United States Solid Waste and . 1530-R-97-035
Environmental Protection Emergency Response : PB97-176 994
Agency . (5305W)
&EPA Regulatory Impact
Analyses: Phase IV
Land Disposal
Restrictions - Toxicity
Characteristic [TC]
Metals
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Regulatory Impact Analyses:
\
Phase IV Land Disposal
Restrictions - TC Metals
Prepared for
U.S. Environmental Protection Agency
Office of Solid Waste
401 M St., SW (5307W)
Washington, DC 20460
Prepared by
Tayler H. Bingham
James. H. Turner
Research Triangle Institute
3040 Comwallis Road
Research Triangle Park, North Carolina 27709-2194
Contract Number 68-W6-0053
RTI Project Number 6720-08
April 14, 1997
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Table of Contents
Section Page
1.0 Nonferrous Foundries 1
2.0 Waste Generation and Management 2
3.0 Current Treatment Practices 2
4.0 Revised UTS Levels for TC Nonwastewaters 3
5.0 Cost Analysis ...... 6
5.1 Unit Costs 6
5.2 Aggregate Costs 10
6.0 Economic Impacts 11
7.0 Impacts on Small Entities ..., 12
8.0 Benefits 12
8.1 The Circular System 13
8.2 The Economic Benefits of Groundwater 14
8.2.1 With Policy Groundwater Quality Changes .- ... 14
8.2.2 Groundwater Service Flow Changes 14
8.2.3 Resource Allocation Changes ..... 15
8.2.4 Human Welfare Changes 18
9.0 Benefit-Cost Comparison ... 19
References 21
Appendix A A-l
Appendix B , B-l
111
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Figures
Page
1. The Circular System 15
2. Groundwater Function ........' 16
Tables
Page
1. Estimated Number of Foundries Employing Each Stabilization Reagent for On-Site
Treatment in the Baseline 2
2. Incremental Cost Per Nonferrous Foundry 10
3. Total Incremental Cost to Nonferrous Foundries :.......:.. 10
4. Economic Impact of UTS on Nonferrous Foundry Industry for Facilities that Generate
Hazardous Wastes .....: '.' 11
5. Storage and Service Functions of Water Resources Potentially Impacted by TC Metals Wastes 17
6. Empirical Estimates of Ground Water Protection Benefits 20
IV
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§3004(m) of the Resource Conservation and Recovery Act directs the EPA Administrator to
promulgate treatment standards for hazardous wastes prohibited from land disposal in'order to minimize
long term threats to human health and the environment.1 In 1990 as part of the Third Third LDR rule
EPA developed treatment standards for Extraction Procedure (EP) metals wastes that require the wastes
meet characteristic levels before land disposal. In 1994 the Phase II LDR rule established Universal
Treatment Standards (UTS) for 216 organic, metal, and cyanide constituents in hazardous waste. In
1995, EPA proposed to revise treatment standards for eight toxicity characteristic (TC) metal wastes:
arsenic, barium, cadmium, chromium, lead, mercury, selenium and silver.2 In the RIA for the proposed
rule, EPA stated that the achievement of the proposed universal treatment standards (UTS) for TC metal
wastewaters and nonwastewaters could be achieved through existing technology at a minimal cost.3
Public commenters have raised concern over their technical ability to meet the.standards and the
costs associated with the previously proposed treatment standards. EPA has carefully considered this
information and, as discussed in Section 4.0 below, EPA believes that there will not be significant costs
to the majority of the TC metals universe affected by the standards. However, nonferrous foundries may
incur additional costs, especially for the management of lead and cadmium nonwastewaters. This RIA
examines the potential costs and the economic impacts of those costs for nonferrous foundries. It also
provides a qualitative assessment of the potential environmental benefits of the standards.
1.0 Nonferrous Foundries
The United States nonferrous foundry industry (SIC codes 3366,3369, also some nonferrous
foundries in the fabricated metal SIC codes, principally 3491,3492, and.3494, valves and fittings)
includes some 2,000 nonferrous foundries (3,000 total) producing fabricated metal products. All
foundries produce spent sand from molds used to form metal castings. Approximately, 791 nonferrous
foundries (either brass & bronze or brass, bronze & aluminum) would be directly impacted by the rule.4
It is generally believed that all nonferrous foundries are small businesses according to the Small
Business Administration definition of small business as firms with fewer than 500 employees. A 1989
survey by the American Foundrymen's Society (AFS) indicated that the average foundry size was 69
employees. The survey was biased towards larger foundries because foundries with 10 or fewer
employees were not included. A 1995 AFS survey indicates that 345 of 614 surveyed copper-based
foundries had fewer than 50 employees. An extrapolation from data from the 1992 Census of
1 42 U.S.C, §6924(m), Solid Waste Disposal Act 3004(m).
2 Developed from a telecon between Gary Mosher, American Foundrymen's Society, and James H.
Turner, RTI. September 24,1996. :
3 -•: • Regulatory Impact Analysis of the Phase IV Land Disposal Restriction Rule, August 18, 1995, pp.
1-11,1-14.
4 Data provided in a letter from Collier, Shannon, Rill, and Scott, November 27,1995 to EPA
RCRA Information Center.
1.
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Manufactures indicates that 1992 annual revenues for this group of nonferrous foundries were
approximately $2.094 billion.1
2.0 Waste Generation and Management
Sand is used in the production of nonferrous castings to provide physical support of the mold and
to serve as a heat sink. While much of this sand is recycled, some is degraded and must be discarded. Of
the estimated seven million tons of foundry sand disposed of annually about 300,000 tons exhibit the
toxicity characteristic for lead and cadmium. This estimate is based on the assumption that each of the
650 brass and bronze foundries and each of the 386 brass, bronze and aluminum foundries generate 375
tons of waste sand annually. Further, it is estimated that 98 percent of the former group and 40 percent
of the latter, generate sand wastes that exhibit the TC for lead and cadmium.6 Thus,
375[(650 * 0.98) + (386 * 0.40)] = 300,000
Assuming all facilities that generate TC wastes requiring treatment require treatment for all their
waste sand, about 791 facilities would be directly impacted by the requirement to meet UTS
requirements. About 89 percent of these facilities (704) treat on site. Of that treated on site about 75
percent is treated with iron filings. The remainder is stabilized with other chemicals typically trisodium
phosphate (TSP)7-see Table 1.
Table 1. Estimated Number of Foundries Employing Each Stabilization Reagent
for On-Site Treatment in the Baseline
Stabilization Reagent Number of Facilities
Iron fillings 528
Trisodium phosphate 176
Total 704
3.0 Current Treatment Practices . . .
The treatment practices used to reduce the mobility of metal concentrations in TC wastes consist
of a series of unit operations that can be combined in different ways depending on the waste to be treated
and its form. These operations are described below for treatment of nonwastewaters. These operations
Data from the 1992 Census of Manufactures indicates that 437 nonferrous foundries (including
copper, brass, bronze foundries) each generated receipts of $2.647 million. This would
extrapolate to an aggregate value of $2.094 billion (791 x 2.647 = 2.094 billion) for
791 nonferrous foundries that AFS believes are affected by today's rule.
Data provided in a letter from Collier, Shannon, Rill, and Scott, November 27,1995 to EPA
RCRA Information Center. .
