 3-9
Estimated Cumulative Probability Distribution of Incremental Annual Cost
of Treating Previously Regulated Hazardous Debris
1 i
0.75
0.5 •
0.25
-6 -4 -2 , 0, !
.Estimated Cumulative Probability Distribution of Incremental Annual cost
of Treating Previously Regulated Hazardous Debris (Jbillion/year)
facilities may save approximately $2 million per faculty annually. Savings for managers of hazardous
debris could range from approximately $60,000 to $11 million per facility annually, depending on the
size of the containment building assumed and the corresponding volumes of hazardous debris
managed. For a seven percent social discount rate, Exhibit 3-11 shows that aluminum reduction
facilities may save approximately $500,000 annually per facility. Lead smelters may lose $30,000 per
facility annually. Primary steel production and high temperature metals recovery (HTMR) facilities
may save approximately $1.9 million annually per facility. Savings for managers of hazardous debris
could range from approximately $40)000 to $10 million annually per facility.
For a three percent discount rate, the aggregated potential national annual cost savings for
the three main industries expected to benefit from the containment building provision could range
from $4.5 million to $325 million. Potential national annual cost savings for managers of hazardous
debris range from $9 million per year to $1.6 billion per year (depending of the amount of debris
assumed to be managed in containment buildings). For a seven percent discount rate, the aggregated
potential national annual cost savings for the three main industries could range from a loss of $4.5
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Page 3-16
Results of Cost Analysis
Exhibit 3-10
Amualfied Cost* and Potential Savings Associated with Containment Buildings
(assuring a 3 percent social discount rate)2'
" Containment Skii ldih0-->':¥
•$-r- " Dimensions ••••n.:--"v.:.:;:
For the Aluirinuw':V:i:^rO:;^.;:*
Reduction; t»d Snwttlng,
. and Primary Steal* >&&$•;£
Product ion/flT«R facilities-;;
50' X W&
160' X 100'*'
340' X 200'^
for Facilities Generating
.Contaminated Debris1'
50' X 30'
160' X 100'
340' X 200'
<..;.-:l-;v%f: '.:V:^ *:•—•
• • '! . .-,.;;;;::• •::-:-:';...:i,:-'y;-.-:fti--w.^.,
:' Of f -Site 0 i sposel/Ko.; ,
Containnent BuUdtng^ ;
. . $100,000
$1,900,000
$5,900,000
Of f-$f t* Treatment/to.
Containment Building2*
$320,000
$8.200,000
$26,000,000
^OffrSlteWf^il;::^ *&•
"•Oi^eMt/IneniaMiit'i ^~
;8t«NB9f'-:Mit«»:ii(p?;;;?:y^
Cont.inBent Sutldi^
$74.000
$1.200.000
$3.700.000
On»Stt* Treatment/
Increased Storage with
Containment Sultdlna17
$250.000
$5.000.000
$15,000.000
"> "v-V11: :':fb::-:::>::?:'*H"Vi~- *C- Y!;-.
>;?vftAnniail-|»otentiai;i ^
Savings Resulting ':'..::•
jf;:j:?;-:>:'fro«^UBe.of.v>: iC;
:-SS^;'S»itainBBht..'v;?: T,;
i-Si-ftertWfn^S'^^ y;>.:
$15,000
$670.000
$2,200,000
Annual Potential
Savings Resulting
from Use of
Containment,
Buildings' ***
$59.000
$3,200.000
$11,000,000
a/
b/
c/
d/
e/
If
h/
I/
j/
Costs «houn are annual costs incurred for 20 years, assuring a 3 percent social discount rate.
Potential savings nay vary significantly from results shown here due to uncertainties in the market
and infrequent waste generation. Annual f zed estimtes consist of capital cost of containment
building construction (including secondary containment, fugitive dust abatement equipment, and
engineer oversight) and yearly operation and Maintenance cost of building. Operation and
maintenance costs are assumed to be 10 -percent of capital costs. Costs for certified professional
engineer assumed four weeks of tine billed at $120 per hour. Costs of recordkeeping have been
subtracted from savings.
EPA assumes that the three industries considered dispose of their waste through mineral processing .
or recycling facilities and would not opt for the more expensive option of waste treatment. Off-
site disposal costs assume a generic transportation costs to thermal treaters (i.e., principal units
of recycling and recovery facilities). .Off-site disposal without a containment building is assumed
'to necessitate more frequent trips to recycling facilities, thereby resulting in higher costs than
with the use of containment buildings. Because of lack of data, there is considerable uncertainty
associated with EPA's estimates of economies of scale that facilities with containment .buildings may
enjoy. . .
Annual savings are calculated by subtracting off -site disposal costs for facilities with containment
buildings from off-site disposal costs for facilities without containment buildings.
Dimension is typical of a containment building that would be used by a lead smelting fecility.
Dimension is typical of a containment building that would be used by an aluminum reduction facility.
Dimension is typical of a containment building that would be used by a facility producing K061.
EPA has little data about the size of containment buildings used. to store hazardous debris. Thus,
it cannot specify a typical storage dimension. .
Off-site treatment costs are calculated by multiplying a weighted average of iomobiliution and
extraction off-site costs for hazardous debris by an annual quantity of waste treated. , '
On- site treatment costs are calculated by multiplying a weighted average of immobilization and
extraction on-slte costs for hazardous debris by an annual quantity of waste treated.
Annual savings are calculated by subtracting on-site treatment costs for facilities with contair
buildings from off-site treatment costs for facilities without containment buildings.
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Results of Cost Analysis
Page 3-17
Exhibit 3-11
Amualized Costs and Potential Savings Associated trith Containment Buildings
(assuring a 7 pefcent social discount rate)
containment Building
'" Dimensions:*:- -
For the
Reduction, Lead Smelting,
"'
Product i on/Jmtt Facl tit tes
Off-Site bS»pos«l/No..
/Containment 7
Oisposet /Increased
;8tortgt.-iiHth^^'jfe-
Containmtnt Building^
Annual Potential:
Savings Resulting
fras use of -<
Contai
50' X 30'^
$100.000
$115,000
($30.000)
160' X 100's/
$1.900.000
$1.370.000
$490.000
340' X 200'-'
$5,900,000
; $3,900,000
$1,900,000
• For. Facilities
Hazardous Debri
pBting
'
; Containment Bui Iding1'
i Increased:: Storase «i
Containment Bui Iding
50' X 30'
$320.000
$270.000
$40.000
160' X 100'
$8,200.000
$5,300,000
$2.900.000
340' X 200'
,$26/000,000
$16,000,000
$10,000,000
a/ Costs shown are annual costs incurred for 20 years, assuming a 7 percent social discount rate.
~ Potential savings may vary significantly from results,shown here due to uncertainties in the market
and infrequent waste generation. Annualized estimates consist of capital cost of containment
building construction (including secondary containment, fugitive dust abatement equipment, and
engineer oversight), and yearly operation and maintenance cost of building. Operation and
maintenance costs are assumed to be 10 percent of capital costs. Costs for certified professional
engineer assumed four weeks of time billed at $120 per hour. Costs of recordkeeping,have been
subtracted from savings. .
b/ EPA assumes that the three industries considered dispose, of their waste through mineral processing
or recycling facilities and would not opt for the more expensive option of waste treatment. Off-'
site disposal costs assume a generic transportation costs to thermal treaters (i.e., .principal units
of recycling and,recovery facilities). Off-site disposal, without a containment building is assumed
,to necessitate more frequent trips to recycling facilities, thereby resulting in higher costs than
with the use of containment buildings. Because of lack of data, there is considerable uncertainty
associated with EPA's estimates of economies of scale that facilities with containment buildings may
enjoy. . ' '.'.'... •
c/ Annual savings are calculated by subtracting off-site disposal costs for facilities with containment
buildings from off-site disposal costs for facilities without containment buildings.
d/ Dimension is typical of a containment building that would be used by a lead smelting facility.
£/ Dimension is typical of a containment building that would be used by an aluminum reduction facility.
f/ Dimension is typical of a containment building that would be used by a facility producing K061.
a/ EPA has little data about the size of containment buildings used to store hazardous debris. Thus, .
.it cannot specify avtypical storage dimension. ' .
h/ Off-site treatment costs are calculated by multiplying a weighted average of {(mobilization and
extraction off-site costs for hazardous debris by.an annual quantity of waste treated.
I/ On-site treatment costs are calculated by multiplying a weighted average of iranobilization and..
.extraction on-site costs for hazardous debris by an annual quantity of waste treated.
\J ' Annual savings are calculated by subtracting on-site treatment costs for facilities with containment
buildings from off-site treatment costs for facilities without containment buildings.
-------
Page 3-18 ' , Results of Cost Analysis
million to a savings of $285 million per year. Potential national savings for managers of hazardous
i.
debris range from a loss of $6 million to a savings of $1.6 billion per year.
. \ "'..'•'•
3.2.2 Costs of Containment Building Construction and Operation land Maintenance
Exhibits 3-14 and 3-15 present annualized cost results for construction .and operation and
maintenance of containment buildings of varying dimensions for social discount rates of three percent
and seven percent, respectively. As indicated, costs under a three percent discount rate range from
approximately $67,000 per year for a 50 ft x 30 ft building to $800,000 per year for a 340 ft x 200
•\ .
ft building. Under a seven percent discount rate, costs range from approximately $77,000 to $927,000
' " • ' ' i
per year for the corresponding building dimensions. • • -.
fV - ' • •
3.2 J Costs of Secondary Containment and Fugitive Dust Abatement Equipment
Exhibit 3-16 shows the annualized costs of engineered barriers and fugitive dust emission
abatement equipment, assuming a 3 percent social discount rate. As shown, the annualized costs for
secondary containment range from $7,000 to $23,000 per year for systems in 50 ft x 30 ft and 340
ft. x 200 ft containment buildings, respectively. Fugitive dust control costs range from approximately
$3,000 for a 50 ft by 30 ft building to $30,000 per year for a 340 ft. x 200 ft. building.
Exhibit 3-17 shows the annualized costs of engineered barriers and fugitive dust emission
abatement equipment, assuming a 7 percent social discount rate. As shown, the annualized costs for
secondary containment range from $7,600 to $27,000 per year for systems in 50 ft x 30 ft and 340
ft x 200 ft containment buildings, respectively. Fugitive dust control costs range from approximately
$3,000 for a 50 ft. by 30 ft building to $30,000 per year for a 340 ft x 200 ft. building.
3.2.'4 Costs of Recordkeeping .
Exhibit 3-18 presents the annual recordkeeping costs for buildings of different dimensions.
