REGULATORY
IMPACT ANALYSIS
FOR THE SHORE
PROTECTION ACT
Of 1988
EPA Implementing Regulation
for Handling Municipal or
Commercial Waste in Coastal
Waters
Prepared/or:
U.S. Environmental Protection Agency
Oceans and Coastal Protection Division
Under subcontract to:
Tetra Tech, Inc.
Lafayette, CA
Kearney/Centaur Division October 1993
A.T. Kearney, Inc.
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Regulatory Impact Analysis
for the
Shore Protection Act of 1988
EPA Implementing Regulation for Handling
Municipal or Commercial Waste in Coastal Waters
Draft
Prepared for:
U.S. Environmental Protection Agency
Oceans and Coastal Protection Division
Prepared by:
Kearney/Centaur Division
A.T. Kearney, Inc.
225 Reinekers Lane
Alexandria, VA 22314
Under Subcontract to:
Tetra Tech, Inc.
3746 Mount Diablo Blvd.
Lafayette, CA
Under U.S. EPA Contract No. 68-C1-008
October 1993
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DISCLAIMER
The review of this draft manuscript has not been completed by the Environmental Protection
Agency (EPA), Oceans and Coastal Protection Division, nor has it been approved for publication.
The opinions, findings, conclusions, or recommendations expressed in this report are those of die
authors, and do not necessarily reflect the views or policies of the EPA. Mention of trade names
or commercial products does not constitute endorsement or recommendation for use.
Disclaimer
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PREFACE
This document was prepared for the Oceans and Coastal Protection Division, U.S. Environmental
Protection Agency under Contract No. 68-C1-008, Work Assignment No. 1-58. This report
estimates the compliance costs of the proposed Shore Protection Act regulations and provides a
comprehensive response to the EPA rulemaking process, Executive Order 12866, the Paperwork
Reduction Act, and the Regulatory Flexibility Act.
This document was prepared under the supervision of Barbara Wallace. Project team members
included Garry Brown, Emily MacDonald, Allen Merriman, Jacqueline Quirk, and Timothy
Sherwood. Joel Salter, with the Oceans and Coastal Protection Division of EPA, provided
Agency oversight. His inputs were invaluable to the preparation of this analysis as were the
suggestions of the interagency working group assembled to implement the Shore Protection Act.
This working group included representatives of EPA, the Coast Guard, and NOAA.
ii Preface
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TABLE OF CONTENTS
PAGE
Table of Contents
List of Exhibits .
1.0 INTRODUCTION AND BACKGROUND 1-1
1.1 Introduction 1-1
1.2 Background 1-1
1.2.1 Existing Federal Laws and Regulations 1-1
1.2.2 The Shore Protection Act 1-2
2.0 PROPOSED SHORE PROTECTION ACT RULE, 40 CFR 237 2-1
2.1 Purpose 2-1
2.2 Applicability 2-1
2.3 Specific Provisions and Compliance Activities 2*1
2.4 Permit Review Procedures 2-2
2.5 Enforcement 2-2
3.0 AFFECTED INDUSTRY SEGMENTS 3-1
3.1 Overview of Affected Industries 3-1
3.2 Uncontainerized Municipal Wastes 3-1
3.2.1 Affected Parties 3-1
3.2.2 Factors Affecting Waste-Handling Procedures 3-5
3.2.3 Current Waste-Handling Procedures 3-6
3.2.3.1 Marine Transfer Stations 3-6
3.2.3.2 Garbage Barges 3-8
3.2.3.3 Fresh Kills Landfill 3-10
3.2.4 Actions Needed to Achieve Compliance 3-10
3.3 Packaged Garbage 3-12
3.3.1 Packaged Garbage from the Offshore and Inland Oil and Gas
Industry 3-12
3.3.1.1 Affected Parties 3-12
3.3.1.2 Factors Affecting Waste-Handling Procedures . . . 3-12
3.3.1.3 Current Waste-Handling Procedures 3-14
3.3.1.4 Actions Needed to Achieve Compliance 3-15
3.3.2 Packaged Garbage from Vessels Anchored Offshore 3-18
3.3.2.1 Affected Parties 3-18
3.3.2.2 Factors Affecting Waste-Handling Procedures . . . 3-18
3.3.2.3 Current Waste-Handling Procedures 3-18
3.3.2.4 Actions Needed to Achieve Compliance 3-21
3.3.3 Packaged Garbage from Islands 3-21
3.3.3.1 Affected Parties 3-21
3.3.3.2 Factors Affecting Waste-Handling Procedures . . . 3-21
3.3.3.3 Current Waste-Handling Procedures 3-21
3.3.3.4 Actions Needed to Achieve Compliance 3-23
iii Table of Contents
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TABLE OF CONTENTS (Cont'd)
3.4 Sewage Sludge 3-23
3.4.1 Affected Parties 3-23
3.4.2 Factors Affecting Waste-Handling Procedures 3-23
3.4.3 Current Waste-Handling Procedures 3-23
3.4.4 Actions Needed to Achieve Compliance 3-27
3.5 Drilling Muds and Cuttings 3-27
3.5.1 Affected Parties 3-27
3.5.2 Factors Affecting Waste-Handling Procedures 3-27
3.5.3 Current Waste-Handling Procedures 3-27
3.5.3.1 Inland Oil and Gas Platforms 3-30
3.5.3.2 Offshore Oil and Gas Platforms 3-31
3.5.3.3 Shore-based Oil and Gas Operations 3-32
3.5.3.4 Transfer Station-Hopper Barge 3-33
3.5.3.5 Reception/Treatment Facility 3-34
3.5.4 Actions Needed to Achieve Compliance 3-35
4.0 COSTS OF COMPLIANCE 4-1
4.1 Approach to Compliance Cost Estimation 4-1
4.2 Unit Cost Development 4-4
4.2.1 Estimates and Assumptions Applicable to All Affected
Segments 4-4
4.2.2 Shoreside Faculties 4-4
4.2.3 Waste Transport Vessels 4-11
4.3 Summary of Compliance Costs 4-16
5.0 BENEFITS OF COMPLIANCE WITH THE PROPOSED REGULATION 5-1
5.1 Establishment of a Minimum Standard of Practice 5-1
5.2 Contribution to Reduction in Marine Pollution 5-1
5.3 Contribution to Reduction in Marine Debris and Its Impacts 5-3
5.3.1 Aesthetic Losses 5-3
5.3.2 Tourism Losses 5-4
5.3.3 Clean Up Costs 5-6
5.3.4 Animal Entanglement 5-6
5.3.5 Fouling of Vessels .. . 5-6
5.3.6 Fouling of Fishing Gear 5-6
5.3.7 Ingestion by Wildlife and Fisheries 5-7
5.3.8 Long-Term Unknown Impacts 5-7
5.4 Contribution to Reduction in Public Health Hazards 5-7
5.5 Complexity in Monetizing Benefits 5-7
5.5.1 Inability to Depict Relative Role of SPA-Related Pollution
to Aggregate Pollution Levels 5-8
5.5.2 Inability to Extrapolate Site-Specific Environmental
Conditions to Generalized Regulatory Changes 5-8
iv Table of Contents
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TABLE OF CONTENTS (Cont'd)
PAGE
5.5.3 Inability to Relate Pollution Levels to Macro Changes in
Species Abundance 5-8
5.5.4 Measurement Issues in Monetizing Injuries to Complex
Natural Resources 5-8
6.0 IMPACTS OF COMPLIANCE COSTS ON AFFECTED INDUSTRIES 6-1
6.1 Economic Impacts by Industry Segment 6-2
6.2 Other Measures of Distribution of Economic Impacts 6-6
6.3 Effects of the Proposed Rule on Small Entities 6-6
6.4 Recordkeeping Costs of the Proposed Rule 6-8
6.5 Conclusion 6-10
REFERENCES R-l
APPENDIX A: Details of Cost Estimates A-l
APPENDIX B: Draft Shore Protection Act Regulations (June 29, 1993) B-l
APPENDIX C: Implementation of the Shore Protection Act of 1988 (33 CFR
Part 151) C-l
U.S. EPA Headquarters Library
Mail code 3201
1200 Pennsylvania Avenue NW
Washington DC 20460
Table of Contents
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LIST OF EXHIBITS
PAGE
2-1 Specific Provisions and Compliance Activities for Waste Sources and
Receiving Facilities During Loading and Offloading and Vessels During
Transport of Municipal and Commercial Waste 2-3
3-1 Summary of Affected Parties: Shore Protection Act 3-2
3-2 Waste Flow Subject to SPA: Uncontainerized Garbage 3-4
3-3 NYC DOS Marine Transfer Stations 3-7
3-4 Amount of Time to Transfer Garbage from MTS to Barge, February 1993 3-9
3-5 Current Level of Compliance: Uncontainerized Garbage 3-11
3-6 Waste Flows Subject to SPA: Packaged Garbage 3-13
3-7 Sample Finn's Yearly Landfilled Non-Hazardous Waste, 1986 to 1990 3-16
3-8 Current Level of Compliance: Packaged Garbage from the Offshore and
Inland Oil and Gas Industry 3-17
3-9 Summary of Cruise Ships in Alaska, 1993 Season 3-20
3-10 Current Level of Compliance: Packaged Garbage from Vessels Anchored
Offshore 3-22
3-11 Current Level of Compliance: Packaged Garbage from Islands 3-24
3-12 Waste Flow Subject to SPA: Sewage Sludge 3-25
3-13 Current Level of Compliance: Sewage Sludge 3-28
3-14 Waste Flows Subject to SPA: Drilling Muds and Cuttings 3-29
3-15 Current Level of Compliance: Drilling Muds and Cuttings 3-36
4-1 Sample of Cost Estimation Model 4-2
4-2 Shoreside Facilities: First-Year Costs 4-18
4-3 Shoreside Facilities: Total First-Year Compliance Costs 4-19
4-4 Shoreside Facilities: Annual Costs 4-20
4-5 Shoreside Facilities: Total Annual Compliance Costs 4-21
4-6 Waste Transport Vessels: First-Year Costs 4-22
4-7 Waste Transport Vessels: Total First-Year Compliance Costs 4-23
4-8 Waste Transport Vessels: Annual Costs 4-24
4-9 Waste Transport Vessels: Total Annual Compliance Costs 4-25
5-1 Benefits of Compliance with the SPA Regulation 5-2
5-2 Summary of Coastal Cleanup Results 5-5
6-1 Average First-Year Compliance Cost per Facility 6-3
6-2 Average First-Year Compliance Cost per Vessel 6-4
6-3 Distribution of Total Cost Between Government and Commercial Entities 6-7
6-4 Recordkeeping Burden and Costs 6-11
vi List of Exhibits
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1.0 Introduction
Background
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1.0 INTRODUCTION AND BACKGROUND
1.1 Introduction
Title IV of the Shore Protection Act (SPA) of 1988 requires EPA to promulgate regulations on
waste handling practices for vessels transporting municipal and commercial waste in coastal
waters and the sources and receiving facilities of such waste. The goals of the regulation are to
minimize deposit of waste into coastal waters during vessel loading, transport, and unloading, and
to ensure that any deposited waste is reported and cleaned up.
This report presents the assessment of the economic impacts of the proposed EPA SPA
regulation. The analysis is based on the draft version of the rule dated June 29,1993. Changes ')i
in later drafts do not require revisions to cost estimates.
This report contains six chapters and three appendices. This initial chapter provides background
on the necessity and purposes of the proposed rule. Chapter 2 presents an analysis and discussion
of the individual provisions of the proposed rule, identification of any provisions which are
partially or fully required under other laws and regulations, and the actions required to comply
with SPA. Chapter 3 identifies the industry segments affected by the rule and the actions
required in each segment to achieve full compliance. The costs of complying with the rule are
presented in Chapter 4, first for each individual activity by an affected entity, and then
summarized to obtain total costs for the affected universe. The benefits accruing from the
implementation of SPA are described in Chapter 5. Finally, Chapter 6 discusses the impact of
these compliance costs on the affected industry segments. References can also be found at the
conclusion of the report.
Details of the compliance cost estimates are presented hi Appendix A. The full text of the
proposed EPA SPA regulation is included as Appendix B. Appendix C contains the text of the
related U.S. Coast Guard regulation. The proposed EPA regulation provided in Appendix B is
covered by this document, while Appendix C is provided for information purposes only.
1.2 Background
On November 18, 1988, Congress enacted the Shore Protection Act (33 U.S.C. 2501 et seq.) to
help prevent trash, medical debris, and other unsightly and potentially harmful materials from
being deposited into the coastal waters of the United States as a result of inadequate_waste
handling; procedures. The Conference Report on the Ocean Dumping Ban Act (Report 1W409^~
stated~that landfills and attendant barging operations are a major source of floatable waste in
harbor areas. The report concluded that this type of waste had fouled the beaches of this country
over the previous two summers, reducing the quality of coastal waters, endangering the health
of humans, marine mammals, waterfowl and fish, and causing severe decline hi the coastal
economies dependent upon tourism and recreational uses.
1.2.1 Existing Federal Laws and Regulations
The handling of wastes and prevention of waste deposition to coastal waters is covered in various
situations, for various types of waste and at various facilities, by a number of other regulations
and laws. The most important of these are:
Chapter 1.0 1-1 Introduction
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• The Rivers and Harbors Act of 1899 (33 U.S.C. 407 §13), which proscribes the
deposition of any waste or refuse, either from shore or from a vessel of any kind, into
any navigable water of the United States, or any tributary thereof, or in such location
as to create the possibility that it might be carried into the navigable waters or a
tributary thereof.
• The Marine Protection, Research and Sanctuaries Act of 1972 (33 U.S.C. 1401 et
seq.), which regulates the dumping of all types of materials into ocean waters, as well
as the transportation of any materials in the waters of the United States for me
purpose of ocean dumping.
• The Federal Water Pollution Control Act and Clean Water Act (33 U.S.C. 1251 et
seq.), which establish the framework for the regulation of the discharge of all
pollutants into navigable waters.
• The Marine Plastic Pollution Research and Control Act of 1987 (Title U of Public
Law 100-220) which amends the Act to Prevent Pollution from Ships (33 U.S.C. 1901
et seq.) and implements MARPOL Annex V, an international treaty on disposal of
ship-generated garbage, in the United States. It prohibits at-sea disposal of plastics
from ships and specifies the distance from shore that certain other materials may be
dumped, as well as requiring reception facilities for garbage at ports and terminals.
• Solid Waste Disposal Act (Title H of RCRA; 42 U.S.C. 6901 et seq.), which
classifies and regulates hazardous wastes and preempts SPA for such wastes.
The ways in which these laws affect or interact with the proposed regulation are discussed in
Chapter 3, along with relevant state regulations, local policies, and industry operating procedures
and guidelines. Some of these existing laws require affected parties to have procedures in place
which would constitute compliance with SPA, particularly with regard to specific or limited
industry segments, operations, or wastes.
The laws and regulations discussed above largely address intentional dumping of solid waste,
although RCRA addresses total control of hazardous wastes. The one area that is not covered
by these laws and regulations is the acciden^^r mcidental,spjllage of wastes juMg transfer and
ttajnsp^rtj^ithjn_a)astal_w.aters. That gap is precisely what this proposed regulation is intended
to fill. The section below discusses the intent and the general requirements and effects of SPA.
1.2.2 The Shore Protection Act
Section 4103(a) of the Shore Protection Act requires owners or operators of waste sources,
vessels transporting waste, and waste reception facilities to take reasonable steps to minimize the
amount of municipal or commercial waste deposited into coastal waters. This applies both during
vesseljojding and unloading operations and during vessel transportation of wastes from waste
sources to waste receiving facilities.
The Act is implemented by both EPA and the U.S. Coast Guard (USCG). In practice, EPA has
the lead with implementing best management practices and recordkeeping requirements, while
USCG has initiated a preliminary SPA permitting process. The USCG also is charged with
Chapter 1.0 1-2 Introduction
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prescribing the permit marking system and enforcing both the USCG and EPA regulations. A
description of each follows.
USCG Responsibility for SPA Vessel Permitting
The AAprohibitsvesseJs from transportingjmunigipal and conunerciajjvasteLunlgssjfagyjiay^a
permit and_ display a numb^jorjottiei^pr^cribed marking. The permitting of these waste
transportation vesselsTTuMer the authority of the USCG. To meet mis requirement of the Act,
an interim rule was implemented by the USCG in 1989 requiring vessels subject to SPA to obtain
a permit (33 CFR Part 151). A copy of these interim regulations is provided in Appendix C for
information purposes. Under this interim rule, vessels subject to SPA must inform the regional
USCG offices of their intention to transport municipal or commercial waste. The USCG then
issues a permit in the form of a letter and identification number. The lists of SPA permitted
vessels are referenced extensively throughout this analysis and subsequently form the basis for
some of the estimates of the affected population.
This permitting process is implemented exclusively by the USCG and is not a subject of this
analysis.
EPA Responsibilities Under SPA
The Environmental Protection Agency (EPA) is responsible for developing, promulgating, and
enforcing regulations which will address the prevention, containment, and re_movaL^Lw.asjeL-
deposited into coastal waters as ja result of the transfer and transportation of municipal and
MmmeYcial"^asteT">~'niiraffects waste sources, waste transportation vessels, and receiving
facilities. "~*~
As stated in the draft of the EPA proposed regulation, the purposes of this regulation are to:
• Establish requirements under the Shore Protection Act, Title IV of Public Law 100-
688 Part 237, for vessels, waste sources, and receiving facilities to assure that
municipal and/or commercial waste is not deposited into coastal waters during
loading, offloading, and transport;
• Require, as appropriate, the submission and adoption by each responsible party of an
operation and maintenance manual identifying procedures to be used to prevent,
report, and clean up any deposit of municipal or commercial waste into coastal
waters, including recordkeeping requirements; and
• Require tracking systems on vessels when and where deemed necessary by the
Administrator to assure adequate enforcement of laws preventing the deposit of
municipal or commercial waste into coastal waters.
Applicability of USCG and EPA SPA Regulations
' Municipal and commercial waste. The wastes <
waste generated by residences and businesses.
garbage (from any source), sewage sludge, and drilling muds. Specifically exempted are
hazardous wastes, construction debris, and dredged or fill material.
Chapter 1.0 1-3 Introduction
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Vessels covered bv SPA. The intent of the USCG is to permit vessels whose purpose is to
transport municipal or commercial waste in the coastal waters of the United States. The
conference report on the Ocean Dumping Ban Act (Report 100-1090) states that the Act was
intended "only to apply to vessels whose purpose is the transportation of municipal or commercial
waste, not all vessels. It was not intended to apply to vessels that may generate waste during
normal operations." Waste generated during normal operations is covered by MARPOL Annex
V. A vessel which regularly transports miscellaneous cargo (e.g., a supply boat) but is hired
expressly for the purpose of transporting waste for a specific voyage would be required to hold
a permit to transport waste for that voyage, since the predominant business or purpose of that
vessel for that voyage is waste transportation. However, a vessel which happens to transport
some waste, such as a ferry, would not be subject to regulation under SPA. A vessel subject to
SPA would be required, in addition to obtaining a permit, to have procedures for loading and
securing waste, as well as cleaning up waste deposits, in its operation and maintenance (O&M)
manual. The vessel would also require the necessary equipment to do so. Such vessels would
also be required to label and seal all valves or ports used to discharge waste or waste residue.
Waste sources. Vessels, transfer stations, and any other facilities, onshore or offshore, from
which waste is loaded onto a vessel may be waste sources subject to SPA. While sources are not
required to obtain any type of permit, they would be required to have O&M manuals for
preventing and cleaning up waste deposits, as well as the equipment necessary to do so, and to
keep records on waste deposits. Examples of waste sources include waste transfer stations and
municipal sewage treatment plants in New York City. Offshore oil and gas platforms are covered
by MARPOL Annex V inasmuch as the garbage is produced only from normal operations.
Similarly, cruise ships which get services from tenders rather than at the dock are also covered
by MARPOL Annex V.
EPA Effluent Guidelines for Offshore Oil and Gas Extraction, along with the National Pollutant
Discharge Elimination System (NPDES) program, cover the oil and chlorine content of discharges
from platforms. Therefore, only non-hazardous, oil-free drilling muds (as well as municipal
garbage) from platforms are covered by SPA.
Waste receiving facilities. Any facility, vessel, or operation which receives municipal or
commercial waste from a waste transport vessel, as defined by this proposed regulation, would
be subject to SPA as a receiving facility. This includes, for instance, the Fresh Kills Landfill in
New York, barges receiving drilling muds from work boats along the Gulf Coast, and docks in
various ports where tenders unload garbage from cruise ships and other vessels.
Waste type is the primary variable in identifying, describing, and analyzing the affected industry
segments and the associated costs arising from this proposed regulation. There is no overlap
between segments handling different types or forms of waste in the case of uncontainerized
garbage barges and sewage sludge barges. These barges are all dedicated to their specific roles,
and are the only vessels which fill those roles. The other segments based on waste types are
packaged garbage and drilling muds and cuttings. Drilling muds are carried by supply vessels
serving the offshore oil and gas industry and the barges serving inland platforms which receive
those muds. Drilling muds are generally taken to a hopper barge at a transfer station or to the
waste treatment facility. Packaged garbage, while more diverse than the other segments and
including several sub-segments, does not overlap with any other segments [except in the case of
supply boats which haul both garbage and drilling muds from offshore platforms].
Chapter 1.0 1-4 Introduction
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Because of the delineation of affected parties on the basis of waste type, each type of waste
handling facility was followed from source to receiving facility to identify the affected segments.
Each segment has been analyzed with respect to necessary compliance activities and the costs of
those activities. This was then used as the basis for organizing the chapters on affected segments,
costs, and economic impacts.
Chapter 1.0 1-5 Introduction
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2.0 Proposed
SPA Rule
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2.0 PROPOSED SHORE PROTECTION ACT RULE, 40 CFR 237
2.1 Purpose [§237. l]
The proposed Shore Protection Act rule is intended to fill the gap in the laws and regulations
concerning waste-handling of municipal and commercial wastes transported by vessels within the
coastal waters of me U.S. As the proposed Part 237 states in §237.1, the purpose is threefold:
• Establish requirements under the Shore Protection Act, Title IV of Public Law 100-
688 part 237, to assure that commercial and/or municipal waste is not deposited into
coastal waters during loading from waste sources to transport vessels, offloading of
vessels at waste receiving facilities, and during transport on a vessel;
• Require the submission and adoption of an operation and maintenance (O&M) manual
for vessels and waste loading and unloading facilities; and
• Require tracking systems when necessary.
2.2 Applicability [§237.2]
The SPA will apply to three types of entities:
• "Waste source means a vessel, or a facility located within the coastal waters of the
U.S. from which municipal or commercial waste is loaded onto a vessel, including
any rolling stock or motor vehicles from which mat waste is directly loaded."
• "Receiving facility means a facility, vessel or operation within the coastal waters of
the U.S. which receives municipal or commercial waste unloaded from a vessel;" and
• "Vessel means every description of watercraft or other artificial contrivance used, or
capable of being used, as a means of transportation on water. Vessels transporting
municipal and commercial waste include, in the case of a non-propelled vessel, both
the non-self-propelled vessel and the towing vessel."
Public vessels, that is vessels owned or demise chartered, and operated by the U.S. government
or a government of a foreign country, are exempt. SPA applies hi addition to, not in lieu of, all
other applicable requirements. It applies to any non-hazardous solid waste generated by
residences and businesses. The major categories are municipal garbage (from any source),
sewage sludge, and drilling muds. Specifically exempt from the regulation are hazardous wastes,
construction debris, and dredged or fill material.
2.3 Specific Provisions and Compliance Activities [§237.4 and 237.5]
The requirements of §237.4 apply to the waste source and receiving facilities. Those of §237.5
apply to waste transporting vessels. The requirements of each provision are presented hi Exhibit
2-1 (located at the end of this Chapter) and explained in terms of what actions are required on
the part of sources and receiving facilities. This exhibit also identifies the potential costs which
may arise from those actions.
Chapter 2.0 2-1 Proposed SPA Rule
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The requirements pertaining to waste sources and receiving facilities (§237.4) include containment
or diversionary structures, or equipment to catch waste deposits, use of fixed lighting during
transfers which take place at night, documentation of procedures in an O&M manual, cleanup of
any waste deposits which occur, record keeping of waste deposits which occur, and notification
of corporate and governmental oversight authorities when prompt and thorough cleanup of waste
deposits cannot be made.
The provisions for waste transporting vessels (§237.5) require development of written procedures
for loading and securing waste in an O&M manual and use of those procedures, cleanup of any
waste deposits, record keeping of waste deposits, and notification of corporate and governmental
oversight authorities when prompt and thorough cleanup of waste deposits cannot be made. In
addition, §237.5(c) authorizes the Administrator (of the Environmental Protection Agency or
his/her designee) to require that vessels use tracking systems after considering: 1) the
owner/operator's history of compliance with SPA; 2) the history of the owners/operator's
compliance with other statutes intended to prevent pollution of coastal waters from municipal and
commercial wastes; 3) the characteristics and amounts of the waste transported; and 4) the
feasibility of installing such a system. Coastal waters refer to the territorial sea of the U.S., the
Great Lakes and their connecting waters, the marine and estuarine waters of the U.S. up to the
head of tidal influence, and the Exclusive Economic Zone.
2.4 Permit Review Procedures [§237.6]
According to §237.6, the permit review procedures identified in 33 CFR 140, mat is the current
procedures used, will be followed. Permit denial grounds are also provided.
2.5 Enforcement [§237.7]
The provisions of §237.7 provide for civil penalties for violation of any provision. It states the
enforcement procedures are outlined in a Memorandum of Understanding between the U.S. Coast
Guard and EPA.
Chapter 2.0 2-2 Proposed SPA Rule
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Exhibit 2-1
^ ™ ^^—•"•-^^-—••^^•^^^^••^^^^^•^^•••^^•^^^^^^•^^•^•^^M
Specific Provisions And Compliance Activities For Waste
Sources And Receiving Facilities During Loading And
Offloading And Vessels During Transport Of Municipal And
Commercial Waste
Proposed SPA Provision (6/29/93 draft)
Activity Required
Potential Cost Element
§237.4 (a) Performance standard. The owner or operator of a
waste source or receiving facility shall have containment,
diversionary structures, and equipment, consistent with the
requirements of this subsection, to contain and remove any
municipal or commercial waste deposited in coastal waters
during loading and offloading. The owner or operator of a
waste source or receiving facility shall use containment or
diversionary structures or equipment in a manner that
minimizes deposit of municipal or commercial waste into
coastal waters.
Appropriate methods to meet this performance standard must
be identified in the O&M manual.
A source or receiving facility must have and use
containment, diversionary structures, or equipment in
accordance with the written procedures it must have in its
operation and maintenance (O&M) manual.
• Purchase of equipment
• Time required to develop and
implement procedures
• Additional employee time to
follow the procedures
§237.4 (b) Fixed Lighting. The owner or operator of a waste
source or receiving facility shall use fixed lighting, that
adequately illuminates the loading and offloading point and
surrounding area, when conducting loading and offloading
operations between sunset and sunrise.
A source or receiving facility must have and use fixed
lighting at the loading and offloading point when waste
transfers occur during non-daylight hours.
• Purchase and installation of
lights
• Electricity
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Exhibit 2-1
to
o
Specific Provisions And Compliance Activities For Waste
Sources And Receiving Facilities During Loading And
Offloading And Vessels During Transport Of Municipal And
Commercial Waste (Cont'd)
Proposed SPA Provision (6/29/93 draft)
Activity Required
Potential Cost Element
Si
2
I
I
§237.4 (c) Waste Deposit Cleanup. The owner or operator of
a waste source or receiving facility shall have means in place
to prompth (before the waste has a chance to disperse), and
thoroughly, cleanup municipal or commercial wastes deposited
into coastal waters during loading and offloading. The
methods for cleanup of the waste must be identified in the
facility's O&M manual. ...
The owner or operator shall have the oversight authority
telephone number(s) visibly and legibly displayed at the
transfer station. The owner or operator shall promptly notify
the designated oversight authority if the owner or operator is
unable to meet the requirements of these regulations. ...
A source or receiving facility must have identified in its O
& M manual methods to clean up waste deposits and, in
the event of a spill during the transfer of wastes, must use
those methods.
A sign must be posted which easily identifies two
oversight authorities: 1) the unit or person in the source
or receiving facility company that must be notified in the
event of a waste spill which cannot be cleaned up and 2)
the governmental oversight authority. The notification
procedures must be explained in the O & M manual. The
information recorded on the waste deposit record keeping
form (i.e., date and time of deposit, type and estimated
amount of waste deposited and cleaned up, vessel name,
cause of deposit, and method and time of cleanup) must be
reported to these oversight authorities in the event a waste
deposit cannot be cleaned up.
Purchase of equipment
Time required to develop and
implement procedures
Additional employee time to
follow the procedures
Time required to identify the
appropriate telephone number
Time required to make (or
have made) the sign
Time to post the sign
§237.4 (d) Waste Deposit Records.
(1) The owner or operator of a municipal or commercial waste
receiving facility, or waste source shall maintain a daily record
of waste deposited into coastal waters. ...
(2) The owner or operator shall retain these records for no less
than three years and must submit these records to the
Administrator or the Secretary upon request. ...
A written record of waste deposits must be kept by a
source or receiving facility. The records should reflect
waste deposits for each completed transfer of waste.
The waste deposit records must be retained for at least
three years and be submitted for review by EPA, if
requested.
Time required to develop
record keeping form
Time required to complete
record keeping form
Storage space for records
(insignificant)
-------
Exhibit 2-1
ff
to
b
Specific Provisions And Compliance Activities For Waste
Sources And Receiving Facilities During Loading And
Offloading And Vessels During Transport Of Municipal And
Commercial Waste (Cont'd)
Proposed SPA Provision (6/29/93 draft)
Activity Required
Potential Cost Element
§237.4 (e) Operation and Maintenance Manuals.
(1) Each receiving facility or waste source shall develop an 0
& M manual 180 days after the regulation is promulgated. The
manual shall include:
i. Record keeping procedures;
ii. A description of the basic O & M standards adopted by
the facility or waste source to implement the requirements
of section 237.4;
iii. Identification of the parties responsible for
implementing the manual;
iv. A description of the procedures the owner or operator
will use to prevent, report, and cleanup any deposit of
municipal or commercial waste into coastal waters
consistent with §237.4 (c).
A source or receiving facility must have a written O & M
manual which covers: 1) record keeping, 2) procedures to
minimize waste deposits during transfer to and from
transport vessels, 3) those responsible for implementing
the procedures described in the manual, and 4) procedures
to cleanup wastes deposited in coastal waters during
transfer to and from transport vessels.
• Time required to develop
procedures and write O&M
manual
§237.4 (e)(2) At the request of the Administrator, the
receiving facility or waste source shall submit or provide the
O&M manual to the Administrator for review or approval...
The O&M manual shall comply with the format and guidelines
established in the SPA "Municipal and commercial waste
handling technical guidance document" (O&M manuals
section) (appendix A).
§237.4 (e) (3) The O&M manual shall be made available and
accessible to all employees on site.
The O&M manual must follow the format and guidelines
set forth in the O&M manual section of the technical
guidance document which is Appendix A of the regulation.
The O&M manual must be made available to EPA for
review and approval, if requested.
A copy of the O&M manual must be readily available and
accessible to all employees at each source or receiving
facility.
• Time and expense required to
submit manual to
Administrator
(6
Cost of reproducing the O&M
manual
Time and expense to distribute
the O&M manual to the
facility
-------
Exhibit 2-1
Specific Provisions And Compliance Activities For Waste
Sources And Receiving Facilities During Loading And
Offloading And Vessels During Transport Of Municipal And
Commercial Waste (Cont'd)
Proposed SPA Provision (6/29/93 draft)
Activity Required
Potential Cost Element
(O
§237.5 Specific waste handling practices for vessels during
transport.
§237.5 (a) Performance Standard. The owner or operator of a
vessel which transports municipal or commercial waste must
secure the waste to assure that it will not be deposited into
coastal waters during transport. At a minimum the owner or
operator must ensure that:
i. Waste is not loaded in excess of the vessel's design
capacity; nor in a manner inconsistent with the instructions
in the vessel's O&M manual.
ii. All waste shall be contained in a way that minimizes
deposition into United States coastal waters. ...
iii. The vessel hauling solid waste shall have and use a
drainage containment system for collection of leaching
liquids. ...
iv. All ports and valves which may be used for flushing or
discharging waste or waste residue from the hull or tanks
must be labelled and the valve seals shall be placed on the
valves.
A waste transport vessel must have and use procedures
which will minimize spills of waste during transport and
which are in accordance with the written procedures it
must have in its O&M manual. A collection system for
leachate is required on vessels carrying solid waste. All
ports and valves used for discharging waste must be
labelled (such as a stencil) with the substance for which
they are used and with the direction of the flow (such as
off/on).
Purchase of equipment (e.g.,
boat hooks, dip nets, and
harnesses for use with a
crane)
Time required to develop and
implement procedures
Additional employee time to
follow the procedures
C/9
I
§237.5 (b) Operation and Maintenance. The owner or
operator shall develop an O&M manual and have it available
on the vessel. The O&M manual must contain instructions on
loading the vessel and securing the waste, including loading
and securing diagrams in accordance with 237.5(a). The
O&M manual shall comply with the format and guidelines
established in Appendix A for vessel O&M manuals. The
O&M manual shall be made available and accessible to all
employees on the vessel.
A waste transport vessel must have and operate according
to an O&M manual. This manual must identify how
wastes are loaded and secured in order to minimize spills
into coastal waters. The O&M manual must follow the
format and guidelines set forth in the vessel O&M manual
section of the technical guidance document in Appendix A
of the regulation. A copy of the manual must be readily
available and accessible to all employees on each SPA-
permitted vessel.
Time required to develop
procedures
Cost of reproducing the O&M
manual
Time and expense to distribute
the O&M manual to the vessel
-------
Exhibit 2-1
JO
'o
Specific Provisions And Compliance Activities For Waste
Sources And Receiving Facilities During Loading And
Offloading And Vessels During Transport Of Municipal And
Commercial Waste (Cont'd)
Proposed SPA Provision (6/29/93 draft)
Activity Required
Potential Cost Element
§237.5 (c) Waste Deposit Cleanup. The owner or operator of a
vessel shall promptly (before the waste has a chance to
disperse), and thoroughly, remove any waste deposited into the
coastal waters during transport. The owner or operator of the
vessel shall have the capability on board to cleanup the spill or
to call a support unit to cleanup the spill. The owner or
operator shall have the support unit telephone nutnber(s) and
the oversight authority telephone numbcr(s) located on the
vessel in a way that these numbers are visible and legible to
the owner or operator and vessel crew. The owner or operator
or crew of a vessel shall promptly notify the designated
oversight authority if the owner or operator is unable to meet
the requirement under 237.5 (b) ...
A waste transport vessel must have identified methods to
clean up waste deposits and, in the event of a waste spill
during transport, must use those methods. A sign must be
posted on the vessel which easily identifies the cleanup
company, if that approached is used, and the two oversight
authorities that must be notified when a waste deposit
cannot be cleaned up: 1) the responsible unit within the
vessel owner or operator firm and 2) the government
oversight agency. The procedures explaining when and
how this notification process is to occur must be explained
in the O&M manual. The information recorded on the
waste deposit record keeping form (i.e., date and time of
deposit, type and estimated amount of waste deposited and
cleaned up, vessel name, cause of deposit, and method and
time of cleanup) must be reported to these oversight
authorities in the event a waste deposit cannot be cleaned
up.
Purchase of equipment
Time required to develop and
implement procedures
Additional employee time to
follow the procedures
Time required to identify
appropriate telephone numbers
Time required to make (or to
have made) the sign and to
distribute it to the vessel
Time required to post the sign
I
§237.5 (d) Waste Deposit Records.
(1) The owner or operator of a vessel shall maintain a record
of all waste deposited into the coastal waters. These records
must include information ...
(2) The owner or operator shall retain these records for no less
than three years and must submit these records to the
Administrator or Secretary upon request within five working
days. The owner or operator shall-promptly notify the
designated oversight authority if the owner or operator is
unable to meet the requirement under 237.5(c). ...
A written record of waste deposits from each SPA-
permitted vessel must be kept. The record should reflect
waste deposits from each completed trip.
The waste deposit records must be retained for at least
three years, and if requested, submitted to EPA. The
information recorded on the waste deposit record keeping
form must be reported to the corporate and governmental
oversight authorities in the event a waste deposit cannot be
cleaned up. These oversight authorities should be
identified in the O&M manual and their telephone
numbers posted on each SPA-permitted vessel.
Time required to develop
record keeping form
Time required to complete
record keeping form
Storage space for records
-------
Specific Provisions And Compliance Activities For Waste
Sources And Receiving Facilities During Loading And
Offloading And Vessels During Transport Of Municipal And
Commercial Waste (Cont'd)
Proposed SPA Provision (6/29/93 draft)
Activity Required
Potential Cost Element
$237.5 (e) Tracking Systems.
(1) The Administrator may require owners and operators of
vessels to operate a vessel tracking system on each vessel or as
the case nay be systems when two or more vessels are
involved. ...
EPA may require SPA-permitted vessels to develop and
use a tracking system for wastes.
Cost incurred only in cases of
noncompliance
|237.6 Permit review procedures.
(a) Permit review procedures will be followed as identified in
33 CFR 140.
(b) This regulation provides permit denial grounds. '
§237.7 Enforcement
(a) Violation of any provision of these regulations could lead
to the imposition of civil penalties.
(b) Enforcement procedures are outlined in the MOD between
USCG and EPA.
Civil penalties can be imposed for violations of the
regulations. The enforcement procedures have been
developed between EPA and the USCG.
-------
3.0 Affected Industry
Segements
-------
3.0 AFFECTED INDUSTRY SEGMENTS
This chapter identifies the industry segments affected by the proposed rule and the actions
required in each segment to achieve full compliance. The chapter is structured around the type
of wastes carried and the corresponding industries affected by the proposed rule. For each of the
four types of waste covered under the proposed SPA regulation - uncontainerized municipal
wastes, packaged garbage, sewage sludge, and drilling muds and cuttings — the chapter identifies
the industry affected; provides an overview of other laws, state regulations, and/or industry
standards which influence that industry's waste-handling practices; describes current waste-
handling practices; and identifies additional actions required for the industry segment to achieve
full compliance with the proposed rule.
3.1 Overview of Affected Industries
Exhibit 3-1 is a summary of the industry segments affected by proposed SPA regulation. As
shown in mis exhibit, the number of waste sources is about the same for uncontainerized
municipal wastes, packaged garbage, and sewage sludge. Most of the vessels covered by SPA
service the offshore oil and gas industry, particularly that industry in the Gulf of Mexico. There
is some overlap with the type of waste carried by offshore supply boats which can carry both
packaged garbage from platforms and drilling muds and cuttings to shore. The largest number
of receiving facilities are those that receive packaged garbage from the offshore oil and gas
industry and those that receive drilling muds and cuttings. Again, most of those facilities are in
the Gulf of Mexico.
3.2 Uncontainerized Municipal Wastes
3.2.1 Affected Parties
As shown in Exhibit 3-1, there are three industry segments affected by SPA in the category of
uncontainerized municipal wastes. All of these segments are part of the New York City
Department of Sanitation (NYC DOS), and are related to the transport of municipal wastes
collected from residences and small businesses in New York City to the Fresh Kills Landfill on
Staten Island. The SPA-permitted vessels operate exclusively in the New York Harbor. A
summary of the waste flow of uncontainerized garbage subject to SPA is shown in Exhibit 3-2.
Fresh Kills is the only remaining active landfill in the city and receives the majority of the city's
garbage. About 11,000 of the 14,000 tons per day of uncontainerized municipal wastes received
at Fresh Kills are delivered by barges which originate from eight Marine Transfer Stations (MTS)
located in the other boroughs of the city. (The remainder of the uncontainerized municipal wastes
is delivered to the landfill by truck.) Tugboats under contract to the DOS transport the barges
to Fresh Kills. The tugboats may stop at other MTSs to pick up more barges. Sometimes,
because of weather or operational conditions, the barges are deposited at a staging area located
in Brooklyn for delivery to Fresh Kills at a later tune (NYC DEP, 1991a). Typically, the
tugboats tow empty barges on the return trip from Fresh Kills. There are no private MTSs or
other municipal MTSs within New York Harbor (Masters, 1993; NYC DEP, 1992b).