Letter from the American Foundrymen's Society, Inc. to Michael Petruska, USEPA, Office of
Solid Waste, August 2, 1996.
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are current practices and can be used to meet the proposed standards. Practices will vary across facilities
depending on the specific conditions of each manager.
While similar to mineral processing waste treatment, quantities and specific treatment practices
may be different. For example, cement is a typical stabilizing agent used in the treatment of metal . -
wastes. However, as noted above, information suggests that foundry wastes are typically treated with
iron filings or trisodium phosphate (TSP).
The current LDR treatment standard for hazardous lead nonwastewaters is 5.0 mg/L TCLP.
After the concentration of lead is reduced below its characteristic level, the waste is no longer hazardous
and may be disposed of in a Subtitle D landfill. A typical waste treatment train used to reduce
concentrations of solid toxic metals includes storage, stabilization of solids with cementitious materials, .
and disposal of stabilized wastes in Subtitle D (nonhazardous) landfills. The treatment methods and
subsidiary operations are summarized below.
Storage
Wastes are typically stored in drums, tanks, roll-off containers, or buildings. Small quantities of
solids are usually stored in drums: Each storage method has its own requirements for moving the waste
into and out of the storage area. Where leaching or leaking can take place, monitoring must be used to
detect such occurrences. As long as the material is defined as hazardous waste, storage facilities must
meet Subtitle C design and operating requirements.
Stabilization
Metal-bearing solids and dewatered sludges that exhibit a characteristic and are, therefore,
hazardous can be treated with cement and/or other materials that form a hard substance with low
leaching characteristics. Stabilization adds significantly to the mass of material that must be landfilled.
Disposal
After treatment, residues must be given a final disposal place. Either Subtitle C or Subtitle D
landfills are generally used.
Subtitle C Landfill Disposal Subtitle C landfills are required for disposal of hazardous wastes.
Stringent monitoring, closure, and post-closure requirements must be met to ensure that toxic materials
do hot migrate from the site. Construction must be such that leaching or migration is kept to a minimum.
Highly impermeable underlying soils and landfill liners are required. In some cases, because of logistics,
it may be less costly to dispose of Subtitle D wastes in a Subtitle C landfill.
Subtitle D Landfill Disposal of Treated Wastes For characteristic wastes that have been
treated to a concentration below the required treatment level, disposal may be made in a Subtitle D
landfill. Some of these landfills do not have the special requirements for construction, monitoring, and
closure that are found at the Subtitle C landfills.
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4.0 Revised UTS Levels for TC Nonwastewaters
Public commenters including a commercial hazardous waste treatment firm and trade
associations representing generators of lead-bearing hazardous waste D008 (primarily secondary lead
slags from lead-acid batter smelters and foundry sands from nonferrbus foundries) stated in their
response that either the proposed treatment standards for certain constituents could not be met .or
alternatively that they could onjy be met at an additional cost.8 These comments focused mostly on the
proposed treatment standards for lead, chromium and selenium. For lead and chromium nonwastewaters,
one commercial hazardous waste treatment firm, Chemical Waste Management, suggested that
additional costs could result from additional treatment reagent when the total lead and chromium content
of these wastes exceeded one percent.9 Another commercial hazardous waste treatment firm, Rollins
Environmental, has suggested that it would have been able to meet treatment standards for lead and -
chromium nonwastewaters at the 0.37 and 0.86 ppm level without modifying its treatment process.10
Only the foundry industry identified cadmium as a constituent of potential concern in terms of
treatability using treatment reagents, trisodium phosphate and iron filings, currently utilized within the
foundry industry. EPA has carefully considered this information in developing revised treatment
standards levels.
For lead, chromium, and selenium TC metal nonwastewaters, EPA had previously proposed UTS
of 0.37, 0.86 and 0.16 ppm respectively. For today's reproposal, EPA is proposing UTS standards for
lead of 0.75 ppm, chromium of 0.85 ppm, and selenium at 5.7 ppm (its current treatment standard) for
TC metal wastes. Most of the wastes identified by the commercial hazardous wastes treaters as not
amenable to the proposed UTS relate to selenium bearing wastes. Since EPA has reproposed to retain its
treatment standard for selenium at its current level, it does not believe that today's rule will incur
incremental costs for any selenium-bearing DO 10 hazardous waste as a result of the reproposed selenium
UTS.
Regarding lead, public commenters for the secondary lead smelter industry and nonferrous
foundry industry indicate that the secondary lead slags and nonferrous foundry sands are either not
amenable to the proposed UTS nonwastewater level of 0.37 ppm" or cannot achieve this level without
8 ' Letter to RCRA Docket from Kevin Igli, Vice-President, Chemical Waste Management,
November 20,1995; Letter to Anita Cummings, USEPA, Office of Solid Waste from Kevin Igli,
Vice-President, Chemical Waste Management, June 17, 1996 (non-CBI portion); Letter to RCRA
Docket from John L. Wittenborn, William M. Guerry, Jr., Peter G. McHugh, of Collier, Shannon,
Rill & Scott on behalf of the American Foundrymen's Society, November 20,1995; Letter to
Mike Petruska, USEPA; Office of Solid Waste from Gary Mosher, Director of Environmental
Affairs, American Foundrymen's Society, August 2, 1996; Letter to Paul A. Bprst, USEPA,
Office of Solid Waste from Susan Panzik of Swindler & Berlin, on behalf of the Association of
Battery Recyclers, November 12,1996.
9 Personal communication between Paul A. Borst, USEPA, Office of Solid Waste and Mitch Hahn,
Chemical Waste Management Inc., June 21,1996. .
10 December 19* 1996 letter to Anita Cummings, USEPA, Office of Solid Waste from Michael G.
Fusco, director of Regulatory Analysis, Rollins Environmental Inc., p.4 of edited draft EPA trip
report letter to Rollins Highway 36 facility in Colorado.
" The secondary lead smelter industry has. been the principal commenter that secondary lead slags
could not meet the proposed UTS for lead.
4
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incurring additional costs.12 However, it is possible that secondary lead smelters may be able to modify
their processes to generate nonhazardous secondary lead slags. Some secondary lead smelters have been
able to render slags generated as nonhazardous by processing them through an electric arc furnace.13
Other secondary lead-smelters have been able to render slags nonhazardous as generated through
reprocessing them through blast furnaces onsite a second time, though this has proven unsuccessful
commercially.14 Finally, it is possible for slags containing hazardous constituents such as lead, cadmium
and arsenic to be cooled in such a way either through ambient cooling or quenching to significantly
reduce the leachability of these constituents in the slag matrix.1J .
Moreover, EPA has data suggesting that secondary lead slags have been successfully treated to
the proposed UTS level for lead by both secondary lead smelters and commercial hazardous waste
treaters.16 In contrast to comments from Chemical Waste Management, the data from Rollins
Environmental (as well as the slag data from BCI/ABR) also seem to suggest that when portlarid cement
is used as the primary stabilization reagent, it is possible to treat a wide variety of TC metal wastes
including high lead and chromium wastes (i.e., those with greater than one percent total concentrations of
lead and chromium) to the previously proposed UTS levels including 0.37 ppm for lead and 0.86 for
chromium without incurring additional treatment cost or modifying existing treatment processes.