EPA's estimates of annual recordkeeping range from $11,000 to $33,000 per building for small to
large buildings. Exhibit 3-19 presents the national annual recordkeeping costs for buildings of
different dimensions. 'EPA's estimates of national annual recordkeeping range from $319,000 to
$957,000 per building for small to large buildings in the aluminum reduction industry; $330,QOO
to 990,000 in the lead smelting industry, $1,001,000 to 3,003,000 in the primary steel industry, and
1,650,000 to 4,950,000 for generators of hazardous debris.
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Results of Cost Analysis
Page 3-19
Exhibit 3-1Z
Potential National Annual Saving* Associated tilth Contai
(assuring a 3 percent social discount rate)
Buildings
'•^^f^SSK
Containaent Building 5
Dimensions ';:::;
i 50' X 30'^'
. - 160' X 100'^
340' X 200'^
>otentf al tetionat An^
Aluainui Reduction
» facilities ; •
$435.000
$19.343.000
$62,843,000
":^leed'sa»ltin8:S
30 facilities :
$450.000
$20.010.000
i $65,010,000
;t! ^Sy-'»te«i:®i
Prbduction/HWR
-•'^vT^facHltfesVv:*
$1.365.000
$60,697.000
$197,197,000
^'•\-jy''! ':$&'£_' '•-'"..
A::^!Srf»»^: ;:;'--::
150 facilities
$8.850.000
$475,050.000
$1,645.050,000
•/ Estimates represent savings Industries potentially My Incur each year for 20 years. 'Potential savings m«y v«ry
~ significantly fro* results thown h*r* du« to uncertainties associated with the market, waste generation, tho
number of containment building* por f»e111ty, end tho number of affected facilities within each Industry.
Annual potential • savings for each of tho throe Industries were calculated by subtracting off-*1to disposal cost*
for facilities tilth containment bulldlngt'frooi off-tlto disposal cost* for facilities without eoRtalmont
bu1ld1ngft> Annuol lavlngt for mtnagort of.hozordout dobr1« woro eoleulfttod by subtracting on*s1to troatnont '
costi for foemtlos with eonttlnownt buddings fro* off-slto trostnont costs for f«e1Ht1o< without contdnmont
buildings. EstliMtos of savings Incorporate costs for 20 yosrs, assuming a 3 Boreont social dlseounfrato.
Annuallzod costs estimates consist of capital cost of containment building construction (Including secondary
containment, fugitive dust abatement equipment, end engineer oversight) and yearly operation and maintenance
cost of building. Operation and maintenance costs are assumed to bo 10 percent of capital costs.. Costs of
. recordkeeplng have boon subtracted from savings. ' '
b/ EPA has little data about the size of containment buildings used to store hazardous debris. Thus. It cannot
~ specify a typical storage dimension. • . :
e/ • Dimension 1s typical of a containment building that would be used by a lead smelting facility. .
d/ Dimension,1s typical of a containment building that would-be used by an aluminum reduction facility.
•/ Dimension 1s typical of a containment building that would be used by a facility producing KM1.
' Exhibit 3-13
Potential National Annual Savings Associated with Containaent Buildings
(assuring a 7 pet cent social discount rate} ~. .
Cont«!f«kent Buitding
'. :•' Oiaensiom
^
Alurinua Beduction
: 29 facilftie*
mw^;;»mv;m;y??K
mta^SmOittaim
ProductiorvntTtat
"""
Jt»**e^U#al*
50' X 30'-'
($870.000)
($900.000)
($2,730.000)
($6.000.000)
160' X 100'-'
$14.000.000
$14.700.000
$44.600.000
$435.000.000
340' X 200'^
$55.100,000
$57.000,000
$173.000.000
$1.500.000.000
i/
£/
Estimates represent savings Industries potentially may Incur each year for 20 years. Potential savings may-vary
significantly from results shewn here due to uncertainties associated with'the market, waste generation, the
r each of the three industries were calculates oy sueirecting orr-site disposal costs TOT
ontalnment buildings from off-site disposal costs for facilities without containment buildings.
r managers of hazardous debris were calculated by subtracting en-site treatment costs for
ontalnment buildings from off-site treatment costs for facilities without containment
number of containment buildings per facility, and the number'of affected facilities within each Industry
Annual savings for oech of the three Industries were calculated by subtracting off-site disposal costs for
fedHtles with coi ' ---.--•- ..-.-..
Annual savings for
facilities with coi... ..
buildings. Estimates of savings Incorporate costs for 20 years, assuming a 7 percent social discount rate
Annuallzed costs estimates consist of capital cost of containment building construction (Including seeendery
containment, fugitive dust abatement equipment, end engineer oversight) and yearly operation and maintenance
cost of building. Operation and maintenance costs are assumed to be 10 percent of capital costs. Costs of
recordkeeplng have been subtracted from savings. . • • —
EC* has little data about the size of containment buildings used to store hazardous debris. Thus, It cannot
specify a typical storage dimension. ' .. . •
Dimension 1s typical of a containment building that would be used by a' toad smelting facility.
Dimension 1s typical of a containment building that would be used by 'an aluminum reduction facility. .'
Dimension Is typical of a containment,building that would be used by a facility producing K061.I
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Results of Cost Analysis
Exhibit 3-U
AmuBlized Costs of Contain*** Building Construction.
^^ operation, and Haintenanee
(asstafnga 3 percent social discount rate*
.50' X 30'-7
160' X 100'S'
Note:
a/
d/
3*0' X 200
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Results of Cost Analysis
Page 3-21
Exhibit 3-16
Annualized Costs of Engineered Barriers and Fugitive Dust Emission Abatement Equipment
{assuring a 3 percent social discount rate)
Containment Building r Dimensions .x
SO' X 30'-'
160' X 100'-'
340' X 200i-/
Note:
a/
ihlll^
^SsVwbndary ; Contatnmant ; •; :;j
$7.000
$9.000
$23,000
l||I**i* tivil;'8«at '; Emissiom Abatement
$3.000
$7,000
$30.000
EPA has little data about the size of containment buildings, used to store hazardous debris. Thus,
it cannot specify a typical' storage dimension. • -
- i ' ' *
Costs shown are annualized cost incurred for 20 years, assuming a 3 percent social discount rate.
fe/
Annualized estimates consist of capital costs of equipment and of annual operations and maintenance.
Operations and maintenance equipment costs are assumed to be 10 percent of capital costs of
equipment. • '
Dimension is typical of a containment building that would be used by a lead smelting facility.
Dimension is typical of a containment building that would be used by en aluminum reduction facility.
Dimension is typical of a containment building that would be used by a facility producing K061.
Exhibit S-17 ' .
Annualized Costs of Engineered Barriers and Fugitive Dust Emission Abatement Equipment
(assuming a 7 percent social discount rate)
Containmeut BuiIding Dimensions
^SeccridaiY-Contiinm^iJlJi-v
Abatement Equipment
50' X
$7.600
$3.000
160' X 100'
£/
$10.000
$7.700
340' X 200'5
$27.000
$30,000
Mote: EPA has little data about the size of containment buildings used to store hazardous debris.' Thus,
, it cannot specify a typical storage dimension.
a/ Costs shown are annualiled cost incurred for 20 years, assuming a 7 percent social discount rate.
Annualized estimates consist of capital costs of equipment and of annual operations and maintenance.
Operations and maintenance equipment costs are assumed to be 10 percent of capital costs of
equipment. * ' • -
b/ " Dimension is typical of a containment building that would be used by a lead smelting facility.
£/ ' Dimension is,typical of a containment building that would be used by an aluminum reduction facility.
d/ Dimension is typical of a.containment building that would be used by a facility producing IC061.
i • • i
In addition to quantitative estimates of recordkeeping costs presented in Exhibits 3-18 and
3-19, EPA qualitatively assessed the benefits of recordkeeping requirements for containment
buildings. EPA believes the costs are justified given the benefits that both the facility and the public
may incur.
Recordkeeping establishes adequate inspection plans to ensure that the unit is operating as
designated. This goal is achieved through the establishment of an inspection program that ensures
the structural integrity of the unit and prompt detection of any leaks or releases. EPA is requiring
an inspection schedule for these units whereby monitoring and leak detection equipment, the
• )
containment building, and the area surrounding the containment building are checked at least once
"X
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Page 3-22
Results of Cost Analysis
Exhibit 3-18
Annual Recordkeeping Cost*
Containment Building Dimension
50' X 30'
160' X 100'
340' X ZOO'
^>:;:-;"^ : -'.--•: .; ..,'.:..
$11.000
$33,000
$33.000
Note: EPA has little data about the size of containment buildings used to manage hazardous debris.
a/ Costs shown assume a maximum of one and one half hours will be needed to comply with the Agency's
recordkeeping requirements. This analysis assumed daily recordkeeping. Note, however, that the Rule
requires only weekly inspections. Thus, these figures conservatively overestimate costs.
{>/ Dimension is typical of a containment building that would be used by a lead smelting facility.
Dimension is typical of a containment building that would be used by an aluminum reduction facility.
Dimension is typical of a containment building that would be used by.a facility producing KMT.
Exhibit 3-19
National Annual Costs of Recordkeeping
Containment Building Dimension*
50' X 30'i'
160' X 100'y
340' X Z00'£/
Estimated National Annual Kecardkeepfng Coat*
Atuminue
Reduction
29 facilities
319.000
957.000
957,000
Lead Smelting
3ft facilities
330.000
990.000
990,000
Primary Steel .
production/HTW
9t facilities
1.001.000
3.003.000
3,003,000
Hazardous
Debris
150 facilities
1.650.000
4.950.000
4,950,000
Note: EPA has little data about-the size of containment buildings used to manage hazardous debris. This
analysis assumes daily recordkeeping. Note, however, that the Rule requires weekly inspections. Thus,
these figures conservatively overestimate recordkeeping costs. .
a/ Dimension is typical of a containment building that would be used by the lead smelting facility.
b/ Dimension is typical «f a containment building that would be used by an aluminum reduction facility.
c/ Dimension is typical of a containment building that would be used by a facility producing K061.,
each operating day to ensure that the unit is being properly operated and that no leaks or reieases
have occurred. This is consistent with the existing inspection requirements for tanks and tank
systems. ,
EPA believes such controls are key to providing maintenance of facilities to prevent
detrimental releases of hazardous waste. Uncontrolled releases could not only endanger human
health and the environment, but could cause relatively large cleanup costs.
EPA does not believe that facilities considering using containing buildings will be adversely
affected greatly by these requirements. It is EPA's understanding that the majority of facilities.
already have these recordkeeping measures or could easily modify their existing operations to include
them. EPA notes that large facilities are the most likely to use containment buildings and believes
that these facilities will be able to incorporate containment building recordkeeping into their present
-------
Results of Cost Analysis •_ , Page 3-23
operations relatively easily. EPA notes, for example/that automatic monitoring of dust is acceptable
in complying with standards for fugitive dust control and that many facilities already use this
machinery.