Chapter 3.0 3-1 Affected Industry Parties
-------
Exhibit 3-1
Summary Of Affected Parties: Shore Protection Act
Uncontainerized Garbage
New York City/EPA Region 2
8
104
0
Packaged Garbage - Oil and Gas
Industry
Gulf of Mexico/EPA Regions 4 and 6
California/EPA Region 9
Alaska/EPA Region 10
N/A
N/A
N/A
66
0
0
740
±10
5-10
.137*
5*
2*
Packaged Garbage - Vessels
Anchored Offshore
Alaska/EPA Region 10
N/A
, **
**
Packaged Garbage - Islands
Massachusetts/EPA Region 1
New York/EPA Region 2
1
12
1
4
0
0
*0il and gas supply bases listed in U.S. Army Corps of Engineers' Port Series
* *Barges and offshore supply boats handling packaged garbage for vessels anchored offshore are treated as a single segment
-------
Exhibit 3-1
Summary Of Affected Parties: Shore Protection Act (Cont'd)
Sewage Sludge
Massachusetts/EPA Region 1
New Jersey and New York/EPA
Region 2
Pennsylvania/EPA Region 3
Illinois/EPA Region 5***
2
4
1
(2)
1
11
1
(2)
0
0
0
0
1
4
1
(1)
Drilling Muds
Gulf of Mexico/EPA Regions 4 and 6
California/EPA Region 9
Alaska/EPA Region 10
N/A
N/A
N/A
126
0
0
740
±10
0
47
3
0
N/A - Not applicable, SPA does not apply to this industry segment
*** Not currently operating
Source: Tetra Tech, 1993; U.S. Coast Guard database ofOSVs; Louisiana and Texas listings of oil field treatment facilities
-------
Exhibit 3-2
Waste Flow Subject To SPA: Uncontainerized Garbage
Transfer Station
Garbage Barge
Receiving Facility
Key:
Transfer covered by SPA
-------
322 Factors Affecting Waste-Handling Procedures
The waste-handling procedures used by the NYC DOS reflect New York State Department of
Environmental Conservation (NYS DEC) regulations, a U.S. District Court Consent Order, and
department manuals and protocols concerning solid waste management.
NYS DEC regulates and permits New York City solid waste-handling facilities including the
Fresh Kills Landfill and the Marine Transfer Stations. The NYS regulations, 6 NYCRR Part 360
Solid Waste Management Facilities, detail die provisions for siting, permitting, and operating a
solid waste management facility. EPA consulted these regulations during development of the
proposed SPA regulations.
The Consent Order stems from a lawsuit originally filed in April 1979 by the Township of
Woodbridge, New Jersey against New York City claiming that garbage lost during offloading at
the Fresh Kills Landfill was washing ashore and fouling their shoreline. Woodbridge was later
joined in the lawsuit by the New Jersey Department of Environmental Protection, the Interstate
Sanitation Commission, Groups Against Garbage, and Save Our Seas, Inc. This action resulted
in a June 1983 court order to New York City to build an enclosed barge unloading facility at the
Fresh Kills Landfill.
New York City was found to be in contempt of this order in 1986 when the City's failure to build
the structure resulted hi the case being brought before the court again. A Consent Order was
developed and signed in 1987 after the suit was re-opened by the court. The Consent Order
required a number of changes in waste handling related to the marine transport of garbage and
waste handling at the Fresh Kills Landfill; a study of floatable garbage and litter hi the New York
Harbor and surrounding waterways; and analyses by an independent consultant of the present
system, enhancements to the system, and alternatives to the system to prevent solid waste debris
from entering the water.
The requirements related to waste-handling practices included development of operation and
maintenance procedures designed to prevent discharges of debris and litter into the water from
the MTSs, barges, and Fresh Kills; monitoring by a New York City Water Quality Compliance
Monitoring Team; monitoring by an independent monitor; and use of specific types of equipment
such as a hydraulic crane, skimmer boats, a boom and lock system, and a Super Boom at Fresh
Kills.
The multi-year Gty-Wide Floatables Study sponsored by the New York City Department of
Environmental Protection (NYC DEP), in cooperation with die NYC DOS, began hi 1989. This
study has characterized and quantified the sources of floatable materials in the New York Harbor.
This included floatables from solid waste-handling facilities - the MTSs, the barges, and the
Fresh Kills Landfill. The study estimated that floatables from solid waste handling (MTSs,
barges, and landfills) represent about 1 percent of general debris in the harbor by any of three
measurements — number of items per month, weight of floatables per month, and volume of
floatables per month (NYC DEP, 1992b). The study concluded that containment procedures used
at the MTSs and at Fresh Kills are very effective (NYC DEP, 1992b). The study observed that
some material was present on barge decks in spite of the use of nylon mesh netting over the
garbage and housekeeping practices to keep the barge decks clean after loading and unloading.
Chapter 3.0 3-5 Affected Industry Parties
-------
The study attributed much of the material accumulated on barge decks to bird feeding activity.
The procedures used at the MTSs, at Fresh Kills, and on the barges to prevent debris from
entering the New York Harbor are described hi the following section.
Based on the findings of the independent consultant's report required by the 1987 Consent Order,
a new Consent Order was executed in February 1993. Under the terms of this Consent Order,
the parties to the suit have agreed that the long-term approach to preventing solid waste from
entering the water from Fresh Kills is the construction of a single-barge enclosed unloading
system at the Fresh Kills Landfill. The construction of this facility is to be completed by March
31, 1998. The Consent Order also calls for the development of a protocol for the operation and
maintenance of this facility.
3.2.3 Current Waste-Handling Procedures
The waste-handling procedures at the MTSs, on the barges, and at the Fresh Kills Landfill
described below are based on the NYC DOS Revised Water Clean Management Plan (draft as
of April 13, 1990); NYC DOS Water Quality Compliance Monitoring Team Protocol; several
volumes of the City-Wide Floatables Study (NYC DEP, 1990, 1991a, 1992b); the 1992 Study of
the Effectiveness of Floatables Containment Systems at the Fresh Kills Landfill (NYC DOS,
1992); and interviews with NYC DOS representatives.
3.2.3.1 Marine Transfer Stations
A MTS, a waste source facility under SPA is typically a two-story structure. The lower floor
has one or two loading slips for the barges. Each slip is surrounded on threes sides by closely
spaced wooden stavings which extend from below the low-tide level to the main floor,
approximately 8 feet above mean high water. The fourth side is open to allow barge movement
(NYC DEP, 1990a). Trucks unload garbage directly onto the DOS barges from the tipping floor
located on the upper level. The MTSs operate 8 or 24 hours per day, depending on the location.
The MTSs operate six days per week (Monday through Saturday), excluding holidays (Begg,
1993). There is fixed lighting in each MTS. A summary of the NITS characteristics is provided
in Exhibit 3-3.
Equipment, good housekeeping practices, and manual removal of debris are used to prevent
floating garbage from entering die harbor from the MTSs. Proper waste-handling procedures at
the MTSs are included in the Water dean Management Plan.
A containment boom, which extends from about 1 foot above the water surface to 3 to 4 feet
below the water surface, is placed across the mouth of each slip when a barge is being loaded.
The boom is intended to prevent fioatables lost during the loading operation from entering the
harbor waters. A daily log of containment boom openings and closings is maintained. Floatables
lost during me loading operations are removed by NYC DOS employees using dip nets prior to
the boom being opened and the barge moved (NYC DEP, 1992b). In addition to the containment
boom, a descending door that completely blocks the entrance is available at two of the MTSs
(NYC DEP, 1990b).
Chapter 3.0 3-6 Affected Industry Parties
-------
Exhibit 3-3
NYC DOS Marine Transfer Stations
Southwest
Brooklyn
24
Hamilton Ave.
Brooklyn
24
Greenpoint
Brooklyn
24
North Shore
Queens
24
South Bronx
Bronx
24
W. 59th St.
Manhattan
1*
8
W. 135 St.
Manhattan
24
E. 91 St.
Manhattan
8
* - Two barges moor at one slip
Source: Beggs. 1993
-------
Measures are also taken on the tipping floor to prevent debris from entering the harbor waters.
The tipping floor is inspected at least once per shift to ensure that there is no debris that could
potentially be blown into the water. Brooms and shovels are used to clean up materials on the
tipping floor and catwalks. Cones or other barriers are used to seal off bays of the slip when a
barge shift is made in order to prevent unauthorized unloading of garbage (NYC DOS, 1990a).
A study of the floatable retention efficiency of MTSs was conducted hi 1989 and 1990 as part
of the City-Wide Floatables Study. The study concluded that the MTS containment structures
(i.e., booms and doors) are highly effective in preventing floatables from entering open waters.
Use of the containment devices prevents significant amounts of floatables from leaving the MTSs
even when no attempts at clean up are made (NYC DEP, 1990b). Current waste-handling
practices require the use of dip nets and other means of collection at several points during the
barge loading process.
3232 Garbage Barges
The barges used to transport garbage from the MTSs to Fresh Kills are waste transport vessels
as defined by SPA. As shown in Exhibit 3-1, there are 104 SPA-permitted NYC DOS barges
for carrying municipal and commercial waste. They are 37 feet wide and ISO feet long on the
outside and, on the inside, are 30 to 31.6 feet wide, 14.1 feet deep, and 130 feet long. Each
barge has a capacity of 2,253 cubic yards or about 630 tons of garbage (NYC DEP, 1992b).
Exhibit 3-4 shows the number of barges loaded per day at each of the MTSs in February 1993.
NYC DOS protocol for barge loading indicates the acceptable draft of a fully-loaded barge is 9
feet and the acceptable peak height of a fully-loaded barge is 8 feet above the coaming. Waste
height is measured with a pike pole which has the 8-foot level clearly marked (NYC DOS,
1990a). The time barge loading and unloading begins and ends is recorded. Tug shifts and hand
shifts of barges at the MTSs are also recorded. A typical tow has three to four barges (Beggs,
1993). An average of 390 round-trip barge excursions between the MTSs and Fresh Kills are
made each month (NYC DEP, 1992b).
To prevent floatables from the barges from entering harbor waters, several abatement measures
are practiced. These and other waste-handling procedures for garbage barges are included in the
Water Clean Management Plan. At the MTS, the barge decks are inspected for cleanliness upon
arrival and any debris is swept into the barge. The barge decks are swept clean before the barge
is moved within or from the MTS. The deck condition of barges incoming and departing from
a MTS is recorded on the MTS Barge Cleanliness Report (NYC DOS, 1990a). Prior to
departure, each barge is covered with a nylon mesh net to prevent garbage from being blown off
while it is in transit. If the net tears during placement, a second net is placed over the garbage
(Begg, 1993).
As part of the City-Wide Floatables Study, field studies were conducted to evaluate the amounts
and types of floatables from the barges in transit to and from Fresh Kills. These studies indicate
that it is unlikely that significant amounts of floatables are lost from full or empty barges in
transit. However, these studies also indicate that sea birds pick at the garbage through the nets
and re-deposit materials on the deck. For full barges, it was found that the number of items on
the deck increased between the MTS and the staging area and decreased between the staging area
and Fresh Kills. For empty barges, the number of items on the deck was highest at Fresh Kills
and lowest at the MTS. These observations suggest that some material is lost from the barges
while in transit (NYC DEP, 1992b).
Chapter 3.0 3-8 Affected Industry Parties
-------
Exhibit 3-4
Amount Of Time To Transfer Garbage From MTS to Barge,
February 1993
Southwest
24
1.77
13.5
Hamilton Ave.
24
4.36
5.5
Greenpoint
24
3.59
6.7
North Shore
24
3.68
6.5
South Bronx
24
2.82
8.5
W. 59th St.
8
1.23
6.5
W.I 35 St.
24
2.23
10.8
E. 91 St.
8
0.73
10.9
* Calculated from first two columns
Source: Beggs, 1993
-------
The leachate or water present in the hopper is generally absorbed by the paper hi the garbage.
There is a bilge compartment hi the bottom of the barge. All barges are also sounded, that is
measured for standing water, upon arrival at a MTS and at the start of every subsequent shift and
prior to departure from a MTS. At Fresh Kills, barges are sounded two times per shift while at
the West Mooring Rack, located outside the Super Boom, where loaded and empty barges are
staged. Excess water is pumped into the sanitary sewer system when available. Or, when that
is not an option, excess water is left on the barge until a sewer is available (NYC DOS, 1990a).
All soundings are recorded.
At Fresh Kills, barges are cleaned and debris swept back into the barge after being unloaded
(NYC DOS, 1990a). Deck conditions on arrival and departure from the off loading area are
recorded on the Daily Digging Activity-Barge Cleanliness Report (NYC DOS, 1990a). Digging
is the process of removing the garbage from the barge with a crane. Barges with partial loads,
which are to be moved prior to completion of the unloading process, are cleaned prior to the
shift.
3.23.3 Fresh Kills Landfill
The Fresh Kills Landfill is a waste receiving facility under SPA. At Fresh Kills, garbage is off-
loaded from the barge using a hydraulic crane or clamshell bucket. Each barge takes about 2.5
hours for crane unloading during an 8-hour shift and 1.75 hours digging tune (Beggs, 1993).
The tune barge unloading begins and ends is recorded. Fresh Kills operates Mondays through
Friday and half a day on Saturday. There is fixed lighting at the mooring areas.
Waste-handling procedures at Fresh Kills are included in the Water dean Management Plan.
Structures and procedures used to prevent debris from being lost during the transfer process
include: 1) booms (a Super Boom and an Outer Boom) to retain floatables within Fresh Kills;
2) skimmer vessels; 3) clean up crews to collect debris from the shoreline within the facility; 4)
a system of fences along the shoreline and the roads crossing the tributaries; 5) covering
procedures on the open face of the landfill; 6) methods for docking barges which deter loss of
materials during offloading; and 7) use of dip nets to retrieve water-borne litter between moored
barges and the catwalk (NYC DEP, 1992b; and NYC DOS, 1990a).
Water cleanliness is recorded on a number of forms. These include the Daily Skimmer Activity
Log, Water Cleanliness Ratings, and the Daily Skimmer Boat Report. Operations at the landfill
are also observed by NYC DOS environmental officers who measure the amount of floatables in
nearby waters and by an independent monitor who sends bi-monthly reports to the NYC DOS
and to other government agencies about the amount of floatables in the Fresh Kills water.
A study of the effectiveness of the containment systems at Fresh Kills was conducted hi 1992.
The abatement practices at Fresh Kills were found to be 100 percent effective in removing surface
floatables (NYC DOS, 1992).
3.2.4 Actions Needed to Achieve Compliance
Exhibit 3-5 summarizes the current level of compliance of the industry segments dealing with
uncontainerized garbage affected by the proposed SPA regulation. As shown in the exhibit, it
is estimated that these industry segments are currently in compliance with the proposed
Chapter 3.0 3-10 Affected Industry Parties
-------
Exhibit 3-5
Current Level Of Compliance: Uncontainerized Garbage
Shoreside Facilities:
Marine Transfer
Stations (NYC)
Vessels:
Garbage Barges
NYC DOS
*Facilities have O&M manuals, but they may not be fully in compliance with the proposed regulations
Source: NYC DOS
-------
regulation, with the exceptions of having the required placard and waste deposit records. While
these industry segments have O&M manuals, they will need to be reviewed by the New York
City Department of Sanitation and EPA to determine if they are fully in compliance with the
proposed regulation. No other compliance activity should be needed.
3.3 Packaged Garbage
As shown hi Exhibit 3-1, there are eight industry segments affected by SPA hi the category of
packaged garbage, that is garbage already bagged, or La cardboard boxes or other containers
before being offloaded from an offshore facility to a vessel for transport to shore. (Note that one
of these segments, offshore supply boats, is also an industry segment La drilling muds and
cuttings; see Section 3.5.) These vessels typically serve the oil and gas industry, vessels
anchored offshore, or islands used as parks or resort areas. Each of the three situations is
described separately below. A summary of the waste flow of packaged garbage subject to SPA
is shown La Exhibit 3-6.
33.1 Packaged Garbage from the Offshore and Inland Oil and Gas Industry
33.1.1 Affected Parties
As explained La Chapter 1 and illustrated hi Exhibit 3-6, die transfer of packaged garbage from
tfaeplatform to the transporting vessel is covered by MARPOL Annex V and is not subject to the
"provisions of the proposed SPA regulation. Therefore, only_jraaspoit vessels (barges and
offshore supply boats) and receiving facilities are segments affectedTbv the proposed SPA
regulation for this type of waste. Packaged garbage from offshore oil and gas platforms is
generated La three regions of the country - the Gulf of Mexico (EPA Regions 4 and 6), southern
California (EPA Region 9), and Alaska (Region 10). The inland platforms from which packaged
garbage is transported are all along the Gulf coast. Since the overwhelming majority of the
platforms are La the Gulf of Mexico, it is not surprising that the largest number of transporting
vessels and receiving facilities for packaged garbage from offshore oil and gas platforms is also
in the Gulf of Mexico.
33.1.2 Factors Affecting Waste-Handling Procedures
The procedures used by the offshore oil and gas industry primarily reflect Minerals Management
Service (MMS) requirements for activities La Federal waters, provisions in the EPA National
Pollutant Discharge Elimination System general permits, the provisions of MARPOL Annex V,
and industry practices and standards.
MMS regulations (30 CFR 250) prohibit the deliberate discharge of containers or garbage and
debris in the marine environment and require equipment, tools, containers, and materials
weighing more than 40 pounds to have a durable operator identification marking. MMS has also
issued Guidelines for Reducing or Eliminating Trash and Debris in the Gulf of Mexico, NTL No.
86-11 (MMS, 1986). These guidelines reiterate the regulations prohibiting deliberate discharge
of containers, garbage and debris, and requiring durable marking of equipment. They also
recommend that operators use solid waste reduction methods such as compaction, that they
develop a training and awareness program on the consequences of debris hi the marine
environment, and that industry implement a control system to account for proper disposal of
wastes (MMS, 1986).
Chapter 3.0 3-12 Affected Industry Parties
-------
Exhibit 3-6
Waste Flows Subject To SPA: Packaged Garbage
a. Oil and Gas Industry
Platform
b. Vessels Anchored Offshore
Cruise Vessel, Fishing Boat
or Other Vessel
c. Islands
Island Transfer Station
Key: not = Transfer covered by SPA
Supply Boat Carrying
Garbage from Offshore
Platform/Rig
Barge Carrying Garbage from
Inshore Platform/Rig
Barge Carrying Garbage from
Vessel Anchored Offshore
Barge Carrying
Garbage from Island
Receiving Facility
(Supply Base)
Receiving Facility
(Port/Dock/Marina)
i — S = Transfer not covered by SPA
Receiving Facility
(Mainland Port or Dock)
-------
The regulations for MARPOL Annex V, an international treaty which restricts at-sea disposal of
garbage generated on vessels and offshore platforms, also affect offshore oil and gas industry
waste-handling procedures. Under MARPOL Annex V, only ground food waste can be disposed
of at sea from platforms and then only at distances of 12 miles or more from shore. The transfer
of the garbage from the platform to the waste transporting vessel is covered under the
implementing regulations for MARPOL Annex V (33 CFR 151 and 158). However, the
transporting vessel and the transfer to shore at the receiving facility is covered by the Shore
Protection Act. (Note: the operational wastes of the waste transporting vessel are covered under
MARPOL Annex V. It is only the wastes being transported from the platform that are covered
by SPA.)
The NPDES general permits issued by EPA prohibit the discharge of "floating solids" and
"rubbish, trash, and other refuse" from offshore platforms.
The Offshore Operators Committee (OOC), the offshore oil and gas industry trade association
in the Gulf of Mexico, has developed an active program on waste handling. The OOC
Environmental Waste Handling-Recycling AD HOC Committee was established to develop and
encourage industry-wide strategies and procedures to reduce and improve handling of non-
hazardous solid wastes generated offshore. (The MMS, U.S. Coast Guard, and the National Park
Service are members of this committee.) The AD HOC committee developed and is
implementing a four-phase plan to address increasing concern about marine debris from the oil
and gas industry hi the Gulf of Mexico. The four phases will: 1) establish industry marine
debris benchmarks; 2) identify offshore waste management practices and areas for improvement;
3) provide industry-wide educational tools; and 4) establish community linkages with die industry
through programs such as recycling and beach cleanups. As of March 1993, only Phase I had
been completed. However, a list of proactive management practices for non-hazardous solid
wastes was developed and disseminated. Among the suggestions in the guidelines are the use of
a net or hard cover for baskets during transport and the use of reusable fiberglass trash bags for
transporting recyclables and wastes not stored in covered containers (OOC, 1992).
33.13 Current Waste-Handling Procedures
The waste-handling procedures described below are based on interviews with industry
representatives and an OOC study of the waste-handling practices of its members.
Operational, galley, and household wastes from offshore platforms are collected and typically
stored in covered bins, compactors, or containers. Occasionally, bagged garbage is thrown onto
crew boats for transport to shore. Crew boats occasionally taking garbage from oil platforms to
shore, however, would not be subject to SPA regulations because the transport of garbage is not
the primary reason for their trip.
In the Gulf of Mexico, 75 percent of the companies responding to a survey of waste-handling
practices on offshore platforms indicated mat they always provide covered bins. Less than 3
percent said they never did (OOC, 1990). Garbage is typically transported to shore in a covered
basket, an uncovered basket, a compactor bag, and/or a dumpster or similar container (OOC,
1990). Garbage generated on the emergency standby vessel is either offloaded to the platform
and then transferred to a supply boat returning to shore or taken to shore directly on its return
trip. In both situations, the garbage is covered by the MARPOL Annex V regulations since it
is garbage generated in the course of normal operations.
Chapter 3.0 3-14 Affected Industry Parties
-------
On inland platforms (e.g., those inside the intracoastal waterway), an empty dumpster is typically
brought to the platform on a flat-deck barge carrying other supplies. The barge is moored
adjacent to the platform. Bagged garbage is put in the dumpster and taken in the dumpster to
shore when the barge is returned to shore. The dumpster is lifted by crane to the supply base
dock where its contents are emptied and taken by waste hauling trucks to its final disposition.
In Southern California dumpster-like containers or cargo bins are rented from a crane company
by an oil company for use on a platform. When full, these covered containers are loaded onto
a transporting vessel by a crane on the platform. Contact between the crane operator and the
vessel during the transfer operation is typically maintained by two-way radio. Other deck cargo,
such as rig equipment and scrap metal, may be taken to shore at the same time in order to use
the vessel's capacity. The containers are secured to the deck to prevent shifting or loss during
transport. At the dock, the containers are removed from the transporting vessel by dockside
cranes and dumped into a larger container which is taken offsite for disposal when it is full. On
average the bin is dumped once every 2 weeks (Brunetti, 1993; Onesti, 1993; Sutton, 1993;
Zermino, 1993).
Estimates of the amount of packaged garbage transported from oil and gas platforms to shore are
limited. Exhibit 3-7 is an example of the landfilled non-hazardous waste from offshore operations
for one major oil company in die Gulf of Mexico during a 5-year period. The increase in waste
shown in this exhibit has not accompanied a significant increase in personnel, drilling, or
production activity according to the company (Babin, 1991). This company has launched a three
point program to reduce the amount of wastes which are landfilled - generate less waste, recycle
as much as possible, and reduce the volume and cost of landfilled waste. Only the first point,
generating less waste through changes in purchasing practices, will affect the amount of garbage
carried to shore by vessels.
33.1.4 Actions Needed to Achieve Compliance
Exhibit 3-8 summarizes the current level of compliance of the industry segments dealing with
packaged garbage from the oil and gas industry affected by the proposed SPA regulation. As
shown in the exhibit, it is estimated that all owners/operators of supply bases (receiving facilities
underSPAjwill need to place a placard at their facilities and develop waste deposit records in
accordance~wim the proposed regulation. A portion of these facilities (estimated at 75 percent
uf small Companies and 10 percent of large ones) will also need to purchase equipment such as
a dip net, boat hook, and/or harness for^use with a crane in the event of a spill. In addition,
about yu percent of small companies and 70 percent of large ones will need to develop an O&M
The owners/operators of vessels carrying packaged garbage from the offshore oil and gas industry
will need to place a placard on each vessel, develop O&M manuals, and develop waste deposit
records in accordance with the regulation. In addition, about 25 percent of the vessel companies
will need to purchase some equipment such as a dip net, boat hook, or harness for use with a
crane.
Barges servicing the inland platforms will need a placard on each vessel, as well as O&M
manuals which include waste handling procedures. These vessels will also need to develop forms
for recording waste deposits. In addition, an estimated 25 percent of these barges will need to
be equipped with dip nets and boat hooks to clean up waste deposits.
Chapter 3.0 3-15 Affected Industry Parties
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Exhibit 3-7
Sample Firm's Yearly Landfilled Non-Hazardous Waste,
1986 To 1990*
1,<>00,000 -
1,400,000 -
1,200,000 -
1,000,000 -
800,000 -
1986
Pounds
1987
1988
1989
1990
Source: Babin, 1991
^Excludes wastes subject to RCRA exemption for drilling muds and cuttings
-------
Exhibit 3-8
Current Level Of Compliance: Packaged Garbage From The
Offshore And Inland Oil And Gas Industry
Shoreside Facilities:
Small/large
25%/90%
100%
Small/large
25%/90%
Small/large
25%/90%
0%
0%
Small/large
10%/30%
Vessels:
OSVs Handling
Garbage (and
Drilling Muds
and Cuttings)
75%
100%*
0%
75%
100%
0%
0%
0%
!
Barges
Handling
Garbage from
Inland Rigs
100%
N/A
0%
75%
100%
0%
0%
0%
* Leachate control does not apply; estimate pertains to labeling and sealing valves
Source: Tetra Tech, 1993
-------
3.3.2 Packaged Garbage from Vessels Anchored Onshore
3.3.2.1 Affected Parties
Large vessels which do not moor at dockside are serviced by local service vessels, called tenders.
This would occur when vessels are too large for the berthing space at the port being visited and
in ports where no berths are available because of the volume of traffic at the time. Both of these
situations can occur for the cruise industry and do occur for the cruise industry in Alaska. Other
reasons that cruise vessels moor offshore include the cost, since mooring offshore eliminates
dockage and wharfage fees, and schedule. If a vessel has just come from a port and has been
fully serviced, it does not need to come to the dock (Geldecker, 1993).
3322 Factors Affecting Waste-Handling Procedures
The wastes from vessels anchored offshore and transported by service vessel to shore are covered
SySPA. However, the transfer of the waste to the service vessel is covered by MARPOL Annex
V, which addresses at-sea disposal of vessel-generated wastes. At-sea disposal of plastics is
always prohioited and at-sea disposal of other materials is restricted depending on distance from
shore. The amount of garbage needing to be disposed of in port varies depending upon several
factors, including the type of solid waste management equipment (e.g., incinerators) available on
board. (Note: The operational wastes of the waste transporting vessel are covered under
MARPOL Annex V. It is only the wastes from the vessel anchored offshore being transported
that are covered by SPA.)
Wastes offloaded from vessels coming from foreign countries other than Canada are also covered
under U.S. Department of Agriculture, Animal and Plant Health Inspection Service (APHIS)
regulations. APHIS regulations require that wastes containing plant or animal material offloaded
in a U.S. port coming from a foreign country be treated at an approved facility by steam
sterilization, incineration, or grinding into an approved sewage system under the supervision of
an inspector. Regulated garbage must be stored in small leakproof, covered containers which are
securely closed. These containers are then placed in a shipping or handling container that is also
leakproof. The outer container is conspicuously marked as regulated garbage. Regulated garbage
is transported by APHIS-permitted waste hauling companies hi covered, leakproof carriers.
Hauling company personnel must be trained in handling regulated garbage, including procedures
for reporting and handling emergency spills. Transportation and disposition records are
maintained APHIS-approved disposal facilities or APHIS-approved hauling companies are not
available at all ports.
3.3.23 Current Waste-Handling Procedures
The waste-handling procedures for service vessels to the cruise industry in Alaska described
below are used as examples of packaged wastes from vessels anchored offshore. The description
is based on interviews with industry representatives.
The cruise season in Alaska runs from May through September. Arrangement for garbage pickup
is typically made through the ship's agent who in turn notifies the company providing the garbage
transport service of the ship's date and time of arrival. A ship's stay in port is variable, but is
made primarily during daytime hours. In Juneau, for example, the stay is a minimum of 6 hours
and may be up to 12 hours (Cheeseman, 1993). In Sitka, a 4-hour stay is more typical (Olsen,
Chapter 3.0 3-18 Affected Industry Parties
-------
1993). The ship typically has garbage pickup service once during its stay. For those vessels
requiring tender service, the service vessel makes as many trips as necessary to pickup the
volume of garbage to be disposed. One trip is usually sufficient, but two trips are sometimes
required. Exhibit 3-9 is a summary of the ship calls expected at each of these three ports during
the 1993 season and an estimate of the number of times these ships will be serviced by tenders,
which are permitted under SPA. As shown in Exhibit 3-9, an estimated 5,960 tons of garbage
will be transferred to shore from cruise vessels in Alaska by tenders during the 1993 season. It
should be noted that although the number of tourists arriving in Alaska by cruise vessel is
increasing, the increase in garbage to be offloaded is not proportional because the newer cruise
vessels have more on-board technology (e.g., incinerators and grinders) for use in disposing of
waste (Cheeseman, 1993).
Garbage from the cruise ships is packaged, that is bagged, double bagged, or hi boxes or other
containers when it is picked up. The packaged garbage is offloaded into a container on the
service vessel. The type of container and service vessel differs by port. The approach used in
three ports to service vessels anchored offshore is described below.
In Sitka, the company providing this service uses a barge with a container with an open top.
Generally, one container is needed but the barge can hold up to three. The barge is fitted with
a fork lift and a crane. 'When the barge is in position next to the ship, the forklift is used to lift
the ship's dumpster from the loading area and empty the dumpster's contents into the container.
A tarp is secured to the container to cover its contents during transport. Dockside, a crane is
used to lift the container onto a truck which is then used to transport the container and its
contents to its ultimate disposal site, an incinerator. Liquid wastes are not accepted. The
company reports no loss of garbage during transfer because it is self-contained. There are no
established procedures for handling a garbage spill. The barge is equipped with a pole which
could be used to retrieve debris should a spill occur. Similarly, leachate has not been a problem
because the garbage is bagged or double bagged (Olsen, 1993).
In Juneau, a 56-foot landing craft, which holds a container with a 40 cubic yard capacity, is used.
Packaged garbage from the cruise ship is tossed into this container by the ship's personnel.
When all garbage has been transferred or the container is full, a tarp is pulled over the top of me
container and secured. In the event the packaged garbage misses the container during the
transfer, personnel on the landing craft use a boat hook to retrieve it and retrieve loose garbage
by hand. The company reports that the need to retrieve garbage from the water is rare because
awareness of MARPOL Annex V regulations causes personnel to use greater caution when
transferring wastes over water. Dockside, the covered container is rolled off the landing craft
onto a truck which carries the wastes to a landfill or an incinerator for ultimate disposal. As in
Sitka, the garbage is self-contained during the transfer to shore and the company reports no
incidence of spillage during the transfer to shore (Cheeseman, 1993).
In Ketchikan, a barge loaded with empty trucks is used to service vessels anchored offshore.
Once alongside the ship, packaged garbage is transferred from the ship's loading bay to the trucks
on the barge. Dockside, the trucks are taken off the barge and then used to transport the garbage
to a local landfill (Sharp, 1993).
U.S. EPA Headquarters Library
Mail code 3201
1200 Pennsylvania Avenue NW
Washinntnn
Chapter 3.0 3-19 Affected Industry Parties
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Exhibit 3-9
Summary Of Cruise Ships In Alaska, 1993 Season
NA - Not available
Sources: Carlson, 1993; Olsen, 1993; Cheeseman, 1993; Jones, 1993; Geldecker, 1993; and Sitka Department of Tourism, 1993
' Based on the following: about 1,600 tons of garbage was offloaded from cruise vessels by tenders in Juneau in 1992. This is
also representative of that offloaded from cruise vessels to tenders in Ketchikan in 1992 (Cheeseman, 1993). The garbage to be
offloaded from cruise vessels to tenders is estimated to increase by 5 percent in 1993 (Cheeseman, 1993). A per ship call unit of
garbage was derived from the estimate for Juneau (9.6 tons per call) and applied to the number of ship calls serviced by tenders
expected in Sitka in 1993 (271) to yield the estimate of garbage offloaded to tenders in Sitka in 1993.
-------
33.2.4 Actions Needed to Achieve Compliance
Exhibit 3-10 summarizes the current level of compliance of the industry segments dealing with
packaged garbage from vessels anchored offshore affected by the proposed SPA regulation. As
shown hi the exhibit, it is estimated that owners/operators of transporting vessels will need to
develop an O&M manual, place a placard on each vessel, and develop waste deposit records in
accordance with the requirements of the proposed regulation. Owners/operators of receiving
facilities for packaged garbage from vessels anchored offshore will also need to place a placard
at their facilities, develop an O&M manual, and undertaken activities related to waste deposit
records in accordance with the proposed regulations.
333 Packaged Garbage from Islands
333.1 Affected Parties
There are two known areas where vessels carry wastes from islands. In New York, there are five
SPA-permitted vessels which carry wastes from Fire Island, a summer resort area, to the
mainland. The other area is Boston Harbor where there is one permitted vessel that carries waste
from Georges Island, which is part of the Boston Harbor Islands State Park. Other islands in that
State Park have a carry on/carry off policy (McCormick, 1993). In both of these situations,
garbage pickup is seasonal.
333.2 Factors Affecting Waste-Handling Procedures
The factors affecting waste-handling procedures in this category relate primarily to the fact that
the wastes are generated on islands which are used seasonally. There are some residences on
Fire Island as well as the National Seashore. Georges Island is, however, a State park.
3333 Current Waste-Handling Procedures
In this situation, the wastes originate on land, are transported by vessel to shore, and are disposed
of onshore. An example of this situation is Georges Island, part of the Boston Harbor Island
State Park. The waste-handling procedures for wastes from Georges Island described below are
used as an example of packaged wastes from islands. The description is based on interviews with
industry representatives.
A landing craft operated by the Metropolitan District Commission is used to transport private and
maintenance vehicles between the mainland and Georges Island. Under SPA, this craft is a waste
transport vessel. The craft typically make two round trips to the mainland per day between early
May and late November. Garbage from Georges Island (the waste source facility under SPA)
is collected in bags and placed into a "packer" located on a 1-ton dump truck. The packer is a
smaller version of a city garbage truck and consists of a solid body frame with doors on the side
where the garbage is loaded. The packer is used to compact garbage. The packer has a capacity
of 10 cubic yards and is self-contained. Therefore, no garbage is exposed to the water or
surrounding environment. The dump truck with the packer is transported to the mainland by the
landing craft where the garbage is men offloaded to a dumpster, the waste receiving facility under
SPA. Dumpsters on the mainland have a 30 yard capacity and are under contract from private
disposal companies. Although no spills are reported to have taken place, equipment available for
use should one occur includes rakes, shovels, and gloves (McCormick, 1993).
Chapter 3.0 3-21 Affected Industry Parties
-------
Exhibit 3-10
Current Level Of Compliance: Packaged Garbage From
Vessels Anchored Offshore
Shoreside Facilities:
Receiving
Packaged Garbage
from Vessels
Vessels:
Vessels Handling
Garbage from
Vessels
N/A-Not applicable
Source: Tetra Tech, 1993
-------
333.4 Actions Needed to Achieve Compliance
Exhibit 3-11 summarizes the current level of compliance of the industry segments dealing with
packaged garbage from islands affected by the proposed SPA regulation. As shown in the
exhibit, it is estimated that the owners/operators of the waste sources and receiving facilities will
need to place a placard at their facilities, develop an O&M manual, and develop and maintain
waste deposit records in accordance with the proposed regulation. Since not all of the facilities
have the required waste deposit cleanup equipment, purchase of items such as dip nets and/or
boat hooks will be required of about 20 percent of the facilities. The owners/operators of the
transporting vessels will need to develop an O&M manual, place a placard on each vessel, and
undertake all the activities related to the waste deposit records in order to be in compliance with
the proposed regulation.
3.4 Sewage Sludge
3.4.1 Affected Parties
As shown hi Exhibit 3-1, there are three industry segments affected by SPA in the category of
sewage sludge. A summary of the waste flow of sewage sludge subject to SPA is presented in
Exhibit 3-12.
3.4.2 Factors Affecting Waste-Handling Procedures
Sewage sludge handling facilities operate under permits from State environmental protection
agencies. The permit dictates the conditions under which the facility can operate. For example,
all sludge transfer operations may be restricted to dry weather only. Health and safety hazards
associated with sewage also affect the procedures used.
3.43 Current Waste-Handling Procedures
In this situation sewage sludge is transported from a land-based waste source by vessel to a land-
based receiving facility. The waste-handling practices for transporting sewage sludge in New
York City described below are an example of waste-handling procedures for this type of waste.
The description is based on interviews with New York City Department of Environmental
Protection (NYC DEP) personnel and the agency's spill prevention manual.
In New York City, sewage sludge is transported by underground pipeline from the treatment plant
to a large storage tank dockside on Wards Island. This tank is the waste source facility under
SPA. The transfer of sludge from the storage tank to the vessel tanks (the waste transport vessel
under SPA) is performed using the shoreside manifold (pipe valve on the dock which is connected
to the storage tank), a 12-inch hose, and the vessel's gate valve connection. When the vessel is
alongside the dock, the hose is connected to its receiving valve. Each hose connection uses a
"quick-connect" coupling mechanism to ensure a sealed connection (i.e., a screw that has three
claws which are connected to a flange - various twists/turns seals the connections). The tank and
vessel valves are then opened for the load to be pumped into the vessel tanks. The valves on
dockside pumps are labelled with open/close indicators (such as arrows) (Mroz, 1993; Tobin,
1993).
Chapter 3.0 3-23 Affected Industry Parties
-------
Exhibit 3-11
6
I
Current Level Of Compliance: Packaged Garbage From
Islands
Shoreside Facilities:
Receiving Packaged
Garbage from Islands
Vessels:
Vessels Handling
Garbage from
Islands
MA-Net applicable
Source: Tetra Tech, 1993
-------
Exhibit 3-12
Waste Flow Subject To SPA: Sewage Sludge
9
o>
b
U»
ft
Transfer Station
Sludge Barge
Receiving Facility
a
Key:
Transfer covered by SPA
-------
Other pump valves used are the vessel's gate valves which are equipped with a rising stem (i.e.,
when the valve is open, the stem is in the raised position; when the valve is closed, there is no
stem apparent). All valves, therefore, have "visual" mechanisms to indicate the open/close status,
but have no actual written labels. The vessel loading dock and the vessel both have lighting
equipment for use during evening-hour transfers. There are large lights spaced evenly apart on
the dock facility. The vessel has a high-power spotlight which is aimed directly on the transfer
connection when at the receiving facility.
When the transfer is completed, the tank valves are shut off and connections secured. The hose
used for the transfer is blasted with an air pump to remove any excess matter from the hose into
the vessel tank (a.k.a. "clearing the line"). The vessel valves are closed and secured and the hose
is disconnected. A 55-gallon "catch" drum is placed beneath the manifold connection in order
to catch any drips during the hose disconnection. When the drum is full, the sludge is returned
to the storage tank. Spills during transfer of sludge to the vessel generally do not occur because
of the secure valve mechanisms, but if one were to, the dock facilities have equipment on hand
to handle spilled material. This includes a spill-containment boom, various types of absorbent
material, wood used to form a barrier (for spills on dock), and other hand cleanup materials
(e.g., rags) (Mroz, 1993; Tobin, 1993).
Three vessels are used to transport sludge consolidated on Wards Island from four treatment
plants to four dewatering plants, the waste receiving facilities under SPA. Two vessels are
operated and the third is used as a backup. Two vessels hold a volume of about 92,000 cubic
feet. The third vessel holds about 50,000 cubic feet. The larger vessels are generally in
operation. Typically, each vessel makes two trips during the 12-hour shift, a total of four round
trips to a dewatering plant daily. On average, 200,000-300,000 cubic feet of sludge is transferred
per day, six days a week (Mroz, 1993; Tobin, 1993).
When the vessels reach the dewatering facility, the transfer of sludge is made using the same
pump/hose transfer method as used on Wards Island. The sludge is transferred into intermediate
holding tanks. There are two pump/hose hook-ups available for transfer at the dewatering plants,
but only one is typically used at any one time. If a spill should occur during the tank loading
procedure while at the receiving facility, the facility is responsible for cleanup procedures. In
such a case, both the vessel and dock personnel would record the spill incident.