Because these results apply to the more conservative previously proposed treatment standards for TC
metal wastes, EPA believes that for the higher revised UTS standard for lead of 0.75 ppm that it will be
even easier to meet these treatment standards using portland cement-based stabilization without incurring
additional treatment costs.
However, when less expensive, less effective treatment reagents other than portland cement are
used to treat TC metal waste, existing data indicates more of these reagents must be used at a higher cost
(principally for additional treatment reagent) to achieve the reproposed UTS standards in today's* rule.
Although most commercial hazardous waste treatment facilities and many industries use portland cement
as the treatment reagent of choice, other industries such as the foundry industry principally use other
treatment reagents such as iron filings or phosphate-based treatment reagents.
12 The American Foundrymen's Society main contention in its public comments has been that
existing management practices of treating lead-bearing foundry sands to the current treatment
, standards of 5 ppm leachable lead cannot be maintained without additional cost However, in
contrast to the Association of Battery Recyclers, AFS has not made the claim that hazardous
foundry sands were not treatable to the proposed UTS for lead. .
13 Personal Communication between Paul Borst, USEPA, Office of Solid Waste and Gerald Dumas,
Vice-President for Environmental Services, RSR Corporation, September 23, 1996, .
!4 RA. Leiby, Jr. Secondary Lead Smelting at East Perm Manufacturing Co. Inc.. EP Congress 1993
as cited in Paul Queneau, et al.. Recycling Heavy Metals in Solid Waste. Sponsored by Office of
Special Programs and Continuing Education, Colorado School of Mines, June 28-30,1994.
15 Paul Queneau, Lawrence D. May, and Douglas E. Cregar, application of slag Technology to
Recycling of Solid Wastes, Incineration Conference, Knoxville, TN, May 1991, as cited in
Queneau, supra, Note 9. . .
16 Supra, Note 11, See also October 9,1996 letter to Anita Cummings, USEPA, Office of Solid
Waste from Steve Emmons, Battery Council International Environmental Committee chair and
Earl Comette, Chairman, Association of Battery Recyclers, Inc.
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Although these reagents are typically less expensive than portland cement,17 the range of TC
metal constituents and long-term effectiveness of some of these reagents is questionable.18 Based on
existing data on iron and phosphate based treatment reagents, EPA believes that phosphate-based
treatment reagents (usually trisodium phosphate or calcium phosphate) with or without ph buffers
represent the least costly management reagent that could be considered effective treatment for a range of
TC metal wastes that are not TC simply for lead. EPA is not commenting on the long term effectiveness
of phosphate-based treatment reagents in this analysis. Rather, because: 1) the American Foundrymen's
Society only provided bench scale data on phosphate-based reagent performance for both lead and
cadmium in foundry wastes and did not provide comparable data on iron filings for TC lead and
cadmium wastes and 2) some industry data indicate that iron filings are ineffective treatment agents for
hazardous EP (extraction procedure) cadmium wastes, EPA does not believe that it is appropriate to
estimate compliance costs from today's rule using iron filings as a baseline management method.
Rather, EPA has modeled phosphate-based reagents as the least expensive reagent that has been
demonstrated in bench scale trials to treat both lead and cadmium in foundry wastes. EPA solicits
•comment on the effectiveness of metallic iron in stabilizing cadmium in TC hazardous cadmium-bearing
nonwastewaters.
5.0 Cost Analysis
Treatment costs are estimated for lead nonwastewater generated by nonferrous foundries at the
facility and industry level.
5.1 Unit Costs
Functions used for estimating existing and future costs due to regulation of TC metal wastes are
based on the same functions used for mineral processing wastes. The modification of these functions for
TC wastes is given in Appendix A, and is included because the functions used for foundry wastes
proceed directly from the TC waste functions. The equation sets listed below are numbered in sequence
from those listed in Appendix A. The equations below are based on changing from cement to TSP as the
stabilizing agent. A set of cost functions based on changing from iron filings to TSP is given in
Appendix B.
Equations used for the analysis of lead wastes from foundries are listed below. Storage,
stabilization, and disposal in a Subtitle D (nonhazardous) landfill are the operations required for the solid
waste treatment and disposal. -
17 Supra, Note 9, August 2, letter from Gary Mosher, American Foundrymen's Society to Mike
Petruska, USEPA, Office of Solid Waste. AFS data indicate that to treat foundry sands, the
reagent cost of portland cement in foundry sand stabilization averages S55 per ton compared with
$26 to $31 per ton for trisodium phosphate or $11 per ton for iron filings.
18 EPA has previously proposed to prohibit the use of iron filings as treatment reagent as
impermissible dilution because the Agency believes that iron filings do not provide effective long
terra stabilization of lead in hazardous wastes such as foundry sands. 60 FR 11702,11731
(Thursday, March 2,1995). The Agency also noted that iron filings or iron material may result in
false negatives for the Toxicity Characteristic Leaching Procedure (TCLP).
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Current Regulations Using 15 Percent Stabilizing Agent
Storage—Equation Set 9
cost = 24.589 Q+132.23
= -0.0022 Q2 + 29.272 Q + 4,840.9
for Q to 200 mt/yr
for 50 < Q < 7,500 mt/yr
These equations, as described above, are taken directly from the February 12, 1997 draft RIA,
Exhibit D-21. They apply to solids in drums and roll-off containers, respectively. Conditions used to
develop equations in the February 12 draft are also used for the equations given here. However, on the
basis of equivalent costs, the drum storage equation could be used to about Q = 2,900 mt/yr.
Stabilization—Equation Set 10
cost = (207.93 Q°7S x 0.9) x 0.09439
+ (87,839 + 52.16 Q)(l - (0.1113 In (Q) - 0.3429)
+(0.1113 In (Q) - 0.3429X260/67.00X10/70))
+ ((9,806 -i- 0.19 Q)/(1.0721)) x 0.09439
= (207.93 Q078 x 0.9) x 0.09439
. + (87,839 + 52.16 Q)(( 1 -0.98) + (0.98)(260/67.00)
x (10/70)) + ((9,806 + 0.19 Q)/( 1.0721» x 0.09439
(annualized capital cost)
(O&M cost minus cement cost)
(TSP cost)
(closure cost)
forQ< 100,000 mt/yr
forQ> 100,000 mt/yr
These equations are taken from the February 12 draft RIA, but are modified by terms that adjust
for different stabilizing agents, different ratios of stabilizing agent to waste quantity, and different ratios
of stabilizing agent cost to total operation and maintenance cost. Each term in the equations is discussed
below. -
The term 207.93 Q078 is taken directly from the February 12 draft RIA, p. D-7. It represents the
capital cost required to build a stabilization facility capable of treating Q mt/yr of waste. Because the
quantity of TSP used for stabilization of foundry wastes is significantly lower than the amount of cement
assumed to be used for mineral processing wastes, the capital costs for the foundry facility are expected
to be lower. This decreased cost, attributable to slightly smaller storage bins and treatment tanks, is
obtained by multiplying the capital cost equation by a factor of 0.9. A factor of 0.09439 is then applied
to obtain an annualization of the capital cost
The term (87,839 + 52.16 Q) is taken directly from the February 12 draft RIA, p. D-7. It
represents the operation and maintenance (O&M) costs associated with stabilizing wastes.
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The term (0.1113 In (Q) - 0.3429) is developed from data generated from plant size vs cost of
cement as a fraction of total O&M cost.19 The data set is: .