3.2.5 Costs of Corrective Action . -
Based on EPA's assumptions, it does not believe that the containment building provision will
produce any incremental costs or benefits with regard to corrective action authority. EPA did not
calculate the additional costs of corrective action to permitted facilities.
,
-------
-------
Economic Impacts . Page 4-1
CHAPTER 4
ECONOMIC IMPACTS
Within the constraints of available data, EPA assessed the economic impacts attributable to
the Phase 1 rule and presents the results below. Section 4.1 describes the economic impacts to
industry generating F037 and P038, while Section 4.2 discusses the economic impacts to industries
generating the other wastes affected by the Phase 1 rule.
i
4.1 PETROLEUM REFINING WASTES (F037 AND F038)
EPA lacked the site-specific data for analysis of the economic impacts from the F037 and
F038 LDRs. The Listing RIA, however, considered the economic impact of the F037 and F038
listing in light of anticipated land disposal restrictions on .these wastes. The impacts estimated in the
Listing RIA were determined by facility-specific compliance costs and the economic viability of. facility
owners. Therefore, the results of the Listing RIA's economic impact analysis are summarized below
as a surrogate measure of the impacts for the Phase 1 LDR F037 and F038 standards.
In order to assure the validity ~6f- such a substitution, EPA compared the incremental
compliance cost for the F037 and F038 standards in the.Phase 1 rule with that of the Luting Rule.
The Agency found that the Phase 1 rule will have an incremental compliance cost for F037 and F038
waste, for both nbnwastewater and hazardous debris, between $43 million and $50 million, while the
Listing RIA estimated an incremental annual LDR compliance cost of $37 million to $71 million
(adjusted to 1992 dollars). Therefore, EPA believes that the economic impacts of today's rule could
be less than the impacts estimated by the Listing RIA. .
In the Listing RIA, two to five percent of the refineries (depending on the post-regulatory
scenario) had cost impacts greater than one percent of sales. Cost impacts exceeding one percent
of sales can be viewed as an indicator of potentially significant economic impact Slightly under two
percent of the refineries had cost impacts that exceeded two percent of sales under the high-cost
scenario, indicating more severe economic impacts. Nine out of ten affected refineries in the high-
\ '
cost scenario had costs below 03 percent of sales, and over three-quarters of the refineries fell below
0.25 percent . .
The analysis of small entities presented, in the Listing RIA indicated that there were
potentially seven non-integrated refineries (i.e., refineries that did not produce their own crude and,
market their own products) with cost-to-sales ratios greater than one percent under the high-cost
-------
Page 4-2
Economic Impacts
scenario. A further analysis of employment effects and potential closures was not possible because
of insufficient financial data for individual refineries.
4.2 OTHER WASTES
Considering the economic impacts of LDRs for the newly listed organic .wastes other than
F037 and F038, EPA determined that the costs associated with all wastes would be minimal, with the
possible exception of costs for dinitrotoluene and toluenediamine production wastes. Even for these
wastes, incremental compliance costs are so low that it is unlikely that they represent a significant
economic impact . s ,
"' A quantitative assessment of the economic impacts .associated with the hazardous debris
standards was not possible because of data limitations. EPA does not have comprehensive site-
' *
specific information on the volumes of previously or newly regulated hazardous debris. EPA expects
that the impacts for previously regulated debris will not be significant since the revised standards will
be no more costly, and in some cases less costly, than the standards which currently exist The
impacts of the standards for newly regulated debris are uncertain. The estimated incremental annual
compliance cost for these standards could range between $4 million and $120 million, with an
expected median value of $10 million. For the organic chemical facilities generating newly regulated
hazardous debris, the incremental annual compliance cost could range from $1 million to $120 million,
with an expected median value of $7 million. Because only 14 faculties potentially generate debris
contaminated with newly regulated organic wastes, EPA acknowledges that in the upper bound some
\.
facilities could suffer significant economic impacts.
-------
Limitations ~ -..-•'.. Page 5-1
CHAPTERS
LIMITATIONS TO THE COST AND ECONOMIC IMPACT ANALYSIS
This chapter presents the limitations to EPA's analyses of costs and economic impacts of the
final rule. Section 5.1 describes limitations with the cost analysis. Many of the limitations which
apply to the cost analysis also apply to the economic impact analysis. Section 5.2 describes additional
limitations found in the economic impact analysis. : .
As there is always uncertainty in analyzing future impacts — uncertainty in future volumes
generated and treated, for example — EPA has not attempted an exhaustive characterization of this
anaiysis's limitations. Rather, in this chapter EPA has sought to discuss those limitations related to
the Phase 1 rule's particular information and methodological confines.
^ * • , ' - ' .
5.1 LIMITATIONS TO THE COST ANALYSIS .
Section 5.1.1 considers process wastes affected by the rule (i.e., those wastes routinely
generated in industrial processes and homogenous in nature), and Section 5.1.2 considers hazardous
debris. The limitations associated with EPA's analysis of the potential cost savings of the containment
building provision is presented in Section 5.13.
5.1.1 Process Wastes
Wastes Not Included in the Cost Analysis
. • EPA assumed that the compliance scenario for F037 and F038 would involve dewatering
sludge to 35 percent solids and oil for solvent extraction and 70 percent solids and oil for other
treatment technologies. EPA did not consider the cost of dewatering in its cost analysis, nor did it
consider the costs associated with managing aqueous residuals from the dewatering of F037 and F038.
EPA believes that as much as two-thirds of the water in F037 and P038 may be separated before the
sludge form of the waste is treated. Hence, the volume of aqueous residual from dewatering is
probably extremely large. EPA believes, however, that the bulk of these wastewaters will be managed
in tanks, and that treatment costs will be low. .
EPA's cost analysis did not include several wastes that could be affected by the rule. These
wastes include P001-F005 spent solvents, 24 K- and U-wastes with wastewater treatment standards
based on scrubber waters, and K062 and F006. EPA does not believe that the revisions included in
-------
Page 5-2
Limitations
the Phase 1 rule for the spent solvents and the 24 K- and U-wastes will change the required
1 * ''
management practices for these wastes significantly. With regard to K062 and F006, EPA expects
that some facilities may be able to reduce their costs as a result of the alternative treatment standards
being promulgated.' EPA did not quantify this reduction in costs because it did not have adequate
information on baseline management and waste characterization of K062 and F006.
Volumes That May Be Inaccurate .
EPA based the cost analysis for K061 on the quantity of this waste being generated. Because
EPA, did not have adequate data on waste characterization, the extent to which high temperature
metals recovery (HTMR) is currently being used, and the effectiveness of the non-HTMR treatment
technologies, it could not quantify the volume of K061 that would be treated differently from current
treatment methods as a result of the rule. EPA assumed that the baseline management practice for
K061 formerly in the low zinc subcategory is stabilization. Because in some instances stabilization
is capable of meeting the concentration-based standards for K061, no volume of K061 would be
affected by the Phase 1 rule. ; .
Unit Treatment Costs That May Be Inaccurate
EPA did not consider on-site treatment technologies for any process wastes except F037 and
F038. Because the costs of on-site treatment are typically less than that of off-site treatment, EPA,
may have overestimated treatment costs in some instances. • ,
For its cost analysis of F037 and F038, EPA used generic unit costs for pn-site treatment
costs. In practice, the unit cost for on-site treatment of wastes is heavily dependent on two factors:
(1) the extent to which capital improvements will heed to be made to a facility's waste management
system, and (2) the aggregated volume of wastestreams likely to be treated using a given technology.
Thus, a more accurate estimate of treatment costs could have been obtained by using cost equations
developed for each technology and applied on a site-specific basis.
5.1.2 Hazardous Debris
EPA obtained its results for the incremental compliance cost of treating both previously and
- «
newly regulated hazardous debris on information gathered from experts. For previously regulated
hazardous debris, EPA solicited information from only two internal sources. Furthermore, the
information gathered regarding the costs of treating previously regulated hazardous debris considered
only washing, incineration, immobilization, either solely or Jn\ combination. For newly regulated
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Limitations
Page 5-3
hazardous debris, EPA relied on structured interviews with environmental managers in the industries
• ' ' , E
affected by the Phase 1 rule. EPA based its estimate of the incremental compliance cost of treating
newly regulated hazardous debris on information gathered in structured interviews with environmental
managers in the industries affected by the Phase 1 rule. Because of governmental restrictions on
requests for data collection, EPA conducted only nine structured interviews and extrapolated the data
collected to estimate results for the universe of facilities potentially affected by the Phase 1 rule. .The
limited quantity of data that EPA could collect in its interviews resulted in volume and cost estimates
. j
with another important source of uncertainty —' the .extent to which this very small sample will be
representative of a much larger set of facilities — in addition to the uncertainty cited by facility
experts.1 EPA indicates the degree of variance attributable only to the uncertainty cited by facility
experts in the course of presenting its results in Chapter 3.
..'''"' .'/••'
5.1 J Containment Buildings
This section identifies important limitations to the analysis of the potential cost savings
„ " >
associated with containment buildings and explains the implications of the limitations. Most of the
limitations stem from data gaps.
'*•
buildings sizes that might be used in the three industries examined, and it assumed similar sizes would
be appropriate for managers of hazardous debris. The data on which EPA based its estimation of
i . '
typical sizes were not comprehensive. Thus, there is uncertainty associated with the typical size of
containment buildings that would be constructed; the variance of sizes may be considerable.
i .... ^
Uncertainty of Number of Affected Facilities. EPA calculated national cost savings for the
three key industries based on the available data of the number of facilities within an industry that
potentially may use containment buildings (see Section 132). This data, however, is somewhat dated
and may not be precise. EPA had little data on the number of facilities that may potentially manage
hazardous debris in containment buildings. Therefore, EPA's calculations of national cost savings
1 The variance associated with the experts' prediction was considerable. For FD37 and P038 contaminated debris the
estimated volume had a mean of 18,000 tons and a standard deviation of 3,000 tons (estimated cost had a mean of S3
million and a standard deviation of SI million). For organic chemically contaminated debris the estimated volume bad a
mean of 32,000 tons and a standard deviation of 31,000 tons (estimated cost had a mean of $18 minion and a standard
deviation of $27 million). The total newly regulated contaminated debris estimated volume had a mean of 49,000 and a
standard deviation of 31,000 (estimated cost bad a mean of $20 million and a standard deviation of $25 million).
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Page 5-4
Limitations
represent a range of possible savings and have a large amount of uncertainty. Thus, calculations of
national cost savings should be considered with caution. ,
Uncertainty in Market for Containment Buildings. EPA has no data on the, number of
'•'«'.
containment buildings per facility or nationally in each industry nor does it have detailed knowledge
of the market conditions of the potentially affected universe of facilities. It is difficult to predict the
potential number of containment buildings that will be built since this is a facility-specific financial
decision for each generator and commercial waste treater.