The waste-handling procedures are detailed in a spill prevention manual which covers: accidents,
person in-charge duties, inspector duties, loading city sludge vessels and barges, topping off
procedures, completion of transfer procedures, containment procedures, pump off procedures for
city sludge vessels, harbor transit procedures, emergency operating procedures for loss of tug
services, and emergency telephone numbers (NYC DEP, n.d.).
In the event of a spill, all sludge transferring stops and the sludge transfer crew is required to
inform EPA Region 2, the U.S. Coast Guard, and the NYC DEP Administrator or Marine
Operations (NYC DEP, n.d.). The NYC DEP Marine Division reports all significant spills
(i.e., described as greater than a "barrel's-worth") to the NYS DEC. The official report is sent
to NYS DEC by the NYC DEP Process Control Section, Bureau of Clean Water in the form of
a letter (Mroz, 1993).
Other reporting forms required by NYC DEP Marine Division personnel include the Captain's
Log entry and the Sludge Loading Record. The Captain's Log entry is filled out once per shift.
Chapter 3.0 3-26 Affected Industry Parties
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The Sludge Loading Record is filled out each time a vessel is loaded during the shift; most likely,
a maximum of four times per shift (Mroz, 1993).
3.4.4 Actions Needed to Achieve Compliance
Exhibit 3-13 summarizes the current level of compliance of the industry segments dealing with
sewage sludge affected by the proposed SPA regulation. As shown hi the exhibit, it is estimated
that the owners/operators of the sewage sludge waste sources and receiving facilities will need
to place a placard at their facilities and review their existing O&M manuals for compliance with
the proposed regulation. About 14 percent of the waste sources and all of the receiving facilities
will need waste deposit records. The owners/operators of the sewage sludge barges will need to
develop an O&M manual, place a placard on each vessel, and undertake all the activities related
to waste deposit records in order to be hi compliance with the proposed regulations.
3.5 Drilling Muds and Cuttings
3.5.1 Affected Parties
As shown in Exhibit 3-1, there are four industry segments affected by SPA in the category of
drilling muds and cuttings, which are: 1) offshore supply vessels; 2) hopper barges and deck
shale barges (considered as one segment); and 3) reception/treatment facilities. (Note that the
first segment, offshore supply boats, is also an industry segment in packaged garbage and is
discussed in Section 3.3.) A summary of the waste flow of drilling muds and cuttings is
presented in Exhibit 3-14. Although the drilling muds and cuttings sources (offshore, inland, and
shore-based oil and gas platforms) are not affected by the proposed SPA regulations, these
industry segments are discussed below to provide the entire waste flow process.
3.5.2 Factors Affecting Waste-Handling Procedures
The transport of drilling muds from platforms and rigs to shore and the transfer from the vessel
to shore are covered by SPA. However, the transfer of the drilling muds to the vessel is covered
by the NPDES. State regulations on discharge of drilling muds and cuttings differ. For
example, Louisiana prohibits the discharge of any drilling muds or cuttings into State waters
(Catrou, 1993), while there are no discharge regulations hi Alabama (Helmich, 1993).
3.5.3 Current Waste-Handling Procedures
The waste-handling procedures for drilling muds and cuttings differ somewhat depending upon
where they originate — from inland oil and gas platforms located in intracoastal waterways such
as lakes, bays, or rivers, from offshore oil and gas platforms, or from shore-based oil and gas
wells, or pits (see Exhibit 3-14). Although each of these uses a different transport mechanism
to the waste disposal site, the final reception facility for the waste is the same. The waste-
handling procedures at the oil and gas platforms, on barges and offshore supply boats, and at the
reception facilities described below are based on interviews with industry and trade association
representatives hi the Gulf of Mexico since most oil and gas platforms are located in that
geographic area of the country. The description of waste-handling practices is organized as
follows. First, a separate description of each of the waste generators is provided in order to
provide a context for the waste transfers which come later hi the disposal process. This is
followed by a discussion of the transfer station-hopper barge where drilling muds and cuttings
Chapter 3.0 3-27 Affected Industry Parties
-------
Current Level Of Compliance: Sewage Sludge
Exhibit 3-13
8
Shoreside Facilities:
Sewage Sludge
Sources
100%
100%
100%
100%
0%
86%
100%*
Sewage Sludge
Receiving
100%
100%
100%
100%
0%
0%
100%*
oo
Vessels:
Sewage Sludge
Barges
*Facilities have O&M manuals, but they may not be fully in compliance with the proposed regulations
Source: Tetra Tech, 1993
-------
Exhibit 3-14
Waste Flows Subject To SPA: Drilling Muds And Cuttings
a. Offshore
Platform
Supply Boat
to supply base
Hopper Barge
Receiving Facility
(Oil-field Treatment Facility)
b. Inland
^ «
^ /* NAyJ • \*^
Platform
c. Shore-Based
Deck Shale Barge
Hopper Barge
Receiving Facility
(Oil-field Treatment Facility)
Hopper Barge
Receiving Facility
Truck
vCy?-
Key:
Transfer covered by SPA
^ Hopper Barge
i—S = Transfer not covered by SPA
Receiving Facility
(Oil-field Treatment Facility)
Note: The hopper barges and the oil-field waste disposal facilities are the same for offshore and inland platforms and for onshore generated
drilling muds and cuttings. The supply boats carrying drilling muds also carry garbage from offshore platforms.
-------
from each of the three types of waste generators are consolidated. Finally, there is a discussion
of die waste treatment receiving facility where the drilling muds and cuttings are disposed.
As an indication of the amount of muds and cuttings brought to shore, MMS estimates the
following quantities: 1,595 barrels of mud and 386 barrels of cuttings per exploratory well
drilled and 444 barrels of mud and 108 barrels of cuttings per development well drilled (MMS,
1993). While these estimates pertain to the Federal waters, over 95 percent of the offshore oil
and gas activity is anticipated to continue to occur in Federal waters (Burroughs, 1993;
Kimbrough, 1993; Lam, 1993; MMS, 1993).
3.53.1 Inland Oil and Gas Platforms
Inland platforms typically off-load oil and gas exploration and production related drilling muds
and cuttings waste to barges which then transport the material to transfer stations. Drilling muds
and drill cuttings (also called shale) are handled together and are piped directly onto the transport
barge by piping through a device known as a shale shaker screen. This transfer process is
covered by NPDES Permits, and is not covered by SPA. However, the process is described here
in order to provide a clearer understanding of the waste-handling procedures. Inland oil and gas
platforms generally operate what is called a closed loop system whereby drilling fluids are reused
within the system to reduce the amount of waste generated by the oil platform (Comeaux, 1993).
The shale shaker screen separates the waste material from reusable material. All waste drill
cuttings and drilling muds then travel by pipe to the transport barge. This type of system
alleviates the need for hoses and/or valves (Boudreaux, 1993; Hanby, 1993).
The transport barge is situated directly underneath the open-ended pipe where the drilling muds
and cuttings simply free-fall into the open compartment. Barges are securely fastened to the
platform to avoid excess movement of the barge during the transfer. Workers from both the
platform and barge supervise the transfer activities which conform to written procedures usually
developed by the company that owns the platform. Communication is maintained by two-way
radio between the oil platform and the barge. Secured lighting is available on the oil platform
to allow for 24-hour operations. Transfer of drilling muds and cuttings is generally not halted
for any weather conditions, except for severe hurricane-type storms (Hanby, 1993; Boudreaux,
1993).
The type of barge used in the inland disposal of drill cuttings is known as a deck shale barge.
These barges are not permitted to operate on the open seas and, therefore, only operate in the
inland waterways. Generally, deck-shale barges have large, open compartments built above the
level of the deck. The compartments range hi size up to 80 feet long by 28 feet wide by 7 feet
high. The overall size of the barge is typically 120 feet long by 30 feet wide and 7 feet high.
The barge is typically divided into four compartments (Toups, 1993; Portier, 1993).
The overall size of the barge and open compartments means that spills are highly unlikely when
the barge is directly underneath the platform. Consequently, there are generally no other safety
precautions used in the transfer of the waste drilling muds and cuttings to deck shale barges. The
consistency of the drill cuttings, once on-board the shale barge, is such that, when barge is tilled
to its maximum height as prescribed by standard procedures (i.e., somewhat below the top edge
of the compartment), there is no danger, aside from the barge completely capsizing, of a spill to
the waterway. Deck shale barges are typically not equipped with coverings for the
Chapter 3.0 3-30 Affected Industry Parties
-------
compartments. Because of the lack of elements (waves, weather, rough seas) on the inland
waterways, the barges are free from routine dangers encountered on the open seas. As a result,
inland deck shale barges typically do not carry emergency response equipment on board. Items
such as booms, dip nets, or other equipment used in emergency response are not carried on-board
(Boudreaux, 1993; Hanby, 1993). U.S. Coast Guard regulations (CFR 33 Parts 150 to 156 and
CFR 46 Subchapter I and Subchapter T) require the operators of barges to have emergency
procedures in place for notification of proper authorities in the event of a spill. These U.S. Coast
Guard regulations require written documentation and record keeping of any spill occurrence as
well as notification of proper authorities (Ruckstuhl, 1993).
Drilling muds and cuttings from inland oil and gas platforms are transported by deck shale barge
to one of two locations: to a marine-based transfer station-hopper barge (described in Section
3.5.3.4); or directly to a treatment facility for non-hazardous waste. The decision as to where
the material is transported is based on the proximity of the inland platform to the reception
facility (Comeaux, 1993).
3.53.2 Offshore Oil and Gas Platforms
Offshore oil and gas platforms use supply boats for transport drilling muds and cuttings to either
a transfer station-hopper barge or to a supply base. (Note that they also carry packaged garbage
to supply bases.) Supply boats receive the material to be disposed of in one of two manners:
in previously filled, fully contained Department of Transportation (DOT) approved tanks; or by
hose into below-deck storage tanks. The most prevalent procedure is the use of DOT approved
tanks, which are commonly called "cuttings boxes." The transfer of cuttings boxes from the
platform to the offshore supply boat is not covered under SPA. Cuttings boxes range in size
from 5 to 25 barrel volumes (a barrel is equivalent to 42 U.S. gallons). Gross weight of the
cuttings boxes, therefore, is roughly between 20 and 30 thousand pounds (Brazzel, 1993; and
Ruckstuhl, 1993).
As on inland platforms, no effort is made to separate drilling muds from drill cuttings. However,
at certain points in the drilling process, the "waste" from the operation is dominated by one or
the other type of material, depending on factors such as depth of drilling and type of material
being drilled. Thus, the overall viscosity of the composition of waste in each cuttings box can
vary greatly among different wells (Ruckstuhl, 1993).
The cuttings boxes are generally made of reinforced, heavy aluminum material, are water-proof,
and are equipped with locked and sealed hatches on top. The boxes are designed so that, even
in the event that one of mem falls into the water, the boxes will remain secure. Cuttings boxes
are constructed with eyelets on the top of the outer frame for use with heavy-duty cranes. From
the oil and gas platform, a crane transfers the boxes to the top deck of the supply boat, where
they are bound and chained to preclude movement during transport. Oil and gas platforms are
equipped with fixed lighting to assist nighttime operations. In contrast to inland waterway
operations, offshore transfer operations are highly dependent upon weather conditions. No
operations occur in moderate to heavy weather conditions (Brazzel, 1993; Ruckstuhl, 1993).
Supply boats typically have operations manuals with proper transfer, transport, and spill
procedures detailed. Supply vessels are currently required to have emergency procedures well
documented and available to all crew members in case of a spill. Some supply vessels are
equipped with emergency spill response equipment and personnel are trained in the use of the
Chapter 3.0 3-31 Affected Industry Parties
-------
equipment. Other supply vessels' operation manuals prescribe the immediate notification of
professional spill response authorities in the event of a spill occurrence. Supply vessel personnel
are required to maintain records of any spill occurrence and submit all record keeping and
documentation of spill events to the Coast Guard. Equipment, such as a boom or containment
pans, are typically maintained on board the vessel to prevent any type of spill on-board the ship
from reaching the waterway (O'Sullivan, 1993; Autin, 1993).
The second method of receiving drilling muds or cuttings from an offshore oil platform (also not
covered by SPA) is through hoses operated by the platform to a below-deck storage tank on the
supply vessel. The below-deck storage tanks vary hi size and capacity from 1,700 to 30,000
gallons. Below-deck storage tanks are fully contained tanks below the main deck of the supply
vessels. Once material enters the tanks, there is virtually no chance of spillage. The operations
manual also details procedures for the transfer of drilling muds and cuttings into the below-deck
storage tank. In this transfer operation, hoses are used in the connection between the platform
and the vessel. Hoses may be supplied by either the platform or the vessel, and are regularly
inspected and tested. Hose fittings are connected to pipes both on the platform and aboard the
supply boat, and are clearly labelled, through the use of stenciling, as to the function of the pipe.
Valves at the end of the pipes can be securely closed, and are regularly inspected by platform and
supply boat personnel. At the end of transfer operations, hoses are blanked by pumping clean
water through the hose. During the transfer operations, spill containment pans are used by both
the platform and the vessel to contain any seepage from hose fittings (Autin, 1993).
Drill cuttings and drilling muds are then transported to one of two locations for off-loading:
either a transfer station-hopper barge (the same transfer station as used by the inland platforms)
or a supply base for oil company operations. Once deposited at either of these two locations, the
supply vessel's responsibility for the material ends. Eventually, all waste drilling muds and
cuttings deposited at oil company supply bases will end up hi specially designated non-hazardous
oilfield waste treatment facilities by land transport (O'Sullivan, 1993; Autin, 1993).
Transfer operations from supply boat to transfer station or supply base occur hi exactly the same
manner (only hi reverse) as from offshore oil and gas platform to supply vessel, and are both
covered by SPA. Cuttings boxes are transferred from supply vessel to transfer station or supply
base using a heavy duty crane. Below deck storage tanks are off-loaded using hoses.
3.5.33 Shore-based Oil and Gas Operations
Shore-based oil and gas operations (consisting of oil and gas wells, or pits) transport waste
drilling muds and cuttings to transfer stations by truck. This waste conforms to the same
standard of non-hazardous oilfield waste as offshore and inland oil and gas platforms. Drilling
muds and cuttings can arrive from shore-based operations in one of two ways: by open dump
truck; or fully enclosed vacuum trucks. In general, dump trucks off-load drilling muds and
cuttings into holding pits located on transfer station property, whereas vacuum trucks off-load
waste material directly into a transfer station-hopper barge (Ruckstuhl, 1993). The transfer from
dump truck to holding pit is not covered by SPA since no transfer operation takes place over
water. The transfer from the holding pit to the hopper barge, under the supervision of transfer
station personnel, is covered by the SPA as is the transfer from vacuum truck directly to the
awaiting hopper barge. In this situation, the transfer station is the waste source. The process
of transfer from both forms of shore-based transport is described below.
Chapter 3.0 3-32 Affected Industry Parties
-------
Transfer stations are equipped with holding pits in the working areas of their property for the
temporary receipt of shore-based operations waste. Dump trucks unload drilling muds and drill
cuttings into the holding pits. Material free-falls into the submerged holding pits. Holding pits
vary in size at each transfer station depending on the volume of wastes received. Dump trucks
are cleaned of all waste through the use of high-pressure water hoses. Due to the size of the
holding pits, a spill during the transfer operation is unlikely. Once inside the holding pit, the
composition of the drilling muds and cuttings is such that a spill incident due to a storm is
unlikely (Ruckstuhl, 1993). Because the holding pit is constructed in-ground, a good distance
from the waterway, surrounded by concrete, and not over-filled, the chance for material to escape
the holding pit and enter the waterway is virtually eliminated.
From shore-based oil and gas operations, non-hazardous oilfield waste conforming to the same
standards may be transported by vacuum truck. This material is generally in a more liquified
state which requires the use of an enclosed truck for transport. Vacuum trucks are equipped with
sealed valves and hatches to preclude any spillage after wastes are loaded into the container.
Vacuum trucks typically deliver material directly to the transfer station-hopper barges.
3.53.4 Transfer Station-Hopper Barge
Transfer stations receive drill cuttings and drilling muds from a variety of sources. Non-
hazardous oilfield waste from offshore oil and gas platforms, inland oil and gas platforms, or
shore-based oil and gas activities all consolidate waste disposal at transfer stations-hopper barges,
but by different means of transport. No effort is made to separate the material delivered from
any of the different sources (Ruckstuhl, 1993; Boudreaux, 1993). The process for reception of
wastes from each of the different sources is described below.
Inland oil and gas platforms transfer waste drilling muds and cuttings by deck shale barges. Deck
shale barges are fastened to a dock and connected to a larger receiving barge (that serves as a
transfer station) by a platform adjoining the two barges. The platform serves as a barge dock
point and as a type of containment device to preclude the spillage of any material into the
waterway (Boudreaux, 1993).
The larger barges, known as a hopper barges, are typically 195 feet long, by 35 feet wide, by
12 feet high. These reception barges can accommodate up to two transport deck shale barges at
a time. The hopper barges are not equipped with covering, but are securely fastened to the dock
to reduce die chance of a spill due to a shift in material. The nature of drilling muds or cuttings
is such that there is no risk of weather blowing the material over the edge of the barge
(Boudreaux, 1993; Brazzel, 1993).
The transfer of drill cuttings from die deck shale barge to die hopper barge occurs in one of two
ways: either by machinery operating a clam bucket or scoop bucket, or through hoses. When
a crane or clam shell bucket is used in the vessel-to-vessel transfer, a platform is placed in
between die barges. This platform serves as a type of containment device for any spilled
material. All waste material collected on die containment platform after die transfer operation
is dumped into die hopper barge (Brazzel, 1993; Ruckstuhl, 1993).
When hoses are used in me transfer operation, a submersible pump is used to pump spent drilling
fluids from die deck shale barge to die hopper barge. The pump is placed in die deck shale barge
and a hose is fed into die hopper barge. The hose is secured to die receiving barge (hopper
Chapter 3.0 3-33 Affected Industry Parties
-------
barge) by a "C" clamp. Material then free-falls from the open end of the hose into the hopper
barge. Hoses are regularly inspected and meet approved standards. The spill containment
platform is used as secondary containment for any spillage during the transfer (Brazzel, 1993;
Ruckstuhl, 1993).
Fixed lighting is available at the hopper barge to facilitate 24 hour transfer operations. Weather
conditions do not affect the ability to transfer drill cuttings from the deck shale barge to the
hopper barge except in cases of hurricane-type storms (Ruckstuhl, 1993; Brazzel, 1993).
Transfer stations receive offshore platform waste in the form of cuttings boxes through the use
of a heavy-duty crane. The crane holds the cuttings box over the hopper barge. While
suspended over the barge, the hatch is opened to allow the material to free-fall into the hopper
barge below. Cuttings boxes are rinsed clean with water from high-pressure water hoses. The
run-off flows directly into the hopper barge. In some cases, the high-pressure water hose is
necessary to break free some congealed material within the cuttings boxes. Clean cuttings boxes
are returned to the supply vessel (Brazzel, 1993; Autin, 1993; O'Sullivan, 1993).
Transfer stations also receive drilling muds and cuttings from platforms from below-deck storage
tanks. Hoses are used to make the transfer. The drilling muds and cuttings are pumped from
below-deck storage tanks directly into a hopper barge. Pipes on the supply vessel are clearly
labelled, and hoses are regularly inspected. Containment pans are used in the transfer operation
on board the supply vessel to preclude spillage into the waterway (Brazzel, 1993; Ruckstuhl,
1993). Any contained material at the end of the operation is fed directly into the hopper barge.
The hopper barge also has a platform spanning between the supply boat and the transfer station.
This platform also serves as a type of containment device for the hopper barge. Once again, any
wastes contained on the platform at the end of the transfer operation are fed directly into the
hopper barge.
As described above, transfer stations receive shore-based oil and gas operations waste in holding
pits from dump trucks and directly into the hopper barge from vacuum trucks. The process of
transfer from the holding pits to the hopper barges is done strictly with transfer station personnel
and equipment. From these holding pits, transfer station personnel move the drilling muds and
cuttings to the hopper barge when the holding pit reaches the specified fill level. A clam shell
bucket is used to transfer the material to the hopper barge (Ruckstuhl, 1993). The holding pit
is situated such that during this transfer process, no material passes over the water.
Transfer stations are equipped with emergency response equipment in the event of an oil spill.
Examples of the types of equipment that transfer stations may maintain for the initial response
to a spill incident to comply with U.S. Coast Guard regulations are a supply of boom, chemical
treatment agents, and/or a small boat. All transfer station personnel are trained in the use of mis
equipment. Regulations also require transfer stations to maintain documentation and record
keeping for all spill occurrences and that proper authorities be notified by telephone at the time
of the event and in writing within a certain time period of the event (Ruckstuhl, 1993;
O'Sullivan, 1993).
3.5.3.5 Reception/Treatment Facility
Hopper barges, once filled to the specified fill level (again, not to the top edge of the barge) are
towed by tug to a treatment facility where they are unloaded. Deck shale barges may
Chapter 3.0 3-34 Affected Industry Parties
-------
occasionally go directly from inland oil and gas platforms to treatment facilities depending on the
proximity of the two alternatives. Barges (the same process is used for either type of barge) are
typically unloaded by crane or clam shell bucket scooping out the spent drilling muds and
cuttings. During this transfer operation, the barge is securely fastened to the dock to prevent
shifting in the material. Containment pans are used to receive any overflow that might occur in
the transfer operation and to prevent any material from spilling into the waterway. Any overflow
waste contained on the spill platform at the end of the transfer operation is emptied directly into
the treatment facility's tank (Ruckstuhl, 1993).
Reception/treatment facilities may also remove drilling muds and cuttings from barges (either
hopper barges or deck shale barge) through the use of hoses. A submersible pump-type
operation, similar to that used in the barge-to-barge transfer operation, is used at the treatment
facility. The submersible pump is used to pump drilling fluids from barge to treatment facility
tank. Facility personnel use "C" clamps to fasten hoses to receiving tanks. Spill containment
pans are used to prevent any spillage to the waterway. Any overflow material contained on the
spill platform at the conclusion of the transfer operation is fed directly into the waiting tank.
Hoses are regularly inspected and tested (Ruckstuhl, 1993).
Drilling muds and drill cuttings are chemically treated to separate out oily waste from solid soil
or shale material. Eventually, all "waste" deposits are removed leaving a solid, inert soil-type
material conforming to "reusable" status. This inert material is stored at the treatment facilities
while awaiting alternative use (Brazzel, 1993).
3.5.4 Actions Needed to Achieve Compliance
Exhibit 3-15 summarizes the current level of compliance of the industry segments dealing with
drilling muds and cuttings affected by the proposed SPA regulation. As shown in the exhibit,
it is estimated that the owners/operators of the receiving facilities for drilling muds and cuttings
will need to place a placard at their facilities. Otherwise, they are currently in compliance with
the proposed regulation. The owners/operators of the barges and the offshore supply boats will
need to develop an O&M manual, place a placard on each vessel, and undertake all the activities
related to the waste deposit records in order to be in compliance with the proposed regulations.
In addition, about 25 percent of the owners/operators of the offshore supply vessels will need to
purchase some equipment, such as a harness for use with a crane, to prevent waste spills.
Chapter 3.0 3-35 Affected Industry Parties
-------
ExhibitS-lS
Current Level Of Compliance: Drilling Muds And Cuttings
Shoreside Facilities:
Oil Field
Treatment
Facilities
Vessels:
OSVs Handling
(Garbage and)
Drilling Muds
and Cuttings
75%
100%
**
0%
75%
100%
0%
0%
0%
Deck Shale &
Hopper Barges
100%
100%
**
0%
100%
100%
0%
0%
0%
0%
* Facilities have O&M manuals, but they may not be fully in compliance with the proposed regulation
** Leachate control does not apply; estimate pertains to labeling and sealing values
Source: Tetra Tech, 1993
-------
4.0 Costs of
Compliance
-------
4.0 COSTS OF COMPLIANCE
This chapter discusses die estimated costs of compliance with the proposed SPA regulation (40
CFR §237) and the methods by which the costs were estimated. Section 4. 1 provides the general
approach used in estimating the costs. Section 4.2 describes the development of unit costs,
including equipment costs and the general assumptions used in estimating time requirements for
performing the tasks necessary to comply with the rule. Section 4.3 presents the compliance
costs by affected industry segment and proposed rule provision and briefly discusses the major
cost elements. The detailed costing matrix, which shows the data elements for each compliance
activity and industry segment, is provided as Appendix A to this report.
4.1 Approach to Compliance Cost Estimation
The general equation used to estimate costs is:
11 % Current s „ Unit Cost _ Compliance
Parties ( Compliance' x of Compliance ~ Cost
This equation is applied to each element of the proposed rule for each affected industry segment.
Therefore, the nature of the activities and cost components of each activity (i.e., labor hours to
develop materials or procedures, equipment purchases, additional labor hours to follow new
procedures) have been estimated for each affected segment. The compliance cost elements for
each activity and segment can then be added to obtain total cost estimates for each provision of
the standard, for each industry segment, or for a single activity across any subset of segments.
Each activity required by the proposed standard which might result in a cost to the affected
parties was identified in Chapter 2. The industry segments affected by the proposed rule were
identified and profiled in Chapter 3, both in terms of the number and nature of the entities and
in terms of current practices and how these practices correspond to the proposed rule. The
estimates of the percentage of facilities and vessels covered by SPA which are currently hi
compliance with the proposed rule are also provided in Chapter 3. The final type of information
needed to develop the compliance costs for a typical facility or vessel currently not in compliance.
The following section describes the development of the unit cost estimates.
Exhibit 4-1 provides one sample page of the cost spreadsheets. This example shows the cost
development for the industry segment Receiving Facilities for Packaged Garbage from Offshore
Oil and Gas Platforms for compliance with subparagraph 237.4(a), the performance standard for
waste handling practices.
For this sample segment, any facility not associated with a large oil and gas, exploration, or
supply company is estimated to be part of a small company. The number of small and large
companies and the number of facilities belonging to each were derived from the U.S. Army
Corps of Engineers' Port Series reports. In other segments, the large and small company
definitions were based on the number of facilities owned by a company (drilling mud treatment
facilities) or me number of vessels owned and/or operated by the company. For barges, it was
estimated mat ten or more barges constituted a large company. A company operating offshore
U.S. EPA Headquarters Library
Mail code 3201
1200 Pennsylvania Avenue NW
ii iyui i
Chapter 4.0 4-1 Costs of Compliance
-------
Exhibit 4-1
Sample of Cost Estimation Model
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
I SHORESIDE FACILITIES 1
Segment:
RECEIVING FACILITIES FOR PACKAGED
GARBAGE FROM OIL & GAS PLATFORMS
Regulatory Requirement:
Action Required:
Frequency of Cost:
Small Company Definition: Independent
Operation (Not Oil Company)
Total Companies: 79
Small Companies: 51
Total Sites: 144
Small Co. Sites: 61
Labor Rates
Management: $30.54
Supervisor: $21.60
Skilled Labor: $25.07
Unskilled Labor: $18.22
Average transactions per facility per year
Small company: 210
Large company: 210
237.4(a) Performance Standard
Waste Containment Structures & Equipment
Purchase. Deployment & Maintenance
One-time Cost
Cost Basis: Site
Annual Cost
Cost Basis: Loadings
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs— Large:
Unit Cost:
Small Co.:
Large Co.:
$3,000
$22
1
1
$3.022
$3.022
Maint. Cost $0
Lab or Costs
Hourly Rate: $18
Hrs-Small: 53
Hrs-Large: 53
Unit Cost per Year:
Small Co.: $957
Large Co.: $957
Percent Affected:
Small Cos.: 75%
Large Cos.: 10%
Total Cost
Small Cos.: $138.238
Large Cos.: $25,079
All Affected Cos.:
Percent Affected:
Small Cos.: 75%
Large Cos.: 10%
Total Cost
Small Cos.: $43,768
Large Cos.: $7.940
All Affected Cos.:
$163.3181
$51.7081
Chapter 4.0
4-2
Costs of Compliance
-------
supply vessels was defined as large if it owned and/or operated more than three vessels, which
is approximately equivalent to the standard definition of a small company having fewer man 20
employees.
Some of the segments included in this analysis include government-operated facilities or vessels.
In this situation, these are State and local government entities. These operations are identified
in a separate category for government entities. Where government entities are involved, the total
number of companies always excludes the government operations, and an extra line for number
of government entities is included. The total number of sites or vessels, however, includes the
government-operated sites or vessels.
This approach allowed the costs to small and large businesses to be identified separately and for
the different baseline compliance rates observed in small and large entities to be quantified.
Four categories of labor rates were estimated for each segment. These rates are fully loaded,
including all benefits in addition to straight wage or salary. Where clerical or secretarial rates
were needed, the unskilled labor rate was used as an approximation. The sources of these
estimates will be explained for each segment.
The average transactions per facility per year represent the number of loadings or unloadings of
municipal or commercial waste. For vessels, this number represents voyages, or round trips
from the port to the destinations) and returning to the port. These estimates are average
transactions per facility or vessel, but the actual range among single facilities may vary widely.
Each of the activities required by the proposed standard has been categorized as a one-time or
annual recurring cost. The costs incurred during the first year the standard is in force would
include the one-time costs and the annual costs. Ensuing years would include only the annual
costs. The initial costs have not been annualized (or amortized) because the majority of these
costs are for labor hours and the equipment (capital) costs are generally small enough to be
expensed.
The cost basis depends on the nature of the activity. Signs which must be posted at each facility
or on each vessel are calculated on a per-site or a per-vessel basis. Requirements, such as
recording waste deposits or cleaning up waste deposits, result in costs based on the number of
transactions or loadings. Other costs, such as the development of operation and maintenance
(O&M) manuals, are calculated on a per-company basis because a company can develop a single
manual and distribute it to all of its sites or vessels.
The unit cost shown in the cost spreadsheet is the equipment cost plus the hourly rate times the
number of hours. If the cost basis is number of sites, then the unit cost shown is cost per site.
Similarly, if the cost basis is number of companies, then the unit cost will be cost per company,
and so on. The percent affected is derived from the percent currently in compliance, as provided
in Chapter 3. The total cost per activity is then calculated using the equation at the beginning
of this section: unit cost times percent affected times the number of sites or companies, depending
on the cost basis. The equipment costs, hourly labor rate, and hours of labor required are
explained for each segment and provision in the discussion below.
Chapter 4.0 4-3 Costs of Compliance
-------
4.2 Unit Cost Development
4.2.1 Estimates and Assumptions Applicable to All Affected Segments
The following assumptions and estimates apply to every situation where the relevant provision
of the standard will require action on the part of an affected party. These elements are estimated
regardless of the segment in which the situation arises.
• Any purchase of materials or equipment requires 0.5 hours of supervisor's time to
identify and obtain the equipment in addition to the direct cost of the equipment or
materials. This estimate was based on experience with similar regulations.
• Every site covered by the proposed standard will be required to post a placard for
notification of waste deposits with telephone numbers; no facilities currently have the
necessary placards in place. This effort is estimated to require 2 hours of supervisor's
tune to obtain and post the placard. One placard is required for each facility. The
cost of the placard is estimated at $17. This was based on a quote from a commercial
vendor for typesetting, printing, and laminating the sign shown hi the Technical
Guidance Document.
• Material costs for O&M manuals have been estimated at $5 per vessel or per facility,
which includes a notebook and 30 pages of reproduction.
• Each company or government entity will need to develop its own waste deposit record
form. It is estimated that this will require 1 hour of management time. Each time
a waste deposit occurs, a record will need to be filled out. It is estimated that this
will require 15 minutes for each deposit. The frequency of occurrences has been
estimated for each segment. The cost of maintaining the waste deposit records would
include the file storage space and file materials, as well as the time required for filing
the documents. Because the number of deposits is small for those sectors not already
keeping records, the cost for maintaining the files has generally been estimated to be
negligible.
The following sections describe the more detailed estimates and assumptions involved hi the
calculation of the costs of compliance. These explanations are organized by industry segment and
provision of the standard.
433, Shoreside Facilities
The proposed regulation contains five major provisions hi §237.4 regarding shoreside facilities.
These provisions, and the cost components of them, are:
237.4(a) Performance Standard. This consists of having: 1) the equipment necessary
to prevent or minimize waste deposits; and 2) the time required to follow
proper procedures and use the equipment.
Chapter 4.0 4-4 Costs of Compliance
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237.4(b) Fixed Lighting. Facilities need to have sufficient lighting for waste handling.
237.4(c) Waste Deposit Cleanup and Notification. Facilities need to: 1) have
necessary cleanup equipment on hand; 2) clean up waste deposits when they
occur; and 3) post die telephone number of the oversight authority to whom
spills must be reported on a placard.
237.4(d) Waste Deposit Records. Facilities must have records of their waste deposits,
which requires: 1) developing a form for recording waste deposits; 2) filling
out a form for each deposit; and 3) maintaining the records of waste deposits.
237.4(e) O&M Manuals. Each facility must have an O&M manual which describes
waste handling procedures and how the procedures address this regulation.
Each of the shoreside facilities covered by SPA already has fixed lighting in place or operates
only during daylight hours. Therefore, no costs have been estimated for subparagraph 237.4(b),
Fixed Lighting.
Other requirements with which a segment is currently 100 percent La compliance, as identified
in Chapter 3, will generally not be discussed in the following sections because there are no
associated costs.
Uncontainerized Municipal Wastes: Marine Transfer Stations
The labor rates for the marine transfer stations (MTS) were obtained directly from the New York
City Department of Sanitation (NYC DOS).1 An overhead rate of 28.2 percent7 was applied
to the direct wages and salaries to arrive at the following labor rates:
• Management: $34:43
• Supervisor: $27.90
• Skilled Labor: $37.60
• Unskilled Labor: $18.49
237.4(c). Each of the eight MTSs will be required to post the telephone numbers for reporting
waste deposits at the standard cost of $17, described in Section 4.2.1.
237.4(d). It was estimated mat only one waste deposit record form will be developed for all
NYC DOS operations and that this will be performed centrally and distributed. While no cost
has been estimated for the distribution or materials (because this can be done along with regular
communications), it is estimated that an additional hour will be needed to develop accompanying
instructions.
Wage rates are for the NYC DOS personnel and were provided by Martell (1993). The
management rate used is the District Superintendent, skilled labor is Crane Operator, and
unskilled labor is Sanitation Worker.
The overhead rate of 28.2 percent is the average overhead rate for state and local government
employees (Shelly, 1993).
Chapter 4.0 4-5 Costs of Compliance
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Based on figures provided by the NYC DOS, an average of 885 barges are loaded at each facility
per year. On average, each MTS loads 2.5 barges per day. It was estimated, however, that
waste deposit records would be filled out either each time a barge is fully loaded or at the end
of a shift, likely to be three times each day for 15 minutes, or total of 234 hours per year per
MTS.
237.4(e). The NYC DOS already has O&M manuals for the MTSs, as well as die other
segments of the department. While these manuals are expected to be in full compliance with the
proposed regulation, they will need to be reviewed to ensure compliance. It was estimated that
one review, which will cover the manual for all eight MTSs, will be performed by the legal
office and will require 4 hours. While the legal function will be involved in this review, it will
not require the participation of an attorney.
Uncontainerized Municipal Wastes: Receiving Facility (Fresh Kills)
Fresh Kills receives approximately 4,680 barges of uncontainerized garbage each year. Labor
rates are the same as those used for the NYC DOS marine transfer stations, described above.
237.4(d). The waste deposit record used at Fresh Kills can be the same as mat developed for the
MTSs. The development cost for Fresh Kills is estimated at one-half hour for the facility
manager to ensure that the form is obtained. It is estimated that each barge unloading will
require rilling out a waste deposit form, so the annual time requirement is estimated to be 15
minutes each for 4,680 unloadings, or 1,170 hours.
237.4(e). Similar to the MTSs, it is estimated that the existing O&M manual will need to be
reviewed to ensure compliance with the proposed standard. This is expected to require 4 hours
of tune by the legal office, which is estimated to be equivalent to the management labor rate.
Packaged Garbage: Receiving Facilities for Garbage from Oil & Gas Platforms
The labor rates for all of the oil and gas industry-related segments are based on rates developed
in a study of employment and earnings in the offshore oil and gas industry (Centaur Associates,
1986). The resulting labor rates, adjusted for inflation and overhead,3 are:
• Management: $30.54
• Supervisor: $21.60
• Skilled Labor: $25.07
• Unskilled Labor: $18.22
It was estimated mat offshore supply vessels (OSVs) make an average of two voyages per week
and that approximately half of these trips involve picking up garbage from the platforms.
Furthermore, it is estimated that all facilities service the same number of voyages. The estimated
3 The inflation adjustment is based on hourly rates for the mining (oil and gas) industry,
averages for 1985 and 1992, from the Survey of Current Business. Hourly and Weekly
Earnings, not seasonally adjusted, U.S. Department of Commerce, Bureau of Economic
Analysis, page S-12. The overhead adjustment of 24.3 percent is the average overhead rate
for private sector employees (Shelly, 1993).
Chapter 4.0 4-6 Costs of Compliance
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number of facilities is based on the offshore oil and gas supply bases listed in the Army Corps
of Engineers' Port Series reports (U.S. Army Corps of Engineers, 1981-1993). Because the Port
Series reports also list the company names of the owners and operators of the facilities, a large
company facility was defined as any facility owned or operated by a recognized major oil and/or
gas company, a major drilling and/or exploration company, or a major offshore supply company.
237.4(a). Each facility which does not currently have adequate means for transferring garbage
from the OSVs to the dock was estimated to require the purchase of a wire sling for use with a
crane, which would require an estimated 1 hour of the facility supervisor's time. The purchase
price of the wire sling was estimated at $3,000.* It was estimated that using the wire sling for
lifting loads (or any similar and similarly effective method) would require an additional IS
minutes each time the vessel was unloaded, resulting in an additional 53 hours per year of labor.
237.4(c). Each facility will need to have a boat hook and a dip net to retrieve waste deposited
in the water during garbage transfer from the vessel to the dock. The estimated cost of this
equipment is $50* and one-half hour of supervisor's time to obtain the equipment and, because
this type of equipment wears out quickly, this is considered an annual cost. Further, this
equipment is generally designed for recreational use, not demanding commercial conditions.
However, there is no evidence, given current practices, that significant amounts of packaged
garbage is deposited into coastal waters, therefore, the cost for cleanup was estimated at zero.
Maintenance of the equipment is estimated to be negligible. Every facility must, however, post
the telephone number for reporting deposits, which is assessed at the standard equipment and
labor costs.
237.4(d). Each facility is expected to develop a form for recording waste deposits. This is
estimated to require 1 hour of the manager's time. However, since no waste deposits are
anticipated, no time has been assigned for filling out the forms. Consequently, no record
maintenance charges have been estimated.
237.4(e). Development of an O&M manual for waste handling practices at a large company
facility, addressing the requirements of the proposed SPA regulation, are estimated to require 16
hours of manager's time, 8 hours of supervisor's time, and 4 hours of clerical time. The
weighted average cost of the required labor time is estimated as equivalent to 28 hours of
supervisor's time. OSV supply bases which need to develop O&M manuals for waste handling
are estimated to require the standard equivalent of 28 hours of supervisor's time. For small
company facilities, the estimated time required was doubled because they would have less ability
to draw on information and other resources for guidance in developing me manuals. Few
facilities already have such manuals. The percentage of facilities which need to develop these
manuals is estimated at 90 percent for small company facilities and 70 percent for large company
facilities.
4 This is the lower end of a quoted range for crane wire slings (Erwin, 1993). The lower quote
was selected since the more costly wire slings are for much heavier applications.
5 Based on a quote from a marine supply company.
Chapter 4.0 4-7 Costs of Compliance
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Packaged Garbage: Receiving Facilities for Garbage from Vessels Anchored Offshore
There are three small companies which operate transfer services for packaged garbage from
vessels anchored offshore, and thus would be responsible for ensuring compliance with the
proposed rule. The labor rates for these companies, all located in Alaska, are based on Bureau
of Labor Statistics data specific to refuse systems (SIC 4953) in the State of Alaska (BLS,
1993).6 The resulting rates are:
• Management: $48.05
• Supervisor: $38.45
• Skilled Labor: $34.61
• Unskilled Labor: $25.63
The total number of vessels serviced by these companies, described in Chapter 3, was divided
by three to obtain the average number of transfers per facility.
237.4(c). Because there are no known instances of significant garbage deposits related to this
segment, no costs are predicted for the purchase of equipment or cleanup of deposits. Each site,
however, is required to post the telephone number for reporting deposits, which has been
estimated to cost $17 for the placard and 2 hours of the supervisor's time.