Plant size, mt/yr Cement cost, % of O&M cost
426 21.0
• 4,265 71.5
42,648 94.9
426,477 98.6
This term estimates stabilizing agent cost as a fraction of total O&M cost for any size plant-
within the range of sizes given in the February 12 draft RIA (the data points were developed from the
mineral processing waste cost functions). When the mineral processing RIA O&M cost equation is
multiplied by one minus this term (as above), an O&M cost without the stabilizing agent is estimated
based on plant size. To account for the cost of TSP as a stabilizing agent, this term is added back into the
equation after modification for different reagent costs and application fractions as shown for the next two
terms. .
The term (260/67.00) is the ratio of TSP cost20 to cement cost21 (both in dollars per ton).
The term (10/70) is the ratio of stabilizing agent used for foundry wastes22 to the amount used for
mineral processing wastes (as given in the February 12 draft RIA).
The term (9,806 + 0.19 Q) is taken directly from the February 12 draft RIA, p. D-7. It represents
closure costs for the stabilization facility. Because this cost is not incurred until after the 20-year life,
but is spread over that life, it must be divided by the terms that follow (1.0721 and 0.09439) to obtain a
uniform annual reserve as explained under equation set 2.
For Q > 100,000 mt, the term (0.1113 In (Q) - 0.3429) is replaced by 0.98 to prevent obtaining
factors greater than 1. Examination of the data suggests that an asymptote exists near this value.
Dispose—Equation Set 11
cost = ((25.485 Q) + 294,70l)x 1.20 : .
This equation (for metric quantities) is developed from data for on-site nonhazardous waste
landfill costs.23 The data set is: .
19 Telecon between Caroline Peterson, DPRA and Jim Turner, RTI. September 25,1996.
20 Supra, Note 9, August 2. Letter from Gary Mosher, American Foundrymen's Society to Mike
Petruska, USEPA, Office of Solid Waste. Exhibits 4 and 7 provide dosage and cost data.
. " . •* - '• \ "
21 Supra,,Note 20, Value reported as $0.0335/lb taken from R.S. Means Construction Cost Data for
1995.
22 Supra, Note 21.
23 Letter from Carol Samat, DPRA, to Paul Borst, U.S. Environmental Protection Agency. March 4,
1993.
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pital cost, $
2,632,000
7,034,000
10,899,000
Annual O&M
cost, $/yr
.114,000
236,000
328,000
Closure cost, $
434,000
1,547,000
2,675,000
Annual post-
closure cost, $
5,000
9,000
12,000
Landfill size, short
tons/yr
5,000
25,000
50,000
The equation is multiplied by a factor of 1.20 to. account for the difference between added
stabilizing agent quantities in lead wastes and in other TC metals wastes. For small quantities, it is likely
that offsite disposal would be used as in equation set 6.
Proposed Regulations Using an Additional 5 Percent TSP
For this case, stabilization costs are increased by 5 percent for additional reagent, and also for the
extra capital associated with a small increase in storage space, increased O&M costs, and increased
closure costs. Reagent cost is a direct increase of 5 percent, but the other added costs are judged to
increase by 2.5 percent. These changes to equation set 10 (for Q < 100,000 mt/yr) are shown as:
cost =(207.93Q078x 0.9x1.025) x 0.09439
+ (87,839 + 52.16 Q) x 1.025 x (1 - (0.1113 In (Q) - 0.3429)
+ (0.1113 In (Q)- 0.3429) (260/67) ((15/70))
+ ((9,806 + 0.19 Q) x 1.025 / (1.0721)) x 0.09439
The changes are factors of 1.025 applied to capital and .closure costs and an increase applied to
the ratio (15/70) for quantity of reagent.
Storage costs are increased using equation set 9, but with Q equal to 34.02 mt/yr for the baseline
case and to 51.03 for the proposed regulation. These values represent reagent usage of 10 percent of the
waste for baseline and 15 percent for the proposed rule. ,
Disposal costs are increased using equation set 6 because of the small quantities involved. The
amount disposed of is increased to 375 x 1.10 tpy (340.2 x 1.10 mt/yr) at baseline and 375 x 1.15 tpy
(340.2 x 1.15 mt/yr) for the proposed regulation. .
The capital costs and annual incremental cost (which includes the annualized capital cost) per
foundry for the revised UTS level is provided in table 2. These values are found by solving appropriate
equations above at baseline and with the stricter levels for lead for Q = 340.2 (the metric equivalent of
375 tpy), the average value per foundry. The methodology for obtaining these costs assumes that the
increased quantity of TSP required to meet the proposed UTS standard also requires slightly increased
capital and O&M costs for all aspects of the treatment facility: more storage and treatment capacity,
higher treatment and disposal labor costs, and higher closure costs.
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Table 2. Incremental Cost Per Nonferrous Foundry
Activity Capital Cost Annual Cost
Storage * 418
Stabilization 441 11,504
Disposal . ' 736
Total Incremental Cost $441 $12,658
* Included in stabilization costs
5.2 Aggregate Costs
The aggregate costs of the UTSs are the sum of the costs for all effected entities. Because of the
existence of economies of scale in metals wastes management some small generators ship their TC
metals wastes to off-site managers. Presumably these generators have compared the cost of on-site
treatment to the cost of transporting wastes to off-site managers and paying the price charged by these
commercial firms and found commercial management cheaper. It is possible that changes in cost and
pricing of commercial waste management services will change some generators' waste management
choice. However, given the small unit cost changes involved, this seems unlikely in this case.
Of more importance regarding the on-site:off-site issue is whether all the current on-site
managers of lead-containing wastes will be able to treat to the UTSs on-site. If some find it technically
infeasible to meet these standards they will have to switch to off-site treatment. This will increase their
costs from those projected here and, perhaps, place pressure on the capacity of commercial managers. In
time any capacity constraints are likely to be overcome with new investment but in the short-run capacity.
limitations could result in price increases for commercial treatment.
The incremental costs for noriferrous foundries of meeting the lead UTSs for nonwastewaters
are provided in Table 3. They are estimated by multiplying the per facility costs from Table 2 by the
number of nonferrous foundries: 791.
Table 3. Total Incremental Cost to Nonferrous Foundries '
Activity
Storage
Stabilization
Disposal
Total Incremental Cost
. . Capital Cost
•• •
348,831
. • • ' *
' $348,831
Annual Cost
$330,638
$9,099,664 :
$582,176
$10,012,478
* Included in stabilization costs
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6.0 Economic Impacts
Based on the foregoing analysis, EPA believes that most generators of TC metal wastes using
Portland cement as the main reagent of stabilization will not incur cost resulting from today's rule.