\ - *
The Agency has assumed only one containmenfper facility. The possibility remains that some
.facilities may .have more than one building. To the extent that facilities elect to build multiple
containment buildings, EPA's results may underestimate cost savings. The Agency also has not
addressed the potential use of containment buildings as temporary units at corrective action sites.
In addition, the Agency's analysis does not capture benefits that some industries (e.g., lead
smelting) may enjoy with the containment building provision. For these industries, there is.no non-
land-based unit that they can use in place of the containment building.
Finally, the Agency's analysis does not include the benefits that some generators may enjoy
by using innovative technologies that become more feasible with the increased storage capacity of
containment buildings.
Economies of Scale for Transportation and Waste Management. EPA had no data regarding
the relationship between waste volumes and cost of waste transportation and management EPA
i ' f •
believes that its results may underestimate the potential cost savings of using containment buildings
at facilities generating large quantities of waste that might be managed using containment buildings.
Storage Area Retrofitting. In calculating the potential cost savings of containment buildings,
EPA assumed that facilities would have to construct completely new containment buildings. These
calculations may overestimate costs because many potentially affected facilities, may only need to
perform minor retrofitting to existing structures to meet or exceed EPA standards for containment
buildings. In addition, EPA Regional offices and States offer flexibility with regard to EPA's design
specifications. Individual facilities may be granted variances from some of the design standards.
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Limitations
Page 5-5
Linear Relationship Between Size of Building and Cost of Recordkecoing. Because EPA
had no data on recordkeeping costs for the potentially affected universe of facilities; it estimated a
key component, inspection costs, by using a man-hour approach. Implicit in this approach is the
assumption of a linear relationship between size of containment building and cost This assumption
is likely to overestimate the actual costs that larger facilities may bear.
5.2 LIMITATIONS TO THE ECONOMIC IMPACTS ANALYSIS ,
In most of its analyses for RIAs, EPA evaluates economic impacts on a facility-by-facility bask
EPA did not consider such an approach for this analysis because its cost analysis did not involve site-
specific estimates of the incremental cost of compliance. Furthermore, EPA did not collect any
•4 / ' ' '
financial data on industries affected by the Phase 1 rule. .
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APPENDIX A
CALCULATIONS OF F037 AND F038
VOLUMES
-------
-------
i ' (
EPA estimated the annual volume of routinely generated F037 and F038 in three steps.
First, EPA estimated the volume from existing tanks. Second, EPA estimated the volume from
surface impoundments due to be replaced by tanks. EPA then aggregated the volumes from the
first two steps.
Waste Volume from Tanks , ,
* As part of the capacity* determination for the Phase 1 rule, EPA estimated that 180,000
tons per year of P037 and F038 (dewatered) were generated annually. This estimate
included waste that is treated in the baseline and waste generated in California.
~> • ''._.'•
• EPA estimated that of the volume of F037 and'F038 generated annually, 70,000 tons were
generated in California. This State has its own land disposal restrictions program, under
which wastes categorized by U.S. EPA as F037 and F038 have to be treated before land
.' disposal. Therefore, P037 and F038 generated California will not be affected by the final
rule.
•. EPA estimated that 29,000 tons of non-California F037 and F038 is currently being
managed using cokers. This volume of waste will not be affected by the final rule.
, . , I' ' . ,
• A total of 80,000 tons (rounded) of F037 and F038 will require additional treatment as a
result of the final rule. ...
Waste Volume from Surface Impoundments .
• As part of the Section 3007 submissions collected for the capacity determination for the
land disposal of TC waste, six facilities provided paired information on surface
impoundment sludge generation and tank sludge generation.
, ' " ' ' '
• The ratios of surface impoundment sludge generation to tank sludge generation for the
facilities that provided information ranged from 10:1 to 1:1. Most of the values were
between 4:1 and 2:1. To determine the volume of sludge generation in tanks replacing
large surface impoundments EPA used the median ratio, 3:1. EPA applied this ratio to
the estimated generation volume of sludges in surface impoundments.
• The estimate of the total annual generation of sludges in surface impoundments was based
on the following: phone calls to individual facilities, comments from individual facilities
regarding the proposed rule, information submitted by several facilities independent of the
' ' rule, and ah estimate based on the Petroleum Refining Data Base for the facilities not
captured by other data sources. EPA's analysis indicated that the total annual generation
of sludge in all surface impoundments ranged from 112,000 to 200,000 tons. The average
annual value was 160,000 tons (rounded). .
A-l
-------
To estimate the generation of F037 and F038 in tanks replacing large surface
impoundments, EPA applied the 3:1 ratio to the 160,000 tons per year estimate. The
result was an estimate of 50,000 tons per year (rounded). Because these wastes will be
newly generated as a result of the conversions to tanks, EPA assumed that the total *
volume would require treatment as a result of the LDRs.
>
• j
EPA determined that only 4 percent of the volume of F037 and F038 generated in tanks
replacing surface impoundments would be generated in California. As a result, the figure
for F037 and F038 affected by the rule did not change when rounded.
Aeereeate Volume of ¥037 and F038
* The annual volume of F037 and F038 requiring additional treatment and currently
generated in tanks is 80,000 tons (rounded). The annual volume of F037 and F038
requiring additional treatment and currently generated in impoundments is 50,000
(rounded). Accordingly, the aggregate annual volume of F037 and FD38 requiring
additional treatment is 130,000.tons.
A-2
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APPENDIX B
y . "
COSTS AND BENEFITS OF DREDGING
AND CLOSURE OPTIONS FOR
PETROLEUM REFINING SURFACE
IMPOUNDMENTS
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Background ; " • -
' " . \ •
On ^oyember 2, 1990 (55 FR 46354), EPA listed two additional wastes generated by the
petroleum refining industry as hazardous wastes F037 and F038. These two newly listed
hazardous wastes are generated in the primary and secondary separation of oil and solids from
petroleum refinery wastewaters. These sludges have waste properties similar to other petroleum
refining wastes listed as K048 and K051. (For more detailed descriptions of all of these
petroleum refining wastes, see 45 FR 74884, May 19, 1980; 55 FR 46354, November 2,1990; 56
FR 21955, May 13,1991; and the associated listing background documents.) These listings
became effective on April 2, 1991. .
Before the effective date of the listing, F037 and F038 sludges were managed as a Subtitle
D waste in a variety of units. Surface impoundments'- sometimes were lined with clay, although
a majority were unUned —were the major affected unit type. The impoundments were used
mainly for passive settling, rather than aggressive wastewater treatment, such as biological
treatment
On the effective date of the listing, surface impoundments containing F037 and F038 came
under the authority of Subtitle C. Section 3005(j)(6) of RCRA allows facilities four years to
comply with the minimum technology requirements (MTR) that are specified for Subtitle C
surface impoundment under section 3004(o)(l)(A) of RCRA. Hence, surface impoundments
managing F037 and F038 do not have to meet the MTRs until April 2,1995. . ' -_
With the setting of treatment standards for F037 and F038, these wastes may no longer be
land disposed withqut prior treatment Because a two-year national capacity variance is being
granted for these wastes, compliance with treatment standards will not be required until two years
after the effective date of the Phase 1 LDR rule (i.e., summer 1994). Wastes that are disposed of
during a national capacity variance and not treated normally must be disposed of in a MTR unit
In the development of the treatment standards for F037 and F038, EPA considered
requiring surface impoundments in the MTR retrofit period to perform annual dredging, as is
required for Subtitle C treatment surface impoundments. EPA also considered alternatives for
closure of surface impoundments used for petroleum refinery wastewaters. These closure
alternatives included closure as a landfill, dredging waste before capping, and clean closure. In
the final rule, EPA does not require dredging during the retrofit period and it allows closure as a
landfill. This appendix discusses'the costs and benefits of the dredging and closure options that
EPA considered.
Costs of Dredging and Closure • > • . . .';
< ' . " *'
Dredging Cost
Costs include dewatering and treating the dredged sludge as appropriate. Cost equations
were developed for annual dredging by curve fitting the estimated costs for each model size.
Summary costs for two years of annual dredging for the four sizes of surface impoundments are
presented in Exhibit B-l. .' '' (
B-l
-------
Exhibit B-l
Costs of Two Years of Annual Dredging
' Sariace Imjwundinent
•' . - .sto^^g%5
0.9 acre
5.5 acres
15 acres
55 acres
(^
M^w^:Vw1a^;Pei^,:i§
$100,000
$720,000
' $2,100,000
$8,800,000
One Year Dredging During .
Variance Period and One Year V
;f Dragging- After Variance Period ;
$400,000
$810,000
$2,300,000
$9,300,000
The following general assumptions were made which apply to annual dredging costs:
* .All impoundment model sizes are square in shape and have an operating depth of
8ft. , .- . • " ' ' ' ' - '
* A retention time of 3.5 days was assumed based on the average wastewater
flow/day to the average impoundment size for categories 3,4,5,6 and 7 from the
Petroleum Industry Studies Database.1
• The wastewater influent contained: 200 ppm solids and the effluent contained
100 ppm solids.
Dredge costs .were developed from vendor contacts.
Dewatering costs were updated from the F037/F038 Listing RIA.
Sludge treatment costs are based on those presented in Chapter 2. . .
Untreated sludge or residuals from treatment are disposed in off-site Subtitle C
MTR landfills.
Annual Dredeine Costs During Retrofit Period Before Variance Expires
All impoundments
Y.= 56.000X1'09
Where X = impoundment size from 0.9 to 55 acres
Y = dredging costyear (in 1992 dollars)
1 Used in the Listing RIA, referenced in Chapter 1.
B-2
-------
The following assumptions apply to dredging costs during the retrofit period:
" ' *(
* Sludge contains 15 percent solids by weight and have a specific gravity of 1.1.
Since sludge is dredged annually, EPA assumed a low solids concentration because
sludge would not have a long period of time to compact.
• Impoundment sludge depth of 0.5 ft when dredged. 1.5 acre and 5.5 acre
impoundment would buy dredging equipment while.a 0.9 acre and 5.5 acre
impoundment would hire a contract dredger.
• Operator dewaters sludge to a solids concentration of 45 percent and a specific
gravity of 1.4.
Sludge is disposed of off-site in MTR Subtitle C landfills.
Annual Dredging Costs During Retrofit Period After Variance Expires
. - i • ^ • ' •
Less than 1 acre = $350,000/acre/year (in 1992 dollars)
1 acre to 55 acre .
Y =
Where X = impoundment size in acres
Y = dredging costtyear (in 1992 dollars)
The following assumptions apply to dredging costs during the retrofit period:
• Sludge contains 15 percent solids by" weight and have a specific gravity of 1.1.
Since sludge is dredged annually, EPA assumed a low solids concentration because
sludge would not have a long period of time to compact
• Impoundment sludge depth of 0;5 ft when dredged. 1.5 acre and 5.5 acre
impoundment would buy dredging equipment while a 0.9 acre and 5.5 acre
impoundment would hire a contract dredger.