237.4(d). Each of the facilities will need to develop a form for recording waste deposits, which
will require an estimated 1 hour of manager's time. However, since no deposits are expected,
the costs for filling out and maintaining the records are estimated to be zero.
237.4(e). Each facility will need to develop an O&M manual covering waste handling
operations. This activity is estimated to require approximately 16 hours of the manager's time
for each facility, because the operations are relatively straightforward.
Packaged Garbage: Sources of Garbage from Islands
There are thirteen sites on Georges Island and Fire Island where garbage is picked up. The
operating companies were all estimated to be small, and the split between government and private
landings on Pure Island was estimated to be equal based on available information.
The labor rates used for island facilities are averages for refuse systems operations in
Massachusetts and New York. The method used to estimate these rates are the same as those
used for the receiving facilities for packaged garbage from vessels anchored offshore. These
rates are:
The basic labor rate provided in this document was then weighted to obtain the estimated rates
for skilled labor, supervisors, and management by factors of 1.35, 1.50, and 1.875,
respectively. These weighting factors are based on average differences between wage rates
for those segments where all four levels were known (e.g., NYC DOS and the oil and gas
industry). The resulting rates were then multiplied by 1.243 to take into account payroll
benefits (Shelly, 1993).
Chapter 4.0 4-8 Costs of Compliance
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• Management: $45.16
• Supervisor: $36.14
• Skilled Labor: $32.52
• Unskilled Labor: $24.09
237.4(c). In die event that a waste deposit does occur, these facilities need to have boat hooks
and dip nets on hand. While most already do, it is estimated that three of the thirteen sites will
need to make these purchases. The unit cost for this equipment is $50 per facility per year.
However, since minimal deposits are anticipated, the cost for cleanups is estimated at zero. The
cost for maintenance of the equipment is estimated to be negligible. Each facility will, however,
need to post the telephone numbers for notification of waste deposits at the standard cost of $17
plus 2 hours of supervisor's tune.
237.4(d). Each facility will need to develop a form for recording waste deposits, which will
require an estimated 1 hour of manager's time. However, since no deposits are expected, zero
cost was estimated for recording deposits and maintaining waste deposit records.
237.4(e). Each facility will be required to develop an O&M manual for handling waste. Because
these manuals should be relatively simple, mis is estimated to require 16 hours of the manager's
time at each facility.
Package Garbage: Receiving Facilities for Garbage from Islands
The two facilities that receive packaged garbage from islands are in Boston and on Long Island.
The Boston facility is government owned and operated, while the Long Island facility is a small
private company. The Boston facility, which receives waste from Georges Island, receives
approximately 364 loads of waste per year, based on two trips per day for six months. The Long
Island facility, consisting of two small companies, receives an estimated 560 loads per year from
Fire Island. The labor rates estimated for this segment are the same as those used for the islands
segment.
237.4(c). Because no significant deposits have occurred or are expected, and because the two
facilities already have the equipment, no costs will be incurred for purchasing equipment
necessary to effect cleanups or to maintain such equipment or to clean up deposits. However,
both faculties will be required to post the telephone numbers for reporting waste deposits.
237.4(d). Each facility will need to develop a form for recording waste deposits. This is
estimated to require 1 hour of manager's time at each facility. Since no waste deposits are
expected to occur, no costs are expected to be incurred for filling out the waste deposit records
or maintaining the waste deposit records on file.
237.4(e). Each facility will need to develop an O&M manual for handling wastes. This is
estimated to require 16 hours of the manager's time at each facility.
Sewage Sludge: Sources (Wastewater Treatment Facilities)
All of the wastewater treatment plants which ship sludge by barge are government facilities.
Based on an estimate of two loads per barge per day (as described in the discussion of sewage
sludge transport vessels in Section 4.2.3), each facility loads an average of 1,356 barges per year.
Chapter 4.0 4-9 Costs of Compliance
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The labor rates used for these facilities were obtained from the NYC DOS and are the same as
those for the MTSs.7
237.4(c). These facilities have equipment on hand to allow cleanup of spills to the
technologically feasible limit. No additional equipment or efforts are required to clean up any
spills which might occur. However, each facility will be required to post on placards the
telephone numbers for reporting spills.
237.4(d). All but one of the facilities already has in use a form for recording waste deposits.
The remaining facility will need to develop a form for recording waste deposits. This is
estimated to require the standard level of effort as discussed in the general assumptions above.
That same facility will also need to record waste deposits and maintain the records thereof. Spills
are estimated to occur in 1 percent of loadings and the recording of the deposit is estimated to
require IS minutes for each event.
237.4(e). Each facility has an O&M manual addressing waste handling procedures. However,
each facility will need to review its manual to ensure compliance with the proposed standard.
The review is estimated to require 4 hours of the manager's time at each facility.
Sewage Sludge: Receiving Facilities (Sludge Dewatering Plants)
There are a total of six sewage sludge receiving facilities, two of which are government operated.
The remaining four sites are operated by four separate companies, each of which is estimated to
be large, based on the volume of waste handled from the sewage sludge sources. Each site is
estimated to receive an average of 1,582 loads per year. Labor rates for these facilities were
estimated to be the same as those for the sewage sludge sources.
237.4(c). These facilities have equipment on hand to allow cleanup of spills to the
technologically feasible limit. No additional equipment or efforts are required to clean up any
spills which might occur. However, each facility will be required to post on placards the
telephone numbers for reporting spills.
237.4(d). Each of these facilities will need to develop a form for recording waste deposits. This
is estimated to require 1 hour of manager's time at each facility. Each facility will also need to
record waste deposits. This effort is estimated to be required for 1 percent of shipments and
require IS minutes for each waste deposit. The cost for maintaining the records is estimated to
be 1 hour of supervisor's time per year.
237.4(e). Each facility has an O&M manual addressing waste handling procedures. However,
each facility will need to review its manual to ensure compliance with the proposed standard.
The review is estimated to require 4 hours of the manager's time at each facility.
7 Although not all of these facilities are located in New York, it was estimated that labor rates
are similar.
Chapter 4.0 ' 4-10 Costs of Compliance
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Drilling Muds: Receiving Facilities (Oil Field Treatment Facilities)
Based on list of approved drilling mud treatment facilities received from the States of Louisiana
and Texas, there are a total of 47 facilities in this segment, owned by 26 companies. A small
company was defined as one which operates only one or two facilities, so 20 of the 26 companies
are small and they operate 22 of the 47 facilities. The estimated labor rates for this segment were
estimated to be the same as those for the other industry segments related to offshore oil and gas
operations. The average number of loads received by each facility are based on the number of
hopper barge loads, as described below.
237.4(c). These facilities have equipment on hand to allow cleanup of spills to the
technologically feasible limit. No additional equipment or efforts are required to clean up any
spills which might occur. However, each facility will be required to post on placards the
telephone numbers for reporting spills.
237.4(d). Each of these facilities already has in place and in use a form for recording waste
deposits. Therefore, no additional efforts or costs will be required.
237.4(e). Each facility has an O&M manual addressing waste handling procedures in order to
comply with the requirements for oil and other hazardous materials. However, each facility will
need to review its manual to ensure compliance with the proposed standard. Because these
facilities tend to have good preexisting waste handling procedures, the review is estimated to
require only 2 hours of the manager's time at each facility.
4.23 Waste Transport Vessels
The proposed regulation contains four major provisions hi §237.5 regarding waste transport
vessels. These provisions, and the cost components of them, are:
237.5(a) Performance Standard. This consists of having: 1) the equipment necessary
to prevent or minimize waste deposits; 2) leachate containment and collection
system, where applicable; 3) the time required to follow proper procedures
and use the equipment for leachate containment; and 4) labels and seals for
waste ports and valves.
237.5(b) O&M Manuals. Each vessel must have an O&M manual which describes
waste handling procedures and the how the procedures address this regulation.
237.5(c) Waste Deposit Cleanup and Notification. Vessels need to: 1) have necessary
cleanup equipment on hand; 2) clean up waste deposits when they occur; and
3) post the telephone number of the oversight authority to whom spills must
be reported on a placard on the vessel.
237.5(d) Waste Deposit Records. Vessels must record their waste deposits, which
requires: 1) developing a form for recording waste deposits; 2) filling out a
form for each deposit; and 3) maintaining the records of waste deposits.
Chapter 4.0 4-11 Costs of Compliance
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Requirements for tracking systems will not come into play except as the result of repeated
noncompliance with the other provisions of the proposed standard. Therefore, no costs have been
estimated for the tracking systems provision of SPA.
Other requirements with which a segment is currently estimated to be 100 percent in compliance,
as identified in Chapter 3, will generally not be discussed in this section because mere are no
anticipated costs of compliance.
Uncontainerized Municipal Wastes: Barges
All of the barges used for transporting uncontainerized municipal wastes in New York City are
owned by the NYC DEP, therefore, no size distinction for companies is necessary. The base
labor rates for this segment were obtained directly from the NYC DEP,8 and were increased by
28.2 percent to estimate the fully loaded labor rates. The resulting labor rates are:
• Management: $36.61
• Supervisor: $29.90
• Skilled Labor: $27.90
• Unskilled Labor: $21.91
The approximate total number of barge loads transported annually was also obtained from the
NYC DOS, as explained in Chapter 3.
237.5(b). The NYC DOS will need to review its operations manual for garbage barges to ensure
compliance with the proposed rule, which is estimated to require 4 hours of time by the legal
office, which is comparable to the manager's labor rate. In addition, a cost of $5 per vessel has
been estimated for reproduction and distribution of the manual to all vessels.
237.5(c). All waste deposits are cleaned up currently to the extent feasible, and the equipment
necessary for cleanups is on hand. However, each vessel will need to post a placard with
notification procedures and the telephone numbers of the oversight authority to notify in the case
of a waste deposit. This is estimated to cost $17 plus 2 hours of supervisor's tune for each
vessel. These costs might be reduced, however, if a bulk purchase of placards was made
centrally and distributed.
237.5(4). The waste deposit record form to be developed by the NYC DOS (shown hi the costs
for the MTSs) will also be adequate for vessels, therefore, no additional cost for developing a
form has been estimated. However, the proposed rule will require the form to be filled out for
each voyage, so an additional 15 minutes per load has been estimated for recording deposits by
the supervisor. The maintenance of the records is considered to require insignificant marginal
efforts.
Wage rates are for the Marine Division personnel and were provided by the NYC Department
of Environmental Protection (Joseph, 1993). The NYC DEP positions used for the four levels
are Manager Level n, Captain of Sludge Vessel, Chief Marine Engineer, and Mariner.
Chapter 4.0 4-12 Costs of Compliance
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Drilling Muds and Packaged Garbage: Supply Boats (OSVs) Transporting Muds and
Garbage From Offshore Oil and Gas Platforms
The numbers of OSV companies and vessels were determined from records maintained in the
U.S. Coast Guard Marine Safety Information System (USCG, 1993). Because the average crew
size of an OSV is nine, a company with only one or two vessels was considered to be small,
approximating the standard definition of fewer than 20 employees for a small company. It was
estimated that the average vessel makes two voyages per week, or about 100 voyages per year.
Based on the estimate that 75 percent of vessels were currently in compliance, it was estimated
that the remaining 25 percent of vessels are among those owned by small companies, constituting
approximately 30 percent of die small company vessels.
The labor rates used for this segment are based on a study of the offshore oil and gas industry
(Centaur Associates, 1986). After adjusting for inflation, as explained above for the receiving
facilities for packaged garbage from oil and gas platforms, die resulting labor rate estimates are:
• Management: $37.82
• Supervisor: $37.22
• Skilled Labor: $28.76
• Unskilled Labor: $16.41
237.5(a). The vessels not currently in compliance with the performance standard are expected
to purchase tarps to cover loads of garbage during transport. The cost of a tarp is estimated at
$45.9 Because of the relatively short life of tarps, this was treated as an annual cost. In
addition, it was estimated that using the tarps would require one-half hour of additional time for
each voyage, or 50 hours per year per vessel. Leachate containment and collection provisions
are not applicable to this segment. This segment is estimated to be 100 percent in compliance
with the provision on waste ports and valves associated with the transport of drilling muds and
cuttings.
237.5(b). Each company operating OSVs will need to develop an O&M manual for handling
wastes. It is estimated that development of the manual will require 2 days of management time,
1 day of supervisory time, and 4 hours of clerical time. Using a weighted cost, this is equivalent
to the cost of 28 hours of supervisory tune. In addition, a cost of $5 for materials (notebook and
photocopying) was included.
237.5(c). Those vessels not currently hi compliance are expected to purchase a boat hook and
a dip net for recovering waste deposits at a cost of $50 plus one-half hour of supervisor's time
to acquire the equipment. It is estimated that accidental waste releases occur hi 1 percent of
voyages (or once per year) and that deposits can be cleaned up by skilled labor personnel La one-
half hour. In addition, each vessel will need to obtain and post a placard with telephone numbers
for reporting waste deposits, at the standard cost.
237.5(d). Each company operating OSVs will need to develop a waste deposit record form. It
was estimated that this will require 1 hour of management time per company. Filling out the
U.S. EPA Headquarters Library
Mail code 3201
9 Based on a quote from a marine supply company. 12°0 Pennsylvania Avenue NW
* **' * ' Washington DC 20460
Chapter 4.0 4-13 Costs of Compliance
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form is estimated to require. 15 minutes for each waste deposit, which was applied only to the
estimated 30 percent of small company vessels not currently in compliance.
Packaged Garbage: Vessels Transporting Garbage from Inland Platforms and Rigs
The vessels which service inland oil and gas platforms were identified from the U.S. Coast Guard
database of SPA-permitted vessels (Tetra Tech, 1993). Small companies in mis segment were
defined as those which operate fewer man ten vessels. It was estimated that the average vessel
performing this service makes three voyages per week, or approximately 150 voyages per year.
The labor rates used for this segment are the same as those described above for OSVs.
237.5(b). Each company operating vessels in this segment will need to develop an O&M manual
and provide copies to each vessel. The unit costs for this provision were estimated to be the
same as those for the OSVs described above.
237.5(c). Those vessels which are not adequately equipped will need to purchase boat hooks and
dip nets, estimated at $50 per vessel. One-half hour of supervisor's time is estimated to obtain
the equipment for each vessel. It is estimated that one-half hour of skilled labor will be required
for the estimated one cleanup per vessel per year. This cost was applied only to the 25 percent
of small company vessels estimated to currently have inadequate equipment. In addition, each
vessel will need to obtain and post a placard with telephone numbers for reporting waste deposits,
at the standard cost.
237.5(d). Each company will need to develop a form for recording waste deposits. This is
estimated to require 1 hour of managerial time at each company. Filling out the forms when
waste deposits occur is estimated to require 15 minutes of supervisor's tune for each deposit.
Deposits are estimated to occur only once per year and these costs were assessed only for those
vessels not currently in compliance.
Packaged Garbage: Vessels Transporting Garbage from Vessels Anchored Offshore
Four vessels transport waste from vessels, primarily cruise ships, anchored offshore hi Alaskan
ports. These vessels are each owned and operated by small companies. Based on the number
of cruise ships serviced during the season, the average number of loads handled by each of these
four vessels is 142. The estimated labor rates for this segment are based on the average annual
wage in Alaska for workers hi SIC 4491, Water Transportation Services (NEC) (BLS, 1993).
The wage rates for 1991 were adjusted to include benefits and inflation, and the rates for skilled
labor, supervisory, and management time were estimated by scaling up the basic wage rate. The
resulting labor rates are:
• Management: $30.90
• Supervisor: $24.72
• Skilled Labor: $22.25
• Unskilled Labor: $16.48
237.5(b). Each company will need to develop an O&M manual covering handling of packaged
garbage from vessels anchored offshore. As described above for OSVs, this is estimated to
require the equivalent of 28 hours of supervisor's time.
Chapter 4.0 4-14 Costs of Compliance
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237.5(c). Because no significant waste deposits are known to occur in this segment, no costs are
predicted for cleanup equipment or activities. However, each vessel will need to post a placard
with the phone numbers and oversight authorities for reporting waste deposits. This is estimated
at the standard cost.
237.5(d). Each company will need to develop a waste deposit record form, estimated to require
1 hour of manager's time at each company. However, because no waste deposits are anticipated,
no costs were estimated for filling out the waste deposit records or maintaining them in files.
Packaged Garbage: Vessels Transporting Garbage from Islands
The landing craft servicing Georges Island in Boston Harbor is government owned and operated.
Two small companies operate the barges serving Fire Island in New York. The vessel in Boston
Harbor makes two trips per day for 6 months of the year, or 364 voyages per year. The other
vessels are estimated to make an average of 140 voyages per year.
Labor rates for this segment are an average of those for Massachusetts and New York in SIC
4491, as described above for Alaska. The resulting labor rates are:
• Management: $35.23
• Supervisor: $28.19
• Skilled Labor: $25.37
• Unskilled Labor: $18.79
237.5(b). Each company and government entity will need to develop an O&M manual for
handling these wastes. As described for OSVs, this is estimated to require the equivalent of 28
hours of supervisory time.
237.5(c). These vessels are sufficiently equipped to clean up waste deposits. However, each
vessel will require a placard, at the standard cost, with the telephone number of the oversight
authority to which waste deposits must be reported.
237.5(d). Each company will need to develop a waste deposit record form, requiring 1 hour of
management time. However, because no significant waste deposits are anticipated, no costs are
predicted for filling out the forms or maintaining the records.
Sewage Sludge: Barges
Three large companies and one government entity operate these vessels. The labor rates used
for this segment are the same as those reported by the NYC DOS for its garbage barge
operations. It was estimated that each barge makes an average of two voyages per day.
237.5(5). Each operating entity will need to develop O&M manuals for sludge transport. As
described for OSVs, above, this is estimated to require the equivalent of 28 hours of supervisor's
time for each company or government entity.
237.5(c). Cleanup of waste deposits is currently carried out to the extent technologically feasible,
therefore, no additional equipment cost or cleanup time is anticipated. However, each vessel will
need to post a placard regarding the reporting of waste deposits. This cost has been estimated
Chapter 4.0 4-15 Costs of Compliance
-------
at the standard rate of $17 for the placard plus 2 hours of supervisor's time for obtaining and
posting it, for each vessel.
237.5(d). Each entity will need to develop a form for recording waste deposits, estimated at 1
hour of managerial time for each company. Assuming that 1 percent of voyages will involve a
waste deposit, seven forms will need to be filled out each year for each vessel. At IS minutes
per deposit, this results in 1.7S hours of supervisory time per vessel per year. Maintaining the
waste deposit records is estimated to involve negligible costs.
Drilling Muds: Deck Shale Barges and Hopper Barges
Hie vessels handling drilling muds and cuttings and die companies which own and operate them
were identified from the U.S. Coast Guard database of SPA-permitted vessels. Small companies
were defined as those operating fewer than ten barges. The labor rates are estimated to be the
same as those for the other oil and gas-related vessel industry segments. Each vessel is estimated
to make two voyages per week or approximately 100 voyages per year.
237.5(b). Each of die companies operating these vessels will need to develop an O&M manual.
As described for OSVs, this is estimated to require the equivalent of 28 hours of supervisor's
time for each company, plus $5 in materials for each manual.
237.5(c). All of the operators of deck shale barges and hopper barges have the equipment and
spill containment and cleanup materials on hand to clean up waste deposits to the extent feasible.
Therefore, no costs have been estimated for equipment purchase or waste cleanup. However,
each vessel will need to post a placard with spill reporting procedures and telephone numbers of
oversight authorities, estimated at the standard cost of $17 plus 2 hours of supervisor's time for
each vessel.
237.5(d). Each company will need to develop a form for recording waste deposits. This is
estimated to require 1 hour of manager's time for each company. Assuming IS minutes are
required to record each deposit, a total of 2.S hours of supervisory time per year per vessel will
be required for filling out the forms. Storing and maintaining the record is estimated to be a
negligible cost.
4.3 Summary of Compliance Costs
Exhibits 4-2 through 4-9 summarize the estimated costs of compliance with the proposed SPA
regulation by industry segment and provision of the standard. The exhibits and the data
summarized in each are as follows:
Exhibit 4-2: First-year costs for shoreside facilities for small companies, large companies,
and government entities (i.e., government-operated facilities)
Exhibit 4-3: Total first-year costs for all shoreside facilities
Exhibit 4-4: Annual (recurring) costs for shoreside facilities for small companies, large
companies, and government entities (i.e., government-operated facilities)
Exhibit 4-5: Annual (recurring) costs for all shoreside facilities
Chapter 4.0 4-16 Costs of Compliance
-------
Exhibit 4-6: First-year costs for waste transport vessels for small companies, large
companies, and government entities (i.e., government-operated facilities)
Exhibit 4-7: Total first-year costs for all waste transport vessels
Exhibit 4-8: Annual (recurring) costs for waste transport vessels for small companies,
large companies, and government entities (i.e., government-operated facilities)
Exhibit 4-9: Annual (recurring) costs for all waste transport vessels
The total estimated first-year costs of compliance for all segments, including shoreside facilities
and vessels, is $1.75 million, including $1.3 million for waste transport vessels and $450,000 for
shoreside facilities. Of the total estimated first-year costs for shoreside facilities, about 75
percent are expected to be incurred by the receiving facilities for packaged garbage from offshore
oil and gas platforms. The majority of the remaining first-year costs are expected to be incurred
by the NYC Marine Transfer Stations and the Fresh Kills landfill.
The greatest single element of first-year costs will be for the additional time required in following
revised procedures for unloading packaged garbage from OSVs at the oil and gas supply bases.
The remaining costs are attributable to the development and revisions of O&M manuals and
developing and keeping waste deposit records. The impacts of these costs are discussed fully in
Chapter 6.
Approximately 82 percent of the estimated first-year costs for waste transport vessels are expected
to be incurred by OSVs serving the offshore oil and gas industry. Most of the remaining first-
year costs will be incurred by barges receiving and transporting drilling muds from the inland
and offshore oil and gas industry. These same two segments account for an even greater share
of the annual (recurring) costs.
Chapter 4.0 4-17 Costs of Compliance
-------
Exhibit 4-2
Shoreside Facilities: First-Year Costs
Cc
>mmercial Facilities
Small Companies by Industry Segment
Receiving Facility for Packaged Garbage from Oil and Gas
Platforms
Receiving Facility for Packaged Garbage from Vessels
Anchored Offshore
Islands (Sources of Packaged Garbage)
Drilling Mud Receiving Facilities (Oil Field Treatment Facs.)
TOTAL
Large Companies by Industry Segment
Receiving Facility for Packaged Garbage from Oil and Gas
Platforms
Receiving Facilities for Packaged Garbage from Islands
Sewage Sludge Receiving Facilities
Drilling Mud Receiving Facilities (Oil Field Treatment Facs.)
TOTAL
-^ w-,%i/.'-vr *,*, /^|Rro$sion7r *-. '/' Ji*~< *~. «x '.
Petfofttiiin.ce
Standard
$182,006
$0
$0
$0
$182,006
$33,020
$0
$0
$0
$33,020
Lighting
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
' 237,5(6)
Waste Bep,
Glean & Not
$6,454
$282
$672
$1.505
$8,913
$5,502
$89
$291
$1,505
$7,387
Waste Dep,
Records
$1,863
$144
$271
$0
$2,278
$2,535
$45
$691
$0
$3,271
O&M
Manuals .,
$66,692
$2,322
$4.366
$1.652
$75,031
$35,435
$728
$571
$1.652
$38,385
TOTAL
$257,015
$2,747
$5,309
$3.157
$268,229
$76,491
$862
$1,553
$3,157
$82,063
Government Facilities
Industry Segment
Marine Transfer Stations for Uncontainerized Garbage (NYC)
Receiving Facility for Uncontainerized Garbage (Fresh Kills
Landfill)
Islands (Sources of Packaged Garbage)
Receiving Facilities for Packaged Garbage from Islands
Sewage Sludge Sources
Sewage Sludge Receiving Facilities
TOTAL
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$582
$73
$693
$89
$510
$146
$2,093
$52,291
$32,656
$316
$45
$682
$345
$86,336
$178
$143
$5,303
$728
$1,209
$295
$7,856
$53,051
$32,871
$6,313
$862
$2,401
$786
$96,285
-------
Exhibit 4-3
Shoreside Facilities: Total First-Year Compliance Costs
Industry Segment
Marine Transfer Stations for Uncontainerized Garbage (NYC)
$0
$0
$582
$52.291
$178
$53.051
Receiving Facility for Uncontainerized Garbage (Fresh Kills
Landfill)
$0
$0
$73
$32.656
$143
$32.871
Receiving Facility for Packaged Garbage from Oil and Gas
Platforms
$215,026
$0
$11,956
$4,398
$102,127
$333,506
Receiving Facility for Packaged Garbage from Vessels
Anchored Offshore
$0
$0
$282
$144
$2,322
$2,747
Islands (Sources of Packaged Garbage)
$0
$0
$1,365
$587
$9,669
$11,621
Receiving Facilities for Packaged Garbage from Islands
$0
$0
$179
$90
$1.455
$1.724
Sewage Sludge Sources
$0
$0
$510
$682
$1,209
$2,401
Sewage Sludge Receiving Facilities
$0
$0
$437
$1.036
$2.339
Drilling Mud Receiving Facilities (Oil Field Treatment Facs.)
$0
$0
$3,010
$0
$3.304
$6.314
TOTAL
$215,026
$0
$18,393
$91,885
$121,273
$446,576
-------
Shoreside Facilities: Annual Costs
Exhibit 4-4
immercial Facilities
Small Companies by Industry Segment
Receiving Facility for Packaged Garbage from Oil and Gas
Platforms
Islands (Sources of Packaged Garbage)
TOTAL
*""--. ^//^ ' ' /- ^rovisioiu ~ - ' 4f^*,- ^n ^
237<5(A) ,
Performance
- Standard
$43,768
$0
$43,768
rfi
$0
$0
$0
Waste ifejp,
Cleaii &Nob
$2,782
$136
$2,918
W«s|ePep,
$0
$0
$0
OStM '
ManniEils
N/A
N/A
N/A
TOTA3U
$46,550
$136
$46,686
Large Companies by Industry Segment
Receiving Facility for Packaged Garbage from Oil and Gas
Platforms
Sewage Sludge Receiving Facilities
TOTAL
$7,940
$0
$7,940
$0
$0
$0
$505
$0
$505
$0
$441
$441
N/A
N/A
N/A
38,445 b
$441 1
$8,886 1
Government Facilities
Industry Segment
Marine Transfer Stations for Uncontainerized Garbage (NYC)
Receiving Facility for Uncontainerized Garbage (Fresh Kills
Landfill)
Islands (Sources of Packaged Garbage)
Sewage Sludge Sources
Sewage Sludge Receiving Facilities
TOTAL
•
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$68
$0
$0
$68
$52,222
$32,639
$0
$95
$221
$85,176
N/A
N/A
N/A
N/A
N/A
N/A
$52,222
$32,639
$68
$95
$221
$85,244
N/A - Not applicable
-------
Exhibit 4-5
Shoreside Facilities: Total Annual Compliance Costs
Industry Segment
Marine Transfer Stations for Uncontainerized Garbage (NYC)
Receiving Facility for Uncontainerized Garbage (Fresh Kills
Landfill)
Receiving Facility for Packaged Garbage from Oil and Gas
Platforms
Islands (Sources of Packaged Garbage)
Receiving Facilities for Packaged Garbage from Islands
Sewage Sludge Sources
Sewage Sludge Receiving Facilities
TOTAL
m,m
* SuiltQQPu *
$0
$0
$51,708
$0
$0
$0
$0
$51,708
msw
v fixed
UgHting
$0
$0
$0
$0
$0
$0
$0
$0
WS&)
Wijste Dw>
,$tafm&fC0t.
$0
$0
$3,286
$204
$0
$0
$0
$3,491
237.5(d)
Waste<0ep.
: Recortte _
$52,222
$32,639
$0
$0
$0
$95
$662
$85,617
\fcwfo)*
Qm '
-( ft|^¥^
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
TOTAL
$52,222
$32,639
$54,995
$204
$0
$95
$662
$140,816
N/A - Not applicable
-------
Exhibit 4-6
Waste Transport Vessels: First-Year Costs
c
ommercial Facilities
Small Companies by Industry Segment
Supply Boats (OSVs) Transporting Muds & Packaged
Garbage from Offshore Rigs
Vessels Transporting Packaged Garbage from Inland Platforms
and Rics
Vessels Transporting Garbage from Vessels Anchored Offshore
Vessels Transporting Packaged Garbage from Islands
Deck Shale Barges and Hopper Barges Handling Drilling Muds
TOTAL
>,"%&&&?>
PeiFfarjnance
';Sto4»urfP~*
$160,186
$0
$0
$0
$0
$160,186
Marittatev
$376,945
$11,628
$2,789
$1.589
$46,069
$439,020
/ Wlistie D.fejtri '"
6leJ&-&'W&
$45,503
$3,651
$266
$294
$4.023
$53,737
$14,621
$493
$124
$141
$4,661
$20,040
r, -^ -^
/% j>' s' '/• Jf "~f
^fgrofe
$597,255
$15,772
$3,178
$2.023
$54,753
$672,982
Government Facilities
Large Companies by Industry Segment
Supply Boats (OSVs) Transporting Muds & Packaged
Garbage from Offshore Ries
Vessels Transporting Packaged Garbage from Inland Platforms
and Rigs
Vessels Transporting Packaged Garbage from Islands
Barges Transporting Sewage Sludge
Deck Shale Barges and Hopper Barge Handling Drilling Muds
TOTAL
$0
$0
$0
$0
$0
$0
$416,734
$2,144
$0
$2.526
$85.857
$507,261
$42,115
$3,651
$73
$998
$7.497
$54,335
$15,054
$76
$35
$1.156
$7.743
$24,063
$473,902
$5,871
$109
$4,681
$101.097
$585,659
Industry Segment
Barges for Uncontainerized Garbage (NYC DOS)
Vessels Transporting Packaged Garbage from Islands
Barges Transporting Sewage Sludge
TOTAL
$0
$0
$0
$0
$666
$794
$842
$2,303
$7.986
$73
$77
$8,137
$17.639
$35
$89
$17,763
$26.292 b
$903 1
$1.008 1
$28,202 |
-------
Exhibit 4-7
Waste Transport Vessels: Total First-Year Compliance Costs
Industry Segment
Barges for Uncontainerized Garbage (NYC DOS)
Supply Boats (OSVs) Transporting Muds & Packaged
Garbage from Offshore Ries
Vessels Transporting Packaged Garbage from Inland Platforms
and Rigs
Vessels Transporting Garbage from Vessels Anchored Offshore
Vessels Transporting Packaged Garbage from Islands
Barges Transporting Sewage Sludge
Deck Shale Barges and Hopper Barges Handling Drilling
Muds
TOTAL
r,,"fe5»tT&
i^^wC8
*&&$$¥;
PerfonnHncc
^tai&ri
$0
$160,186
$0
$0
$0
$0
$0
$160,186
38O&X
'AJjtkm --,$
'Maniiata •<.;
$666
$793,678
$13,772
$2,789
$2,383
$3,368
$131,926
$948,583
rx]$3p^5(f!^>\ •
fefean' & Wot.
$7.986
$87,618
$7,302
$266
$440
$1,075
$11,520
$116,208
/^W.r
Waste Dppif x?
if-,,>
-------
Exhibit 4-8
Waste Transport Vessels: Annual Costs
Commercial Facilities
Small Companies by Industry Segment
Supply Boats (OSVs) Transporting Muds & Packaged
Garbage from Offshore Rigs
$160,186
N/A
$12,587
$1,005
$173,778
Vessels Transporting Packaged Garbage from Inland Platform!
and Rigs
$0
N/A
$634
$77
$710
Deck Shale Barges and Hopper Barges Handling Drilling
Muds
$0
N/A
$0
$4,094
$4,094
TOTAL
$160,186
N/A
$13,221
$5,175
$178,582
Large Companies by Industry Segment
Supply Boats (OSVs) Transporting Muds & Packaged
Garbage from Offshore Rigs
Vessels Transporting Packaged Garbage from Inland
Platforms and Rigs
Barges Transporting Sewage Sludge
Deck Shale Barges and Hopper Barges Handling Drilling Muds
TOTAL
$0
$0
$0
$0
$0
N/A
N/A
N/A
N/A
N/A
$5,724
$634
$0
$0
$6,358
$0
$0
$680
$7,629
$8,309
$5,724
$634
$680
$7,629
$14,667
Government Facilities
Industry Segment
Barges for Uncontainerized GarbageJNYC DOS)
Barges Transporting Sewage Sludge
TOTAL
$0
$0
$0
N/A
N/A
N/A
$0
$0
$0
$17,639
$52
$17,691
$17,639 b
$52 I
$17,691 |
N/A - Not applicable
-------
Exhibit 4-9
Wa
iste Transport Vessels: Tc
Industry Segment
Barges for Uncontainerized Garbage (NYC DOS)
Supply Boats (OSVs) Transporting Muds & Packaged
Garbage from Offshore Rigs
Vessels Transporting Packaged Garbage from Inland
Platforms and Rigs
Barges Transporting Sewage Sludge
Deck Shale Barges and Hopper Barges Handling Drilling
Muds
TOTAL
ttal Annual Compliance Costs
$0
$160,186
$0
$0
$0
$160,186
J'iJghtirtgr
N/A
N/A
N/A
N/A
N/A
N/A
^$stelBteD. '
$0
$18,311
$1,267
$0
$0
$19,579
$17.639
$1,005
$77
$732
$11,732
$31,176
%^j£.:
$17.639
$179,502
$1,344
$732
$11,723
$210,940
N/A - Not applicable
-------
5.0 Benefits
-------
5.0 BENEFITS OF COMPLIANCE WITH THE PROPOSED
REGULATION
This chapter identifies die benefits that may occur as the result of compliance with the proposed
regulation. The benefits of compliance, which are summarized in Exhibit 5-1, fall into four
categories: 1) establishment of a minimum standard of practice for industry, 2) contribution to
the reduction of marine pollution, 3) contribution to the reduction of marine debris and its
impacts, and 4) contribution to the reduction of public health hazards. The chapter is structured
around these four types of benefits and the four types of waste and related waste-handling
practices identified in Chapter 3 as covered by SPA. In addition, there is a discussion of the
complexity of monetizing the benefits of compliance with the proposed regulation.
5.1 Establishment of a Minimum Standard of Practice
The regulation establishes a minimum standard of practice hi the industry segments involved in
the transfer of garbage, drilling muds, and sewage sludge to and from vessels and the transport
of these commercial and municipal wastes by vessel. The regulation establishes a minimum
standard of practice not only for existing industry, companies or government entities using this
form of waste-handling but for those that will choose to do so in the future. Minimizing the
release of municipal and commercial solid waste into coastal waters through these standards
should contribute to the reduction of the adverse impacts of these wastes on the marine
environment and its economic potential and help to avoid potential public health risks.
5.2 Contribution to Reduction in Marine Pollution
An Office of Technology study, Wastes in the Marine Environment, concluded that many of the
adverse impacts on water and organisms are caused by the introduction of pollutants through the
disposal of wastes (OTA, 1987). The same study cited the following observed effects of wastes
in estuaries and coastal waters:
impacts on water quality;
loss of submerged aquatic vegetation;
impacts on fish and shellfish;
impacts on entire marine communities such as species of fish or marine mammals;
closure of beaches and shellfish grounds because of contamination;
a rising incidence of reported human disease from consuming contaminated shellfish
or swimming hi contaminated waters; and
• accumulation of toxic pollutants in sediments.
As indicated by this list, accumulations of municipal and commercial wastes, sewage sludge, and
drilling muds eventually enter into the sediments. While the relative role of wastes, sludge, and
drilling muds to the contamination of sediments is not fully understood, these sources of pollution
contribute to this problem. Reducing the contamination of sediments will benefit: 1) benthic
biota, and 2) higher-level foodchain species, including humans.
Bottom-dwelling (i.e., benthic) organisms consist of species that live within the bottom sediments,
and others living upon the bottom surface or in the near-bottom portion of the water column,
including filter-feeders and deposit-feeders. Some species burrow; others attach themselves to
Chapter 5.0 5-1 Benefits of Compliance
-------
Exhibit 5-1
Benefits Of Compliance With The SPA Regulation
Contribution to Reduction in Marine Pollution
Contribution to Reduction in Marine Debris
and Its Impacts:
• Aesthetic Losses
• Tourism Losses
• Clean-Up Costs
• Entanglement
• Fouling of Vessels
• Fouling of Fishing Gear
• Ingestion
• Long-Term Unknown Impacts
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Contribution to Reduction in Public Health
Hazards
-------
or crawl on the substratum surface. Deposit-feeders are of two types: 1) those that skim material
off the upper layer of sediment; and 2) and those that eat their way through the sediments as they
burrow.
Sensitive species that succumb readily to contaminated sediments will pose a relatively small
threat to the fbodchain. It is the more tolerant species that accumulate contaminants hi their
tissues and survive that represent the greater threat because these organisms can serve as prey to
other species, passing contamination up the food chain, ultimately to predatory birds and
mammals, including humans
Municipal and commercial wastes in coastal waters contributes to the overall degradation of me
marine environment and to marine pollution. It therefore follows that anything that prevents
these types of wastes from being disposed of in the marine environment will contribute to a
reduction in marine pollution.
5.3 Contribution to Reduction in Marine Debris and Its Impacts
The term "marine debris" refers to any man-made object in the marine environment, although
the term is often used to refer specifically to persistent plastics in the ocean. It is really a subset
of marine pollution, but marine debris is singled out as a separate issue here because of the
number of problems it causes and the fact that waste-handling practices of two of the three types
of waste covered by the SPA regulation (particularly municipal wastes and potentially sewage
sludge) contribute to it.
Marine debris can float at the surface, be suspended, sink to the ocean floor or break up and
persist at the microscopic level. It causes a variety of problems for wildlife, maritime commerce,
and coastal communities. All marine user groups as well as land-based sources have been
identified as contributors to the problems of marine debris (CMC, 1988, 1992; OTA, 1987;
Shomura, 1990; Cottingham, 1988). Municipal and commercial wastes transported over water
contribute to the marine debris problem, but are by no means the primary source of the problem.
Minimizing municipal and commercial waste deposits in the coastal U.S. waters during loading,
offloading, and transport by vessels will contribute to solving the marine debris problem, but by
itself will not solve the problem. The types of problems for wildlife, maritime commerce, and
coastal communities caused by marine debris are elaborated upon below.
53.1 Aesthetic Losses
Debris in the water and washed up onto beaches is ugly. Municipal solid waste and sewage
sludge deposited into coastal waters may end up as polluting coastal waters with associated
aesthetic losses in coastal recreation areas where marine debris and waste accumulates. These
losses are demonstrated by users who are willing to go to extra expense to avoid marine debris
either through efforts of beach cleanups or extra travel time to use less polluted recreational
areas. Property owners hi coastal areas may experience losses in property value when marine
debris makes the property less desirable from either an aesthetic or recreational point of view
(Meade, 1990). A study of persistent marine debris identified aesthetic degradation and the
accompanying costs of clean up as the most serious impact of marine debris in the Northwest
Atlantic area (Heneman, 1988).
Chapter 5.0 5-3 Benefits of Compliance
-------
The universal response to dirty beaches is to clean them up. In the last few years, a national
volunteer beach clean up has been organized as part of the celebration of COAST WEEKS each
September. As seen in Exhibit 5-2, which summarizes the results of these clean up efforts for
1988 through 1991, this program has grown hi terms of number of participants, miles of beach
cleaned, and pounds of debris collected. Admittedly, not all the debris collected comes from
vessels carrying commercial or municipal wastes or their corresponding waste sources or
receiving facilities. Nonetheless, to the extent that these wastes become marine debris, they may
well be part of the beach litter cleaned up hi this national effort.
The concern about dirty beaches and related impacts to tourism and governmental clean up costs
has led to Adopt-a-Beach Programs in some communities. For example, the State of Texas
established a State Adopt-a-Beach Program hi 1986 to increase public awareness of the beach
litter problem, to augment other beach cleaning efforts, and to involve citizens hi the solution to
the marine debris problem (Texas General Lands Office, 1993).
533, Tourism Losses
Revenue losses can also result from marine debris through losses to the travel and tourism
industry. Municipal solid waste and sewage sludge deposited into coastal waters may end up as
marine debris that contributes not only to aesthetic losses hi coastal recreation areas, but to losses
hi tourism. A study detailing the effects of debris on an individual's willingness to pay for tourist
accommodations hi coastal Massachusetts found that overnight visitors place a premium on
reduced quantities of beach litter (Wilman as reported in Meade, 1990).