However, nonferrous foundries will collectively incur estimated incremental costs of $ 10.0 million
annually resulting from today's rule. Because economic impact analysis indicates that this costs will
represent less than 1 percent of nonferrous foundry revenues and about 3 percent of nonferrous foundry
profits, EPA does not believe that today's rule will impose a significant economic impact on a substantial
number of nonferrous foundries — see Table 4. •
Table 4. Economic Impact of UTS on Nonferrous Foundry Industry for Facilities that Generate
Hazardous Wastes
Estimated Phase
IVUTS/TC
Metal
Compliance
Costs for
Nonferrous
Foundries
SI 0.0 million
Estimated
Revenues*
S2.094 million
Compliance Cost
as Percentage
of Revenues
0.48
Estimated
Profits"
S3 16 million
• Compliance Costs
as a Percentage of
Profits
3
•Based on per facility averages for SIC 3366 and 3369 from the 1992 Census of Manufactures scaled by
79 L
The standard view of the facility closure decision is that profit-maximizing managers will elect
to exit a market when the value of the productive assets in their best alternative use exceeds the expected
present value of remaining in the market. This view requires that managers of nonferrous foundries
assess the current and future market for the commodity produced at the facility to evaluate the revenue
implications .of keeping the facility open and remaining in the market. It also requires that they assess
the current and future markets for the inputs used to make foundry products to evaluate the cost
implications of keeping the facility open and remaining in the market. Finally, managers must evaluate
the market for the land and the plant and equipment used to produce the foundry products. Presumably,
if only informally, managers of the 791 foundries in this analysis have completed that evaluation and
found that staying in the market is the profit maximizing choice. .
'Compliance with the revised standards for lead will raise the costs of production at each affected
nonferrous foundry about $13,000 annually. Depending on market conditions some or all of this amount
may be passed downstream to consumers in the form of higher prices for foundry products or upstream
to input suppliers to in the form of lower input prices. In the long run these costs are likely to be passed
on entirely to consumers of foundry products as new facilities will not be constructed unless investors
can expect to cover all their costs. However, in the short run when there is specificity in the fixed capital
(e.g., the plant and .equipment used in making castings may have no value except that of scrap metal
outside the foundry industry), the costs will be shared across foundry owners, consumers of foundry
products, and suppliers of inputs to nonferrous foundries.
It seems unlikely that even if foundry owners are forced to absorb the entire cost of meeting the .
revised standards that an additional $13,000 annually Would cause a nonferrous foundry to prematurely
close. Most of these costs are variable thus, owners would not be required to make large up front
11
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expenditures for additional plant and equipment which are inherently more risky than operating and
maintenance costs since the latter can be readily avoided if continued facility operation becomes
unprofitable. Further, there is considerable randomness to all prices rendering both costs and revenues
for nonferrous foundries subject to fluctuation. It seems likely that much of the costs of meeting the
revised standards would be largely lost in the normal profit fluctuations.
7.0 Impacts on Small Entities . .
The Small Business Regulatory Enforcement Fairness Act of 1996 (SBREFA) requires that
agencies consider the impact of new regulations potential impacts on small businesses, amending and
strengthening the requirements of the Regulatory Flexibility Act (FRA). Agencies must either certify
that a rule will not have "significant impacts on a substantial number of small entities" (with a factual
justification) or must comply with additional requirements. -
Virtually all nonferrous foundries are small businesses by the SBA definition (less than 500
employees). According to current EPA draft guidance on completing small business initial assessment,
there is a rebuttable presumption that significant economic impacts result to a substantial number of
small entities (firms) when the estimated compliance cost of the rulemaking equals or exceeds 3 percent
of firm sales/revenues. When firm-specific data is unavailable, industry sales/revenues may be used as a
proxy for estimating impacts.
Using this guidance, EPA does not believe that there is a significant impact to a substantial
number of small entities resulting from the part of today's reproposal pertaining to the revision of UTS
for TC metal wastes. Table 4 indicates that the estimated compliance costs are less than one percent
nonferrous foundry revenues. AFS previously indicated to EPA that it does not have accurate number on
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8.1 The Circular System
Pearce and Turner (1990) identify three key economic functions of the environment that can be
used to guide this analysis:
resource supply-the extraction or in-situ use of environmental and natural resources in the
production of goods and services ("commodities") by governments, firms, and households (e.g., use of
ground water for drinking water supply or for process water).25
' t ...
waste assimilation-the provision of a sink for disposal of waste products produced by economic
and natural systems (e.g., use of land for disposal of wastes).26
aesthetic and spiritual services-the direct, incidental exposure to the environment (e.g.,
enjoyment provided when people observe the environment). .
Integrating these three functions we arrive at Boulding's (1966) metaphor of the earth as a
spaceship with a closed economic and environmental system except for solar energy. This system
recognizes the limits that exist at any point in time in our resource base, environmental quality, capital
and labor stock, technical methods, and institutions for creating utility flows (Figure 1). Utility is the
term used to describe individual's subjective sense of economic well-being. It is conditioned by people's
values and preferences. Economic systems are designed to promote improvements in utility.
If the assimilative capacity of the groundwater is exceeded by the release of TC metals to the
environment then the resource supply function of the environment will be threatened. Faced with the
threats posed by contaminated groundwater decisionmakers in government, industry, and in households
may take averting or preventative actions to avoid or reduce these risks. They may also undertake
mitigating or repair actions once the event has been registered.
Both averting and mitigating behaviors require the diversion of resources away from their
alternative uses reducing the utility provided by those uses. Also, mitigating actions may only
incompletely restore the services provided by the affected natural, physical or human capital. The
benefits of the controls are the avoided losses in utility to the US population from the release of TC
metals to the environment. ' • •
• - i
'. ' • ' '
> In addition to these "use" benefits people may also enjoy "nonuse" benefits from the protection
.of the three functions of the environment. Nonuse benefits may derive from altruistic preferences.
Nonuse services may also contribute to an individual's welfare through a sense of stewardship for the
25 Labor services, capital services (e.g., plant and equipment, infrastructure created from past
' ; production), intermediate production (e.g., materials, energy), and environmental and natural
resource services are combined in the economic system where public, market, and household
• systems use the appropriate techniques or receipts to convert these inputs into, more desired public
and household commodities. '
26 Economic systems generate unwanted byproducts or residuals in the form of heat, scrap,
combustion byproducts, etc. As Kneese, Ayres, and d'Arge (1970) point out, the First Law of
Thermodynamics requires that "...the amount (i.e., mass) of residuals inserted into the
environment must be approximately equal to the weight of basic fuels, food, and raw materials
entering the processing and production system, plus oxygen taken from the atmosphere."
13
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environment. That is, individuals not directly impacted by the controls may experience a utility gain
when they learn that the quality of the environment has been protected.
8.2 The Economic Benefits of Groundwater Protection
The key threat to the environment from TC metals is from their potential to leach into
groundwater resources. Bergstrom et al. (1996) have developed a framework to assess the economic
benefits of groundwater that, with some modifications, forms the basis of this evaluation of the benefits
of protecting groundwater resources from TC metals wastes. The framework consists of (1) assessing
the changes in the quality of the resource stock with the rule, (2) identifying groundwater service flows
that may be effected by the quality changes, (3) evaluating how market and household production may be
impacted by the change in service flows, and (4) valuing the effect on human welfare of the production
impacts and of the passive linkages between human welfare and environmental quality.
Developing quantitative estimates of the economic benefits of protecting groundwater entails
two challenging requirements. First, formal linkages between groundwater protection policies and
changes in the biophysical condition of groundwater must be established. Second, these linkages must
be developed in a manner that allows for the estimation of policy-relevant economic values. The
framework in Figure 1 is used to identify and characterize the potential benefits of the proposed
regulation. However, only a qualitative assessment of the expected benefits are provided due to the
multitude of impacted locations and the complexity of the linkages between releases of TC metals to the
environment and any changes in human welfare.