• Operator dewaters sludge to a solids concentration of 45 percent* and a specific
gravity of 1.4.
• Sludge from 0.9 acre impoundment is shipped off site for incineration.
• Sludge from 5.5 acre, 15 acre, and 55 acre impoundment are treated on-site. . The
treatment unit cost represents a combination of coking, solvent extraction, and
incineration. ,
B-3
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Closure Costs ,
Costs for closure were estimated for the following four scenarios: (1) capping and closure
as a landfill for undredged surface impoundment, (2) capping and closure as a landfill for surface
impoundment that has undergone annual dredging, (3) clean closure assuming the impoundments
have been dredged annually, and (4) clean closure assuming the impoundments have never been
dredged. Cost equations were developed for the four scenarios by curve fitting the estimated
costs for each model size. Summary costs for closure options for the four sizes of surface
impoundments are presented in Exhibit B-2.
Exhibit B-2
i . .
Costs of Surface Impoundment Closure Options
Impoundment Size
• Oeaa Oosure/
0.9 acre
$1,400,000
$1,700,000
$2,000,000
$2,600,000
5.5 acres
$5,100,000
$7,700,000
$12,000,000
$15,000,000
15 acres
$12,000,000
$20,000,000
$31,000,000
$40,000,000
55 acres
$40,000,000
$71,000,000
$110,000,000
$150,000,000
Closure As a Landfill for Dredged and Undredged Impoundments
Landfill closure and post-closure costs were estimated for four model size petroleum refining
wastewater impoundments: 0.9 acre, 5.5 acre, 15 acre, and 55 acre. Closure costs were estimated
for landfill closure assuming the impoundments have been dredged annually and landfill closure
assuming the impoundments have never been dredged. Cost equations were developed for the
two closure scenarios and post-closure by curve fitting the estimated costs for each model size.
. Landfill closure cost equation:
-------
(2) If impoundment has never been dredged:
Y* 1446.000X1-02
where X = impoundment size in ranging in acres from 0.9 to 55
Y = landfill closure cost
Hie following design and operating assumptions were made for estimated the landfill closure
costs: ..-'.-.
• Landfill closure cost components included the following: x '
removal of free' liquid, - .
• < - solidification of sludge,
fill to grade with native soil, ,
final cover,
construction quality assurance program for final cover,
i - . installation of ground-water monitoring wells, /
establishment of background ground-water chemistry,
decontamination of equipment,
testing for success of equipment decontamination, and
certification of closure. ,
• All impoundment model sizes are square in shape and have an operating depth of
8 ft.
* The impoundment is 100 percent full at closure. The free liquid is pumped out
and disposed in an on-site wastewater treatment system. The volume of > free liquid
is equal to the operating volume (capacity) minus the volume of accumulated
sludge. EPA assumed a free liquid specific gravity of 1.0 and 264.3 gal/m3.
• . Accumulated sludge remaining in the impoundment at closure is solidified to
support the final cover. The volume of accumulated sludge varies depending on
whether the impoundment has been dredged annually or has never been dredged.
If the impoundment has been dredged annually, the volume of sludge to be
. ' solidified at closure is equal to the same volume of sludge that has been
• dredged annually. . '
If the impoundment has never been dredged, the volume of sludge to be
solidified at closure is assumed to be 13 years of accumulated sludge (i.e.,
the maximum sludge accumulation that would allow for efficient operation).
B-5
-------
Following sludge solidification, EPA assumed the impoundment is filled with native
soil to bring the impoundment to grade. Assumed solidification of sludge results in
a 50 percent increase in sludge quantity. The volume, of native soil required to
bring the impoundment to grade is equal to the operating volume (capacity) minus
the volume of accumulated sludge, which has doubled in volume. Note: the
volume of native soil required varies depending on whether the impoundment has
been dredged annually.
The final cover system design consists of the following layers in ascending, order,
starting with the layer closest to the waste:
j t ' ,
0.6 meter clay layer,
30 mil PVC liner,
- - 0.3 sand layer,
geotextile filter fabric,
0.6 meter topsoil layer, and
vegetation.
EPA's estimate includes cost for a construction quality assurance program for the
final cover. ,
EPA's estimate includes cost for installation of upgradient and downgradient
ground-water monitoring wells.
Upgradient wells (6 wells)
- Installation of three shallow wells to provide horizontal profile of
ground-water composition and one cluster of three wells at
different depths to provide a vertical profile of ground-water
composition.
Downgradient wells (minimum of 9 wells)
— Minimum of three clusters of three wells for all impoundments with
a side dimension less than 300 ft
i*
- For impoundments with a side dimension greater than 300 ft, three
clusters for first 300 ft, plus one cluster of. three wells for every
additional ISO ft
EPA's estimate includes cost for establishment of background ground-water
composition, which consists of quarterly sampling of upgradient wells for one year
for the following parameters: pH, specific conductance, total organic carbons, total
organic halogens, and metals. Note: EPA assumed the operator would .
demonstrate to the Regional Administrator that more than 180 days are necessary
for closure. .
B-6
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• EPA's estimate includes cost for decontamination of equipment, which consists of
steam cleaning heavy equipment used to close the impoundment as a landfill and
flushing lines and decontamination pumps with an alkaline solution. Includes cost
for protective clothing for decontamination personnel. Decontamination residuals
collected and disposed in on-site wastewater treatment system.
• EPA's estimate includes cost for testing to determine that all equipment, pumps,
and lines have been successfully decontaminated, which consists of collecting
samples from the decontamination residuals and analyzing for metals, volatile
organics, semivolatile organics, and sulfides. Assumed one sample collected and
analyzed from the residuals from each piece of equipment, pump, and line. .
• EPA's estimate includes cost for certification of closure by an independent
registered professional engineer (PE). Costs include review of the closure plan,
weekly inspections by the PE during the closure period, and final documentation
that the facility has been closed in accordance with the approved closure plan.
*
The following design and operating assumptions were made for estimated the landfill post-closure
costs: ' . .
* Landfill post-closure cost components included the following:
- . preparation and submittal of survey plat,
- submittal of waste record,
placement of notation on property deed,
inspection of final cover,
maintenance of final cover, . '
- partial revegetation of final cover,
, - routine erosion damage repair,
i - rodent control, . ' ' • '
ground-water monitoring, and
certification of post-closure care.
• Preparation and certification of a survey plat by a professional land surveyor,
indicating location and dimension of the closed impoundment with respect to
permanently surveyed benchmarks. Includes filing the,plat with the local zoning
] • ' authority. . •
. . • Submittal of waste record to the local zoning authority.
, 1 • "
' • Placement of notation on property deed stating the previous land use.
• Semi-annual inspection of the final cover throughout the post-closure care period,.
which was assumed to be 30 years in duration.
' •" • ' ' ' .
, • Maintenance of the final cover throughout the post-closure care period, by mowing
semi-annually and fertilizing annually.
B-7
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• Partial replacement of the vegetative cover, which includes reseeding, fertilizing,
mulching, and watering one-sixth of the final cover every five years.
• - Extermination of burrowing rodent in final cover every two years.
• Routine erosion damage repair of the final cover and ditch. Damage repair
consists of soil placement by hand every five years.
• Semi-annual detection monitoring of downgradient wells for the following
parameters: pH, specific conductance, total organic carbon, total organic halogen,
metals, volatile organics, semivolatile organics, and sulfides.
• Costs of for certification of closure by an independent registered professional
engineer (PE). Costs include review of the post-closure plan, weekly inspections
by the PE during the closure period, and final documentation that the facility has
been closed in accordance with the approved post-closure plan.
Landfill post-closure cost equation:
Y = SSUOOX0-5 + 384,100
. where X = impoundment size in ranging in acres from 0.9 to 55
Y = total post-closure cost for 30-year period
Clean Closure f Dredged and Undredged Impoundments)
;, '- *' * — » • F -^
Clean closure cost equations:
N '
(1) If impoundment has been dredged annually:
. Y-2,200,OOOXa89
Where X = Impoundment size in acres ranging from 0.9 to 55 acres
. . . Y = Clean closure cost (in 1992 dollars)
(2) If impoundment has never been dredged:
Y~2,700,OOOX-64,000
Where X = Impoundment size in acres ranging from 0.9 to 55 acres
Y = Clean closure cost (in 1992 dollars) •• .
EPA's analysis considered the following cost components:
Removal of free liquid and treatment in on-site wastewater treatment system,
Excavation and treatment of accumulated sludge,
B-8
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Excavation and treatment of contaminated soils,
Installation of ground-water monitoring wells, '
Establishment of background ground-water chemistry,
Establishment of background soil chemistry,
Decontamination of equipment, .
Testing for success of equipment and soil decontamination,
.Ground-water monitoring, and
Certification of closure. .'.-...
The following design and operating assumptions were made for estimating the clean
closure costs: : ,
• All impoundments model sizes are square in shape and have an operating depth of
''8ft . - ' ' •' • . .
• The impoundments is 100 percent full at closure. The free liquid is pumped out
and discharged to an on-site wastewater treatment system. The volume of free
liquid is equal to the operating volume (capacity) minus the volume of
accumulated sludge. EPA assumed a free liquid specific gravity of 1.0 and 264.2
, gal/m3.
r ' ^
• Accumulated sludge would be removed as a part of clean closure. The volume of
accumulated sludge depends on whether the impoundment has been dredged
annually or has never been dredged.
i ( ' -
If the impoundment has been dredged annually, the volume of sludge to be
removed at closure is equal to the same volume of sludge dredged annually
'_ , ' , and is characterized and managed as follows:
, ~ Sludges contain 15 percent solids by weight and have a specific
gravity of 1.1 prior to dewatering.
— Dewatered sludges contain 45 percent solids and have a specific
.gravity of 1.4.
— Sludge from 0.9 acre impoundments is shipped off site for
incineration.
-- Sludge from 5.5 acre, 15 acre, and 55 acre impoundments are
- treated on-site. The treatment unit cost represents a combination
of coking, solvent extraction, and incineration.
1 - If the impoundment has never been dredged, the volume of sludge to be
, removed at closure is assumed to be 13 years of accumulated sludge since
any more sludge accumulation would result in inefficient operation of the
surface impoundment In this case, sludges were characterized and
managed as follows: , . • .,
- Sludges contain 45 percent solids by weight and have a specific
gravity of 1.4 prior to dewatering. Since sludge remains in
B-9
-------
impoundment a long period of time assumed a high solids
concentration because sludge would be very compacted.
~ No dewatering is done prior to sludge treatment. .
- Sludge is treated on site. The treatment unit cost used represents a
mixture of coking, solvent extraction, and incineration.
/
Two feet of contaminated soil are excavated.