Efforts to develop regional tourism may be thwarted by negative perceptions of and experience
with the environmental quality of the coastal zone. A study of the impacts of the offshore marine
industry on coastal tourism found that the level of satisfaction with beaches was directly related
to the perceived frequency of seeing litter and debris and from getting dirty or stained with tar.
Trip satisfaction was found to be directly tied to satisfaction with the beach, while perceptions
concerning beach litter and debris had an indirect effect on trip satisfaction (Roehl, 1993).
Clearly, beach and trip satisfaction have potential economic implications for developing a strong
local or regional tourism or recreation industry.
Local economies with developed tourism may suffer revenue losses due to degradation of
environmental quality from marine debris. A synthesis of the literature focusing on the economic
impacts of the beach closings hi the New York and New Jersey area from floatable debris and
medical waste washup hi 1988 identifies some of the economic impacts of these closings
(Wagner, 1990). For example, the Long Island Tourism and Convention Center documented a
decline La tourism and estimated the economic losses from the decline hi visitors and
accompanying expenditures at $1.4 billion. (The actual net effect was estimated to be lower than
$1.4 billion because some visitor expenditures were likely to have been made elsewhere in the
area, just not at the beach.) A survey of New York City and Long Island charter boat and party
boat captains 'indicated a decline hi passengers hi 1988 compared to previous years. The captains
cited floatable wastes as the most important issue affecting their business. A New York State
Department of Environmental Conservation study (also summarized in Wagner 1990) identified
the Fresh Kills Landfill and the barges carrying the wastes, and the marine transfer stations as
one of the primary sources of medical waste and other floatable marine debris along the shores
of NYC, Long Island, and nearby areas. Other sources of floatable debris included combined
sewer overflows, raw sewage discharges, storm water outlets, and illegal dumping.
Chapter 5.0 5-4 Benefits of Compliance
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Exhibit 5-2
Ul
o
1
I
Summary Of Coastal Cleanup Results
1991
1990
1989
1988
1988
130,152 1991
1990
1989
40,000 80,000 120,000
Number of Volunteers
1.0 2.0
Million Pounds of Debris
3.0
1988
0
1991
4,347
2,000 4,000
Miles of Beach Cleaned
6,000
662.2
711.0
200 400 600
Pounds Per Mile Cleaned
Sources: CMC, 1989; 1990; 1991; and 1992.
-------
533 Clean Up Costs
Some coastal communities and other government agencies spend considerable time and money
cleaning up and maintaining recreational beaches. Enforcement officers are sometimes used to
patrol and control for beach litter left by beach goers. Not all beach litter is the result of beach
goers, however. In the Gulf of Mexico, for example, sampling studies show that less than 10
percent of the beach litter comes from beach goers. The remaining 90 percent comes from the
Gulf of Mexico itself, from all the marine user groups (Luken, 1985). Texas coastal communities
are reported to spend about $14 million annually on beach cleaning. The Padre Island National
Seashore in Texas spends about $10,000 per year on beach cleaning efforts, primarily in the most
heavily visited 0.5 mile stretch of beach (King, 1985). Almost all of the complaints received by
the park's staff since its founding in 1962 focus on the beach litter problem (Luken, 1985).
53.4 Animal Entanglement
One of the ways that marine debris affects wildlife occurs when animals become entangled in it.
An animal can suffocate, strangle or exhaust itself when it becomes entangled in plastic debris,
such as strapping bands, beverage container rings, rope, or net. Municipal solid waste which
includes these items may end up as marine debris and contribute to the problem of animal
entanglement. Marine and terrestrial mammals and sea and shore birds have been identified as
being particularly vulnerable to entanglement by plastic debris (Cottingham, 1988; Heneman,
1988). Much of the literature on animal entanglement focuses on the problem of entanglement
caused by fishing nets (Shomura, 1990). However, there are examples of animal entanglement
hi items which could have come from municipal solid waste deposited in coastal waters. For
example, during an international beach cleanup in 1991, volunteers found dead birds and fish
entangled in the following items which could be part of municipal solid waste: socks, plastic
bags, plastic cups, rope, string, beverage container rings, tires, and balloon ribbon (CMC, 1992).
53.5 Fouling of Vessels
Vessels can become entangled in marine debris as well as animals. To the extent that municipal
solid waste includes items such as rope and strapping bands which are deposited into coastal
waters it may contribute to the problem of fouling of vessels. This creates extra and unexpected
expense for vessel owners. A 1987 survey of fishermen in the Seattle area, 64 percent of the
respondents indicated their vessels had been damaged by plastic debris within the last 2 years.
The estimated cost of repairs and downtime was $110,000 (Cottingham, 1988). In a survey of
commercial and recreational fishermen, the vessel propeller of 45 percent of the commercial
fishermen and 28 percent of the recreational fishermen had at some time been entangled in plastic
debris (Wallace, 1990). The vessel's cooling intake system had been clogged by plastic debris
for almost 40 percent of the commercial fishermen and about 21 percent of the recreational
fishermen.
53.6 Fouling of Fishing Gear
Fishing gear also becomes entangled in marine debris. Municipal solid waste includes items such
as rope and strapping bands which may contribute to the problem of fouling of fishing gear. This
creates extra and unexpected expense for the affected fishermen. In a survey of commercial and
recreational fishermen, over 30 percent of the commercial fishermen and between 15 and 20
Chapter 5.0 5-6 Benefits of Compliance
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percent of the recreational fishermen had had their gear caught or fouled by plastic debris
(Wallace, 1990).
53.7 Ingestion by Wildlife and Fisheries
The second way that marine debris affects wildlife occurs when animals ingest it. Plastic
particles have been found by researchers in about 63 percent of the world's 250 seabird species
(Cottingham, 1988). Since plastic is nondigestable, individual pieces accumulate in the animal's
gut. The animal stops feeding because it thinks it is full. Breeding is reduced and migration
hindered. The bird slowly starves to death. Sea turtles often mistake plastic bags for jelly fish,
plankton, or the larval stages of crabs. All types of plastic items have been found in dead sea
turtles — plastic bags, balloons, line or rope, beads or pellets, and shards of polystyrene, for
example (Plotkin, 1990; Balazs, 1985). Many populations of sea turtles are already threatened
or endangered from overfishing or other adverse factors such as floating debris. To the extent
that municipal solid waste includes plastics items such as polystyrene, sheeting, or bags, it may
contribute to the problem of ingestion of plastics by animals. In addition to the concern about
populations of the species affected by ingesting plastic debris, the concern is also that the plastic
will enter into the human food chain.
5.3.8 Long-Term Unknown Impacts
The problems and consequences of marine debris have only fairly recently received wide-spread
attention. For example, the first workshop on the fate and impact of marine debris was held in
1984 (Shomura and Yoshida, 1985). There may be other, as yet unknown, long-term impacts
from marine debris on the environment and/or on human health.
5.4 Contribution to Reduction in Public Health Hazards
Municipal solid waste in the form of sewage sludge deposited into coastal waters can create
surface slicks, decrease water transparency, and wash up on beaches creating potential health
hazards. The public health hazards include the threat of long term heavy-metal toxicity, the
accumulation of persistent chlorinated hydrocarbons, and infectious pathogenic viruses, bacteria,
and parasites (Vaccaro, 1981). There are two ways contaminants can be passed to humans -
directly, typically through the air or skin or ingestion such as swallowing contaminated water or
indirectly through ingestion of contaminated plants or animals. Human health impacts result from
direct and indirect exposure to pathogens (OTA, 1987). The etiological agents of typhoid fever,
food poisoning, and anaerobic dysentery are recognized human pathogens commonly associated
with sewage sludge (Vaccaro, 1981). A major route to human exposure to metals and organic
chemicals is through consumption of contaminated seafood (OTA, 1987). Preventing sewage
sludge releases hi nearshore coastal waters is obviously one mechanism to reduce the potential
public health risks associated with it.
5.5 Complexity in Monetizing Benefits
There are three insurmountable complexities in quantifying the anticipated benefits from the
proposed regulatory changes. First, injury to living marine resources and humans from marine
debris, pollution, and contaminated sediments is highly dependent on site-specific chemical and
environmental conditions. Second, the relationship between contamination levels and organisms
is understood only for a limited number of the "less-valuable" species under laboratory
Chapter 5.0 5-7 Benefits of Compliance
-------
conditions. Information on the marginal impacts to biota and the ecosystem from different
contamination levels are not available. Third, most of the prevented injuries flow from natural
resource services, which must be measured on a marginal basis depending on site-specific
conditions. A brief summary of these issues follows.
5.5.1 Inability to Depict Relative Rote of SPA-Related Pollution to Aggregate Pollution
Levels
While some limited estimates of aggregate problems associated with marine debris are available,
there is no basis to estimate the relative proportion of these aggregate estimates to those pollution
incidents addressed by SPA. On the aggregate basis, there are many pollution sources of marine
debris (commercial and military vessels, pleasure craft, beach users, sewer systems, the fishing
industry, etc.) which are likely to be more significant than vessels transporting municipal and
commercial wastes. However, as the incidents hi New York and New Jersey indicate, at the site-
specific level, these activities can be a major cause of debris-related pollution. There are no data
upon which to base an estimate of the relative role that SPA-related pollution plays in the overall
problem.
5.5.2 Inability to Extrapolate Site-Specific Environmental Conditions to Generalized
Regulatory Changes
Real-world marine pollution and contamination is made up of hundreds of known hazardous
constituents and contamination levels cannot be defined in terms of a generic unit of " toxicity."
It is not uncommon for one sample to be evaluated relative to SO to 100 chemical constituents.
In this way, the mix of the various contaminants is highly site-specific and can vary depending
on the location or even at different depths within the sediment. Because the draft regulations
propose to manage release of pollution, not contamination levels per se, the draft action cannot
be characterized in terms of some physical unit of contamination (e.g., concentration of heavy
metals).
5.5 J Inability to Relate Pollution Levels to Macro Changes in Species Abundance
Even for a given level of any pollution, the ultimate toxicity to the marine environment is highly
dependent on a range of other site-specific factors including: sediment particle size, the organic
carbon content and permeability of the sediment, oxygen content of sediments and overlying
waters, water temperature, salinity, presence and relative mix of other contaminants, extent of
natural nutrients, the nature and extent of local populations of marine biota, mobility of the biota
at issue, and the presence of other, unrelated natural or man-made adverse conditions. Measures
of toxicity represent a complex web of dozens of site-specific factors that prevent the biological
measurement of the outcomes of the proposed action.
5.5.4 Measurement Issues in Monetizing Injuries to Complex Natural Resources
The final and most limiting hindrance to monetizing the benefits of the proposed action results
from the complexity in measuring economic damages from subtle impacts on the marine
environment. In general, the measurable benefits of isolating contaminated sediment from the
general marine environment include enhancements to the biological health of resources. Further,
species important to humans such as seabirds and marine mammals could also expect to benefit.
Public health effects, enhanced recreational fishing opportunities, and enhanced opportunities for
Chapter 5.0 5-8 Benefits of Compliance
-------
safe, marine-dependent outdoor recreation are also benefits. Some of these benefits can be
measured in terms of the value of the commercial fisheries, recreational fisheries, and recreation
opportunities. However, in order for even these more obvious benefits to be monetized, a
measurable relationship between pollution levels and macro marine populations would be
required. As previously discussed, such a basis does not exist in the existing literature, and
development of these data would require an extensive and costly research initiative.
Monetizing value becomes even more complex when highly migratory and upper-trophic level
organisms are involved. For example, in the case of marine mammals and seabirds, total
compensable value flowing from the resources would include a range of additional non-use
values:
• Nonconsumptive resource values such as those derived from wildlife observation,
diving, and swimming;
• Option values as measured by the willingness to pay to maintain the resource for
future use by mat individual; and
• Bequest and genetic values including the value of preserving a resource for future
generations.
Other benefits would relate to human-health risks and the value of adjacent coastal property.
While tools (e.g., contingent valuation, travel cost, and hedonic pricing methods, etc.) are,
available for monetizing impacts on marine environmental services, any predicted results are
highly site-specific and only meaningful if measured on a marginal basis. In this way, even if
monetized estimates were available, they would not be applicable to the relatively large volumes
of sediments addressed hi this analysis.
For the above noted reasons, monetized estimates of anticipated benefits cannot be made at this
time. Even if monetized benefits were to be derived from the existing literature, such benefit
estimates would be highly speculative.
Chapter 5.0 5-9 Benefits of Compliance
-------
6.0 Impacts
-------
6.0 IMPACTS OF COMPLIANCE COSTS ON AFFECTED
INDUSTRIES
The economic impacts of the proposed SPA regulation on the affected industries must be
examined in a number of ways. This chapter summarizes the implications of the estimated costs
presented in Chapter 4 on the affected industry segments. References to government entities in
this chapter refer to government-operated facilities or vessels. In this situation, these are State
and local government entities.
The questions to be answered in the following sections include:
• What are the costs on a per-facility, per-vessel, or per-company basis?
• Are the costs significant relative to profits, revenues, or (for government entities)
costs for any industry segment?
• If the costs are significant, can they be passed on to customers or consumers or must
they be absorbed by the affected industries?
• Is any geographical region impacted more severely or differently than other regions?
• How are the overall costs distributed between government entities and the private
sector? Further, within the private sector, are the impacts different between small and
large businesses?
Section 6.1 presents the costs on per-vessel and per-facility bases and discusses the significance
of costs on die affected industry segments.
In addition to the foregoing questions, it is necessary to satisfy certain specific requirements
pertaining to regulatory impact analysis. Executive Order 12866' which calls for balancing
benefits and costs, minimizing unnecessary regulations, and selecting the regulation which
achieves the stated goals at the least cost. The Order requires that a regulatory impact analysis
(RIA) be performed for each "significant regulatory action," which is defined as one that has an
annual affect on the economy of $100 million or more or adversely affects in a material way the
economy or a sector of the economy. However, a regulatory impact analysis can be required for
virtually any regulatory action at the request of OMB. Each federal agency is required to prepare
a preliminary and final RIA of each major rule for OMB review. The RIAs are to contain the
following kinds of information:
"(1) A description of the potential benefits of the rule, including any beneficial effects that
cannot be quantified in monetary terms, and the identification of those likely to
receive the benefits;
1 Executive Order 12866 was issued October 4, 1993, and supersedes Executive Orders 12291
and 12498. E.O. 12866 sets forth similar requirements for regulatory impact analysis as the
prior Orders and was used throughout this analysis.
Chapter 6.0 6-1 Compliance Impacts
-------
(2) A description of the potential costs of the rule, including any adverse effects that
cannot be quantified in monetary terms, and the identification of those likely to bear
the costs;
(3) A determination of the potential net benefits of the rule, including an evaluation of me
effects that cannot be quantified in monetary terms;
(4) A description of alternative approaches that could substantially achieve the same
regulatory goal at a lower cost, together with an analysis of this potential benefit and
costs and a brief explanation of the legal reasons why such alternatives, if proposed,
could not be adopted; and
(5) Unless covered [above] ..., an explanation of any legal reasons why the rule cannot
be based on the requirements set forth in ... this order."
This report is focused on items (1) and (2) above. Because the proposed SPA regulation is
legislatively mandated, the flexibility in selecting alternatives and maximizing the net benefits has
been significantly reduced and is not addressed here.
Additional requirements of the regulatory impact analysis are stipulated by the Regulatory
Flexibility Act, which pertains primarily to small business effects, and the Paperwork Reduction
Act. These statutes are discussed and addressed in Sections 6.2 and 6.3, respectively.
The following discussions of costs and impacts are based solely on the estimated first-year costs
since they are significantly greater than the annual (recurring) costs. Annual costs will only be
examined in greater detail where first-year costs are found to be significant.
6.1 Economic Impacts by Industry Segment
Exhibit 6-1 presents die average first-year compliance costs per facility for each shoreside
industry segment. Exhibit 6-2 presents the first-year costs for waste transport vessels on a per-
vessel basis. The numbers of facilities and vessels are taken from the industry profiles in Chapter
3 and the total costs by segment are from Chapter 4. As evidenced by the results shown in the
exhibit, the average costs on a per-facility or per-vessel basis are quite low and generally not
significant.
"Not significant" costs are defined as being too small to have an effect on the decisions of how
to operate the business. In the specific case of the proposed SPA regulation, the options a
company could have available to respond to the costs of compliance would be:
• Absorb the costs, thus reducing profit;
• Raise prices, passing on die costs to customers;
• Discontinue the waste handling services; or
• Go out of business.
Chapter 6.0 6-2 Compliance Impacts
-------
Exhibit 6-1
Average First-Year Compliance Cost Per Facility
Shoreside Facilities
Industry Segment
Marine Transfer Stations for Uncontainerized
Garbage (NYC)
Receiving Facility for Uncontainerized Garbage
(Fresh Kills Landfill)^
Receiving Facility for Packaged Garbage from
Oil and Gas Platforms
Receiving Facilities for Packaged Garbage
from Vessels Anchored Offshore
Islands ( Sources of Packaged Garbage)
Receiving Facilities for Packaged from Islands
Sewage Sludge Sources
Sewage Sludge Receiving Facilities
Drilling Mud Receiving Facilities
(Oil Field Treatment Facilities)
M
-
-
61
3
6
.
.
-
25
|!M
KV, » f
m
-
-
83
-
_
1
_
4
25
iW^&Ji
$j
P?
8
1
-
-
7
1
7
2
"
Wf)
&?:
p?
8
1
144
3
13
2
7
6
50
ispi
pi
r *
-
•
$257,015
$2,747
$5,309
-
.
-
$3,157
?%'£$r&*gi?
^MiMw
^
7 '-«' x&*^s3tfp^
* '•/•" ^' "!
y ,-' /' (, /'is, '
*/"'^'
/ >;Tv"/
$53,051
$32,871
$333,506
$2,747
$11.622
$1,724
$2.401
$2,339
$6,314
iip
-*-' f<-2
**]&&
&*&*
f"''*<*g*i">
/•>,".'&•£?}
-
-
$4,213
$916
$885
.
.
-
$126
?> Vf'^Xlt 47t y*
-
-
$922
-
.
$862
-
$388
$126
«f*« Vif-fj^v:;
CostPo
T^S*****^ £
Aixv%\ >/" %
^A>y>* *
TJ
•/<-',*&
f--;f' *• f
$6,631
$32,871
-
-
$902
$862
$343
$393
4 *"f*>lt , % -J.
wKaoility
Kx,
$6,631
$32,871
$2,316
$916
$894
$862
$343
$390
$126
V ' '- I
/
[
1 Government - State or local government-operated facilities
-------
Exhibit 6-2
Average First-Year Compliance Cost Per Vessel
Waste Transportation Vessels
A
Industry Segment /*>
Barges for Uncontainerized Garbage (NYC)
Supply Boats (OSVs) Transporting Packaged
Garbage and Muds from Offshore Rigs
Vessels Transporting Packaged Garbage from
Inland Platforms and Rigs
Vessels Transporting Garbage from Vessels
Anchored Offshore
Vessels Transporting Packaged Garbage
from Islands
Barges Transporting Sewage Sludge
Deck Shale Barges and Hopper Barges Handling
Drilling Muds and Cuttings
'
360
33
4
4
-
44
4 Numl>e^f^ess|ls^J ~}_ lotal Cost for Segment , /'/////^ •'/$&/£/
-------
None of the compliance costs estimated for this regulation begin to approach the magnitude at
which an affected party will be threatened with going out of business as a result of this
regulation.
Discontinuing the waste handling service is not an option for the segments related to
uncontainerized municipal waste (MTSs, Fresh Kills, and barges) or sewage sludge (sources,
barges, and receiving facilities). Most of the affected parties in these segments are government
entities. The estimated costs for the Marine Transfer Stations and Fresh Kills landfill hi New
York City are the largest per-facility costs of any segment. However, these costs represent
primarily labor hours and account for a very small fraction (considerably less than 1 percent at
the MTSs) of total labor hours at any of these facilities. Therefore, these costs are not significant
for the NYC DOS facilities. The costs for the commercial sewage sludge receiving facilities and
barges are very low, about $390 per vessel or facility, and are considered inconsequential.
The segments related to packaged garbage from islands face fairly low compliance costs of less
than $1,000 per affected vessel or facility. Furthermore, they are providing a necessary service
for which there are no easy substitutes and the entry barriers are greater than the incremental
costs for the current players to comply with the proposed rule. These costs are expected to be
absorbed or passed on in the form of higher fees.
The operators of vessels and receiving facilities for transporting packaged garbage from vessels
anchored offshore will most likely be able to pass on most of their modest compliance costs of
$800-900 to the cruise ships they serve. If the total cost for these two segments of $5,925 is
distributed over the 568 total loads of garbage these vessels pick up each year, the cost per
transaction is just over $10, which could likely be added to the servicing fee.
The costs for the barges handling drilling muds and cuttings, about $1,240 per vessel, should not
have any significant economic effect. In addition, because all of these vessels will be affected
in the same manner and at the same cost, none will gain any competitive advantage over the
others as a result of the SPA regulation. A very modest price increase would quickly cover these
costs. The oil field waste treatment facilities are virtually unaffected by the proposed regulation.
The commercial industry segments facing the greatest costs of compliance are those related to the
transport of packaged garbage from oil and gas platforms and rigs. Small companies in this
segment face an average estimated first-year cost of $4,213. The major components of this cost
are to purchase and use the equipment necessary to meet the performance standard and the time
and effort required to develop an O&M manual. While this level of cost is not likely to cause
a business failure, it may represent a significant portion of profits for some facilities. However,
since every facility in this segment will face similar costs, it might be possible to pass through
some of the costs.
A major aspect of these cost estimates is that they represent averages across all facilities. The
range of costs among facilities is very broad in some segments. For instance, in the small oil
and gas supply facility segment, costs will range from $91 per facility for those which only need
to post a placard and develop a waste deposit record form, up to $5,346 for a facility which
needs to purchase equipment, develop a manual, and implement changed procedures.
The major component of the costs for these facilities is the $3,000 cable sling for lifting
dumpsters from the OSVs onto the dock. This cost could be addressed in two ways. First, the
Chapter 6.0 6-5 Compliance Impacts
-------
purchase could be capitalized, thus removing the bulk of the cost from the first year's expenses
and spreading outlays over a longer period. If this asset were capitalized with a ten-year life at
7 percent, the annualized cost would be $427 per year. In this case, the maximum first-year cost
for a small oil and gas supply facility would be $2,773. This level of costs is not expected to
have a significant impact on any individual facilities. A second alternative for minimizing or
avoiding the cost of a cable sling would be to develop and demonstrate alternative procedures as
effective as the use of the sling.
One potential caveat germane to all costs applicable to the offshore oil and gas industry segments
is that, while small, they are but one of numerous recent regulatory costs imposed on mis
industry. The cumulative effect of these costs is substantial. Examples of other regulations being
imposed during the same general period include regulations applicable to drilling muds, cuttings,
and produced waters, air emission regulations, dramatically higher liabilities imposed by the Oil
Pollution Act of 1990, new vessel and facility spill response plans, regulations on the handling
of hazardous materials at supply bases, to name but a few. These additional requirements on the
offshore oil and gas industry come at a time when prices for domestic energy remain low and the
industry is facing an uncertain future. Thus, while the SPA provisions applicable to oil and gas
segments remain minor, they should be considered within the context of a much greater
regulatory agenda facing the industry at a time of depressed revenues. Even within this context,
however, the proposed regulations are of such a small magnitude that they represent a negligible
portion of the substantial problems being faced by the industry.
6.2 Other Measures of Distribution of Economic Impacts
No geographical region will suffer significant adverse economic effects as a result of the
implementation of the proposed SPA regulation. However, different regions will be affected by
different industry segments. Uncontainerized municipal waste is handled only in New York City.
Other activities in the Northeast include sewage sludge transfers and packaged garbage from
islands. The Gulf Coast, mainly Texas and Louisiana, is home to the majority of OSVs and
supply bases handling packaged garbage, as well as the vessels and facilities handling drilling
muds and cuttings. The west coast of the mainland United States consists of a few OSVs and
supply bases, as well as the packaged garbage handling for vessels anchored offshore.
The distribution of costs between government and commercial entities is shown in Exhibit 6-3
for bom initial and annual costs. Costs for government entities hi the first year constitute only
7 percent of the total first-year costs. This is primarily because of the large number of
commercial enterprises which will need to develop manuals and purchase equipment. However,
government entities are expected to account for nearly 30 percent of the recurring annual costs.
6.3 Effects of the Proposed Rule on Small Entities
Regulatory Flexibility Act Requirements
The Regulatory Flexibility Act was enacted by Congress in September 1980 with the purpose of
ensuring that regulatory and informational requirements are molded to the scale of those
businesses, organizations, and government jurisdictions subject to federal regulations. To achieve
mis goal, the Act requires federal agencies to consider flexible regulatory alternatives and to
explain their rationale for regulatory actions that affect small entities. The underlying premise
of the Act is mat existing regulations have often imposed disproportionately burdensome demands
Chapter 6.0 6-6 Compliance Impacts
-------
Exhibit 6-3
Distribution Of Total Cost Between Government And
Commercial Entities
First-Year Total Costs
Annual (Recurring) Total Costs
Shoreside Facilities
Vessels
Total
$350,000
$1,259,000
$1,609,000
$96,000
$28,000
$124,000
Shoreside Facilities
Vessels
Total
$56,000
$193,000
$249,000
$85,000 1
$18,000
$103,000
* Government entities - State and local government-operated facilities or vessels
-------
on small businesses and other small entities, thereby adversely affecting market competition,
restricting productivity improvements, and discouraging innovation. Under the Regulatory
Flexibility Act, agencies are required to prepare and make available for public comment an initial
regulatory flexibility analysis of small entities whenever a notice of proposed rulemaking is issued
and a final regulatory flexibility analysis of small entities whenever a final rule is promulgated.
Hie exact requirements for the contents of the initial and final regulatory flexibility analyses
differ. Generally, both analyses should contain, among other requirements: (1) a description of
the need for and objectives of the rule; (2) a quantitative or qualitative analysis of the number of
small entities subject to the rule and the effects of the rule on these entities; and (3) a description
of alternatives to the rule that would minimize any significant economic impacts of the rule on
small businesses and other small entities. Possible alternative regulations might include
establishing different compliance timetables for small and large entities or perhaps exempting
small businesses from the entire rule or certain portions of the rule. A regulatory flexibility
analysis is generally included as part of the regulatory impact analysis required under Executive
Order 12866 and reviewed by OMB.
Effects on Small Entities
There is a potential that the proposed rule could differentially affect non-federal small entities
involved in transport of commercial and municipal wastes by vessels. These entities could
include small port authorities (including quasi-governmental organizations), small private
companies (barge and OSV operators, oil and gas supply bases, and other sources and receiving
facilities), and local governments (NYC DOS). However, based on the results described in
Section 6.1 above, few negative effects on small entities are expected if the proposed rule is
promulgated.
6.4 Recordkeeping Costs of the Proposed Rule
Paperwork Reduction Act Requirements
The purpose of the Paperwork Reduction Act of 1980 (P. L. 96-511; 44 USC Chapter 35) is to:
1) minimize the federal paperwork burden for individuals, small businesses, state and local
governments, and other persons; 2) minimize the federal government's cost of collecting,
maintaining, using, and disseminating information; and 3) maximize the usefulness of information
collected by federal agencies. OMB has oversight responsibility under the Act and has
promulgated implementing rules and procedures.2
For example, to obtain OMB approval for the collection of information, an agency must show
that it has attempted to ensure that: 1) data collection is accomplished by the least burdensome
means while allowing the agency to comply with the law and achieve program objectives; 2)
information collected is not duplicated by other sources; and 3) the information has practical
utility and is collected and used at minimum cost. Based on this analysis, OMB will consider
whether the burden of all or part of the collection effort is justified by the practical utility of the
information. OMB also has imposed specific strictures regarding data collection. For instance,
See 5 CFR Part 1320. Guidelines were initially prepared as shown in Federal Register,
March 31, 1983, pp. 13666-13689.
Chapter 6.0 6-8 Compliance Impacts
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OMB will not approve collection efforts that: 1) require respondents to report more often than
quarterly; 2) require responses in fewer than 30 days; 3) do not separate and simplify reporting
for small businesses and other small entities (i.e., relief under the Regulatory Flexibility Act);
and 4) require respondents to submit proprietary, trade-secret, or other confidential information
(unless the agency can show that procedures exist to protect confidentiality).
Under the OMB guidelines, information collection includes the use of written report forms,
application forms, schedules, questionnaires, reporting or recordkeeping requirements, or other
similar methods (e.g., contracts, agreements, plans, policy statements, rules or regulations,
planning requirements, circulars, directives, interview guides, labeling requirements, telephone
requests, and standard questionnaires used to monitor compliance with agency requirements).
Requirements to obtain or compile information for the purpose of disclosure to members of the
public or to the public at large (e.g., by posting, notification, or labeling) can also constitute
information collection.3
In addition to these requirements under the Paperwork Reduction Act, there are special rules
governing the collection of data that may be needed by a federal agency to develop a rule or
evaluate a program, or for other reasons. OMB clearance is usually required if a federal agency
has need of such information to be obtained through mail, telephone, or on-site surveys or other
information- or data-gathering efforts that may impose a burden upon the respondent population.
Federal agencies collecting information by means of identical questions from 10 or more persons
(other than federal employees) must obtain prior clearance from OMB.4
Recordkeeping Costs
The proposed SPA regulation has been developed in accordance with the statutory requirements
of the Shore Protection Act, 33 U.S.C. 2601, enacted November 18,1988. Under §4103 of SPA
(33 U.S.C. 2603), subparagraph (b)(2) requires "...as appropriate, the submission and adoption
by each responsible party of an operation and maintenance manual identifying procedures to be
used to prevent, report, and clean up any deposit of municipal or commercial waste into coastal
waters, including recordkeeping requirements...." These statutory requirements are addressed
in the proposed SPA regulation at 40 CFR §237.4(d) and (e) and §237.5(b) and (d).
The inclusion of waste handling and clean up procedures in the operation and maintenance
(O&M) manuals of waste sources, receiving facilities and vessels is necessary for several reasons,
in addition to the statutory requirement. First, the procedures must be developed, in written
form, so that they are available for reference and training of employees. Second, written
procedures for vessels must be available, if requested, for verification by the Department of
Transportation (specifically, the U.S. Coast Guard) of proper waste handling procedures prior
to granting a permit for waste transportation. Finally, the written procedures should be on hand
upon inspection or for enforcement actions.
The recordkeeping requirements consist of documenting any waste deposits into coastal waters
and the clean up status of such deposits. These records are necessary so that they will be
3 Ibid.
4 Ibid.
Chapter 6.0 6-9 Compliance Impacts
-------
available upon inspection or request for permit renewal as an indicator of the effectiveness of the
responsible party's procedures.
The O&M manuals may serve as training tools for employees to understand and follow the
procedures necessary to minimize and clean up waste deposits. They will also serve as references
for employees, following or hi place of training [note: SPA does not require training of
employees in these procedures]. Finally, the inclusion of procedures in the O&M manual will
demonstrate upon permitting or enforcement that the responsible party does have procedures in
place as required, and will provide a basis for evaluating the sufficiency of such procedures.
The records of waste deposits and clean up will serve, in conjunction with reporting, as an
indicator of the effectiveness of the responsible parties' procedures. These records may be
reviewed and considered by appropriate authorities during inspections as well as when the parties
request permit renewal.
Development of the O&M manuals and the waste deposit reporting form are one-time only costs,
whereas the reporting of waste deposits is an ongoing responsibility. The burdens of time and
cost for fulfilling these recordkeeping requirements are summarized in Exhibit 6-4. The estimate
provided in the exhibit includes average burden per responsible party. The annual cost will
consist of keeping records of each waste deposit, which will vary widely across the affected
parties, with a range of 0 to 1,170 hours per year (the upper end of this range is for the Fresh
Kills Landfill). For the segments excluding Fresh Kills, the average burden hours for the annual
component for each responsible party is only 8.1 hours. The annual burden might fluctuate,
either increasing or decreasing, for any responsible party. This would depend on the frequency
of waste deposits. It is anticipated that the total burden will decrease as waste deposit frequency
decreases. No other fluctuations are expected.
6.5 Conclusion
In summary, the estimated costs of compliance with the proposed SPA regulation are minimal
for almost all responsible parties. If standard waste reporting forms were developed, bom the
total cost and the paperwork burden would be significantly reduced for the first year.
Standardized procedures for waste handling to be included in O&M manuals would eliminate the
majority of first-year costs estimated for the affected parties. Nevertheless, the estimated
compliance costs associated with the proposed SPA regulation are expected to have no significant
impact on any industry segments or even on the individual entities, whether shoreside facilities
or vessels, involved in the transportation by vessel of municipal and commercial waste.
Chapter 6.0 6-10 Compliance Impacts
-------
Exhibit 6-4
Recordkeeping Burden And Costs
Initial Burden
Shoreside Facilities
22.9
$518
$127,000
Vessels
26.1
$910
$979,000
Total
$1,106,000
Annual Burden
Shoreside Facilities
13
$366
$ 86,000
Vessels
$29
$ 31,000
Total
$117,000
-------
References
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-------
Appendices
-------
Appendix A:
Details of Cost Estimates
-------
APPENDIX A
DETAILS OF COST ESTIMATES
The cost spreadsheets presented in this appendix show how die compliance cost estimates were
developed in detail. The first spreadsheet (pages A-2 through A-28) contains die costs for
shoreside facilities. The costs are shown by industry segment and provision of the proposed
standard. There are three pages for each segment.
The second spreadsheet (pages A-29 through A-49) contains the costs for vessels transporting
municipal or commercial waste. Individual cost elements are shown for each provision for each
affected industry segment. There are three pages for each segment.
A-l
-------
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
SHORES! DE FACILITIES
Segment:
MARINE TRANSFER STATIONS FOR
UNCONTAINERIZED GARBAGE (NYQ
Regulatory Requirement:
Action Required:
Frequency of Cost:
Small Company Definition: n/a
Total Com panics: 0
Small Companies: 0
Government Entities 1
Total Sites: 8
Small Co. Sites: 0
Government Sites: 8
Labor Rates
Management: $34.43
Supervisor: $27.90
Skilled Labor: $37.60
Unskilled Labor: $18.49
Average transactions per facility per year
Small company: 0
Large com pan/: o
Government: 936
237.4(a> Performance Standard
Waste Containment Structures & Equipment
Purchase. Deployment & Maintenance
One-time Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Mrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
Annual Cost
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
237.4(bl Fixed Lighting
Cost Basis: Loadings
Maint. Cost: $0
Labor Costs
Hourly Rate: $0
Hrs-Small: 0
Hrs-Large: 0
Hrs-Gov't: 0
Unit Cost per Year:
Small Co.: $0
Large Co.: $0
Gov't: $0
Percent Affected:
Small Cos.: 0%
Large Cos.: 0%
Gov't: 0%
Total Cost
Small Cos.: $0
Large Cos.: $0
Gov't: $0
All Affected Cos.:
$6]
Purchase and Installation
One-time Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Mrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
I '
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
$Q:|
Operation and Maintenance
Annual Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs- Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
I
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
$o|
A-2
-------
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
I SHORESIDE FACILITIES |
Segment:
MARINE TRANSFER STATIONS FOR
UNCONTAINERIZED GARBAGE (NYC)
Regulatory Requirement:
Action Required:
Frequency of Cost:
Small Company Definition: n/a
Total Companies: 0
Small Companies: 0
Government Entities 1
Total Sites: 8
Small Co. Sites: 0
Government Sites: 8
Labor Rates
Management: $34.43
Supervisor: $27.90
Skilled Labor: $37.60
Unskilled Labor: $18.49
Average transactions per facility per year
Small company: 0
Large company: 0
Government: 936
237.4(cl Waste Deposit Cleanup and Notification
Purchase Equipment
One-time Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
I *
Cleanupof Deposits and Post Telephone Number
Operation and Maintenance of Oversight Authority
Annual Cost
One-time Cost
Cost Basis: Loadings
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
$o|
Maint. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hre-Gov't:
Unit Cost per Year:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
t
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
$6|
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
1
$17
$28
2
2
2
$73
$73
$73
100%
100%
100%
$0
$0
$582
$582 1
A-3
-------
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
SHORES! DE FACILITIES
Segment:
MARI ME TRANSFER STATIONS FOR
UNCONTAINERIZED GARBAGE (NYC)
Regulatory Requirement:
Action Required:
Frequency of Cost:
Small Company Definition: n/a
Total Companies: 0
Small Companies: 0
Government Entitles 1
Total Sites: 8
Small Co. Sites: 0
Government Sites: 8
Labor Rates
Management: $34.43
Supervisor: $27.90
Skilled Labor: $37.60
Unskilled Labor: $18.49
Average transactions per facility per year
Small company: 0
Large company: 0
Government: 936
237.4(d> Waste Deposit Records
Develop Waste Deposit
Record Form
One-time Cost
Cost Basis: De|
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs- Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
1
Record Waste Deposits
Annual Cost
pt. Cost Basis: Loadings
$0
$34
0
0
2
Maint. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs- Large:
Hrs-Gov't:
$0
$26
0
0
234
Unit Cost per Year:
$0
$0
$69
0%
0%
100%
$0
$0
$69
$69 1
Small Co.:
Large Co.:
Gov't:
Percent Affected
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos
I
$0
$0
$6,528
0%
0%
100%
$0
$0
$52,222
$52,222)
Maintain Waste Deposit
Records (File Space)
One-time Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs -Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
I
$0
$0
0
0
0
$0
$0
$0
0%
0%
100%
$0
$0
$0
' $Ql
237.4(e) O&M Manuals
Develop O&M Manual
One-time Cost
Cost Basis: Dept.
$0
$0
0
0
0
$0
$0
$0
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs -Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
$5
$34
0
0
4
$0
$0
$178
100%
$0
$0
$176
$1 761
A-4
-------
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
I SHORESIDE FACILITIES |
Segment:
RECEIVING FACILITY FOR UNCONTAINERIZEP
GARBAGE FRESH KILLS LANDFILL!
Regulatory Requirement:
Action Required:
Frequency of Cost:
Small Company Definition: n/a
Total Companies: 0
Small Companies: 0
Government Entities 1
Total Sites: 1
Small Co. Sites: 0
Government Sites: 1
Labor Rates
Management: $34.43
Supervisor: $27.90
Skilled Labor: $37.60
Unskilled Labor: $18.49
Average transactions per facility per year
Small company: 0
Large company: 0
Government: 4680
237.4(al Performance Standard
Waste Containment Structures & Equipment
Purchase. Deployment & Maintenance
One-time Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Mrs-Small:
Hrs- Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
3B]
Annual Cost
Maint. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
$0
$0
0
0
0
Unit Cost per Year:
Small Co.: $0
Large Co.: $0
Gov't: $0
Percent Affected:
Small Cos.: 0%
Large Cos.: 0%
Gov't: 0%
Total Cost
Small Cos.: $0
Large Cos.: $0
Gov't: $0
All Affected Cos.:
r- m\
237.4(b) Fixed Lighting
Cost Basis: Loadings
Purchase and Installation
One-time Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Mrs-Small:
Hrs -Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
Operation and Maintenance
Annual Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs- Small:
Hrs -Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
$01
Jl
A-5
-------
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
SHORESIDE FACILITIES
Segment:
RECEIVING FACILITY FOR UNCONTAINERIZED
GARBAGE (FRESH KIL
LS LANDFILL)
Regulatory Requirement:
Action Required:
Frequency of Cost:
Small Company Definition: n/a
Total Companies: 0
Small Companies: 0
Government Entities 1
Total Sites: 1
Small Co. Sites: 0
Government Sites: 1
Labor Rates
Management: $34.43
Supervisor: $27.90
Skilled Labor: $37.60
Unskilled Labor: $18.49
Average transactions per facility per year
Small company: 0
Large company: 0
Government: 4660
237.4(c) Waste Deposit Cleanup and Notification
Purchase Equipment
One-time Cost
Cost Basis: Site
Eq. Cost:
Lab or Costs
Hourly Rate:
Hrs-Small:
Hrs- Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
f
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
$&l
Cleanup of Deposits and Post Telephone Number
Operation and Maintenance of Oversight Authority
Annual Cost One-time Cost
Cost Basis: Loadings
Maint. Cost: $0
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs- Large:
Hrs-Gov't:
Unit Cost per Year:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
I
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
$o|
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs- Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
I
$17
$28
0
0
2
$0
$0
$73
0%
0%
100%
$0
$0
$73
$73 1
A-6
-------
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
I SHORESIDE FACILITIES |
Segment:
RECEIVING FACILITY FOR UNCONTAiNERIZEP
GARBAGE (FRESH KILLS LANDFILL)
Regulatory Requirement:
Action Required:
Frequency of Cost:
Small Company Definition: n/a
Total Companies: 0
Small Companies: 0
Government Entities 1
Total Sites: 1
Small Co. Sites: 0
Government Sites: 1
Labor Rates
Management: $34.43
Supervisor: $27.90
Skilled Labor: $37.60
Unskilled Labor: $16.49
Average transactions per facility per /ear
Small company: 0
Large company: 0
Government: 4680
237.4(d) Waste Deposit Records
Develop Waste Deposit
Record Form
One-time Cost
Cost Basis: Site
Eq. Cost:
LaborCosts
Hourly Rate:
Hrs- Small:
Hrs-Large:
Hrs-Gov't:
$0
$34
0
0
0.5
Maint. Cost:
LaborCosts
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
$0
$0
$17
Percent Affected:
Small Cos.: 0%
Large Cos.: 0%
Gov't: 100%
Total Cost
Small Cos.: $0
Large Cos.: $0
Gov't: $17
All Affected Cos.:
Record Waste Deposits
Annual Cost
Cost Basis: Loadings
$0
$28
0
0
1170
Unit Cost per Year:
Small Co.: $0
Large Co.: $0
Gov't: $32,639
Percent Affected:
Small Cos.: 0%
Large Cos.: 0%
Gov't: 100%
Total Cost
Small Cos.: $0
Large Cos.: $0
Gov't: $32.639
All Affected Cos.:
Maintain Waste Deposit
Records (File Space)
One-time Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Mrs-Small:
Hrs-Large:
Hrs-Qov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.: 0%
Large Cos.: 0%
Gov't: 100%
Total Cost
Small Cos.: $0
Large Cos.: $0
Gov't: $0
All Affected Cos.:
237.4(e) O&M Manuals
Develop O&M Manual
One-time Cost
Cost Basis: Dept.