8.2.1 With Policy Groundwater Quality Changes
The first step in developing estimates of the impact of the regulation on groundwater is to
measure or estimate current groundwater conditions in quantity and quality terms. Since the proposed
rule affects the quality of groundwater, rather than the quantity, further discussion will focus primarily
on quality. Step two is to assess how baseline quality will change with and without the proposed
regulation. This step provides estimates of the reference (without-policy) quality and the subsequent
(with-policy) quality.
No explicit effort is made here to estimate the water quality changes of the rule. The potential
sources of pollution, disposal sites of the treated sands, are likely to be numerous and diffuse. Further,
the expected improvements in groundwater quality, while positive, are nevertheless likely to be small.
8.2.2 Groundwater Service Flow Changes
Groundwater has two broad functions that may be positively impacted by the regulation. The
first function is storage, of a water resource. Groundwater stored in an aquifer provides a reserve of
water with given quantity and quality dimensions. The second function is discharge to surface waters.
Again, this discharge supply has quantity and quality dimensions. Through this function, groundwater
indirectly contributes to services generated by surface waters. As Figure 2 indicates, surface waters may
also recharge groundwaters. Table 5 is adapted from the Bergstrom et al. (1996) framework and presents
the groundwater service flows associated with each of the two broad groundwater functions that could be
threatened by TC metals wastes. Of these services, provision of drinking water and nonuse services
appear to be most threatened by the release of TC metals into groundwater.
14
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Emta
(ton.
JMMto
Figure 1. The Circular System
&2J Resource Allocation Changes
Changes in the quality of services provided by groundwater may directly change some market
and household activities. In Figure 1, this phenomenon is depicted by the arrows flowing from
environmental systems to the economic stocks and production processes (market and household). Two
types of productive behaviors are particularly important-averting and mitigating.
15
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.16
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withdrawals
residuals
Human
Activity
withdrawals
in-site uses
residuals
Ground
Water
discharge/recharge
Surface
Water
recharge
rtvorocycM
(La., precipitation,
runoff)
recharge
Figure 2. Grooadwater Function
Averting behaviors are those takeato avoid or to reduce the impact of service quality reductions.
For example, polluted irrigation water may induce formers to change cropping patterns or pn
Households may purchase bottled water in lieu of consuming well water. Governments may install
alternative municipal water supply systems to avoid contaminated water supplies. The result of health-
related averting activities is a lower level of realized (or ex post) exposure to environmental
contaminants. This will effect one's actual health state. The relationship between realized exposures
and the ex ante health state is determined through the human biological system.
TC metals are very toxic causing a variety of human health effects even at low doses and especially
to children. Brain, kidney, and nervous system functions may ail be impaired by exposures to these metals
leading to excess illness and even premature death. Knowledge of these effects and of the potential for
exposure is likely to lead to averting activities by households.
17
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Table 5. Storage and Service Functions of Water Resources Potentially Impacted by TC Metals Wastes
Services
Effects
1 Provision of Drinking Water
2 Provision of Water for Crop Irrigation
Provision of Water for Livestock
4 Provision of Water for Food Processing
Provision of Water for Other Manufacturing
Processes
Change in Quality of Drinking Water .
Change in Human Health or Health Risks .
Change in Value of Crops or Production Costs
Change in Human Health or Health Risks
Change in Value of Livestock Products or Production
Costs
Change in Human Health or Health Risks
Change in Value of Food Products or Production Costs.
Change in Human Health or Health Risks
Change in Value of Manufactured Goods or Production
Costs
6 Provision of Clean Water Through Support of Change in Human Health or Health Risks
Living Organisms
7 Support of Recreational Swimming, Boating,
Fishing, Hunting, Trapping, and Plant
Gathering
8 Support of Commercial Fishing, Hunting,
' Trapping, and Plant Gathering
9 Support of On-Site Observation or Study, of
Fish, Wildlife, and Plants for Leisure,
. Educational, or Scientific Purposes
Change in Animal Health or Health Risks
Change in Value of Economic Output or Production
Costs
Change in Value or Costs of Recreational Activities .
Change in Human Health or Health Risks
Change in Value or Costs of Commercial Harvest or
Costs
Change in Value or Costs of On-Site Observation or
Study Activities
10 Pro vision of Passive or Non-Use Services (e.g., Change in Personal Utility
Existence or Bequest Motivations
11 Provision of Non-Use Services (e.g., Existence Change in Personal Utility
Services) Associated with Surface Water Body
or Wetlands Environments or Ecosystems by
. Ground Water _ .
Source: Bergstrom, J.C., KJ. Boyle, C.A. Job, and M.J. Kealy, "Assessing the Economic Benefits of Ground Water for
Environmental Policy Decisions." Paper No. 95041 of the Water Resources Bulletin with some modifications.
18
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Conditional upon contracting an environmentally-related illness, the individual's realized health
state may differs from the ex ante health state because of mitigating behaviors. The key resources
needed to treat the ill individuals are the labor, materials, and capital from the medical services sector.
Since averting behaviors are taken to avoid some or all of the anticipated effects of a reduction in
service quality, the role of information is critical to those choices. Further, averting and mitigating
behaviors are substitutes. Indeed, costless irreversibility is a perfect substitute for averting behaviors.
Health related pathways groundwater quality could affect human welfare. In this framework,
household time is an endowment and must be allocated among multiple uses. In Figure 2, time is
divided between labor and leisure (leisure makes up part of the flow from household production to
utility). In the health model, this is expanded to include averting activities, mitigating activities, and sick
time. . .
The issue of information and uncertainly is particularly applicable to the health model. While the
health model in Figure 1 implicitly treats the relationship between exposures, averting, and mitigating
behaviors, and health state as certain, the reality is individuals face considerable uncertainty and must
make decisions based on expected health outcomes.
8.2.4 Human Welfare Changes
In Figure 1, the rule may positively impact human welfare by
• reducing the amount of resources allocated to averting and mitigating activities by
producers and households thereby leaving more resources for consumption goods and
services,
• increasing health, and
• increasing the passive or nonuse services of the environment.
The conceptual measure of the change in human welfare in economic analysis is the change in an
individual's utility due to the above-listed changes. However, utility is unobseryable, thus the need for a
surrogate. The surrogate used in most analyses is money. Two monetary measures of individual welfare
change are employed—willingness to pay (WTP) and willingness to accept (WTA). WTP is the
maximum amount an individual is willing to pay for utility-augmenting changes and is taken as the
individual's value (benefits) of the change. WTA is the minimum compensation the individual would be
willing to accept to forgo the welfare improvement It is also accepted as the individual's the value
(benefits) of the improvement . ,
Prices formed in competitive markets provide a basis for developing WTP/WTA values for averting
and mitigating activities. WTP/WTA is simply the avoided expenditures (i.e., price times quantity). For
household time spent on averting or mitigating activities or sick, the price of labor services (i.e., the
wage rate) may be used to develop estimates of foregone income.
In addition to these direct costs any utility loss associated with the inability of averting activities to
completely protect or mitigating activities to completely restore the individual's utility stream must also
be valued. For example, individuals who purchase bottled water to avoid exposures to lead in drinking
19
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water may still be exposed through purchased meals prepared with contaminated water. Or, individuals
who do experience an environmentally-related illness my not have immediate or complete recovery.