EPA assumed a soil density of 1.7 ton/m3.
Contaminated soil is treated on site. The treatment unit cost used
represents a mixture of coking, solvent extraction, and incineration.
Installation of upgradient and downgradient groundwater monitoring wells are
installed to demonstrate no ground-water contamination. These wells are installed
as follows:
Upgradient wells (6 wells)
- Installation of three shallow wells to provide a horizontal profile of
ground-water composition and one cluster of three wells at
different depths to provide a vertical profile of ground-water
composition.
• - /
Downgradient wells (minimum of 9 wells)
- Minimum of three clusters of three wells for all impoundments with
a side dimension less than 300 ft
• '\
• - For impoundments with a side dimension greater than 300 ft, the
minimum three clusters tor the first 300 ft plus one cluster of three
wells for ever additional ISO ft
* • - ,
Establishment of background ground-water composition consists of quarterly
sampling of upgradient wells for one year for the following parameters: pH,
specific conductance, total organic content, total organic halogens, and metals.
Note: EPA assumed the owner/operator would demonstrate to the Regional
Administrator that more than 180 days are necessary for clean closure.
Establishment of background soil chemistry consists of collecting four soil samples
at same depths that impoundment soils samples will be collected, and analyzing for
metals, volatile organics, semivolatile organics, an sulfides. EPA assumes
background samples are collected from "uncontaminated" areas which have not
been affected by routine operations of the facility.
Decontamination of equipment consists of steam cleaning heavy equipment used to
excavate sludge and contaminated soil, flushing lines, and decontaminating pumps
with an alkaline solution. This includes costs for protective clothing for
B-10
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decontamination personnel. Decontamination residuals are collected and disposed
in on-site wastewater treatment systems.
• Testing to determine that all contaminated soil has been removed consists of
collecting soil samples from the base and side walls of the' impoundment, analyzing
the soil samples for metals, volatile organics, semivolatile organics, and sulfides,
and comparing the results to EPA recommended health based exposure limits or
background values. The number of soil samples collected for each impoundment is
based on establishing a grid system over the area and collecting one soil sample at
the intersection of the grids. EPA assumed the following grid intervals:
• Impoundment Size «. Grid Interval
, . less than 0.25 acre 20 feet (a minimum of nine sample stations)
025 - 3.00 acre 40 feet
3.01 - 35.00 acre , 60 feet
80 acre 80 feet
» Testing to determine that all equipment, pumps, and lines have been successfully
decontaminated consists of collecting samples from the decontamination residuals
and analyzing for metals, volatile organics, semivolatile organics, and sulfides. EPA
assumed one sample is collected and analyzed from the residuals from each piece
of equipment, pump, and line.
' . , • Groundwater monitoring during the closure period consists of semi-annual
sampling of downgradient wells for the following parameters: pH, specific
conductance, total organic content, total organic halogen, metals, volatile organics,
semivolatile organics, and sulfides. EPA assumed two sampling events during the
closure period. Note: EPA assumed the owner/operator would have
demonstrated to the Regional Administrator that more than/180 days are necessary
for closure. . -
• Equation includes costs for certification of closure by an independent registered
'. professional engineer (PE). Costs include review of the closure plan, weekly
inspections by the PE during the closure period, and final documentation that the
facility has been closed in accordance with the approved closure plan.
Benefits of Dredging and Closure • / . '
, This section focuses on the benefits of dredging surface impoundments containing F037
and F038 in terms of the effect on risk to human health. EPA is limiting this section further to a
qualitative discussion of contaminant release to ground water because fate and transport
modelling are beyond the scope of this study. EPA believes that analyzing the fate and transport
of contaminants released during and after the retrofit period is complicated by the release of .
contaminants from impoundments during the period in which F037 and F038 were not regulated
as hazardous. Potential releases during and after the retrofit period are probably insignificant
compared with these previous releases. ' .
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In its analysis, EPA considered the factors influencing contaminant release, how dredging
would effect each'of these factors, and finally contaminant release involved with closure and clean
closure. Concentrations of contaminants, barriers (liners or natural), and the hydraulic head
within the surface impoundment all contribute to the release of contaminants as leachate.
Constituents from F037 and P038 may be present in both the wastewater and sludge in
impoundments. The contaminants in the sludge may exhibit higher concentrations than those
found in the aqueous medium, and therefore have a potential to leach more contaminants to the
unsaturated zone. Where this is the case, dredging the surface impoundment to remove the
sludge will also remove a significant amount of the contaminants. • •.'
As was discussed earlier in this analysis, most surface impoundments containing F037 and
F038 are unlined. In some situations, native clay material could form a natural barrier to
contaminant transport Even where this is not the case, the sludge layer at the bottom of the •
impoundment may form a barrier to leaching. The sludge layer may clog the pore spaces of the
material beneath the surface impoundment and thus retard release of contaminants from
wastewater to the unsaturated zone. Where native material or the sludge in the impoundment
form a barrier to contaminant movement, dredging the impoundment could have
counterproductive effects by damaging the native barrier and removing the sludge barrier. .
Whereas dredging annually during the retrofit period would determine the potential for
leachate release over a relatively short period of time (i:e., no longer than two years), the
conditions for closure could potentially, determine the rate of contaminant release for hundreds of
years. Final dredging before capping would remove the bulk of contaminant mass and therefore
eliminate most of the potential risk of contaminants leaching into ground water at a unit
Because most petroleum refinery surface impoundments are unlined, soil beneath the unit could
.also contain high levels of constituents. If clean closure were required, these contaminants would
also be removed and the potential ground-water contamination would diminish almost to zero,
except for the potentially large mass of contaminants that had been released while F037 and F038
were not yet regulated by Subtitle G . -
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APPENDIX C
UNIT COST DATA GATHERED FOR
HAZARDOUS DEBRIS TREATMENT
TECHNOLOGIES
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-------
\
A list of technologies for which EPA obtained unit prices is presented below. For each
technology there is a line to provide price ranges, a typical price,, the number of vendors supplying
information, and the number of price ranges supplied by the vendors. In addition, there is space
for special notes that apply to the technology or price ranges. Unit costs for previously regulated
hazardous debris treatment technologies are presented as the last section of this appendix.
A quick review of this list will show that EPA has been unable to obtain price information
for the majority of hazardous debris treatment technologies. The next section of this appendix
details the difficulties EPA has had in obtaining unit price information.
It should be noted that the only prices that include transportation costs are the typical
unit prices. .Typical prices are supplied for only three technologies: washing (physical extraction),
immobilization, and destruction. Price data is insufficient to develop typical prices for the
remaining technologies. That is, EPA did not determine a typical cost when only one price range
was supplied.
Hazardous Debris Treatment Technologies
Extraction Technologies
Abrasive Blasting
Price Range:
Typical Price:
Number of Vendors: ,
Number of Ranges: , •
• Note: EPA was not able to obtain cost data for
abrasive blasting that was available and
demonstrated.
Acid Washing .
Price Range:
Typical Price: ,
Number of Vendors:
Number of Ranges:
Note: EPA was not able to obtain cost data for
acid washing that was available and
demonstrated.
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High Temperature Metals Recovery
Price Range:
Typical Price: ;.
Number of Vendors:
Number of Ranges:
Note: EPA was not able to obtain cost data for
high temperature metals recovery (HTMR)
that was available and demonstrated.
Liquid Phase Solvent Extraction
Price Range: $150 to $700 per .ton .
Typical Price:
Number of Vendors: 1
Number of Ranges: 1 .
Notes: Pieces up to 3.5 inches.
Plan to expand to larger pieces in the future. .
Thermal Desorption
Price Range: $55 per ton
Typical Price:
Number of Vendors: 1 '
Number of Ranges: 1
Notes: Pieces up to 4 inches.
(Also received an equipment price of $500,000 to $600,000 for pieces
up to 4 inches.)
Scarification, Grinding, and Planing
Price Range:
Typical Price:
Number of Vendors:
Number of Ranges: . .
Note: EPA was not able to obtain cost data for
scarification, grinding; and planing that was
available and demonstrated.
SpaUing .
Price Range:
Typical Price: . .
Number of Vendors:
Number of Ranges:
Note: EPA was not able to obtain cost data for
spaQing that was available and demonstrated. *
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Vapor Phase Solvent Extraction ,
Price Range:
Typical Price:
Number of Vendors: .
Number of Ranges: , • •
Note: EPA was not able to obtain cost data for
vapor phase solvent extraction that was
available and demonstrated. ,. .
* Vibratory Finishing , . . , •
Price Range:
Typical Price: ,
Number of Vendors:
Number of Ranges: . .
^ ' *
Note: EPA was not able to obtain cost data for
vibratory finishing that was available and
'• demonstrated. . _ . .
_'
Water Washing and Spraying
Price Range: $35 per cubic foot ._
$300 per ton (off site) ;
• $40 to $500 per cubic yard j
$400 per hour '
$32 to $108 per cubic yard (does not include wash water
treatment or residual disposal) ' , ' • •
. $75 to $100 per cubic yard (does not include wash water
treatment or residual disposal)
Typical Price: $350 ton x
Number of Vendors: 6
; Number of Ranges: 6
f * • * " • •.
Note: The typical price presented above was developed from the last two
price ranges presented and includes wash water treatment,
transportation, and residual disposal in a Subtitle D landfill. Typical
price does not include grinding, which will be required under the final
rule. ,
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Immobilization Technologies '
Stabilization
Price Range: $280 per ton (stabilization only?)
$45 to $60 cubic yard (stabilization only),
-'.-'" $600 to $2000 per ton (includes stabilization and disposal
at a Subtitle C landfill)
Typical Price: $550 per ton
Number of Vendors: 6 ,
Number of Ranges: 6
Notes: « The price per cubic yard is limited to pieces up to 2.inches.
The typical price was calculated using .the price ranges presented above
and determining the difference in the cost of Subtitle C and Subtitle D
disposal for the stabilized residual. Price ranges for stabilization were
not provided specifically for debris. This unit price assumes relatively
small pieces of debris and includes transportation.
Macroencapsulation • . •
Price Range: ,
Typical Price: " ;
Number of Vendors: -
. Number of Ranges: '
Note: . EPA was not able to obtain cost data for
macroencapsulation that was available and
demonstrated.
Microencapsulation - .
Price Range: ;
Typical Price:
Number of Vendors:
Number of Ranges: .
i •'"..-
Note: EPA was not able to obtain cost data for
micrbencapsulation that was available and
demonstrated.
Sealing
Price Range: ,
Typical Price:
Number of Vendors:
- Number of Ranges-
Note: EPA was not able to obtain cost data for .
sealing that was available and demonstrated.
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v Vitrification
Price Range:
Typical>rice:
Number of Vendors:
Number of Ranges:
• i
Note: EPA was not able to obtain cost data for
vitrification that was available and
demonstrated.