$5
$34
0
0
4
$5
$5
$143
Percent Affected:
Small Cos.: 0%
Large Cos.: 0%
Gov't: 100%
Total Cost
Small Cos.: $0
Large Cos.: $0
Gov't: $143
All Affected Cos.:
$0
$0
0
0
0
$0
$0
$0
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
$17|
$32,639 1
c
$143|
A-7
-------
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
I SHORES! DE FACILITIES |
Segment:
RECEIVING FACILITIES FOR PACKAGED
GARBAGE FROM OIL & GAS PLATFORMS
Regulatory Requ irement:
Action Required:
Frequency of Cost:
Small Company Definition: Independent
Operation (Not Oil Company)
Total Companies:
Small Companies:
Total Sites:
Small Co. Sites:
Labor Rates
Management:
Supervisor:
Skilled Labor:
Unskilled Labor:
79
51
144
61
$30.54
$21.60
$25.07
$18.22
Average transactions per facility per year
Small company:
Large company:
210
210
2 37.4 (a) Performance Standard
Waste Containment Structures & Equipment
Purchase. Deployment & Maintenance
One-time Cost
Cost Basis:
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs -Large:
Unit Cost:
Small Co.:
Large Co.:
Site
$3,000
$22
1
1
Annual Cost
Cost Basis: Loadinqs
Maint. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs- Large:
$0
$18
53
53
Unit Cost per Year:
$3,022
$3,022
Percent Affected:
Small Cos.:
Large Cos.:
Total Cost
Small Cos.:
Large Cos.:
75%
10%
$138,238
$25,079
All Affected Cos.:
L
$163,318)
Small Co.:
Large Co.:
Percent Affected
Small Cos.:
Large Cos.:
Total Cost
Small Cos.:
Large Cos.:
All Affected Cos
(Z
$957
$957
75%
10%
$43,768
$7,940
$51,708)
237.4{bJ Fixed Liahtina
Purchase and Installation
One-time Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs -Large:
Unit Cost:
Small Co.:
Large Co.:
Percent Affected:
Small Cos.:
Large Cos.:
Total Cost
Small Cos.:
Large Cos.:
All Affected Cos.:
.
$0
$0
0
0
$0
$0
0%
0%
$0
$0
Operation and Maintenance
Annual Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Larga;
Unit Cost:
Small Co.:
Large Co.:
Percent Affected:
Small Cos.:
Large Cos.:
Total Cost
Small Cos.:
Large Cos.:
All Affected Cos.:
$0
$0
0
0
$0
$0
0%
0%
$0
$0
1 $0|
A-8
-------
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
I SHORESIDE FACILITIES
Segment:
RECEIVING FACILITIES FOR PACKAGED
GARBAGE FROM OIL & GAS PLATFORMS
Regulatory Requirement:
Action Required:
Frequency of Cost:
Small Company Definition: Independent
Operation (Not Oil Company)
Total Companies: 79
Small Companies: 51
Total Sites: 144
Small Co. Sites: 61
Lab or Rates
Management: $30.54
Supervisor: $21.60
Skilled Labor: $25.07
Unskilled Labor: $18.22
Average transactions per facility per year
Small company: 210
Large company: 210
237.4(cl Waste Deposit Cleanup and Notification
Purchase Equipment
Annual Cost
Cost Basis: Site
Eq. Cost: .
Lab or Costs
Hourly Rate:
Mrs-Small:
Hrs-Large:
Unit Cost:
Small Co.:
Large Co.:
Percent Affected:
Small Cos.:
Large Cos.:
Cleanup of Deposits and Post Telephone Number
Operation and Maintenance of Oversight Authority
Annual Cost
One-time Cost
Cost Basis: Loadings
$50
$22
0.5
0.5
$61
$61
75%
10%
Maint. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Unit Cost per Year:
Small Co.:
Large Co.:
Percent Affected:
Small Cos.:
Large Cos.:
$0
$22
0
0
$0
$0
75%
10%
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Unit Cost:
Small Co.:
Large Co.:
Percent Affected:
Small Cos.:
Large Cos.:
$17
$22
2
2
$60
$60
100%
100%
Total Cost
Small Cos.: $2,762
Large Cos.: $505
All Affected Cos.:
Total Cost
Small Cos.: $0
Large Cos.: $0
All Affected Cos.:
$3.2661
L
JO]
Total Cost
Small Cos.: $3,673
Large Cos.: $4,997
All Affected Cos.:
I $8.6701
A-9
-------
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
[T^SHORESIDE FACILITIES |
Segment:
RECEIVING FACILITIES FOR PACKAGED
GARBAGE FROM OIL & GAS PLATFORMS
237.4(d) Waste Deposit Records
Action Required:
Frequency of Cost:
Small Company Definition: Independent
Operation (Not Oil Company)
Total Companies: 79
Small Companies: 51
Total Sites: 144
Small Co. Sites: 61
Labor Rates
Management: $30.54
Supervisor: $21.60
Skilled Labor: $25.07
Unskilled Labor: $16.22
Average transactions per facility per year
Small company: 210
Large company: 210
Develop Waste Deposit
Record Form
One-time Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Unit Cost:
Small Co.:
Large Co.:
Percent Affected:
Small Cos.:
Large Cos.:
Total Cost
Small Cos.:
Large Cos.:
All Affected Cos.:
d
$0
$31
1
1
$31
$31
100%
100%
$1 ,863
$2,535
$4,398 1
Record Waste Deposits
Annual Cost
Cost Basis: Loadings
Maint. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Unit Cost per Year:
Small Co.:
Large Co.:
Percent Affected:
Small Cos.:
Large Cos.: '
Total Cost
Small Cos.:
Large Cos.:
All Affected Cos.:
$0
$22
0
0
$0
$0
100%
100%
$0
$0
Maintain Waste Depost
Records (File Space)
One-time Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Unit Cost:
Small Co.:
Large Co.:
Percent Affected:
Small Cos.:
Large Cos.:
Total Cost
Small Cos.:
Large Cos.:
All Affected Cos.:
$0
$18
0
0
$0
$0
100%
100%
$0
$0
237.4(e) O&M Manuals
Develop O&M Manual
One-time Cost
Cost Basis: Site
Eq. Cost: $5
Labor Costs
Hourly Rate: $22
Hrs-Small: 56
Hrs-Large: 28
Unit Cost:
Small Co.: $1,215
Large Co.: $610
Percent Affected:
Small Cos.: 90%
Large Cos.: 70%
Total Cost
Small Cos.: $66,692
Large Cos.: $35,435
All Affected Cos.:
| $102.1271
A-10
-------
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
I SHORESIDE FACILITIES I
Segment:
RECEIVING FACILITIES FOR PACKAGED
GARBAGE FROM VESSELS ANCHORED
OFFSHORE
Regulatory Requirement:
Action Required:
Frequency of Cost:
Small Company Definition: n/a
Total Companies: 3
Small Companies: 3
Govern merit Entities 0
Total Sites: 3
Small Co. Sites: 3
Government Sites: 0
Labor Rates
Management: $46.05
Supervisor: $36.45
Skilled Labor: $34.61
Unskilled Labor: $25.63
Average transactions per facility per year
Small corn pan/: 189
Large company: O
Government: 0
237.4(a) Performance Standard
237.4(bl Fixed Lighting
Waste Containment Structures & Equipment
Purchase. Deployment & Maintenance
One-time Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
Annual Cost
Cost Basis: Loadings
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
Maint. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost per Year:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
Purchase and Installation
One-time Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
Operation and Maintenance
Annual Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
illtlllll [ ' $0| |. $0| I $Q|
A-ll
-------
SHORE PROTECTIONACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
I 3HORESIDE FACILITIES |
Segment:
RECEIVING FACILITIES FOR PACKAGED
GARBAGE FROM VESSELS ANCHORED
OFFSHORE
Regulatory Requirement:
Action Required:
Frequency of Cost:
Small Company Definition: n/a
Total Companies: 3
Small Companies: 3
Government Entities 0
Total Sites: 3
Small Co. Sites: 3
Government Sites: 0
Labor Rates
Management: $46.05
Supervisor: $38.45
Skilled Labor: $34.61
Unskilled Labor: $25.63
Average transactions per facility per year
Small company: 189
Large company: 0
Government: 0
237.4(c) Waste Deposit Cleanup and Notification
Purchase Equipment
One-time Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs- Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
h
Cleanup of Deposits and Post Telephone Number
Operation and Maintenance of Oversight Authority
Annual Cost
One-time Cost
Cost Basis: Loadings
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
$Q|
Maint. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs -Large:
Hrs-Gov't:
Unit Cost per Year:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
1 -
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
$6|
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
1
$17
$38
2
2
2
$94
$94
$94
100%
100%
100%
$282
$0
$0
$282 |
A-12
-------
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
I 3HORESIDE FACILITIES \
Segment:
RECEIVING FACILITIES FOR PACKAGED
GARBAGE FROM VESSELS ANCHORED
OFFSHORE
Regulatory Requirement:
Action Required:
Frequency of Cost:
Small Company Definition: n/a
Total Companies: 3
Small Companies: 3
Government Entities 0
Total Sites: 3
Small Co. Sites: 3
Government Sites: 0
Labor Rates
Management: $48.05
Supervisor: $39.45
Skilled Labor: $34.61
Unskilled Labor: $25.63
Average transactions per facility per year
Small company: 189
Large company: 0
Government: 0
237.4(d) Waste Deposit Records
Develop Waste Deposit
Record Form
One-time Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
$0
$48
1
1
1
$48
$48
$48
100%
100%
100%
$144
$0
$0
Record Waste Deposits
Annual Cost
Cost Basis: Loadings
Maint. Cost: $0
Labor Costs
Hourly Rate: $38
Hrs-Small: 0
Hrs-Large: 0
Hrs-Gov't: 0
Unit Cost per Year:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
$0
$0
$0
100%
100%
100%
$0
$0
$0
Maintain Waste Deposit
Records (File Space)
One-time Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
$0
$26
0
0
0
$0
$0
$0
100%
100%
100%
$0
$0
$0
237.4(el O&M Manuals
Develop O&M Manual
One-time Cost
Cost Basis: Site
$0
$26
0
0
0
$0
$0
$0
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
$5
$48
16
16
16
$774
$774
$769
100%
100%
100%
I $144|
Total Cost
Small Cos.: $2,322
Large Cos.: $0
Gov't: $0
All Affected Cos.:
| $2,322]
A-13
-------
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
I SHORESIDE FACILITIES I
Segment:
ISLANDS (SOURCES OF PACKAGED GARBAGE!
Regulatory Requirement:
Action Required:
Frequency of Cost:
Small Company Definition: Privately owned
landing
Total Companies: 6
Small Companies: 6
Government Entities 3
Total Sites: 13
Small Co. Sites: 6
Government Sites: 7
Labor Rates
Management: $45.16
Supervisor: $36.14
Skilled Labor: $32.52
Unskilled Labor: $24.09
Average transactions per facility per year
Small company: ' 50
Large company: 0
Government: 100
237.4(al Performance Standard
Waste Containment Structures & Equipment
Purchase. Deployment & Maintenance
One-time Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
Annual Cost
237.4(M Fixed Lighting
Cost Basis: Loadings
Maint. Cost: $0
Labor Costs
Hourly Rate: $0
Hrs-Small: 0
Hrs-Large: 0
Hrs-Gov't: 0
Unit Cost per Year:
Small Co.: $0
Large Co.: $0
Gov't: $0
Percent Affected:
Small Cos.: 0%
Large Cos.: 0%
Gov't: 0%
Total Cost
Small Cos.: $0
Large Cos.: $0
Gov't: $0
All Affected Cos.:
Purchase and Installation
One-time Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
Operation and Maintenance
Annual Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
I
A-14
-------
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
I 8HORE3IDE FACILITIES
Segment:
ISLANDS (SOURCES OF PACKAGED GARBAGE!
Regulatory Requirement:
Action Required:
Frequency of Cost:
Small Company Definition: Privately owned
...
Total Companies:
Small Companies:
Government Entities
Total Sites:
Small Co. Sites:
Government Sites:
Labor Rates
Management:
Supervisor:
Skilled Labor:
Unskilled Labor:
landing
6
6
3
13
6
7
$45.16
$36.14
$32.52
$24.09
Average transactions per facility per year
Small company:
Large company:
Government:
50
0
100
237.4(c) Waste Deoosit Cleanuo and
Purchase Equipment
Annual Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Mrs-Small:
Hrs- Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
I
Cleanup of Deposits and
Operation and Maintenance
Annual Cost
Notification
Post Telephone Number
of OverslghtAuthorltv
One-time Cost
Cost Basis: Loadings
$50
$36
0.5
0.5
0.5
$68
$68
$68
33%
0%
14%
$136
$0
$68
$204 1
Maint. Cost:
Labor Costs
Hourly Rate:
Hrs- Small:
Hrs -Large:
Hrs-Gov't:
Unit Cost per Year:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
t „
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
,, $Q|
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs- Small:
Hrs- Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
I $
$17
$36
2
2
2
$89
$89
$89
100%
100%
100%
$536
$0
$625
1.161 |
A-15
-------
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
| 8HORESIDE FACILITIES
Segment:
ISLANDS (SOURCES OF PACKAGED GARBAGE!
Regulatory Requirement:
Action Required:
Frequency of Cost:
Small Company Definition: Privately owned
...
Total Companies:
Small Companies:
Government Entities
Total Sites:
Small Co. Sites:
Government Sites:
Labor Rates
Management:
Supervisor:
Skilled Labor:
Unskilled Labor:
landing
6
6
3
13
6
7
$45.16
$36.14
$32.52
$24.09
Average transactions per facility per year
Small company:
Large company:
Government:
50
0
100
237.4(d) Waste Deposit Records
Develop Waste Deposit
Record Form
One-time Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs- Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
I
$0
$45
1
1
1
$45
$45
$45
100%
100%
100%
$271
$0
$316
$567 1
Record Waste Deposits
Annual Cost
Maintain Waste Deposit
Records (File Space)
One-time Cost
Cost Basis: Loadings
Maint. Cost:
Labor Costs
Hourly Rate:
Hrs- Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost per Year:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
[
$0
$0
0
0
0
$0
$0
$0
100%
100%
100%
$0
$0
$0
•$0|
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs- Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
x Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
I
$0
$0
0
0
0
$0
$0
$0
100%
100%
100%
$0
$0
$0
ft I
237.4tel O&li/l Manuals
Develop O&M Manual
One-time Cost
Cost Basis: Site
Eq. Cost: $5
Labor Costs
Hourly Rate: $45
Hrs-Small: 16
Hrs-Large: 16
Hrs-Gov't: 16
Unit Cost:
Small Co.: $726
Large Co.: $728
Gov't: $758
Percent Affected:
Small Cos.: 100%
Large Cos.: 100%
Gov't: 100%
Total Cost
Small Cos.: $4,366
Large Cos.: $0
Gov't: $5.303
All Affected Cos.:
I $9.6691
A-16
-------
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
I SHORESIDE FACILITIES
Segment:
RECEIVING FACILITIES FOR PACKAGED
GARBAGE FROM ISLANDS
Regulatory Requirement:
Action Required:
Frequency of Cost:
Small Company Definition: n/a
Total Companies: 1
Small Companies: 0
Government Entities 1
Total Sites: 2
Small Co. Sites: 0
Government Sites: 1
Labor Rates
Management: $45.16
Supervisor: $36.14
Skilled Labor: ., $32.52
Unskilled Labor: $2-4.09
Average transactions per facility per /ear
Small company: 560
Large company: 0
Government: 364
237.4(a) Performance Standard
237.4(b) Fixed Lighting
Waste Containment Structures & Equipment
Purchase. Deployment & Maintenance
One-time Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Mrs-Small:
Mrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
[ ;
Annual Cost
Cost Basis: Loadings
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
" *D|
Maint. Cost:
Labor Costs
Hourly Rate:
Hrs -Small:
Hrs -Large:
Hrs-Gov't:
Unit Cost per Year:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
r;
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
$o|
Purchase and Installation
One-time Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs -Small:
Hrs -Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
1
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
' $$l
Operation and Maintenance
Annual Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs- Small:
Hrs -Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
1
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
$Q|
A-17
-------
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
I SHORESIPE FACILITIES |
Segment:
RECEIVING FACILITIES FOR PACKAGED
GARBAGE FROM ISLANDS
Regulatory Requirement:
Action Required:
Frequency of Cost:
Small Company Definition: n/a
Total Companies: 1
Small Companies: 0
Government Entitles 1
Total Sites: 2
Small Co. Sites: 0
Government Sites: 1
Labor Rates
Management: $45.16
Supervisor: $36.14
Skilled Labor: $32.52
Unskilled Labor: $24.09
Average transactions per facility per year
Small company: 560
Large company: 0
Government: 364
237.4(cl Waste Deposit Cleanup and Notification
Purchase Equipment
One-time Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
f
Cleanup of Deposits and Post Telephone Number
Operation and Maintenance of Oversight Authority
Annual Cost
One-time Cost
Cost Basis: Loadings
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
$o|
Maint. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost per Year:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
f
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
' $o|
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
1
$17
$36
2
2
2
$89
$89
$89
100%
100%
100%
$0
$89
$89
$179)
A-18
-------
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
I SHORESIDE FACILITIES I
Segment:
RECEIVING FACILITIES FOR PACKAGED
GARBAGE FROM ISLANDS
Regulatory Requirement:
Action Required:
Frequency of Cost:
Small Company Definition: n/a
Total Companies: 1
Small Companies: o
Government Entities 1
Total Sites: 2
Small Co. Sites: 0
Government Sites: 1
Labor Rates
Management: $45.16
Supervisor: $36.14
Skilled Labor: $32.52
Unskilled Labor: $24.09
Average transactions per facility per year
Small company: 560
Large company: 0
Government: 364
237.4(d) Waste Deposit Records
Develop Waste Deposit
Record Form
One-time Cost
Cost Basis: Site
Eq. Cost: $0
Labor Costs
Hourly Rate: $45
Hrs- Small: 1
Hrs-Large: 1
Hrs-Gov't: 1
Unit Cost:
Small Co.: $45
Large Co.: $45
Gov't: $45
Percent Affected:
Small Cos.: 100%
Large Cos.: 100%
Gov't: 100%
Total Cost
Small Cos.: $0
Large Cos.: $45
Gov't: $45
All Affected Cos.:
Maintain Waste Deposit
Record Waste Deposits
Annual Cost
Cost Basis: Loadings
Maint. Cost: $0
Labor Costs
Hourly Rate: $0
Hrs-Small: 0
Hrs-Large: 0
Hrs-Qov't: 0
Unit Cost per Year:
Small Co.: $0
Large Co.: $0
Gov't: $0
Percent Affected:
Small Cos.: 100%
Large Cos.: 100%
Gov't: 100%
Total Cost
Small Cos.: $0
Large Cos.: $0
Gov't: $0
All Affected Cos.:
Records (File Space)
One-time Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
$0
$0
0
0
0
$0
$0
$0
100%
100%
100%
$0
$0
$0
I $90 | | $0] I • f&|
237.4(e) O&M Manuals
Develop O&M Manual
One-time Cost
Cost Basis: Site
Eq. Cost: $5
Labor Costs
Hourly Rate: $45
Mrs-Small: 16
Hrs-Large: 16
Hrs-Gov't: 16
Unit Cost:
Small Co.: $728
Large Co.: $728
Gov't: $728
Percent Affected:
Small Cos.: 100%
Large Cos.: 100%
Gov't: 100%
Total Cost
Small Cos.: $0
Large Cos.: $728
Gov't: $728
All Affected Cos.:
I $1,455|
A-19
-------
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
| SHORE3IDE FACILITIES
Segment:
SEWAGE SLUDGE SOURCES
Regulatory Requirement:
Action Required:
Frequency of Cost:
Small Company Definition: n/a
Total Companies: 0
Small Companies: 0
Government Entities 4
Total Sites: 7
Small Co. Sites: 0
Government Sites: 7
Labor Rates
Management: $34.43
Supervisor: $27.90
Skilled Labor: $20.86
Unskilled Labor: $18.49
Average transactions per facility per year
Small company: 0
Large company: 0
Government: 1356
237.4(a) Performance Standard
Waste Containment Structures & Equipment
Purchase. Deployment & Maintenance
237.4fbl Fixed Lighting
One-time Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs- Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
f
Annual Cost
Cost Basis: Loadings
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
$o|
Maint. Cost:
Labor Costs
Hourly Rate:
Hrs- Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost per Year:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
i
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
$0)
Purchase and Installation
One-time Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Mrs-Small:
Mrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
Operation and Maintenance
Annual Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs- Small:
Hrs- Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
i m\ i "w\
A-20
-------
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
I SHORESIDE FACILITIES]
Segment:
SEWAGE SLUDGE SOURCES
Regulatory Requirement:
Action Required:
Frequency of Cost:
Small Company Definition: n/a
Total Companies: 0
Small Companies: 0
Government Entities 4
Total Sites: 7
Small Co. Sites: 0
Government Sites: 7
Labor Rates
Management: $34.43
Supervisor: $27.90
Skilled Labor: $20.86
Unskilled Labor: $18.49
Average transactions per facility per year
Small company: 0
Large company: 0
Government: 1356
237.4tel Waste Deposit Cleanup and Notification
Purchase Equipment
One-time Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs- Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
Cleanup of Deposits and Post Telephone Number
Operation and Maintenance of Oversight Authority
Annual Cost One-time Cost
Cost Basis: Loadings
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
Maint. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs- Large:
Hrs-Gov't:
Unit Cost per Year:
Small Co.:
Large Co.:
Gov't:
Percent Affected;
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs -Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
$17
$28
2
2
2
$73
$73
$73
100%
100%
100%
$0
$0
$510
I $510|
A-21
-------
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
I SHORESIDE FACILITIES
Segment:
SEWAGESLUDGESOURCES
Regulatory Requirement:
Action Required:
Frequency of Cost:
Small Company Definition: n/a
Total Companies: 0
Small Companies: 0
Government Entities 4
Total Sites: 7
Small Co. Sites: 0
Government Sites: 7
Labor Rates
Management: $34.43
Supervisor: $27.90
Skilled Labor: $20.86
Unskilled Labor: $16.49
Average transactions per facility per year
Small company: 0
Large company: 0
Government: 1356
237.4(dl Waste Deposit Records
Develop Waste Deposit
Record Form
One-time Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs- Small:
Hrs- Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
1
$0
$34
16
16
16
$551
$551
$551
0%
0%
14%
$0
$0
$551
$551 |
Record Waste Deposits
Annual Cost
Cost Basis: Loadings
Maint. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost per Year:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
I
$0
$28
3.4
3.4
3.4
$95
$95
$95
0%
0%
14%
$0
$0
$95
$95 1
Maintain Waste Deposit
Records (File Space)
Annual Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
I
$0
$18
2
2
2
$37
$37
$37
0%
0%
14%
$0
$0
$37
$37 1
237.4(ei O&M Manuals
Develop O&M Manual
One-time Cost
Cost Basis: Site
$0
$18
2
2
2
$37
$37
$37
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
$5
$34
4
4
4
$143
$143
$173
Percent Affected:
Small Cos.: 100%
Large Cos.: 100%
Gov't: 100%
Total Cost
Small Cos.: $0
Large Cos.: $0
Gov't: $1.209
All Affected Cos.:
I $1.209]
A-22
-------
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
I SHORESIDE FACILITIES |
Segment:
SEWAGE SLUDGE RECEIVING FACILITIES
Regulatory Requirement:
Action Required:
Frequency of Cost:
Small Company Definition: n/a
Total Companies: 4
Small Companies: 0
Government Entities 2
Total Sites: 6
Small Co. Sites: 0
Government Sites: 2
Labor Rates
Management: $34.43
Supervisor: $27.90
Skilled Labor: $20.86
Unskilled Labor: $18.49
Average transactions per facility per year
Small com pany: 1582
Large company: 1582
Government: 1562
237.4(a) Performance Standard
237.4(bl Fixed Lighting
Waste Containment Structures & Equipment
Purchase. Deployment & Maintenance
One-time Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
temm®
\fiftf{'fifffwi
Annual Cost
Cost Basis: Loadings
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
illH
Maint. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost per Year:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
1 '
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
" $0|
Purchase and Installation
One-time Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
I ;..
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
...$0|
Operation and Maintenance
Annual Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
1
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
... $0.1
A-23
-------
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
I SHORESIDE FACILITIES |
Segment:
SEWAGE SLUDGE RECEIVING FACILITIES
Regulatory Requ irement:
Action Required:
Frequency of Cost:
Small Company Definition: n/a
Total Companies: 4
Small Companies: 0
Government Entities 2
Total Sites: 6
Small Co. Sites: 0
Government Sites: 2
Labor Rates
Management: $34.43
Supervisor: $27.90
Skilled Labor: $20.86
Unskilled Labor: $18.49
Average transactions per facility per year
Small company: 1582
Large company: 1582
Government: 1582
237.4(c) Waste Deposit Cleanup and Notification
Purchase Equipment
One-time Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs- Small:
Mrs- Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
Cleanup of Deposits and Post Telephone Number
Operation and Maintenance of Oversight Authority
Annual Cost One-time Cost
Cost Basis: Loadings
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
Maint. Cost:
Labor Costs
Hourly Rate:
Hrs- Small:
Hrs -Large:
Hrs-Gov't:
Unit Cost per Year:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Smalt Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs -Small:
Hrs- Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
$17
$28
2
2
2
$73
$73
$73
100%
100%
100%
$0
$291
$146
I $437|
A-24
-------
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
I SHORESIDE FACILITIES |
Segment:
SEWAGE SLUDGE RECEIVING FACILITIES
Regulatory Requirement:
Action Required:
Frequency of Cost:
Small Company Definition: n/a
Total Companies: 4
Small Companies: 0
Government Entities 2
Total Sites: 6
Small Co. Sites: 0
Government Sites: 2
Labor Rates
Management: $34.43
Supervisor: $27.90
Skilled Labor: $20.86
Unskilled Labor: $18.49
Average transactions per facility per year
Small company: 1582
Large company: 1582
Government: 1582
237.4(d) Waste Deposit Records
Develop Waste Deposit
Record Form
One-time Cost
Cost Basis: Site
Eq.Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
$34
$34
$34
100%
100%
100%
$0
$138
$69
Record Waste Deposits
Annual Cost
Maintain Waste Deposit
Records (File Space)
Annual Cost
'Cost Basis: Loadings Cost Basis: Site
$0
$34
1
1
1
Maint. Cost:
Labor Costs
Hourly Rate:
Mrs-Small:
Hrs-Large:
Hrs-Gov't:
I $207|
Unit Cost per Year:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.: 100%
Large Cos.: 100%
Gov't: 100%
Total Cost
Small Cos.: $0
Large Cos.: $441
Gov't: $221
All Affected Cos.:
I $6621
$0
$28
4.0
4.0
4.0
$110
$110
$110
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs- Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.: 100%
Large Cos.: 100%
Gov't: 100%
Total Cost
Small Cos.: $0
Large Cos.: $112
Gov't: $56
All Affected Cos.:
237.4(el O&M Manuals
Develop O&M Manual
One-time Cost
Cost Basis: Site
$5
$34
4
4
4
$143
$143
$148
Percent Affected:
Small Cos.: 100%
Large Cos.: 100%
Gov't: 100%
Total Cost
Small Cos.: $0
Large Cos.: $571
Gov't: $295
All Affected Cos.:
$0
$28
1
1
1
$28
$28
$28
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs- Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
$167|
$8661
A-25
-------
SHORE PROTECTIONACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
3HORESIDE FACILITIES
Segment:
DRILLING MUD RECEIVING FACILITIES
(OIL FIELD TREATMENT FACILITIES!
Regulator/ Requirement:
Action Required:
Frequency of Cost:
Small Company Definition: < 3 facilities
Total Companies: 29
Small Companies: 23
Total Sites: 50
Small Co. Sites: 25
Labor Rates
Management: $30.54
Supervisor: $21.60
Skilled Labor: $25.07
Unskilled Labor: $16.22
Average transactions per facility per year
Small company: 270
Large company: 270
237.4(a) Performance Standard
237.4fbl Fixed Lighting
Waste Containment Structures & Equipment
Purchase. Deployment & Maintenance
One-time Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Unit Cost:
Small Co.:
Large Co.:
Percent Affected:
Small Cos.:
Large Cos.:
Total Cost
Small Cos.:
Large Cos.:
All Affected Cos.:
I
$0
$0
0
0
$0
$0
0%
0%
$0
$0
$o 1
Annual Cost
Cost Basis: Loadings
Maint. Cost: $0
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Unit Cost per Year:
Small Co.:
Large Co.:
Percent Affected:
Small Cos.:
Large Cos.:
Total Cost
Small Cos.:
Large Cos.:
All Affected Cos.:
t
$0
0
0
$0
$0
0%
0%
$0
$0
MQ.I
Purchase and Installation
One-time Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Unit Cost:
Small Co.:
Large Co.:
Percent Affected:
Small Cos.:
Large Cos.:
Total Cost
Small Cos.:
Large Cos.:
All Affected Cos.:
1
$0
$0
0
0
$0
$0
0%
0%
$0
$0
M\
Operation and Maintenance
Annual Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Unit Cost:
Small Co.:
Large Co.:
Percent Affected:
Small Cos.:
Large Cos.:
Total Cost
Small Cos.:
Large Cos.:
All Affected Cos.:
1
$0
$0
0
0
$0
$0
0%
0%
$0
$0
$Q|
A-26
-------
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
I SHORESIDE FACILITIES |
Segment:
DRILLING MUD RECEIVING FACILITIES
(OILFIELD TREATMENT FACILITIES)
Regulatory Requirement:
Action Required:
Frequency of Cost:
Small Company Definition: < 3 facilities
Total Companies: 29
Small Companies: 23
Total Sites: 50
Small Co. Sites: 25
Lab or Rates
Management: $30.54
Supervisor: $21.60
Skilled Labor: $25.07
Unskilled Labor: $18.22
Average transactions per facility per year
Small company: 270
Large company: 270
237.4(c) Waste Deposit Cleanup and Notification
Purchase Equipment
One-time Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs- Small:
Mrs -Large:
Unit Cost:
Small Co.:
Large Co.:
Percent Affected:
Small Cos.:
Large Cos.:
Total Cost
Small Cos.:
Large Cos.:
All Affected Cos.:
Cleanup of Deposits and
Operation and Maintenance
Annual Cost
Cost Basis: Loadings
$0
$0
0
0
$0
$0
0%
0%
$0
$0
nil
Maint. Cost:
Labor Costs
Hourly Rate:
Hrs- Small:
Hrs -Large:
Unit Cost per Year:
Small Co.:
Large Co.:
Percent Affected:
Small Cos.:
Large Cos.:
Total Cost
Small Cos.:
Large Cos.:
All Affected Cos.:
f,
$0
$0
0
0
$0
$0
0%
0%
$0
$0
..Ml
Post Telephone Number
of Oversight Authority
One-time Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs- Large:
Unit Cost:
Small Co.:
Large Co.:
Percent Affected:
Small Cos.:
Large Cos.:
Total Cost
Small Cos.:
Large Cos.:
All Affected Cos.:
in
$17
$22
2
2
$60
$60
100%
100%
$1.505
$1,505
$3,010 1
A-27
-------
SHORE PROTECTIONACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
I SHORE8IDE FACILITIES
Segment:
DRILLING MUD RECEIVING FACILITIES
fOIL FIELD TREATMENT FACILITIES!
Regulator/ Requirement:
Action Required:
Frequency of Cost:
Small Com pany Definition: < 3 facilities
Total Companies: 29
Small Companies: 23
Total Sites: 50
Small Co. Sites: 25
Labor Rates
Management: $30.54
Supervisor: $21.60
Skilled Labor: $25.07
Unskilled Labor: $18.22
Average transactions per facility per year
Small company: 270
Large company: 270
237,4(d) Waste Deposit Records
Develop Waste Deposit
Record Form
One-time Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs -Large:
Unit Cost:
Small Co.:
Large Co.:
Percent Affected:
Small Cos.:
Large Cos.:
Total Cost
Small Cos.:
Large Cos.:
All Affected Cos.:
$0
$0
0
0
$0
$0
0%
0%
$0
$0
Record Waste Deposits
Annual Cost
Cost Basis: Loadings
Maint. Cost: $0
Lab or Costs
Hourly Rate: $0
Hrs-Small: o
Mrs-Large: 0
Unit Cost per Year:
Small Co.:
Large Co.:
Percent Affected:
Small Cos.:
Large Cos.:
Total Cost
Small Cos.:
Large Cos.:
All Affected Cos.:
$0
$0
0%
0%
$0
$0
Maintain Waste Deposit
Records (File Space)
One-time Cost
Cost Basis: Site
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs- Large:
Unit Cost:
Small Co.:
Large Co.:
Percent Affected:
Small Cos.:
Large Cos.:
Total Cost
Small Cos.:
Large Cos.:
All Affected Cos.:
$0
$0
0
0
$0
$0
0%
0%
$0
$0
t $0| t $Q| | $Q\
237.4(e> O&M Manuals
Develop O&M Manual
One-time Cost
Cost Basis: Site
$0
$0
0
0
Eq. Cost:
Labor Costs
Hour!/ Rate:
Hrs-Small:
Mrs-Large:
Unit Cost:
Small Co.:
Large Co.:
Percent Affected:
Small Cos.:
Large Cos.:
$5
$31
2
2
$66
$66
100%
100%
Total Cost
Small Cos.: $1,652
Large Cos.: $1,652
All Affected Cos.:
I $3,3041
A-28
-------
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
L
WASTE TRANSPORT VESSELS
Segment:
BARGES FOR UNCONTA1NERIZED GARBAGE
(NYC DOS)
Regulatory Requirement:
Action Required:
Frequency of Cost;
Small Company Definition: n/a
Total Companies: 0
Small Companies: 0
Government Entities 1
Total Vessels: 104
Small Co. Vessels: o
Qov't Vessels: 104
Labor Rates
Management: $36.61
Supervisor: $29.90
Skilled Labor: $27.90
Unskilled Labor: $21.91
Total approximate barge loads per /ear
Small company: 0
Large company: 0
Government: 7080
237.5(a) Performance Standard
Implement and
Follow Procedures
Annual Cost
Cost Basis: Vessel
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
f ' '
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
' $ftl
Leachate Containment and Collection
One-time Cost
Annual Cost
Cost Basis: Vessel
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
1 ' x"
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
'$&]
Cost Basis: Loadings
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
r
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
-"W
Label and Seal
Waste Ports and Valves
One-time Cost
Cost Basis: Vessel
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
I'"*-
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
$o|
A-29
-------
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
WASTE TRANSPORT VESSELS
Segment:
BARGES FOR UNCONTAINERIZEDGARBAGE
(NYC DOS)
Regulatory Requirement:
Action Required:
Frequency of Coat:
Small Company Definition: n/a
Total Companies: 0
Small Companies: 0
Govern merit Entities 1
Total Vessels: 104
Small Co. Vessels: 0
Gov't Vessels: 104
Labor Rates
Management: $36.61
Supervisor: $29.90
Skilled Labor: $27.90
Unskilled Labor: $21.91
Total approximate barge loads per year
Small company: 0
Large company: 0
Government: 7060
237.5 (bl O&M Manuals
Develop O&M Manual
One-time Cost
Cost Basis: Company
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs- Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
$5
$37
0
0
4
$5
$5
$666
Percent Affected:
Small Cos.: 0%
Large Cos.: 0%
Gov't: 100%
Total Cost
Small Cos.: $0
Large Cos.: $0
Gov't: $666
All Affected Cos.:
237.5(cl Waste Deposit Cleanup and Notification
r
Purchase Equipment
One-time Cost
Cost Basis: Tow
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
I
Cleanup of Deposits and Post Telephone Number
Operation and Maintenance of Oversight Authority
Annual Cost
Cost Basis: Loadings
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
$0)
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
1
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
$6|
One-time Cost
Cost Basis: Tow
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
1
$17.00
$30
0
0
2
$17
$17
$77
0%
0%
100%
$0
$0
$7,986
$7,986 1
A-30
-------
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
WASTE TRANSPORT VESSELS
Segment:
BARGES FOR UNCONTAINERIZEDGARBAGE
(NYC DOS)
Regulatory Requirement:
Action Required:
Frequency of Cost:
Small Company Definition: n/a
Total Companies: 0
Small Companies: 0
Government Entities 1
Total Vessels: 104
Small Co. Vessels: 0
Gov't Vessels: 104
Labor Rates
Management: $36.61
Supervisor: $29.90
Skilled Labor: $27.90
Unskilled Labor: $21.91
Total approximate barge loads per year
Small company: 0
Large company: 0
Government: 7080
237.5(dl Waste Deposit Records
Develop Waste Deposit
Record Form
One-time Cost
Cost Basis: Company
Record Waste Deposits
Annual Cost
Cost Basis: Tows
Maintain Waste Deposit
Records (File Space)
One-time Cost
Cost Basis: Company
(see Marine Transfer Stations)
Eq. Cost:
Lab or Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
\
$0
$0
0
0
0
$0
$0
$0
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
$0
$30
0
0
0.25
$0
$0
$7
Percent Affected:
0%
0%
100%
$0
$0
$0
$b|
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos
I
0%
0%
100%
$0
$0
$17,639
."