Nonuse or passive use represents final benefit category to consider. Nonuse values are said to arise
from a variety of motives, including knowledge of existence, a desire to bequeath natural resources to
future generations, a sense of stewardship or responsibility for preserving fe.atures of ecosystems and/or
natural resources, and a desire to preserve options for futures use (Freeman, 1993). One cannot rely on
observable behavior such as expenditures or price differences for evidence of nonuse values because they
arise without an individual taking any action. They enter the utility function directly and are not related
to other processes within the household production framework. For example, individuals may gain
utility from the knowledge that a healthy ecosystem exists, or simply that a stock of groundwater is
protected by regulation of waste streams. The only way to determine these values is to ask people to
directly provide them in response to a contingent outcome question.
While there are no specific studies on the WTP/WTA for this regulation the economic literature
does offer evidence that individuals do value groundwater resources and have positive WTP for their
protection. Specifically, Table 6, reproduced from Crutchfield et al. (1995) shows that households value
groundwater protection in the range of several hundred dollars annually. This regulation would
contribute to such protection. However, the values reported in Table 6 would not apply to the very small
changes in groundwater quality expected with this rule. The values for this rule would be some fraction
of those for complete protection since contaminants other than TC metals from sources regulated under
this rule also contribute to reductions in groundwater quality.
9.0 Benefit-Cost Comparison
The potential benefits of the regulation may accrue to direct users of the affected water resources
and to nonusers who would benefit to the extent that they hold altruistic values for the affected
individuals or a sense of environmental stewardship for the impacted resources. The potential key gains
to users are the reduced averting and mitigating expenditures, increased incomes, and improved health
states. Individuals proximate to the several thousand sites where these wastes are managed would
benefit through direct use of the environment. The rest of the U.S. population would benefit through
nonuse linkages.
Juxtaposed against these potential benefits are the annual costs of the regulation. These costs are
cents per household annually for the entire U.S. population. EPA believes that the typical U.S.
household would value the benefits from this regulation more than its costs.
20
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Table 6. Empirical Estimates of Ground Water Protection Benefits
Study
"Good" being valued
Estimated willingness to pay
(WTP)
Caudill, 1992, and
Caudill and Hoehn, 1992
Powell, 1991
McClelland and others,
1992
Shultz, 1989, and Shultz
and Lindsay, 1990
Jordan and Elnagheeb,
1992
Poe, 1993, and Poe and
Bishop, 1992
Edwards, 1988
Sun, 1990, and Sun,
Protection of ground water subject to
pesticides and nitrates.
Ground water subject to contamination by
toxic chemicals and diesel fuel.
Ground water, type of contaminant not
specified
, \ . -
Ground water, type of contaminant not
specified /
Drinking water subject by contamination by
nitrates.
Drinking water subject to contamination by
nitrates.
Ground water subject to contamination by
nitrates and pesticides.
Rural: $43-$46/househoid
(hhyyear.
Urban: $34-$69/hh/yr.
All data: $61.55/hr/year.
Respondents with a history of
contamination: $81.66/hh/year.
Respondents with no
contamination: SSS.79/hh/year.
Complete sample: $84/hh/year.
Mean WTP: $129/hh/year.
•Public water system: $146/hh/year.
Private wells: $169/hh/year.
S168-$708/hh/year.
S286-$l,130/hh/year.
Ground water subject to contamination by Mean WTP: $641/hh/year, ranges
Bergstrom, and Dorfman. agricultural fertilizers, nitrates and pesticides, from $165-$l,452/hh/year.
1992
Source: Crutchfield, S.R., P.M. Feather, D.R. Hellerstein. "The Benefits of Protecting Rural Water Quality: an Empirical
Analysis." Report No. 701 Economic Research Service, U.S. Department of Agriculture.
21
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References
Bergstrom, J.C., K.J. Boyle, C.A. Job, and M.J. Kealy, "Assessing the Economic Benefits of Ground
Water for Environmental Policy Decisions." Paper No. 9504 1 of the Water Resources Bulletin.
Boulding, K. "The economics of the coming spaceship Earth," in H. Jarrett (ed.) Environmental Quality
in a Growing Economy, Johns Hopkins University Press, Baltimore, 1966.
Crutchfield, S.R., P.M. Feather, d.r. Hellerstein. "The Benefits of Protecting Rural Water Quality: an
Empirical Analysis." Report No. 70 1 Economic Research Service, U.S. Department of Agriculture.
j A.V., R.U. Ayres, R.C. D'Arge. Economics and the Environment: A Materials Balance
Approach. The Johns Hopkins Press, Baltimore and London. ISBN 0-80 18- 12 15-1. 1972.
Pearce, D. W., and R.K. Turner. Economics of Natural Resources and the Environment. The Johns
Hopkins University Press, Baltimore, 1990.
22
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APPENDIX A
DEVELOPMENT OF COST FUNCTIONS FOR METAL WASTES
-------
This appendix describes the basic cost functions used for estimating storage, treatment, and
disposal of TC metal wastes. Most of the equations are taken directly from functions developed for
mineral processing, wastes or developed from information associated with those functions. Sets of typical
treatment practices, which form the basis for the cost functions given here, are shown in Figure A-1 for
liquids, sludges, and solids. .
Quantities shown in Figure A-l begin with 100 tons of waste entering the treatment system. In the
treatment of solids, for example, mass in the form of treatment chemical is added to the entering stream.
The amount of cement required for stabilization of solids from storage increases by 75 percent from the
original 100 tons.
10O ton* 102 tons 104 tot* 39 ton* ' • f Surface Impoundment
nontou.) 0-" <»*••• °>
Slant WetSdtts
I
3.25 tons T i^Stont
waarand • Sfrharttton • LjndfB (Subtitle 0)
StaMttng Agents
Suraw* Impoundment
4.5 don* Wet Solids
25 tons f 7.1 ant
Wmterand • StabiUzacon • Lanofffl (Subtitle D)
173 tana
Landni(Su«M«0)
75 ions
Wstsrand
StsttsaigAgsnts
Figure A-l. One Model for TC Metals Treatment Practices.
A-l
-------
A major visual difference between the equations listed here and in Appendix D of the minerals
processing regulatory impact analysis (RIA) is the form of the functions. Because TC costing is based
on an annual ized format, all of the mineral processing capital cost functions are converted to an
annualized form. For ease of use, two or more equations may be aggregated into a single function. Each
of the equations used for the TC metals wastes is related below to its companion equation for minerals
processing. Changes to the equations caused by differences between TC wastes and mineral processing
wastes in processing or treatment quantities and techniques are discussed. New equations not used for
mineral processing are also described. Except as noted, the assumptions and ranges used to form the
mineral processing waste functions are assumed also to apply to the TC metals waste functions.
Although costing in this RIA is required only for solids associated with foundry wastes, the generalized
equation sets for other TC waste forms are presented as precursors to the foundry equations. Separate
equations for foundry operations are described in the body of the report.
Equations used for TC wastes are listed below for current and proposed regulations. The term Q
is the quantity of material presented for treatment in metric tons per year. Table A-l shows the
application of equations by case.