Destruction Technologies
Biodegradation
Price Range: $50 to $100 per ton
Typical Price:
Number of Vendors: '1
Number of Ranges: ,1 .
Note: Pieces up to 4" only.
Chemical Oxidation
Price Range:
" /Typical Price:
Number of Vendors:
Number of Ranges:
Note: EPA was not able to obtain cost data for
chemical oxidation that was available and.
demonstrated.
Chemical Reduction
Price Range: •
Typical Price:
Number of Vendors:
Number of Ranges:
Note: EPA was not able to obtain cost data for
chemical reduction that was available and
.demonstrated.
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Thermal Destruction , ' ,
Price Range: $1200 to $3400 per ton
Typical Price: $2300 per ton
Number of Vendors: 7 i
Number of Ranges: 7
Notes: The price ranges presented above were not obtained specifically for
v hazardous debris. They are price ranges provided by vendors for low
BTU, high ash content waste. It is assumed that the waste is received
in drums or consists of relatively small pieces. This typical unit price
includes transportation.
Limitations to Obtaining Unit Prices for Hazardous Debris
Vendor Contacts
— — — — - (
As noted above, EPA has been unable to obtain unit prices for the majority of the
hazardous debris treatment technologies. EPA contacted 19 vendors in our efforts to obtajn unit
price information for hazardous debris treatment Of these 19 vendors, 12 vendors provided unit
prices for hazardous debris treatment, but two of the vendors supplied prices for in situ methods
that can be used when soils contain small pieces of hazardous debris. In addition to these 19
vendors, EPA asked vendors who supplied TG treatment prices for information on debris
treatment prices. ;
EPA attempted to contact all six of the vendors that participated in the Round Table
EPA received very tentative price information from two of the vendors and are waiting for
responses from the remaining four vendors. One of the two "round table1* vendors that supplied
unit price information supplied information for a technology that they have not used but intend to
market
.,v Most of the vendors contacted indicated that they could only handle small pieces of
debris, typically up to two to four inches in diameter. A couple of vendors indicated that they
could take larger pieces of debris or were trying to work on accepting larger prices of debris (i.e.,
larger than four inches). » . •
• t , _ • ,
Most of the traditional vendors that EPA contacted in the past for unit prices (e.g.,
Chemical Waste Management, Envirite, Ebasco) do not handle hazardous debris. Their standard
answer is that they ship the debris to a hazardous waste landfill. Since commercial hazardous
waste vendors are not decontaminating debris, EPA also attempted to contact response action
contractors (RACs). Those contractors are likely to deal with hazardous debris during the course
of their cleanup work. Many of the RACs contacted indicated that they also send the hazardous
debris to hazardous waste landfills. Other RACs do decontaminate the debris prior to disposal.
C-6
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These companies were willing to discuss the treatment methods they use for debris, but were
unwilling to provide price information.
Published Data , '
/ • •
There has been very little information published regarding the cost of treating hazardous
debris. There are several references that discuss different methods to decontaminate debris, but
EPA located only one reference that contains price/cost information. This document was
published by EPA in 1985 and is entitled Guide for Decontaminating Buildings. Structures, and
Equipment at Superfund Sites (EPA/600-2-85-028). The information in the report was compiled
by PEI Associates, Inc. (now IT) arid Battelle Columbus Laboratories. The report was prepared
for the Hazardous Waste Engineering Research Laboratories in Cincinnati. The unit prices/costs
in the document are most likely in 1983 or 1984 dollars. EPA contacted PEI and the library at
the Hazardous Waste Engineering Research Laboratory, but could not locate an updated version
of this report This report has never been updated according to current EPA information.
Inputs for Probabilistic Modeling of Previously Regulated Hazardous Debris . , •
As inputs for its probabilistic modeling of the cost of treating previously regulated
hazardous debris, EPA developed'prices for on-site and off-site treatment of hazardous debris.
Three prices (high, moderate and low) were developed, with disposal of residuals in Subtitle C or
Subtitle D units where appropriate. . . .' ;
i i - '
EPA developed unit cost ranges for the technologies listed below:
• Extraction (i.e., washing); ,
* Destruction (i.e, incineration);
* Immobilization (i.e., stabilization);
• Extraction followed by immobilization; and :
• Destruction followed by immobilization.
This section of the appendix provides basic assumptions for the prices listed for each technology.
For treatment trains the assumptions for each individual technology apply as well as those listed
with the treatment train. The prices provided below include transportation as appropriate.
EPA based lower bound costs for extraction and immobilization and extraction followed by
immobilization on Subtitle D disposal. Upper bound costs for these technologies are based on -
Subtitle C disposal. EPA did not consider Subtitle D disposal for destruction (i.e., incineration) in
either the upper or lower bounds because it believed that debris would always be treated along
with other wastes whose residuals would remain hazardous and would not be separable from the
treated debris. .
1 ' - ' •.'
The prices for the treatment trains were developed by summing the, individual treatment
prices and subtracting excess transportation and disposal prices as appropriate. The prices for
C-7
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destruction and immobilization may be overestimated since it is impossible to remove the disposal
component from the incineration price.
* * * *
On-site Extraction
High:
Moderate:
Low:
Assumptions:
Off-site Extraction
High:
Moderate:
Low:
Assumptions:
On-site Destruction
High:
Moderate:
Low:
Assumptions:
$665/ton ' ,
$350/ton •
$280/ton
' '
The washing step of the treatment process occurs on site and all
residuals are transported off site for further treatment and disposal as
necessary. In the low and moderate cost scenarios, residuals are
disposed in Subtitle D units. In the high cost scenario, residuals are
disposed in Subtitle C units. (The difference in disposal costs between
Subtitle C and Subtitle D units is approximately $165 per ton.)
$880/ton
>$390/ton
$300/ton ^
• ~ . \, '
These prices are best guess based on the on-site washing prices provided
by vendors. All residuals are transported off site for further treatment
and disposal as necessary.. In. the low and moderate cost scenarios,
residuals are disposed in Subtitle D units. In the high cost scenario,
residuals are disposed in.Subtitle C units. (The difference in disposal'
costs between Subtitle C and Subtitle D units is approximately $165 per
ton.) /
$2,000/ton
$ 400/ton
$ 300/ton ...
Vendor provides mobile incineration on-site. This is not a price range
for a fixed, on-site incinerator.
Debris size is small enough such that it can be incinerated in existing,
equipment Additional charges may be added for size reduction, if
necessary. Residuals from incineration are disposed in Subtitle C units.
(Disposal of residuals in Subtitle D units would decrease all prices by
approximately $80 per ton.)
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Off-site Destruction •
High:
Moderate:
Low:
Assumptions:
On-siteImmobilization
High:
Moderate:
Low:
Assumptions:
$4,120/ton
$l,720/ton
$ 520/ton
Debris size is small enough that it can be incinerated in existing
equipment. Additional charges may be added for size reduction, if
necessary. Approximately 50 percent of the initial quantity of debris
remains after incineration. Residuals are disposed in Subtitle C units.
(Disposal of residuals in Subtitle D units would decrease all prices by
approximately $80 per ton.)
$l,000/ton . :'
$ 410/ton ! - . . . '
$.105/ton
\
EPA did not obtain a sufficient number of price quotes for on-site.
stabilization. The high number presented above is approximately half of
the upper bound commercial price.
Stabilization is performed on-site and the residuals are shipped off-site
for disposal In the low cost scenario, residuals are disposed in Subtitle
*• D units. In the moderate and high cost scenarios, residuals are disposed
in Subtitle C units. (The difference in disposal costs between Subtitle C
and Subtitle D units is approximately $250 per ton.)
Debris size is small enough such that it can be stabilized in existing
equipment Additional charges may be added for size reduction, if
necessary. , , •
Off-site Immobilization
High:
Moderate:
Low:
Assumptions:
$2,050/ton - .
$ 550/ton
$ 365/ton ,
Debris size is small enough such that it can be stabilized in existing
equipment Additional charges may be added for size reduction, if
necessary. In the low and moderate cost scenarios, residuals are
disposed in Subtitle D units. In the high cost scenario, residuals are •
disposed in Subtitle C units.' (The difference in disposal costs between
Subtitle C and Subtitle D units is approximately $250 per ton.) , .
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Op-site Extraction and Immobilization
High:
Moderate:
Low:
Assumptions:
$l,625/ton
$ 720/ton .
$ 240/ton .
t
Essentially 100 percent of the initial quantity requires stabilization. That
is, the debris washed is an insoluble material and only a small fraction of
material (i.e., contamination) is removed during the washing process. In
the low cost scenario, residuals are disposed in Subtitle D units. In the
moderate and high cost scenarios, residuals are disposed in Subtitle C
units. (The difference in disposal costs between Subtitle C and Subtitle
D units is approximately $250 per ton.) .
Off-site Extraction and
High:
Moderate:
Low:
Assumptions:
$2,840/ton
$ 850/ton
$ 575/ton ;
Essentially 100 percent of the initial quantity requires stabilization. That
is, the debris washed is an insoluble material and only a small fraction of
material (i.e., contamination) is removed during the washing process. In
the low and moderate cost scenarios, residuals are disposed in Subtitle D
units. In the high cost scenario, residuals are disposed in Subtitle C
units. (The difference in disposal costs between Subtitle C and Subtitle
D units is approximately $250 per ton.)
On-site Destruction and Immobilization
High:
Moderate:
Low: '
Assumptions:
$2,475/ton
$ 605/ton
$ 335/ton '
Approximately 50 percent of the initial quantity (i.e., ash) remains after
incineration and requires stabilization. Residuals are disposed in a
Subtitle C unit
Off-site Destruction and Immobilization
High:
Moderate: .
Low:
Assumptions:
$5,120/ton
$l,970/ton . • • . . .
$ 675/ton ;.
Approximately 50 percent of the initial quantity (i.e., ash) remains after
incineration and requires stabilization. Residuals are disposed in a
Subtitle C unit
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APPENDIX D
GUIDE FOR STRUCTURED INTERVIEWS
CONDUCTED FOR THE COST ANALYSIS
OF NEWLY REGULATED HAZARDOUS
DEBRIS
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Expert Judgment Elicitation Protocol
EPA's expert assessment protocol was similar in structure to those used by Stanford/SRI1
and Morgan and Henrion,2 although much abbreviated due to the time constraints on the
analysis. It involved five basic steps that would overlap or be iterated upon, to some extent, in
the course of an interview, as warranted by the technical discussions. These steps can be
described as: 1) motivating, 2) structuring, 3) debiasing, 4) encoding, and 5) verification. Each will
be described below. .•-,.. .