$17,639)
Eq. Cost:
Lab or Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
I
$0
$0
0
0
0
$0
$0
$0
0%
0%
100%
$0
$0
$0
:$0|
A-31
-------
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
I WASTE TRANSPORT VESSELS |
Segment:
SUPPLY BOATS (OSVsl TRANSPORTING MUDS &
PACKAGED CABBAGE FROM OFFSHORE RIGS
Regulatory Requirement:
Action Required:
Frequency of Cost:
Small Company Definition: 2 or fewer vessels
Total Companies: 370
Small Companies: 308
Total Vessels: 758
Small Co. Vessels: 360
Labor Rates
Management: $37.82
Supervisor: $37.22
Skilled Labor: $28.76
Unskilled Labor: $16.41
Average voyages per vessel per year
Small company: 10O
Large company: 100
237.5(a) Performance Standard
Implement and
Follow Procedures
Annual Cost
Cost Basis:
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Mrs-Large:
Unit Cost:
Small Co.:
Large Co.:
Vessel
$45
$29
50
0
$1 ,483
$45
Percent Affected:
Small Cos.: 30.0%
Large Cos.: 0%
Total Cost
Small Cos.: $160,186
Large Cos.: $0
All Affected Cos.:
L
$160,186)
Leachate Containment and Collection
One-time Cost
Cost Basis: Vessel
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Unit Cost:
Small Co.:
Large Co.:
Percent Affected:
Small Cos.:
Large Cos.:
Total Cost
Small Cos.:
Large Cos.:
All Affected Cos.:
I
$o
$0
0
0
$0
$0
0%
0%
$0
$0
$03
Annual Cost
Cost Basis: Loadinas
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Unit Cost:
Small Co.:
Large Co.:
Percent Affected:
Small Cos.:
Large Cos.:
Total Cost
Small Cos.:
Large Cos.:
All Affected Cos.:
1
$0
$0
0
0
$0
$0
0%
0%
$0
$0
$01
Label and Seal
Waste Ports and Valves
One -time Cost
Cost Basis: Vessel
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Unit Cost:
Small Co.:
Large Co.:
Percent Affected:
Small Cos.:
Large Cos.:
Total Cost
Small Cos.:
Large Cos.:
All Affected Cos.:
f
$0
$0
0
0
$0
$0
0%
0%
$0
$0
$i)
A-32
-------
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
1 WASTE TRANSPORT VESSELS |
Segment:
SUPPLY BOATS (OSVsl TRANSPORTINQMUDS &
PACKAGED GARBAGE FROM OFFSHORE RIGS
Regulatory Reauirement: 237.5 (b) O&M Manuals
Action Required:
237.5(c) Waste Deoosit Cleanuo and Notification
Cleanup of Deposits and
Develop O&M Manual
Frequency of Cost:
Small Company Definition: 2 or fewer vessels
Total Companies:
Small Companies:
Total Vessels:
Small Co. Vessels:
Labor Rates
Management:
Supervisor:
Skilled Labor:
Unskilled Labor:
• !•
370
308
758
360
$37.82
$37.22
$28.76
$16.41
Average voyages per vessel per year
Small company:
Large company:
100
100
One-time Cost
Cost Basis:
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Unit Cost:
Small Co.:
Large Co.:
Company
$5
$37
28
28
$1 ,047
$1 ,047
Percent Affected:
Small Cos.:
Large Cos.:
Total Cost
Small Cos.:
Large Cos.:
100%
100%
$376,945
$416,734
All Affected Cos.:
r
$793,678)
Purchase Equipment
Annual Cost
Cost Basis: Vessel
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Unit Cost:
Small Co.:
Large Co.:
Percent Affected:
Small Cos.:
Large Cos.:
Total Cost
Small Cos.:
Large Cos.:
All Affected Cos.:
I
$50
$37
0.5
0.5
$69
$69
30%
0%
$7,410
$0
$7.410)
Operation and Maintenance
Annual Cost
Cost Basis: Voyages
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Unit Cost:
Small Co.:
Large Co.:
Percent Affected
Small Cos.:
Large Cos.:
Total Cost
Small Cos.:
Large Cos.:
All Affected Cos
I
$0
$29
0.5
0.5
$14
$14
100%
100%
$5,178
$5,724
$10,902)
Post Telephone Number
of Oversight Authority
One-time Cost
Cost Basis: Vessel
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Unit Cost:
Small Co.:
Large Co.:
Percent Affected
Small Cos.:
Large Cos.:
Total Cost
Small Cos.:
Large Cos.:
All Affected Cos
I
$17
$37
2
2
$91
$91
100%
100%
$32,916
$36,391
$69,307)
A-33
-------
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
I WASTE TRANSPORT VESSELS I
Segment:
SUPPLY BOATS (OSVsl TRANSPORTING MUDS &
PACKAGED GARBAGE FROM OFFSHORE RIGS
Regulatory Requirement:
Action Required:
Frequency of Cost:
Small Company Definition: 2 or fewer vessels
Total Com panics: 370
Small Companies: 308
Total Vessels: 758
Small Co. Vessels: 360
Labor Rates
Management: $37.62
Supervisor: $37.22
Skilled Labor: $28.76
Unskilled Labor: $16.41
Average voyages per vessel per year
Small company: 100
Large company: 100
237.5(dl Waste Deposit Records
Develop Waste Deposit
Record Form
One-time Cost
Cost Basis: Company
Eq. Cost: $0
Labor Costs
Hourly Rate: $38
Hrs-Small: 1
Hrs-Large: 1
Unit Cost:
Small Co.:
Large Co.:
Percent Affected
Small Cos.:
Large Cos.:
Total Cost
Small Cos.:
Large Cos.:
All Affected Cos
LZ
$38
$38
100%
100%
$13,616
$15,054
$28,670)
Record Waste Deposits
Annual Cost
Cost Basis: Voyages
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Unit Cost:
Small Co.:
Large Co.:
Percent Affected:
Small Cos.:
Large Cos.:
Total Cost
Small Cos.:
Large Cos.:
All Affected Cos.:
cz
$0
$37
0.25
0.25
$9
$9
30%
0%
$1,005
$0
$1 ,005 1
Maintain Waste Deposit
Records (File Space)
One -time Cost
Cost Basis: Company
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Unit Cost:
Small Co.:
Large Co.:
Percent Affected:
Small Cos.:
Large Cos.:
Total Cost
Small Cos.:
Large Cos.:
All Affected Cos.:
r
$0
$0
0
0
$0
$0
100%
100%
$0
$0
$0|
A-34
-------
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
I WASTE TRANSPORT VESSELS |
Segment:
VESSELS TRANSPORTING PACKAGED GARBAGE
FROM INLAND PLATFORMS AND RIGS
Regulatory Requirement:
Action Required:
237.5(a) Performance Standard
Implement and
Follow Procedures
Frequency of Cost:
Small Company Definition: Fewer than 10 barges
Total Companies: 13
Small Companies: 1 1
Total Vessels:
Small Co. Vessels:
Labor Rates
Management:
Supervisor:
Skilled Labor:
Unskilled Labor:
66
33
$37.82
$37.22
$28.76
$16.41
Average voyages per vessel per year
Small company: 1 50
Large company: 1 50
Annual Cost
Coat Basis: Vessel
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Unit Cost:
Small Co.:
Large Co.:
Percent Affected:
Small Cos.:
Large Cos.:
Total Cost
Small Cos.:
Large Cos.:
All Affected Cos.:
I
$0
$0
0
0
$0
$0
0%
0%
$0
$0
,,'fal
Leachate Containment and Collection
One-time Cost
Cost Basis: Vessel
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Unit Cost:
Small Co.:
Large Co.:
Percent Affected:
Small Cos.:
Large Cos.:
Total Cost
Small Cos.:
Large Cos.:
All Affected Cos.:
f
$0
$0
0
0
$0
$0
0%
0%
$0
$0
..rlftl
Annual Cost
Cost Basis: Voyages
Eq. Cost: $0
Labor Costs
Hourly Rate: $0
Hrs-Small: 0
Hrs-Large: 0
Unit Cost:
Small Co.:
Large Co.:
Percent Affected:
Small Cos.:
Large Cos.:
Total Cost
Small Cos.:
Large Cos.:
All Affected Cos.:
f: -.„
$0
$0
0%
0%
$0
$0
.*$
Label and Seal
Waste Ports and Valves
One-time Cost
Cost Basis: Vessel
Eq. Cost: $0
Labor Coats
Hourly Rate: $0
Hrs-Small: 0
Hrs- Large: 0
Unit Cost:
Small Co.: $0
Large Co.: $0
Percent Affected:
Small Cos.: 0%
Large Cos.: 0%
Total Cost
Small Cos.: $0
Large Cos.: $0
All Affected Cos.:
L
A-35
-------
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
I WASTE TRANSPORT VESSELS |
Segment:
VESSELS TRANSPORTING PACKAGED GARBAGE
FROM INLAND PLATFORMS AND RIGS
Regulatory Requirement:
Action Required:
Frequency of Cost:
237.5 (bl O&M Manuals
Develop O&M Manual
One-time Cost
Cost Basis: Company
Small Company Definition: Fewer than 10 barges Eq. Cost: $5
Labor Costs
Hourly Rate: $37
Total Companies: 13 Hrs-Small: 26
Small Companies: 11 Hrs-Large: 28
Total Vessels: 66
Small Co. Vessels: 33
Labor Rates
Management: $37.82
Supervisor: $37.22
Skilled Labor: $28.76
Unskilled Labor: $16.41
Average voyages per vessel per year
Small company: 150
Large company: 150
Unit Cost:
Small Co.:
Large Co.:
$1,057
$1 ,072
Percent Affected:
Small Cos.: 100%
Large Cos.: 100%
Total Cost
Small Cos.: $11,628
Large Cos.: $2,144
All Affected Cos.:
[ $13.772|
237.5te) Waste Deposit Cleanup and Notification
Purchase Equipment
Annual Cost
Cost Basis: Vessel
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Mrs-Large:
Unit Cost:
Small Co.:
Large Co.:
Percent Affected:
Small Cos.:
Large Cos.:
Total Cost
Small Cos.:
Large Cos.:
All Affected Cos.:
d
$50
$37
0.5
0.5
$69
$69
25%
25%
$566
$566
$1,132|
Cleanup of Deposits and
Operation and Maintenance
Annual Cost
Cost Basis: Voyages
Eq. Cost: $0
Labor Costs
Hourly Rate: $16
Hrs-Small: 0.5
Mrs-Large: 0.5
Unit Cost:
Small Co.:
Large Co.:
Percent Affected:
Small Cos.:
Large Cos.:
Total Cost
Small Cos.:
Large Cos.:
All Affected Cos.:
I
$8
$8
25%
25%
$68
$68
$135 1
Post Telephone Number
of Oversight Authority
One-time Cost
Cost Basis: Vessel
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs- Large:
Unit Cost:
Small Co.:
Large Co.:
Percent Affected:
Small Cos.:
Large Cos.:
Total Cost
Small Cos.:
Large Cos.:
All Affected Cos.:
El
$17
$37
2
2
$91
$91
100%
100%
$3,017
$3,017
$6,035)
A-36
-------
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENTAND ITEM
L
WASTE TRANSPORT VESSELS
Segment:
VESSELS TRANSPORTING PACKAGED GARBAGE
FROM INLAND PLATFORMS AND RIGS
Regulator/ Requirement:
Action Required:
Frequency of Cost:
237.5(d) Waste Deposit Records
Develop Waste Deposit
Record Form
One-time Cost
Cost Basis: Company
$0
Small Company Definition: Fewer th an 10 barges Eq. Cost:
Labor Costs
Hourly Rate: $38
Total Companies: 13 Hrs- Small: 1
Small Companies: 11 Hrs-Large: 1
Record Waste Deposits
Annual Cost
Cost Basis: Voyages
$0
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
$37
0.25
0.25
Maintain Waste Deposit
Records (File Space)
One-time Cost
Cost Basis: Company
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
$0
o
0
.Total Vessels: 66
Small Co. Vessels: 33
Labor Rates
Management: $37.82
Supervisor: $37.22
Skilled Labor: $28.76
Unskilled Labor: $16.41
Average voyages per vessel per year
Small company: 150
Large company: 150
Unit Cost:
Small Co,:
Large Co.:
$38
$38
Percent Affected:
Small Cos.: 100%
Large Cos.: 100%
Total Cost
Small Cos.: $416
Large Cos.: $76
All Affected Cos.:
Unit Cost:
Small Co.:
Large Co.:
Percent Affected:
Small Cos.:
Large Cos.:
Total Cost
Small Cos.:
Large Cos.:
All Affected Cos.
Unit Cost:
$9 Small Co.:
$9 Large Co.:
25%
0%
$77
$0
$0
Percent Affected:
Small Cos.: 100%
Large Cos.: 100%
Total Cost
Small Cos.: $0
Large Cos.: $0
All Affected Cos.:
I $492|
J77J
L
A-37
-------
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
L
WASTE TRANSPORT VESSELS
Segment:
VESSELS TRANSPORTINGGARBAGE
FROM VESSELS ANCHORED OFFSHORE
Regulatory Requirement:
Action Required:
Frequency of Cost:
Small Corn pan/ Definition: fewer than 6 vessels
Total Companies: 4
Small Companies: A
Government Entities 0
Total Vessels: A
Small Co. Vessels: 4
Gov't Vessels: 0
Labor Rates
Management: $30.90
Supervisor: $24.72
Skilled Labor: $22.25
Unskilled Labor: $16.46
Average loadlngs/unloadingsper vessel per year
Small company: 142
Large company: 142
Government: • 0
237.5(a) Performance Standard
Implement and
Follow Procedures
Annual Cost
Leachate Containment and Collection
One-time Cost
Cost Basis: Vessel
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs- Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
I
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
$o|
Cost Basis: Vessel
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs- Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
I
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
$0|
Annual Cost
Label and Seal
Waste Ports and Valves
One-time Cost
Cost Basis: Loadings
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs -Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
I '
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
$0|
Cost Basis: Vessel
Eq.Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
Kill
$o
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
Ilill
A-38
-------
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
WASTE TRANSPORT VESSELS
Segment:
VESSELS TRANSPORTING GARBAGE
FROM VESSELS ANCHORED OFFSHORE
Regulatory Requirement:
Action Required:
Frequency of Cost:
Small Company Definition: fewer than 6 vessels
Total Com panics: 4
Small Companies: 4
Government Entities 0
Total Vessels: 4
Small Co. Vessels: 4
Gov't Vessels: 0
Labor Rates
Management: $30.90
Supervisor: $24.72
Skilled Labor: $22.25
Unskilled Labor: $16.48
Average loadings/unloadingsper vessel per year
Small company: 142
Large company: 142
Government: 0
237.5 fb> O&M Manuals
Develop O&M Manual
One-time Cost
Cost Basis: Company
Eq. Cost: $5
Labor Costs
Hourly Rate: $25
Mrs-Small: 28
Mrs-Large: 28
Hrs-Gov't: 28
Unit Cost:
Small Co.: $697
Large Co.: $697
Gov't: $692
Percent Affected:
Small Cos.: 100%
Large Cos.: 100%
Gov't: 100%
Total Cost
Small Cos.: $2,789
Large Cos.: $0
Gov't: $0
All Affected Cos.:
I $2.7891
237.5(cl Waste Deposit Cleanup and Notification
Purchase Equipment
One-time Cost
Cost Basis: Vessel
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
('
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
$6]
Cleanup of Deposits and
Operation and Maintenance
Annual Cost
Post Telephone Number
of Oversight Authority
One-time Cost
Cost Basis: Loadings
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
jr.
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
*c«j
Cost Basis: Vessel
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
1
$17
$25
2
2
2
$66
$66
$66
100%
100%
100%
$266
$0
$0
$266 1
A-39
-------
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
\ WASTE TRANSPORT VESSELS
Segment:
VESSELS TRANSPQRTINGGARBAGE
FROM VESSELS ANCHORED OFFSHORE
Regulatory Requirement:
237.5fdl Waste Deposit Records
Action Required:
Frequency of Cost:
Develop Waste Deposit
Record Form
Record Waste Deposits
One-time Cost
Cost Basis: Company
Small Company Definition : fewer than 6 vessels
Total Companies:
Small Companies:
., ,
4
4
Government Entities 0
Total Vessels:
Small Co. Vessels:
Gov't Vessels:
Labor Rates
Management:
Supervisor:
Skilled Labor:
Unskilled Labor:
4
4
0
$30.90
$24.72
$22.25
$16.48
Average loadings/unloadings per vessel per year
Small company:
Large com pany:
Government:
142
142
0
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs- Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
I
$0
$31
1
1
1
$31
$31
$31
100%
100%
100%
$124
$0
$0
$124)
Annual Cost
Maintain Waste Deposit
Records (File Space)
One-time Cost
Cost Basis: Loadings
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Mrs- Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
I
$0
$25
0
0
0
$0
$0
$0
100%
100%
100%
$0
$0
$0
$o|
Cost Basis: Company
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs- Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
I
$0
$16
0
0
0
$0
$0
$0
100%
100%
100%
$0
$0
$0
$o|
A-40
-------
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
I WASTE TRANSPORT VESSELS
Segment:
VESSELS TRANSPORTING PACKAGED
GARBAGE FROM ISLANDS
Regulatory Requirement:
237.5(a) Performance Standard
9
* T
Action Required:
Frequency of Cost:
Small Company Definition: fewer than 1 0 vessels
• t«
Total Companies:
Small Companies:
Government Entities
Total Vessels:
Small Co. Vessels:
Gov't Vessels:
Labor Rates
Management:
Supervisor:
Skilled Labor:
Unskilled Labor:
2
2
1
5
4
1
$35.23
$28.19
$25.37
$18.79
Average loadings/unloadingsper vessel per year
Small company:
Large company:
Government:
140
0
364
Implement and
Follow Procedures
Annual Cost
Leachate Containment and Collection
One-time Cost
Cost Basis: Vessel
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
f
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
$:Q|
Cost Basis: Vessel
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
|.r
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
$oj
Annual Cost
Cost Basis: Loadings
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected
Small Cos,:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos
|ilf
$0
$0
0
0
0
$0
$0
$0
I
0%
0%
0%
$0
$0
$0
.1
iiiilill
Label and Seal
Waste Ports and Valves
One-time Cost
Cost Basis: Vessel
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
\
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
$o|
A-41
-------
SHORE PROTECTIONACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
WASTE TRANSPORT VESSELS
Segment:
VESSELS TRANSPORTING PACKAGED
GARBAGE FROM ISLANDS
Regulatory Requirement:
Action Required:
Frequency of Cost:
237.5 UP) O&M Manuals
Develop O&M Manual
One-time Cost
Cost Basis: Company
237.5(c) Waste Deposit Cleanup and Notification
Small Company Definition:
Total Companies:
Small Companies:
• Government Entitles
Total Vessels:
Small Co. Vessels:
Gov't Vessels:
fewer than 10 vessels Eq. Cost:
Labor Costs
Hourly Rate:
2 Hrs-Small:
2 Hrs-Large:
1 Hrs-Gov't:
5
4
1
Unit Cost:
Small Co.:
Large Co.:
Gov't:
$5
$28
28
28
28
$794
$794
$794
Labor Rates
Management: $35.23
Supervisor: $28.19
Skilled Labor: $25.37
Unskilled Labor: $18.79
Average loadings/unloadings per vessel per year
Small company: 140
Large company: 0
Government: 364
Percent Affected:
Small Cos.: 100%
Large Cos.: 100%
Gov't: 100%
Total Cost
Small Cos.: $1,589
Large Cos.: $0
Gov't: $794
All Affected Cos.:
I $2,383]
Cleanup of Deposits and
Purchase Equipment
One-time Cost
Cost Basis: Vessel
Eq. Cost:
Labor Costs
Hourly Rate:
Mrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
i
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
,,19 1
Post Telephone Number
Operation and Maintenance of Oversight Authority
Annual Cost
One-time Cost
Cost Basis: Loadings
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs- Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
i ',
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
M
Cost Basis: Vessel
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost;
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
1
$17
$28
2
2
2
$73
$73
$73
100%
100%
100%
$294
$73
$73
$440 1
A-42
-------
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
WASTE TRANSPORT VESSELS
Segment:
VESSELS TRANSPORT! NGPACKAQED
GARBAGE FROM ISLANDS
Regulatory Requirement:
Action Required:
Frequency of Cost:
237.S(dl Waste Deposit Records
Develop Waste Deposit
Record Form
One-time Cost
Record Waste Deposits
Annual Cost
Maintain Waste Deposit
Records (File Space)
One-time Cost
Cost Basis: Company Cost Basis: Loadings Cost Basis: Company
Small Company Definition:
fewer than 10 vessels Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Total Companies: 2
Small Companies: 2
Government Entities 1
Total Vessels: 5
Small Co. Vessels: 4
Gov't Vessels: 1
Labor Rates
Management: $35.23
Supervisor: $28.19
Skilled Labor: $25.37
Unskilled Labor: $18.79
Average loadlngs/unloadingsper vessel per year
Small company: 140
Large company: 0
Government: 364
Unit Cost:
Small Co.:
Large Co.:
Gov't:
$0
$35
1
1
1
$35
$35
$35
Percent Affected:
Small Cos.: 100%
Large Cos.: 100%
Gov't: 100%
Total Cost
Small Cos.: $141
Large Cos.: $35
Gov't: $35
All Affected Cos.:
I $211|
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
$0
$0
0
0
0
$0
$0
$0
Percent Affected:
Small Cos.: 100%
Large Cos.: 100%
Gov't: 100%
Total Cost
Small Cos.: $o
Large Cos.: $0
Gov't: $0
All Affected Cos.:
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
$0
$0
0
0
0
$0
$0
$0
Percent Affected:
Small Cos.: 100%
Large Cos.: 100%
Gov't: 100%
Total Cost
Small Cos.: $0
Large Cos.: $0
Gov't: $0
All Affected Cos.:
F~~"~$ol
A-43
-------
SHORE PROTECTIONACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
WASTE TRANSPORT VESSELS
J
Segment:
BARGES TRAMSPORTINQSEWAGE SLUDGE
Regulatory Requirement:
Action Required:
Frequency of Cost:
Small Com pan/Definition: n/a
Total Companies: 3
Small Companies: o
Government Entities 1
Total Vessels: 13
Small Co. Vessels: 0
Gov't Vessels: 1
Labor Rates
Management: $36.61
Supervisor: $29.90
Skilled Labor: $27.90
Unskilled Labor: $21.91
Average loadings/tin loadingsper vessel per year
Small company: 0
Large company: 730
Government: 730
237.5(a) Performance Standard
Implement and
Follow Procedures
Annual Cost
Leachate Containment and Collection
One-time Cost
Cost Basis: Vessel
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs- Small:
Hrs- Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
I
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
$o|
Cost Basis: Vessel
Eq. Cost:
Labor Costs
Hourly Rate:
Mrs-Small:
Hrs- Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
r '
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
$o?|
Annual Cost
Label and Seal
Waste Ports and Valves
One-time Cost
Cost Basis: Loadinas
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs- Small:
Hrs- Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
r
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
$o|
Cost Basis: Vessel
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs- Small:
Hrs -Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Qov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
r
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
$o|
A-44
-------
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
I WASTE TRANSPORT VESSELS
Segment:
BARGES TRANSPORTING SEWAGE SLUDGE
Regulatory Requirement:
Action Required:
Frequency of Cost:
Small Company Definition: n/a
Total Companies: 3
Small Companies: o
Government Entities 1
Total Vessels: 13
Small Co. Vessels: 0
Gov't Vessels: 1
Labor Rates
Management: $36.61
Supervisor: $29.90
Skilled Labor: $27.90
Unskilled Labor: $21.91
Average loadings/unloadingsper vessel per year
Small company: 0
Large company: 730
Government: 730
237.5 (b) O&M Manuals
Develop O&M Manual
One-time Cost
Cost Basis: Company
237.5(0} Waste Deposit Cleanup and Notification
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
$5
$30
28
28
28
$642
$642
$642
Percent Affected:
Small Cos.: 100%
Large Cos.: 100%
Gov't: 100%
Total Cost
Small Cos.: $0
Large Cos.: $2,526
Gov't: $642
All Affected Cos.:
I $3.3681
Purchase Equipment
One-time Cost
Cost Basis: Vessel
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Hrs-Gov't:
Unit Cost:
Small Co.:
Large Co.:
Gov't:
Percent Affected:
Small Cos.:
Large Cos.:
Gov't:
Total Cost
Small Cos.:
Large Cos.:
Gov't:
All Affected Cos.:
(
$0
$0
0
0
0
$0
$0
$0
0%
0%
0%
$0
$0
$0
«
-------
SHORE PROTECTIONACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
L
WASTE TRANSPORT VESSELS
J
Segment:
BARGES TRANSPORTING SEWAGE SLUDGE
Regulator/ Requirement:
Action Required:
Frequency of Cost:
Small Company Definition: n/a
Total Companies: 3
Small Companies: 0
Government Entities 1
Total Vessels: 13
Small Co. Vessels: 0
Gov't Vessels: 1
Labor Rates
Management: $36.61
Supervisor: $29.90
Skilled Labor: $27.90
Unskilled Labor: $21.91
Average loadings/unloadingsper vessel per year
Small company: 0
Large company: 730
Government: 730
237.5(d) Waste Deposit Records
Develop Waste Deposit
Record Form
One-time Cost
Cost Basis: Company
Eq. Cost: $0
Labor Costs
Hourly Rate: $37
Mrs- Small: 1
Mrs-Large: 1
Hrs- Gov't: 1
Unit Cost:
Small Co.: $37
Large Co.: $37
Gov't: $37
Percent Affected:
Small Cos.: 100%
Large Cos.: 100%
Gov't: 100%
Total Cost
Small Cos.: $0
Large Cos.: $476
Gov't: $37
All Affected Cos.:
I $513 |
Record Waste Deposits
Annual Cost
Cost Basis: Loadings
Eq. Cost: $0
Labor Costs
Hourly Rate: $30
Hrs- Small: 1.75
Hrs- Large: 1.75
Hrs-Gov't: 1.75
Unit Cost:
Small Co.: $52
Large Co.: $52
Gov't: $52
Percent Affected:
Small Cos.: 100%
Large Cos.: 100%
Gov't: 100%
Total Cost
Small Cos.: $0
Large Cos.: $660
Gov't: $52
All Affected Cos.:
| $732 |
Maintain Waste Deposit
Records (File Space)
One-time Cost
Cost Basis: Company
Eq. Cost: $0
Labor Costs
Hourly Rate: $0
Hrs-Small: 0
Hrs-Large: 0
Hrs-Gov't: 0
Unit Cost:
Small Co.: $0
Large Co.: $0
Gov't: $0
Percent Affected:
Small Cos.: 100%
Large Cos.: 100%
Gov't: 100%
Total Cost
Small Cos.: $0
Large Cos.: $0
Gov't: $0
All Affected Cos.:
f :" *6|
A-46
-------
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
WASTE TRANSPORT VESSELS
Segment:
DECK SHALE BARGES AND
HOPPER BARGES HANDLING DRILLING MUDS
237.5(a) Performance Standard
Action Required:
Frequency of Cost:
Small Company Definition: Fewer than 1 0 barges
Total Companies: 18
Small Companies: 1 5
Total Vessels: 126
Small Co. Vessels: 44
Labor Rates
Management: $37.82
Supervisor: $37.22
Skilled Labor: $28.76
Unskilled Labor: $16.41
Average transactions per vessel per year
Small company: 100
Large com pany: 1 00
Implement and
Follow Procedures
Annual Cost
Leachate Containment and Collection
One-time Cost
Cost Basis: Vessel
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Unit Cost:
Small Co.:
Large Co.:
Percent Affected:
Small Cos.:
Large Cos.:
Total Cost
Small Cos.:
Large Cos.:
All Affected Cos.:
I
$0
$0
0
0
$0
$0
0%
0%
$0
$0
$QJ
Cost Basis: Vessel
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Unit Cost:
Small Co.:
Large Co.:
Percent Affected:
Small Cos.:
Large Cos.:
Total Cost
Small Cos.:
Large Cos.:
All Affected Cos.:
I
$0
$0
0
0
$0
$0
0%
0%
$0
$0
tm
Annual Cost
Cost Basis: Load in qs
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Unit Cost:
Small Co.:
Large Co.:
Percent Affected:
Small Cos.:
Large Cos.:
Total Cost
Small Cos.:
Large Cos.:
All Affected Cos.:
i ,,„
$0
$0
0
0
$0
$0
0%
0%
$0
$0
m
Label and Seal
Waste Ports and Valves
One-time Cost
Cost Basis: Vessel
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Unit Cost:
Small Co.:
Large Co.:
Percent Affected:
Small Cos.:
Large Cos.:
Total Cost
Small Cos.:
Large Cos.:
All Affected Cos.:
t
$0
$0
0
0
$0
$0
0%
0%
$0
$0
$p]
A-47
-------
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
WASTE TRANSPORT VESSELS
Segment:
DECK SHALE BARGES AND
HOPPER BARGES HANDLING DRILLING MUDS
Regulatory Requirement:
Action Required:
Frequency of Cost:
237.5 (M O&M Manuals
Develop O&M Manual
One-time Cost
Cost Basis: Company
Small Company Definition: Fewer than 10 barges Eq. Cost: $5
Labor Costs
Hourly Rate: $37
Total Companies: 18 Hrs-Small: 28
Small Companies: 15 Mrs-Large: 28
Total Vessels: 126
Small Co. Vessels: 44
Labor Rates
Management: $37.82
Supervisor: $37.22
Skilled Labor: $28.76
Unskilled Labor: $16.41
Average transactions per vessel per year
Small company: 100
Large company: 100
Unit Cost:
Small Co.:
Large Co.:
$1.047
$1,047
Percent Affected:
Small Cos.: 100%
Large Cos.: 100%
Total Cost
Small Cos.: $46,069
Large Cos.: $85,857
All Affected Cos.:
237.5(cl Waste Deposit Cleanup ana* Notification
$131.926|
Purchase Equipment
One-time Cost
Cost Basis: Vessel
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Mrs-Large:
Unit Cost:
Small Co.:
Large Co.:
Percent Affected:
Small Cos.:
Large Cos.:
Total Cost
Small Cos.:
Large Cos.:
All Affected Cos.:
1
$0
$0
0
0
$0
$0
0%
0%
$0
$0
$01
Cleanup of Deposits and Post Telephone Number
Operation and Maintenance of Oversight Authority
Annual Cost One-time Cost
Cost Basis: Loadings
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Mrs-Large:
Unit Cost:
Small Co.:
Large Co.:
Percent Affected:
Small Cos.:
Large Cos.:
Total Cost
Small Cos.:
Large Cos.:
All Affected Cos.:
[
$0
$0
0
0
$0
$0
0%
0%
$0
$0
*Q]
Cost Basis: Vessel
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs -Large:
Unit Cost:
Small Co.:
Large Co.:
Percent Affected
Small Cos.:
Large Cos.:
Total Cost
Small Cos.:
Large Cos.:
All Affected Cos
LZ
$17
$37
2
2
$91
$91
100%
100%
$4,023
$7.497
$11,520)
A-48
-------
SHORE PROTECTION ACT REGULATORY IMPACT ANALYSIS: COSTS BY SEGMENT AND ITEM
WASTE TRANSPORT VESSELS
Segment:
DECK SHALE BARGES AND
HOPPER BARGES HANDLING DRILLING MUDS
Regulatory Requirement:
Action Required:
Frequency of Cost:
237.5(d) Waste Deposit Records
Develop Waste Deposit
Record Form
One-time Cost
Record Waste Deposits
Annual Cost
Cost Basis: Company Cost Basis: Loadings
Maintain Waste Deposit
Records (File Space)
One-time Cost
Cost Basis: Company
Small Company Definition:
!••
Total Companies:
Small Companies:
Total Vessels:
Small Co. Vessels:
Fewer than 10 barges
18
15
126
44
Eq.Cost:
Labor Costs
Hourly Rate:
Mrs-Small:
Hrs- Large:
Unit Cost:
Small Co.:
Large Co.:
$0
$38
1
1
$38
$38
Eq. Cost:
Labor Costs
Hourly Rate:
Mrs-Small:
Hrs-Large:
Unit Cost:
Small Co.:
Large Co.:
$0
$37
2.5
2.5
$93
$93
Eq. Cost:
Labor Costs
Hourly Rate:
Hrs-Small:
Hrs-Large:
Unit Cost:
Small Co.:
Large Co.:
$0
$0
0
0
$0
$0
Labor Rates
Management: $37.62
Supervisor: $37.22
Skilled Labor: $28.76
Unskilled Labor: $16.41
Average transactions per vessel per year
Small company: 100
Large company: 100
Percent Affected:
Small Cos.: 100%
Large Cos.: 100%
Total Cost
Small Cos.: $567
Large Cos.: $113
All Affected Cos.:
Percent Affected:
Small Cos.: 100%
Large Cos.: 100%
Total Cost
Small Cos.: $4,094
Large Cos.: $7,629
All Affected Cos.:
Percent Affected:
Small Cos.: 100%
Large Cos.: 100%
Total Cost
Small Cos.: $0
Large Cos.: $0
All Affected Cos.:
I $681 |
I $11.723|
A-49
-------
Appendix B:
Draft Shore Protection Act Regulations
(June 29,1993)
U.S. Environmental Protection Agency
Office of Wetlands, Oceans and Watersheds
Oceans and Coastal Protection Division
Marine Pollution Control Branch
-------
DRAFT
1 RgSTTIATTOH June 29, 1993
2 Part 237 Waste handling practices for vessels and waste transfer
3 stations,
4 It is proposed that 40 CFR Part 237 read as follows:
5 AUTHORITY: Shore Protection Act of 1988 (section 4001), 33 U.S.C.
6 2600.
7 237.1- Purpose.
8 The purpose of this part is to; (a) establish requirements
9 under the Shore Protection Act, Title IV of Public lav 1QO-688
10 part 237, for vessels, waste sources, and receiving facilities to
11 assure that commercial and/or municipal vaste is not deposited
12 into coastal waters during loading, offloading and transport; (b)
13 require the submission and adoption by the owner or operator of a
14 vessel or a vaste loading or unloading facility of an operation
15 and Maintenance (O & M) manual identifying procedures to be used
16 to prevent, report, and cleanup any deposit of municipal or
17 commercial waste into coastal waters, including record keeping
18 requirements; (c) require tracking systems where and when the
19 Administrator determines they are necessary to assure adequate
20 compliance with laws preventing the deposit of municipal or
»
21 cou&ercial waste into coastal waters.
22 237.8. Applicabilitv•
23 (a) Except *9 provided by paragraph (b) of tuis section,
24 this part applies «Q each owner or operator of:
25 l) a vessel transporting municipal or commercial waste in
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1 coastal waters;
2 2) a waste source as defined in section 337. 3 (j);
3 3) a receiving facility as defined in section 237. 3 (f ) .
4 (b) This part does not apply to the owner or operator of a
5 public vessel,
6 (c) The requirements of the Shore Protection Act (SPA) and
7 this regulation apply in addition to, and not in lieu of, all
S applicable requirements under any other statutes*
9 23?*3«
10 As used in this part-
11 (a) "Administrator*1 means the Administrator of the Environmental
12 Protection Agency or person designated by the Administrator.
13 (b) "Coastal waters" means -
14 (1) the territorial sea of the United States;
15 (2) the Great lakes and th«ir connecting waters;
16 (3) the marine and esttiarine waters of the United States up
17 to the head of tidal influence;
18 (4) the Exclusive Economic Zone as established by
19 Presidential Proclamation Number 5030, dated March 10, 1963.
*»
20 Hates The Exclusive Economic Zone extends from the baseline
21 of the territorial sea of the United States seaward 200
22 ' nautical miles.
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1 (c) "Municipal or commercial vaste" means solid vaste* (as
2 defined in section 1004 of the Solid Waste Disposal Act (42
3 U.S.C. 6903)) except-
4 (1) solid waste identified and listed under section 3001 of
5 the Solid Waste Disposal Act (42 U.S.C. 6921);
6 (2) waste generated by the vessel during normal operations;
7 (3) debris solely from construction activities;
8 (4) sewage sludge subject to regulation tmder title I of the
9 Marine Protection/ Research, and Sanctuaries Act of 1972 (33
10 U.S.C. 1401 et. seq.);
11 (5) dredged or fill material subject to regulation under
12 title I of the Marine Protection, Research and Sanctuaries
13 ' Act of 1972 (33 tJ.S.c. 1401 et seq.}* the Federal water
i* - Pollution control Act (33 u.s.c. 1251 et seg-), or the
is Rivers and Harbors Appropriation Act of 1899 (33 U.S.C. 401
16 «t seg.) .
17 (d) "Person" means an individual, trust, firm, joint stock
18 company* corporation (including a government corporation),
19 partnership, association, state, municipality, commission,
20 political subdivision of a state, or any interstate body,
';.
21 (e) "Public vessel" means a vessel that:*
22 (1) is owned, or demise chartered, and operated by the
23 united states Government or a government of a foreign
24 country; and
U.S. EPA Headquarters Library
Mail code 3201
1200 Pennsylvania Avenue NW
Washington DC 20460
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l (2) is not engaged in commercial service.
2 (f) "Receiving facility" means a facility, vessel or operation
3 within the territorial aaas of the U.S. which receives
4 municipal or commercial waste unloaded from a vessel*
5 (g) "SEA" means the Shore Protection Act, Title IV of Public law
6 100-688 section 4001, tJSC 2600.
7 (h) "Vessel" means every description of vatercraft or other
d artificial contrivance used, or capable of being used, as a
9 means of transportation on water.
10 "Vessel transporting municipal and commercial waste"
11 includes, in the case of a non-self-propelled vessel, both
12 the non-self-propelled vessel and the towing vessel.
13 (i) "Waste deposit * means any municipal or commercial waste
14 originating from a waste source, receiving facility, or
IS vessel that is deposited into a water body*
16 (j) "Waste source" means a vessel, or a facility located within
17 the territorial seas of the U.S. from which municipal or
18 commercial waste is loaded onto a vessel, including any
19 rolling s-fcoelc or motor vehicles from which that waste is
20 directly loaded.
-------
l (Jc) "Waste transfer station" means a waste source or receiving
2 facility as defined 237.3 (j) & (£)-
3 237*4* specif ie w^fee bandling practices for vaate aouxcaa and
4 iraeaiviag facilities durlaq loading &nd offloading.
5 (a) Performance standard. The owner or operator of a waste
6 source or receiving facility shall have containment, diversionary
7 structures, ^m? equipment, consistent with the requirements of
^SrSjE
8 this subsection, to contain and remove any municipal or
g eonaercial waste deposited in coastal waters during loading and
10 offloading. Tne evnsr or operator of a waste source or receiving
11 facility shall us« containment ^^^.versionary structures or
12 equipment in a manner the minimizes deposit of municipal or
13 commercial waste into coastal waters.
14 Appropriate methods to meet this performance standard must
IS be identified in the O & M manual.
(b) Fixed lighting. The owner or operator of a waste
17 source or receiving facility shall use fixed lighting, that
18 adequately illuminates the loading and offloading point and the
•*»
19 surrounding area, when conducting loading and offloading
20 operations between sunset and sunrise*
21 (c) waste Deposit Cleanup. The owner or operator of a
22 waste source or receiving facility Shall have means in place to
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1 promptly (before the waste has a chance to disperse) , and
2 lAgpeughlv. cleanup municipal or commercial wastes deposited into
3 coastal waters during loading and offloading. The methods for
4 cleanup of the waste must be identified in the facility's o & M
5
€ The methods vised may include sweeper boats to sweep up splid
7 wastes deposited, manned boats with nets to remove waste, boons
8 or other equipment to recover waste deposited near shore, and/or
9 shoreline cleanup crews and equipment to clear shore areas of
10 waste which could be refloated by tides or deposited in the
11 coastal waters by vinds or high water resulting from a storm*
* ••' '*
12 Cleanup of deposited waste shall insure that all waste which
13 clearly resulted from, or nay have resulted from waste loading
14 operations is removed fron the water and the shoreline prior to
15 the first high tide following the completion of any loading
16 operation.
17 Cleanup resources shall be in continuous operation, or on standby
18 at the loading facility for loading operations which take place
*>
19 during an ebb tide.
20 The owner or operator shall have the oversight authority
21 telephone nmaber(s) visibly and legibly displayed at the transfer
22 station The owner or operator shall promptly notify the
-------
i designated oversight authority if the owner or operator is unable
2 to meat the requirements of these regulations. Failure to report
3 such ait went will result in a civil penalty established by the
4 USCG.
5 (d) Waste Deposit .Records.
6 (1) The owner or operator of a municipal or commercial
7 waste receiving facility, or vaste source shall maintain a daily
8 record of waste deposited into the coastal waters- These records
d must include information pertaining to the:
10 i. Date of deposit;
11 ii. Time of day;
12 iii. Estimated amount of vaste deposited and amount
13 recovered;
14 iv. Description of the type of waste deposited;
15 v. Name of the vessel being loaded/offloaded;
16 vi. Cause of deposit;
17 vii. Method and time of cleanup.
18 (2) The owner or operator shall retain these records for no
19 less than three years and must submit these records to the
20 Administrator or the Secretary upon request within five working
»,
21 days.
22 (e) Operation and Maintenance Manuals.
23 (l) Each receiving facility or waste source shall develop
24 an 0 ft M manual ISO days after the regulation is promulgated.
25 The manual shall include:
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1 i. Record keeping procedures;
2 ii. A description of the basic o & M standards adopted by
3 the facility or waste source to implement the
4 requirements of section 237.4G^J~^F);
5 iii. Identification of the parties responsible for
6 implementing the manual;
7 iv. A description of the procedures the owner or operator
8 will use to prevent, report, and cleanup any deposit of
$ municipal or commercial waste into coastal waters
10 consistent with §237.4(o)*
il
12 (2) At the request of the Administrator, the receiving
13 facility or waste source shall submit or provide the o & n manual
14, to the Administrator for review or approval within ten working
is days. Upon disapproval by the Administrator of an o £ M manual,
16 the receiving facility or waste source shall make the corrections
17' ' indicated by the Administrator and resubmit the manual for review
18 vitnin 90 days, operations may continue during this review
19 process. Failure to make the recommended corrections to the 0 &
20 K manual within 180 days would be a violation of this regulation.
21 The O $ M manual shall comply with the format and guidelines
»•»
22 established in the SPA "Municipal and Commercial waste handling
23 technical guidance document'1 (0 & M manuals section) (appendix
24 A).
25 (3) The O & M manual shall be made available and accessible
26 to all employees on site.
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2 237»5 specifie vaste handling pra^fcieea for Vessels Ourincr
3
4 (a) Performance ftfcandard. The owner or operator of a vessel
S which transports municipal or commercial waste must secure the
6 vaste to assure that it will not be deposited into coastal waters
7 during transport. Jit a minimus the owner or operator roast ensure
8 that:
9 i. Waste is not loaded in excess of the vessel's design
10 capacity; nor in a manner inconsistent with the
11 instructions in the vessel's O 4 M manual.
12 ii- All waste shall be contained in a way that minimizes
13 deposition into United states coastal waters, e.g. open
14 barges hauling solid waste shall be covered during
15 transport with netting or other means adequate to
16 ensure that waste will not be deposited into the water.
17 Another exaxople is that an open barge hauling liquid
18 waste shall be loaded such that waste will not be
19 deposited into the water.
20 iii. The vessel hauling solid waste shall have and use a
21 drainage containment system for collection of leaching
*»
22 liquids.
23 Tbe following will be used in combination with the
24 requirements identified above:
25 iv. All ports and valves which may be used for flushing or
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i discharging waste or waste residue from the hull or
2 tanks must be Labelled and the valve seals shall be
3 placed on the valves.
4 ' (b) omaratigp and Maintenance. The owner or operator shall
5 develop an O & X manual and have it available on the vessel. The
6 o & M manual must contain instructions on loading the vessel and
7 securing the waste, including loading and securing diagrams in
8 accordance with 237.5(a). The O & M manual shall comply with, the
9 foraat and guidelines established in Appendix A for vessel O & M
10 manuals. Th« O & M manual shall be made available and accessible
11 to all employees on the vessel.
12 (e) Waste Deposit Cleanup. The owner or operator of a vessel
13 shall promptly (before the waste has a chance to disperse), and
14 thoroughly, remove any waste deposited into the coastal waters
IS during transport. The owner or operator of the vessel shall have
16 the capability on board to cleanup the spill or to call a support
1? unit to cleanup the spill. The owner or operator shall have the
18 support unit telephone nunber(s) and the oversight authority
19 telephone number (s) located on the vessel in a way that these
20 numbers are visible and legible to the owner or operator and
2i vessel crew. The owner or operator or crew of a vessel shall
22 promptly notify the designated oversight authority if the owner
23 or operator is unable to meet the requirement: under 237.5(b),
24 Failure to report such an event will result in a civil penalty
2$ established by the USCG.
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1 (d) Waste Deposit. Records.
2 (1) The owner or operator of a vessel shall maintain a
3 record of all waste deposited into the coastal waters. These
4 records wist include information pertaining- to the:
S i. Date of deposit;
6 ii. Time of day;
7 iii. Estimated amount of waste deposited and amount
8 recovered;
s iv. Description of the type of waste deposited;
10 v. tfame of the vessel the waste is deposited from;
11 vi. Cause of deposit?
12 vii. Method and time of cleanup.
13 (2) The owner or operator shall retain these records for no
14 less than three years and must submit these records to the
IS Administrator or the Secretary upon request within five working
16 days. The owner or operator shall promptly notify the designated
17 oversight authority if the owner or operator is unable to Beet
18 the requirement, -under 237.5(e). Failure to report such an event
is will result in a civil penalty established by the USCG.
20 (e) Tracking Svataata.
21 (1) The Administrator may require owners and operators of
A
22 vessels to operate a vessel tracking system on each vessel or as
23 the case may be systems when two or more vessels are involved, in
24 determining whether to require a tracking system the
25 Administrator will consider the following:
23 i. The owner/operator's history of compliance with SPA;
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1 ii. The owner/ opera tor's history of compliance vith otter
2 statutes intended to prevent deposit of municipal or
3 commercial waste, as defined in the regulation, into
4 coastal waters;
5 iii. The characteristic* and amounts of vaste transported;
6 iv. The feasibility of installing a specific kind of
7 tracking system. Manifest systems arc for the purposes
8 of the regulation considered feasible for all vessels.
9 Where an owner or operator of a vessel has a record of
10 violations of SPA or other statutes intended to prevent deposit
11 of municipal or commercial waste, the Administrator has the
12 option to recommend that a tracking system he installed*
13 Such systems shall be implemented or installed and placed in
14 operation within 30 days of the receipt of a notice from the
15 Administrator.
237*6 Permit reviev procedures.
17 (a) Permit review procedures will be followed as identified
is in 33 CFR Part 140.
19 (b) This regulation provides permit denial grounds.
*
*
20 237*7 Enforcement.
21 (a.} Violation of any prevision of these regulations could
22 lead to tne imposition of civil penalties.
23
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Appendix C:
Implementation of the Shore Protection Act of 1988
(33 CFR Part 151)
U.S. EPA Headquarters Library
Mail code 3201
1200 Pennsylvania Avenue NW
Washington DC 20460
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Wednesday
May 24, 1989
Part HI
Department of
Transportation
Coast Guard
33 CFR Part 151
Implementation of the Shore Protection
Act of 1988; Interim Rule with Request
for Comments
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22546 Federal Register / Vol. 54. No. 99 / Wednesday. _May24. 1969 / Rules and Regulations
DEPARTMENT OF TRANSPORTATION
Coast Guard
33 CFR Part 151
[CGD 83-014]
RIN2115-AD23
Implementation of the Shore
Protection Act of 19S3
AGENCY: Coast Guard, DOT.
ACTION: Interim rule with request for
comments.
SUMMARY: The Coast Guard is
publishing an interim rule to implement
permitting the numbering requirements
of the Shore Protection Act of 1988. The
Coast Guard is issuing these
requirements as an interim rule because
the Shore Protection Act requires that
permits be in place 240 days after the
Act's enactment, ivhich will occur on
July 15,1989. By issuing an interim rule,
the Coast Guard and the public will be
able to meet this mandated deadline.
DATES: EffectiveDate: 1. May 24,1989.
2. The Coast Guard will accept
comments on this interim rule until
August 24,1989.
ADDRESSES: Comments should be
submitted to the Executive Secretary,
Marine Safety Council (G-LRA-2/3600),
U.S. Coast Guard Headquarters, 2100
Second Street SW.. Washington, DC
20593-0001 between the hours of 8:00
a.m. and 3:00 p.m., Monday through
Friday, except Federal holidays.
Comments may-be delivered to and will
be available for copying at that address.
The Categorical Exclusion from the
requirements of the'National
Environmental Policy Act (NEPA) is
available for inspection and copying at
the same address.
Persons wishing to comment on the
information collection requirements
should submit their comments to: Office
of Regulatory Policy, Office of
Management and Budget. 726 Jackson
Place NW., Washington, DC 20503,
ATTN: Desk Officer, U.S. Coast Guard.
FOR FURTHER INFORMATION CONTACT:
Lieutenant James H. McDowell, Office
of Marine Safety. Security and
Environmental Protection (G-MPS-3)
(202) 267-0491, between 7:00 a.m. and
3:00 p.m., Monday through Friday,
except Federal holidays.
SUPPLEMENTARY INFORMATION: The
public is invited to participate in this
rulemaking by submitting written views,
data or arguments. Comments should
include the name and address of the
person making them, identify this
interim rule (CGD 89-014) and the
specific section of the interim rule to
•which each comment applies, and give
the reasons for the comment. If an
acknowledgment of receipt is desired, a
stamped, self-addressed postcard should
be enclosed.
All comments received before the
expiration date of the comment period
\vill be considered before any action is
taken on this interim rule. They will also
be considered in preparing the notice of
proposed rulemaking for the second
regulatory project described below in
the paragraphs under Regulatory
Approach.
Drafting Information
The principal persons involved in
drafting this rule are: Lieutenant James
H. McDowell, Project Manager, and
Stanley M. Colby, Project Counsel,
Office of Chief Counsel.
Discussion of the Interim Rule
/. Background
On November 18,1988, Congress
enacted the Shore Protection Act (33
U.S.C. 2501 et seq.), hereafter referred to
as the Act to help prevent trash.
medical debris and other unsightly and
potential harmful materials from being
deposited into the costal waters of the
United States as as result of sloppy
waste handling procedures. The
Conference Report on the Ocean
Dumping Ban Act (Report 100-1090)
stated that landfills and attendant
barging operations are a major source of
floatable waste hi harbor areas. The
report concluded that this type of waste
has fouled the beaches of this country
over the last two summers, reducing the
quality of coastal waters, endangering
the health of humans, marine mammals,
waterfowl and fish, and causing severe
decline in coastal economies dependent
upon tourism and recreational uses.
Section 4103(a)(l) of the Act requires
owners or operators of waste sources,
vessels transporting waste and waste
reception facilities to take reasonable
steps to minimize the amount of
municipal or commercial waste
deposited into coastal waters during
vessel loading and unloading operations
and during vessel transportation from a
waste source to receiving facilities. The
Act prohibits vessels from
transportating municipal and
commercial waste unless they have a
permit and display a number of other
prescribed marking 240 days after
enactment, which will occur on July 15,
1989. The Act also outlines provisions
for enforcing these requirements.
The Environmental Protection Agency
(EPA) and the Department of
Transportation (DOT) have been
assigned responsibility for implementing
the provisions of the Act. DOT is
responsible for issuing permits.
prescribing the number or marking
which vessels must display, and
enforcing regulations implementing the
Act. On January 12.1989. the Secretary
of Transportation delegated these
responsibilities to the Coast Guard.
//. Regulatory Approach
These interim regulations amend Part
151 of Title 33, Code of Federal
Regulations. This part is concerned with
shipboard requirements to prevent
pollution. Existing regulation in this Part
implement Annexes I, II and V of
MARPOL 73/78. There are no new
requirements in the regulations in this
document which change Annexes I, II or
V requirements. This interim rule
reorganizes Part 151 into 2 Subparts.
Subpart A will contain the existing
regulations in Part 151. Existing
Subparts A, B, C, and D will be
reorganized as undesignated hearings
under Subpart A. The new Subpart B
will contain the regulations
implementing the Act.
Due to the July 15,1989 statutory
implementation date, the Coast Guard
has decided to issue two regulatory
projects implementing the
responsibilities delegated under the Act
The first regulatory project which is this
document, is being initiated in the public
interest as expeditiously as possible, to
meet this deadline and allow vessels to
continue to operate without interrupting
the flow of waste removal. It establishes
the requirement for the owner or
operator of each vessel, whose purpose
is to transport municipal or commercial
waste, to apply for a conditional permit
and to display a vessel number. It
details the procedure to apply for a
conditional permit and requirements for
displaying the vessel number. It
establishes the procedures for issuing
conditional permits and the conditions
for denying issuance and-withdrawing a
conditional permit.
At a later date, procedures for
applications and issuance of a regular
permit will be proposed. These
procedures will continue, modify or
replace the procedures contained in this
document. Regulations implementing the
suspension and revocation provisions of
the Act will also be proposed.
///. Vessels Effected By This Ruin:
This rule applies to vessels whose
purpose is to transport municipal or
commercial waste in the coastal waters
of the United States. The conference
report on the Ocean Dumping Ban Act
(Report 100-1090) states that the Act
was intended "only to apply to vessels
whose purpose is the transportation of •
municipal or commercial waste, not all
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Federal Register / Vol. 54, No. 99 / Wednesday, May 24, 1989 / Rules and Regulations 22547
vessels. It was not intended to apply to
vessels that may generate waste during
their normal operations". There are
many vessels which transport some
quantities of municipal or commercial
waste incidentally to the predominant
business or purpose of the vessel, e.g., a
ferry which transports a garbage truck
loaded with municipal or commercial
waste. In this example, the ferry is not
required to apply for a permit, since the
ferry's predominant business or purpose
is not waste transportation. However, a
vessel which regularly transports
miscellaneous cargo but is hired to
transport waste for a specific voyage
would be required to h6ld a permit to
transport waste for that voyage, since
the predominant business or pyrflPfif °f
the vessel tor that voyage in waste
transportation.
7V. What Constitutes Municipal or
Commercial Waste
Section 151.1006 defines the term
"municipal or commercial waste", which
is the same definition provided by
section 4101(3) of the Act. This
definition includes solid waste regulated
under the Solid Waste Disposal Act (42
U.S.C. 6903) and transported for
disposal on land, including municipal
garbage, commercial refuse, medical
wastes, and wood debris. However, in
accordance with the Act, the term
specifically excludes hazardous wastes
identified and listed under the Solid
Waste Disposal Act (42 U.S.C. 6921),
waste generated by the vessel during
normal operations, construction debris,
sewage, sludge as permitted by the EPA,
and dredge spoil or fill materials subject
to regulation'under title I of the.Marine
Protection, Research and Sanctuaries
Act of 1972 (33 U.S.C. 1401 et seq.}, the
Federal Water Pollution Control Act (33
U.S.C. 1251 etseq.), or.the Rivers and
Harbors Appropriation Act of 1899 (33
U.S.C. 401 et-seq.).
V. Applying For a Permit
In order to. receive a conditional .
permit to transport municipal or ;
commercial waste, the owner or
operator of a vessel must apply by letter
to Commandant (G-MPS-1), U.S. Coast
Guard Headquarters, 2100 Second Street
SW.. Washington. DC 20593-0001. Attn:
Shore Protection Act Desk. Applications
must include the information required
by § 151.1012. which is also required by
section 4102(b) of the Act and an
acknowledgment that the information
provided on the application is true and
correct. After reviewing the application
for completeness, the Coast Guard will
determine, whether or.hot to issue the
conditional permit A vessel number and
the termination date of the conditional
permit will be added to the application.
A copy of the application will be
returned to the owner or operator to
serve as the conditional permit for the
vessel to transport municipal or
commercial waste after July 15,1989.
This expeditious method of issuance is
being implemented in the public interest
to avoid the interruption of waste
removal or any unnecessary
accumulation of waste on vessels or
shore structures.
Under the provisions of the Act, it will
be unlawful to transport municipal or
commercial waste after July 15,1989
without a permit. To allow the continued
transportation of municipal and
commercial waste and to avoid the
health hazards that would occur if
waste accumulated, this interim rule
provides for the issuance of conditional
permits, which will be effective
immediately. These conditional permits
are subject to being withdrawn if further
inquiry or consultation with
Environmental Protection Agency (EPA)
officials indicates the vessel would not
qualify for a regular permit As required
by the Act, regular permits will not be
effective until 30 days after they are
issued.
Conditional permits will be valid for
18 months, unless a shorter period is
specified on the permit The Coast
Guard may deny issuance of a
conditional permit if the application for
the conditional permit does not contain
the required information or if the Coast
Guard has reason to believe the
information provided is not true or
correct The Coast Guard will notify the
owner or.operator in writing of the
denial, the reason for the denial and the
procedures for appealing this decision.
After issuing the conditional permit.
the Coast Guard will consult with the
regional director of the EPA, as required
by 4102(d) of the Act, to determine
whether or not the owner or operator of
the vessel has a record or a pattern of
serious violations of the Act, the Solid .
Waste Disposal Act (supra), the Marine
Protection. Research and Sanctuaries
Act of 1972 (33 U.S.C. 1401 et seq.). the
Rivers and Harbors Appropriations Act
of 1899 (33 U.S.C. 401 et seq.), or the
Federal Water Pollution Control Act (33
U.S.C. 1251 etseq.).
A conditional permit may be
withdrawn at any time after issuance if
the Administrator of the EPA requests
withdrawal because the Administrator
has determined that the owner or
operator of the.vessel has a record or a
pattern of serious violations of the
statutes listed under section 4102(d) (1)
through (5) of the Act and described
above. The Coast Guard will notify the
owner or operator in writing of the
withdrawal, the reason for the
withdrawal and the procedures for
appealing this decision.
Owners or operators of vessels which
have been denied issuance of a
conditional permit or have had a
conditional permit withdrawn may
request reconsideration by the issuing
authority. Owners or operators who are
not satisfied with a ruling after it has
been reconsidered may appeal this
decision to the Chief, Office of Marine
Safety, Security and Environmental
Protection, U.S. Coast Guard
Headquarters, Washington, DC 20593-
0001. Appeals must be in writing and
contain complete supporting
documentation and evidence which the
appellant wishes to have considered.
VI. Displaying a Vessel Number
Vessels under the Act are required to
display a number or other marking on
the vessel as prescribed by the
Secretary of Transportation. The
purpose of this marking is to aid in
identification. The number assigned to
the vessel will be stated on the
conditional permit as described above.
The vessel number must be displayed
on the vessel so that it is readily visible
from either side. The vessel number
must be clearly legible, displayed
against a contrasting background and in
block figures that are at least 18 inches
in height.
Regulatory Evaluation
There are approximately 400 vessels
whose purpose is the transportation of
municipal and commercial w.aste in
coastal waters. As explained above, the
owner or operator of each of these
vessels will be required to apply by
letter for a permit to transport municipal
and commercial waste in coastal waters
and to display, a number on the vessel.
Conditional permits issued under this
rule are in effect for a period no longer
than 18 months. At the end of this
period, vessel owners or operators who
intend to transport municipal or
commercial waste will be required to
reapply for a permit. The Coast Guard
estimates the total cost to the public for
completing the application and
displaying the vessel number will
amount to less than $15,000.00 Appeals,
when utilized, are estimated to cost less
than $2,000.00. The cost of this
regulatory project is so low that no
further regulatory evaluation is
considered necessary.
The Coast Guard concludes that these
regulations are non-major under .
Executive Order 12291 and
nonsignificant under DOT. regulatory
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22548 Federal Register / Vol. 54, N'o. 99 / Wednesday, May 24, 1989 / Rules and Regulations
policies and procedures (44 FS 11034;
February 26,1979).
Regulatory Flexibility Act
The Coast Guard has considered the
impact of these regulations on small
entities. The Coast Guard has adopted
the Small Business Administration's
(S3A) definition of "small business"
used when considering SBA loans to
concerns engaging in transportation and
wharehousing (13 CFR 121.10(0) as a
definition for small entities. A concern is
considered small, under this definition,
if its annual receipts do not exceed Sl.5
million.
These regulations contain only
minimal reporting requirements.
Respondents are required to complete
an application containing only the
minimum information necessary for the
Coast Guard to fulfill its obligation
under the Act. They are also required to
display a number on the vessel. The cost
of complying with these requirements
will be minima!. These costs are
proportionally lower for small entities
than for larger ones because a small
entity will have fewer vessels and
therefore will have fewer applications to
complete and numbers to display. Since
these costs are so low, the cost to any
individual small entity will be negligible.
Therefore, the Coast Guard certifies that
this rule will not have a significant
economic impact on a substantial
number of small entities. .
Paperwork Reduction Act
This rule will add the new information
reporting requirement that all vessels
whose purpose is the transportation of
municipal and commercial waste apply
for a conditional permit The
information reporting requirements have
been submitted to the Office of
Management and Budget for approval
under the provisions of the Paperwork
Reduction Act of 1980 (44 U.S.C. 3501 et
seq.). OMB Control Number 2115-0579
has been assigned under the provisions
of 5 CFR 1320.18.
Environmental Impact
The permit and numbering system,
prescribed by the interim rule, are a part
of a regulatory program intended to
minimize the amount of municipal or
commercial waste entering the coastal
waters of the U.S. However, the
proposed regulations are administrative
in nature-and do not prescribe any
operational requirements which would
have an impact on the environment. The
interim rule has been thoroughly
reviewed by the Coast Guard and has
been determined to be categorically
excluded from further environmental
documentation as provided for in 10
CFR 51.22(c}(3). Therefore, neither an
Environmental Assessment or
Environmental Impact Statement has
been prepared for this interim rule. The
categorical exclusion determination is
available in the docket for examination
and copying as indicated under
"ADDRESSES".
Federalism Assessment
This interim rule has been analyzed in
accordance with the principles and
criteria contained in Executive Order
12612, and it has been determined that
this rulemaking does not have sufficient
federalism implications to warrant the
preparation of a Federalism
Assessment.
Regulatory Information Number (RIN)
A regulatory information number has
been assigned to this regulatory action
and will be listed in the Unified Agenda
of Federal Regulations. The Regulatory
Information Service Center (RISC)
publishes the Unified Agenda in April
and October of each year. The RIN
number listed at the heading of this
document can be used to follow the
progress of this action in the Unified
Agenda.
List of Subjects in 33 CFR Part 151
Oil pollution, Reporting and
recordkeeping requirements. Water
pollution control.
In consideration of the preceding, the
Coast Guard amends Part 151 of Title 33,
Code of Federal Regulations, as follows:
PART 151—[AMENDED]
1. By removing the authority citation
for Part 151 and adding the authority
citation for Subpart A to read as
follows:
Authority: 33 U.S.C. 1321(j)(l)(C) and
1903(b): E.0.11735,3 CFR. 1971-1975 Comp.,
p. 793; 49 CFR 1.46.
2. By revising the title of Part 151 to
read as follows:
PART 151—VESSELS CARRYING OIL,
NOXIOUS LIQUID SUBSTANCES,
GARBAGE AND MUNICIPAL OR
COMMERCIAL WASTE
3. By removing all subpart
designations but leaving the headings of
those removed subparts and adding a
new Subpart A above the undesignated
"General" heading to read as follows:
Subpart A—Implementation of
MARPOL 73/78
4. By adding a new Subpart B to read
as follows:
Subpart B— Transportation of Municipal
and Commercial Waste .
151.1000 Purpose.
151.1003 Applicability.
151.1006 Definitions.
151.1009 Transportation of municipal or
commercial waste.
151.1012 Applying for a conditional perciii.
151 .' 015 Issuing or denying the issuance of
a conditional permit.
T51.1018 Withdrawal of a conditional
permit.
151.1021 Appeals.
151.1024 Display of vessel number.
Subpart B — Transportation of
Municipal and Commercial Waste
Authority: 33 U.S.C. 2602; 49 CFS 1.46.
§ 151.1000 Purpose.
The purpose of this subpart is to
implement the permit provisions of the
shore Protection Act of 1988, (33 U.S.C.
2501 et set;.).
§ 151.1003 Applicability.
(a) Except as provided by paragraph
(b) of this section, this subpart applies to
each vessel whose purpose is the
transportation of municipal or
commercial waste hi coastal waters.
(b) This subpart does not apply to
public vessels.
§ 151.1006 Definitions.
As used in this subpart —
"Coastal Waters" means —
(1) The territorial sea of the United
States;
(Z) The Great Lakes and their
connecting waters;
(3) The marine and estuarine waters
of the United States up to the head of
tidal influence; and
(4) The Exclusive Economic Zone as
established by Presidential
Proclamation Number 5030, dated March
10. 1983.
Note: The Exclusive Economic Zone
extends from the baseline of the territorial
sea of the United States seaward 200 miles.
"Municpal and commercial waste"
means solid waste as defined in section
1004 of the Solid Waste Disposal Act (42
U.S.C. 6903) except-
(1) Solid waste identified and listed
under section 3001 of the Solid Waste
Disposal Act (42 U.S.C. 6921);
(2) Waste generated by a vessel
during normal operations;
(3) Debris solely from construction
activities;
(4) Sewage sludge subject to
regulation under title I of the Marine
Protection, Research, and Sanctuaries
Act of 1972 (33 U.S.C. 1401 et 9£>q.}; and
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Federal Register / Vol. 54, No. 99 / Wednesday, May 24, 1989 / Rules and Regulations 22549
(5) Dredge or fill material subject to
regulation under title I of the Marine
Protection, Research and Sanctuaries.
Act of 1972 (33 U.S.C. 1401 et seq.), the
Federal Water Pollution Control Act (33
U.S.C. 1251 et seq.), or the Rivers and
Harbors Appropriation Act of 1899 (33
U.S.C. 401 et seq.).
"Public vessel" means a vessel that—
(1) Is owned, or demise chartered, and
operated by the United States
Government or a government of a
foreign country; and .
(2) Is not engaged in commercial
service.
"Vessel" means every description of
watercraft or other artifical contrivance
used, or capable of being used, as a
means of transportation on water.
§ 151.1009 Transportation of municipal or
commercial -waste.
A vessel may not transport municipal
or commercial waste in coastal waters
without—
(a) A conditional permit to transport
municpal or commercial waste issued
under this subpart; and
(b) Displaying a number in
accordance with § 151.104.
§ 151.1012 Applying for a conditional
permit
(a) The owner or operator of each
vessel to which this subpart applies
shall apply by letter for a conditional
permit required by § 151.1009.
Applications must be submitted to
Commandant (G-MPS-1), U.S. Coast
Guard Headquarters, 2100 Second Street
SW.. Washington. DC 20593-0001, Attru
Shore Protection Act Desk and include
the following:
(1) The name, address, and telephone
number of the vessel owner and
operator, . .
(2] The vessel's name and official
number, if any.
(3) The vessel's area of operation.
(4) The vessel's transport capacity.
(5) A history of the types of cargo
transported by the vessel during the
previous year, including identifying the
type of municipal or commercial waste
transported as—
(i) Municipal waste:
(ii) Commercial waste;
(Hi) Medical waste: or
(iv) Waste of another character.
(6) The types of cargo to be
transported by the vessel during the
effective period of trie conditional ,..
permit, including identifying the type of
municipal or commercial waste as.it is
identified in paragraphs (a)(5)(i) through
(iv] of this section. \ ' '••'
(7) A statement of whether the
application for a conditional permit is
for a single voyage, a short term
operation or a continuing operation. If
the application is for a single voyage or
a short term operation, the statement
must include the duration of the voyage
or operation.
(8) An acknowledgment that certifies
as to the truthfulness and accuracy of
the information provided.
(b) The owner or operator under
paragraph (a) of this section shall
provide any additional information the
Coast Guard may require.
§151.1015 Issuing or denying the
issuance of a conditional permit
(a) After reviewing the application
made under § 151.1012, the Coast Guard
either—
(1) Issues the conditional permit for a
vessel under this section: or
(2) Denies the issuance of the
conditional permit to the vessel in
accordance with paragraph (c) of this
section. On denying the issuance of the
permit, the Coast Guard notifies the
applicant of the—
(i) Denial and the reason for the
denial; and •
(ii) Procedures under § 151.1021 for
appealing the denial.
(b) Each conditional permit issued
under this section is effective—
(1) On the date it is issued; and
(2) Until the expiration date stated on
the conditional permit unless it is—
(i) Withdrawn under § 151.1018;
(ii) Terminated because—
(A) The vessel is sold: or
(B) This subpart no longer applies to •
the vessel. .
(c) The Coast Guard may deny the
issuance of a conditional permit if—
(i) The application does not contain
the information required under
§151.1012; or . .
(ii) There is reason to believe that the
information contained on the
application is not true and correct.
§151.1018 Withdrawal of a conditional
permit.
(a) The Coast Guard may withdraw a
conditional permit if the Administrator
of the EPA requests withdrawal because
the Administrator has determined that
the owner or operator of the vessel has
a record or a pattern of serious
violations of-^
(1) Subtitle A of the Shore Protection
Act of 1988 (33 U.S.C. 2601 et seq.);
(2) The Solid Waste Disposal Act (42
U.S.C. 6901 et seq.):
(3) the Marine Protection, Research,
and Sanctuaries Act of 1972 (33 U.S.C.
1401 et seq.); :
(4) The Rivers and Harbors
Appropriations Act of 1899 (33 U.S.C.
1401 et seq.); or
(5) The Federal Water Pollution
Control Act (33 U.S.C. 1251 et seq,).
. (b) Upon reaching a determination to
withdraw a conditional permit, the
Coast Guard notifies the owner or
operator of—
(1) The withdrawal and the reason for
the withdrawal;
(2) The procedures for appealing the
withdrawal.
(c) After receiving the notice under
paragraph (b) of this section, the owner
or operator shall ensure that—
(1) The vessel immediately ceases
transporting municipal or commercial
waste and the marking required by
§ 151.1024 is removed; and
(2) The conditional permit is returned
to the Coast Guard within 5 days after
receiving the notice.
§151.1021 Appeals.
(a) Any person directly affected by an
action taken under this subpart may
request reconsideration by the Coast
Guard officer responsible for that action.
(b) The person affected who is not
satisfied with a ruling after having it
reconsidered under paragraph (a) of this
section may—
(1) Appeal that ruling in writing within
30 days after the ruling to the Chief,
Office of Marine Safety, Security and
Environmental Protection, U.S. Coast
Guard. Washington, DC 20593-0001; and
(2) Supply supporting documentation
and evidence that the appellant wishes
to have considered.
(c) After reviewing the appeal
submitted .under paragraph (b) of this
section, the Chief, Office of Marine
Safety, Security and Environmental
Protection issues a ruling which is final
agency action.
(d) If the delay in presenting a written
appeal has an adverse impact on the
operations of the appellent, the appeal
under paragraph (b) of this section—
(1) May be presented orally; and
(2) Must be submitted in writing
within five days after the oral
presentation— . ..
(i) With the basis for the appeal and a
summary of the material'presented
orally: and . . .....
(ii) To .the same Coast Guard official
who heard the oral presentation.
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22550 Federal Register / Vol. 54, No. 99 / Wednesday, May 24, 1989 / Rules and Regulation^
§151.1024 Display of number.
(a) The owner or operator of each
vessel under this subpart must ensure
that the vessel number stated OR the
conditional permit issued under
.§ 151.1015 is displayed so that it—
(1) Is clearly legible;
(2) Has a contrasting background;
(3) Is readily visible from either side
of the vessel; and
(4) Is in block figures that are at least
18 inches in height.
(b) No person may tamper with or
falsify a number required under this
section.
J.D. Sipes.
Rear Admiral, U.S. Coast Guard, Chief. Office
of Marine Safety, Security and Environmental
Protection.
April 28,1989.
[FR Doc. 89-12396 Filed 5-23-89; 8:45 am)
BIUJNG CODE 4910-14-*
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U.S EPA Headquarters Library
Mail code 3404T
1200 Pennsylvania Avenue NW
Washington, DC 20460
202-566-0556
MEMORANDUM JAH < ' «*
SUBJECT: Work Group Closure for Proposed Shore Protection Act
Regulations: Waste Handling Practices for Vessels and
Waste Transfer Stations, Appendix A - Guidance for
developing operation and maintenance manuals.
40 CFR Part 237
FROM: Joel Salter, Chair
Shore Protection Act Regulations Work Group
TO: Shore Protection Act Work Group Members
The following draft document provides guidance to owners and
operators of municipal and commercial waste transportation
operations for the development of operation and maintenance
manuals. We are sending this out too late for formal review at the
workgroup closure meeting scheduled for January 18, 1994 at
3:00 pm, but, if you would like to submit written comments on this
document at that time please do. We will accept further comment
prior to Red Border Review.
Addresses: Deborah Lebow
David Drelic, OE-Water
Ron Jordan, OW/OST
Paul Cassidy, OSWER
Moira Shoen, OPPE T
Andy Gordon, OGC
Brad Mahanes, OW/OWEC
Estelle Bolka, OSWER/OWPE
Stan Siegel, Region II
Janine Tankoos, Region II
Daniel Forger, Region II
Bob Hazen, Region II
Bob Howard, Region IV
Chistopher McArthur, Region IV
Becky Weber, Region VI
Ken Huffman, Region VI
Commander William Chubb, United States Coast Guard
Janice Jackson, United States Coast Guard
Geoff Warren, United States Coast Guard
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APPENDIX A - GUIDANCE ON OPERATION AND MAINTENANCE MANUALS FOR
WASTE SOURCES, VESSELS AND RECEIVING FACILITIES
This appendix provides a basic structure for the development
of operation and maintenance manuals for the regulated entities.
The operation and maintenance manual developed by a vessel
permitted under the Shore Protection Act, or associated waste
source and receiving facility should be a clear statement of
operation and maintenance procedures for preventing waste from
accidentally spilling into coastal waters of the United States.
Each regulated vessel, or associated waste source and receiving
facility should develop an operation and maintenance manual to
suit its particular characteristics.
Applicability
The owners or operators of the following vessels (unless
excluded below) are required to develop and submit an operation
and maintenance manual:
A vessel transporting municipal or commercial waste in
coastal waters;
• Vessels that regularly transport miscellaneous cargo but are
hired, contracted, or used to transport municipal or
commercial waste for a specific voyage; and
• Vessels that transport operational waste from other vessels
that meet the definition of municipal or commercial waste -
this does not include vessels transporting their own
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operational wastes.
The owners or operators of the following vessels are
excluded from developing and submitting operation and maintenance
manuals:
• Public vessels, defined as vessels that are owned, demise
chartered, and operated by the United States Government or a
government of a foreign party, and do not engage in
commercial service;
• Vessels that transport some quantity of waste incidental to
the predominant business or purpose of the vessel. For
example, a ferry which transports a garbage truck loaded
with municipal or commercial waste; and
• Vessels transporting recreational vessel sewage or
"blackwater" pumped from recreational vessel holding tanks.
The owners or operators of waste sources and receiving
facilities, as defined below and in 237.3(g) and (1) are required
to develop and submit an operation and maintenance manual:
• A facility, vessel, or operation that receives municipal or
commercial waste unloaded from a vessel; and
• A vessel or a facility from which municipal or commercial
waste is loaded onto a vessel, including any rolling stock
or motor vehicles from which that waste is directly loaded.
The Manual
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The structure and detail of each operation and maintenance
manual may vary as the vessel, waste source, or receiving
facility will vary and as the type of waste transferred and
transported will vary. As a result of the variation in the
physical nature of municipal and commercial waste, the structure
and requirements provided in this appendix are necessarily
generic and will require further elaboration based on the
specifics of the operations and maintenance nuances at your
facility, source, or vessel. However, it is expected that an
operation and maintenance manual meeting the minimum requirements
of this regulation need not exceed 20 to 30 pages in length. It
is recommended that owners and operators of sources, facilities
and vessels review the recommended waste handling practices
provided in the Shore Protection Act Implementation Guidance
document (EPA842-B-94-001).
Operation and Maintenance Manuals for Vessels
The operation and maintenance manual for vessels consists of
three parts: 1) waste transfer procedures, 2) waste clean up
procedures, and 3) waste deposit reporting procedures.
The first part of the operation and maintenance manual shall
identify the measures that you will take to minimize the deposit
of waste into coastal waters during transport and transfer
activities. In the operation and maintenance manual you should:
• Describe the roles and responsibilities of each relevant
member of the crew during waste transfer and transport.
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• Provide a detailed step-wise description to the vessel crew
on the implementation of the technologies and techniques
that will be employed during waste transfer and transport.
These should include appropriate containment or diversionary
structures, or other equipment designed to minimize waste
deposits. The technologies and techniques described shall
be appropriate to the size and nature of the vessel and must
represent a responsible effort to minimize the spillage of
waste,
• Instruct the crew to secure the waste in such a way as to
prevent the deposit of waste.
Direct the crew not to load the vessel in excess of its
capacity.
• Direct the crew that all ports and valves that may be used
for flushing or discharging waste or waste residue from the
hull or tanks must be clearly labelled and that all ports
and valves must be sealed except for the purpose of
transferring wastes.
Describe record keeping procedures, i.e. record of amount
and type of waste offloaded, or amount and type of waste
received.
The second part of the operation and maintenance manual
describes for the vessel crew the procedures that will be used to
clean up, promptly and thoroughly, any waste deposited into
coastal waters. This section must:
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• Describe the role and responsibilities of each relevant
member of the crew during clean up.
• Describe in detail for the crew the techniques and
technologies that will be employed during waste clean up.
The technologies or techniques must be appropriate to the
waste type and the size and nature of the vessel and must
represent a responsible effort to clean up all waste
promptly and thoroughly.
In the third part of the operation and maintenance manual
describe the procedures to be followed if the vessel's crew is
unable to clean up all of the waste deposited. In this section
you must:
• Provide a contact name and telephone number of the
designated responsible person (40 CFR 237.5) involved in the
ownership or operation of the vessel. Indicate that this
contact person should be notified immediately by telephone,
marine radio or in writing if the crew is unable to
completely clean up the waste deposited. This contact name
and phone number must be posted on the vessel in a location
visible to the vessel's crew.
• Provide a contact name and telephone number of the
appropriate USCG official to be contacted by the responsible
person if the crew is unable to completely clean up the
waste deposited. This contact name and phone number must
also be posted on the vessel in a location visible to the
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vessel's crew.
• Provide an example of a follow up letter to be used by the
responsible person to report the waste deposit to the
appropriate USCG official (Table 1).
• Provide copies of the form that assists record-keeping and
reporting in the event of a waste deposit (EPA guidance
document EPA842-B-94-001). The operation and maintenance
manual must instruct the appropriate crew member to complete
one of these forms for each deposit of waste. The record
must include the time and date of the deposit, estimates of
the amount of wastes deposited and amount retrieved, actions
taken to clean up the waste deposit, and any other pertinent
information. If an action was not accomplished or it was
decided to attempt an unsuccessful control strategy, it is
important to document why those actions were taken. Any
actions to prevent further incidents of this type should
also be recorded. All waste deposits must be recorded/
whether cleaned up or not.
4.2 Operation and Maintenance Manuals for Waste Sources and
Receiving Facilities
The operation and maintenance manual for waste sources and
receiving facilities consists of three parts: waste transfer
procedures, waste clean up procedures, and waste deposit
reporting procedures.
The first part of the operation and maintenance manual must
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identify the measures that you will take to prevent the deposit
of waste into coastal waters during the transfer of wastes. In
the operation and maintenance manual you must:
• Describe the roles and responsibilities of each relevant
facility staff member during waste transfer.
Provide a detailed step-wise description to relevant
employees on the implementation of technologies and
techniques that will be employed during waste transfer.
These should include appropriate containment or diversionary
structures, or other equipment designed to minimize waste
deposits. The technologies or techniques described must be
appropriate to the waste type and size and nature of the
vessels loaded/unloaded, and represent a responsible effort
to minimize the deposit of wastes.
Describe record keeping procedures, i.e record of amount and
type of waste offloaded, or amount and type of waste
received.
The second part of the operation and maintenance manual
describes for your employees the procedures that will be used to
clean up, promptly and thoroughly, any waste deposited into
coastal waters. This section must:
• Describe the roles and responsibilities of each relevant
employee during waste clean up.
Describe in detail how to implement the techniques and
technologies that will be employed during waste clean up.
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The technologies and techniques used must be appropriate to
the waste type and size and nature of the vessels, and must
represent a responsible effort to clean up all waste
promptly and thoroughly. The methods described may include
sweeper boats, manned boats to remove waste, shoreline clean
up crews, and booms or other equipment designed to recover
waste deposited near shore.
Specify that clean up equipment and personnel be in
continuous operation, or on standby at the transfer facility
for waste transfer operations that occur during an ebb tide.
Direct all employees that all waste that clearly resulted
from, or may have resulted from, waste loading or unloading
operations shall be removed prior to the first high tide
following the completion of any waste transfer operation or
before the waste has had a chance to disperse.
The third part of the operation and maintenance manual
describes the procedures to be followed if the facility's staff
is unable to clean up all of the waste deposited. This section
must:
• Provide a contact name and telephone number of the
designated responsible person (40 CFR 237.4) involved in the
ownership or operation of the facility. Indicate that this
contact person should be notified immediately by telephone
or in writing if the employees are unable to completely
clean up the waste deposit. This contact name and phone
8
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number must be posted at the facility in a location visible
to the facility's employees.
Provide a contact name and telephone number of the
appropriate EPA official to be contacted if the employees
are unable to completely clean up the deposit. This contact
name and phone number must also be posted at the facility in
a location visible to the facility's employees.
Provide an example of a letter to be used by the responsible
person to report the waste deposit to the appropriate EPA
official (Table 2).
Provide copies of the form that assists record-keeping and
reporting in the event of a waste deposit (Table 3). The
operation and maintenance manual must instruct the
appropriate employee on duty to complete one of these forms
for each waste deposit. The record must include the time
and date of the deposit, estimates of the amount of wastes
deposited and amount retrieved, cause of deposit, actions
taken to clean up the waste deposit, and any other pertinent
information. If an action was not accomplished or it was
decided to attempt an unsuccessful control strategy, it is
important to document why those actions were taken. Any
actions to prevent further incidents of this type should
also be recorded. All waste deposits must be recorded,
whether cleaned up or not. »•
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