7. Motivating. During the "motivating" phase of the interview the interviewer developed
an initial rapport with the expert This included explaining the purpose of the estimation exercise,
the need to incorporate uncertainty, why the expert was asked to participate, the quantities we
were interested in having the expert estimate, and a brief explanation of the judgment elicitation
process that will follow. This orientation on the part of the interviewer was followed by asking
the expert to briefly describe his/her own background and experience and perspective on the
processes to be discussed.
2. Structuring From the general discussion of an expert's own perspective, the interviewer
then directed the discussion to the next phase of the interview, hi which the estimation task was
more formally "structured." This involved the development of more careful and specific
definitions of the quantities to be estimated, in a manner and at a level of detail that was
appropriate to the expert's knowledge. The total volume of hazardous debris that an expert
identified was disaggregated into volumes for which different treatment technologies would be
used for treatment The quantities to be obtained were defined with sufficient detail that the .
expert could, in principal, provide the actual values of these quantities. .
3. Debiasing Throughout the final three steps of the elicitation process, the interviewer
took steps to ensure that the expert had made thorough and careful use of the information at
hand and had incorporated the impact of uncertainty into his or her quantified judgments. While
the formal step of "debiasing" is sometimes used as an opportunity to review relevant research on
the psychology of human judgment under uncertainty and hi particular, shortcomings hi.human
judgment, in EPA's much abbreviated interview format case, this step was used to explain to the
expert why these deliberate efforts were being made to encourage their consideration of sources
of uncertainty. The interviewer merely pointed out that people typically find it difficult to assess
and quantify uncertainties and usually employ judgment heuristics that, though successful hi
simplifying the cognitive processes involved, can result in estimates that actually don't account for
all of the uncertainty that they may be aware of. Participants were told that the systematic
probing for underlying assumptions and judgment rationales that would follow help counteract
these sources of bias in subjective judgments.
1See C.S. Spetzler and C.-A.S. Stael Von Holstein, "Probability Encoding in Decision
Analysis", Management Science, VoL 22, No. 3. and C.-A.S. Stael Von Holstein and J.E
Matheson, A Manual far Encoding Probability Distributions, SRI International, Palo Alto, CA.,
1979.
2 M.G. Morgan and M. Henrion, Uncertainty: A Guide to Dealing with Uncertainty in ,
Quantitative Risk and Policy Analysis, Cambridge: Cambridge University Press, 1990.
- ' ' ' - ; - D-l .',-.:
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4. Encoding Once the quantity to be estimated had been clearly defined and the need to
consider sources of uncertainty described, the interviewer directed the expert toward specific
discussion of the basis for estimating the quantities of interest; i.e., the processes generating
volumes of contaminated debris and treatment costs per unit volume. For each quantity,
discussion of current processes and future contingencies that could affect future levels was directly
followed by "encoding" the expert's subjective probability distribution (SPD) based on. the first,
ninety-ninth, and fiftieth percentiles. The expert also specified the operational scenario or critical
assumptions that correspond to each percenue estimate. .
5. Verification After the expert had provided a set of probabilistic estimates for a given
quantity, the interviewer reviewed the estimates with the expert to "verify" that they are actually
consistent with the expert's beliefs and level of uncertainty, in addition to conforming to the laws
of probability (e.g., the estimate associated with cumulative probability 0.99 had to be greater than
or equal to the expert's median estimate). In some cases, the interviewer probed to verify that
the estimated upper and lower bounds actually had the level of subjective probability assigned and
were neither more nor actually less likely, and .that the interval between the upper bound and
median, on the one hand, and the interval between the lower bound and median, on the other
hand; were considered to be equally probable. Adjustments to the initial set of estimates were
made when determined to be necessary by the expert and the interviewer.
The encoding and verification steps described above were repeated for each quantity
identified in the structuring phase of the interview. After obtaining probabilistic estimates from
all participants, for all variables, a computer model was specified and simulations run to obtain
probabilistic estimates of the average total volume of Phase 1 contaminated debris generated per
year, and total average yearly cost of treatment ',-•'.
D-2
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PHASE 1 NEWLY REGULATED HAZARDOUS DEBRIS
COST ANALYSIS - INTERVIEW GUIDE
(Motivating) .,.,.'.
. We're calling today because EPA has asked us to develop an estimate of the cost of treating
debris contaminated with Phase 1 wastes that will be covered in a new rule.
•*• ' * v
They particularly want the estimate to incorporate uncertainty about what those costs will be ~
over the short term, say over the next 5 years - and long term - about 5 to 25 years out into the
future. .
To, characterize the uncertainties and their impacts we need to talk to people with experience in
the industries that would be affected. , '
You've been identified as one of the experts we should talk'to. . .,
We want to know what you really think about this. In keeping with that we will not identify you
or your facility as the source of these estimates unless you specifically want us to.
. ' ' ' N
What we're going to ask you to do is describe the types and volumes of debris that would likely
be contaminate with (specify the waste types) waste at vour facility.
We are also going to ask you to estimate the cost of treating that debris. When we ask for those
estimates, we won't just ask for a single number. We'd tike to know what you'd consider to be a
plausible range of values, since these things can't be predicted exactly.
But before we go into that, could you describe your role at (facility namet and what you'd
consider to be the main uncertainties affecting the costs you'd incur from treating contaminated
debris at your facility. . .
(allow about 3-5 minutes for this discussion, make note of key uncertainties cited)
D-3
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(Structuring)
: •.•'''''•'
Well, in our initial discussions we've identified 2 pretty basic modes of debris generation we'd like
you to consider.
One is debris that may be generated in the course of normaLdav-to-dav operations. Do
you have debris of this sort at your facility? How does it get generated?
The other kind of debris results from periodic maintenance, expansions or discontinuation
of some part of facility operations. Have you had debris generated from these sorts of activities?
About how much of this sort of debris would typically be generated in a year?
Is there any other way that debris may be generated at your facility?
With the sorts of debris you've describe so far, what kind of treatment are you using, or
considering (in anticipation of the Phase 1 rule)?
Can all of this debris be treated in the same "stream", with the same technology?
If not how would you need to separate the different kinds of debris?
How many different "streams" would you need?
For each of the different streams : \ ' '
How would you characterize the debris in this treatment stream?
<• ' . • \
What kind of treatment do you (expect to) use, or what alternative
technologies are you considering for that debris?
If it's ail treated in the same "stream",
What kind of treatment do you (expect to) use, or what alternative
technologies are you considering for that debris? .
For the F037 and F038 waste interviews:
\ • • -
What fraction of U.S. production does your facility account for?
Relative to other facilities in this industry, would you describe yours as
small? mid-range? large? .
i . '
Would you describe your facility's operations (including debris generation) as .
'typicaT for a facility of that size?
If not, by what factor would your debris generation differ (eg., it represents what fraction or what
multiple of that generated by other faculties of similar size)
' " • \ . • • .- • . '
:' ... ' D-4
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(If possible, get assessment of how facilities in other size classes would differ in rates of debris
generation, relative to facilities in same class)
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(Debiasing) . • ' .
Now, before I go on to ask you for estimates, I want to.tell you that as we go through the
estimation, I'll be asking you to consider uncertainties, and extreme values, both above and below
your nominal, or baseline estimate, and how those extreme numbers could occur.
" "l • •
The reason we do this is because most of us don't, in the course of our normal work, focus on
extremes, and it's hard to do. ' ' - . "
i • . . i
People typically anchor on their "best guess" and don't move far from it when estimating extremes.
\ • .
-But the probabilities associated with the extremes well be asking for are quite small;
i • ' . . • ' • " -
So we want to be sure that the estimates you give for those are correspondingly unlikely on the
high side, or on the low side. . .
Okay, now I'd like to go ahead and ask you for some estimates.
D-6
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(Encoding with Verification)
Okay, going back to the types of debris streams and treatment technologies you described earlier
What sort of [volumes per month, or year] of [costs per Ib. or ton] . ' are typical
'now?
1 * " **"•
What are, the main factors that determine those [volumes! or [costs! ? -
Looking at the time period we're considering right now (repeat what that is; i.e., [the next five
years] or [5 to 25 years into the future])
I'd like you to consider HOW MUCH HIGHER THOSE NUMBERS COULD POSSIBLY
GET. ;
' ' ' . . ' • V '
•."•'" ^ - -
Are there any technological uncertainties that could cause a significant INCREASE in
those [volumes]/[costs]? .
Are there any plausible regulatory scenarios that could cause a major INCREASE in
those [volumes]/[costs]?
' Are there any changes in the market conditions affecting vour facility (that would result
in a change in the scale of operations at your facility) that would result in a significant
INCREASE in those [volumes]/[costs]?
Given those factors, what would be your UPPER BOUND estimate? This is a number that
should be so extreme on the HIGH side that there is only on the order of a 1 out of 100 chance
that the [volume] / [cost per unit] would be HIGHER than that
[get the 99th percentile estimate]
And what conditions would have to exist, or what assumptions would we have to make, for the "
number tb'go that high?
. '
And you consider that scenario so unlikely that there is only a 1 out of 100 chance that could ,
occur? [adjust number upward if not extreme enough]
Okay,, now I'd like you to consider HOW MUCH LOWER THOSE NUMBERS COULD
POSSIBLY GET.
D-7
-------
Are there any technological
those [volumes]/[costs]?
unties that could cause a significant DECREASE in
Are there any plausible regulatory scenarios that could cause a major DECREASE in
those [volumes]/[costs]? 4
D-8
-------
Are there any changes in the market conditions affecting your facility (that would result
in a change in the scale of operations at your facility) that would result in a significant
DECREASE in those [volumes]/[costs]? .
Given those factors, what would be your LOWER BOUND estimate? This is a number that
should be so extreme on the LOW side that there is only on the order of a 1 out of 100 chance
that the [volume] / [cost per unit] would be LOWER than that r -
[get the 1st percentile estimate]
And what conditions would have to exist, or what assumptions would we have to make, for the
number to be that,low? .
There's really only a 1 out of100 chance of such conditions occurring?
[adjust number downward if not extreme enough] .
Alright, what number would represent the middle of that range, in terms of its likelihood? In
other words, what would be your MEDIAN estimate? ' .
Would that number be your baseline estimate, or something a bit higher, or lower, than that?
[get the estimate] ,
What conditions would correspond to that estimate?
Do you think it's JUST AS LIKELY that the real levels of [volume]/[cost] you'll experience will
fall in the range from [median estimate] to [upper bound estimate] as in the range from power
bound estimate] to [median]? . '
[if not, (make the less likely range wider) or (move the median estimate up or down) to obtain
intervals of about equal probability]
[Repeat the Encoding with Verification for every quantity identified in the Structuring phase of the
interview.] >_'_'. ,.'•'•
D-9
-------
-------
APPENDKE
LINE ITEM EXPENSE PROJECTIONS
GENERATED FOR COSTING
CONTAINMENT BUILDING DESIGN AND
OPERATING REQUIREMENTS
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