Current Regulations for Liquid Wastes
Storage — Equation Set 1
cost = -4x10-" Q2 + 0.1 175 Q + 3,679.5
This equation was developed for 7-day tank storage based on the general assumptions used to
generate other storage cost functions for minerals processing wastes.1 The equation is taken directly
from the February 12, 1997 draft RIA, Exhibit D-35.) Note that this equation, and all other equations .
with exponents or logorithms (non linear equations) will give erroneous answers if used to estimate costs
for incremental increases in quantities of waste treated. For example, the cost estimated for a Q of 5 tpy
is not the same as the cost of, say, 60 tpy minus the cost of 55 tpy.
pH Adjustment— Equation Set 2
cost =11,471 . forQ<350mt/yr
= -203,3 10 + 36,594 In (Q) + 14.34 QOJ
+ (6,493/1. OT^Ox 0.09439
for 350 sQ* 37,9 lOmt/yf
= -203,3 10 + 36,594 In (Q) + 14.34 Q"
+ ((6,361 + 0.003 Qy 1 .0721)) X 0.09439
for Q> 37,9 lOint/yr
Telecon between Jen Mayer, ICF, and Jim Turner, Research Triangle Institute (RTI).
.September 24,1996.
A-2
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Table A-l. 'Application of Equations by Case
Case
Current regulation
Liquid
Sludge
Solid
Proposed, regulations '
Liquid
Sludge
Solid
Foundry wastes
Current regulations
cement
iron filings
TSP .
Proposed regulations
cement
iron filings
TSP
Equation set*
1,2,3,4,5,6 •
1 , and 4,5,6 with new factors
8, and 5,6 with new factors
7 applied to 1 through 6
1, and 4,5,6 with new factors
8, and 5,6 with new factors
9,10,11
9, and 1 0, 1 1 with new factors
9, and 10,1 1 with new factors
9, and 10, 1 1 with new factors
9, and 10,1 1 with new factors
9, and 10, 1 1 with new factors
'Basic equations are developed for treatment and disposal operations. As cases change, the basic equations are
modified by factors developed for each case as listed in the column. The changes generally represent changes in
quantity of material being processed or changes in size (and cost) of required facilities. See text for further
explanation. Equation sets are for;
1: storage for liquids and sludges, 2: pH adjustment, 3: precipitation,
4: dewatering, 5: stabilization, 6: disposal, 7: all operations (proposed regulations for liquids), 8: storage for solids,
9: storage for foundry wastes, 10: stabilisation of foundry wastes, 11: disposal of foundry wastes.
These equations are taken, in aggregated form, from the February 12,1997 draft RIA. The
individual terms are discussed below.
The term 11,471 is the value obtained at the lower limit of the next equation below. This limit is
used for small quantities to avoid negative values obtained outside the valid range of the next equations.
A lower limit on cost is also assumed because the physical plant required for processing cannot be
economically built below a certain size.
A-3
-------
The term -203,310 + 36,594 In (Q) + 14.34 Qos is the sum of two equations derived from the
February 12 draft RIA, p. D-4 for on-site neutralization. Two costs are included: capital (in annualized
form) and operation and maintenance (O&M). The elements of the equation from the RIA are:
(36,131 + 151.95 Q03)x 0.09439 (capital cost x an annualization factor)
-206,719 + 36,594 In (Q). (annual O&M cost)
The terms 6,493 (for Q < 37,910 mt/yr) or 6,361 + 3.0xlO'3 Q (for 37,910 * Q * 370,000 mt/yr)
are also taken in part from p. D-4, and represent the annualized versions of closure costs. The only
elements not found on p. D-4 are the factors 1.0721 and 0.09439, which are used to annualize the .capital
costs. The term 1.0721 is used in lieu of a sinking fund term to represent the annual payment required to
accumulate capital necessary at the end of 20 years to pay for closure costs beginning in the 21st year
and continuing thereafter. The term is taken directly from the February 12 draft RIA, p. D-2, and
assumes 7 percent interest and closure payments beginning in the 21st year.
The term 0.09439 is also taken directly from the February 12 draft RIA, p. D-2. It is a capital
recovery factor, based on 7 percent interest and 20-year equipment life, that is applied to.the closure cost
to complete the equivalent of a sinking fund factor.
Precipitation—Equation Set 3 -
cost = (3,613 + 15.195 Q") x 0.09439 * 0.3465 Q + 826.48 for 350 < Q < 370,000 \
Precipitation operations take place in the same equipment used for pH adjustment, hence costs
are estimated as a fraction of pH adjustment costs and added to the total costs. This equation is taken
directly from the February 12 draft RIA, p. D-4.
Dewatering—Equation Set 4 ' ' . • . •
cost = 0.09439 (95,354 + 664.48 (1.04 Q)OJ) + 12,219 + 286^86 (1.04 Q)03
The term 0.09439 (95,354 + 664.48 (1.04 Q")) is taken from the dewatering capital cost
equation on p. D-7 of the February 12 draft RIA, but modified in two ways. The equation is annualized
using the capital recovery factor 0.09439 described above, and Q is increased by an estimated 4 percent
to account for the increased volume of waste after pH adjustment and precipitation (see Figure A-1).
. — *
The term 12,219 + 286.86 (1.04 Q)05 is also taken from p. D-7 as the O&M cost for dewatering.
The quantity of waste is increased by 4 percent as for the previous term.
Stabilization—Equation Set 5
cost = 0.09439 (8,008 + 347 x 0.05 Q)
+ 82,748+ 5.12 x 0.05 Q
+ ((9,806 + 0.19 x 0.05 Q)/(l.0721)) x 0.09439
A-4
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The capital cost term (8,008 + 3.47 x 0.05 Q) was developed (in different form as described
below) for stabilization of residues produced after neutralizing and dewatering mineral processing
wastes. However the term was not used for those wastes and was not included in the Appendix D
description of cost functions.2 The term is used here because of the residues obtained after TC metals
waste treatment. The factor 0.05 is applied to Q because the quantity of solids to be stabilized is
5 percent of the original mass of material entering the treatment process. The term is multiplied by
0.09439 to ahnualize the cost as described above.
The term 82,748 + 5.12 x 0.05 Q, which estimates the annual O&M costs, is a companion to the
previous equation and, except for the factor of 0.05, was developed at the same time. The factor again
represents the reduction in mass to be stabilized to 5 percent of the original quantity.
The term (9,806 + 0.19 x 0.05 Q), except for the factor of 0.05, is taken directly from p. D-7 of
the February 12 draft RIA and represents closure costs. The 0.05 factor again represents the reduction in
mass to be treated. The factors 1.0721 and 0.09439 are used for annualization as described above for pH
adjustment
Disposal in a Subtitle D Landfill—Equation Set 6
cost = (35 + 5.68) Q x 0.0825 x 0.9072 x (381.1/358.2)
This equation is developed from a more general equation for off-site nonhazardous waste landfill
costs.3 Disposal cost is taken as $35/ton tipping fee plus $5.68/ton-mile for 20 miles transportation. The
factor of 0.0825 represents a reduction in volume from the original 100 tons of liquid waste to 8.25 tons
of dewatered, stabilized solids sent to the landfill. The remaining terms represent conversion to metric
tons and escalation of costs to the current year.
Proposed Regulations for Liquid Wastes—Equation Set 7
cost = 1.15 x cost for current regulations for D007 wastes
= 1.29 x cost for current regulations for D008 wastes
The factors for proposed regulations are based on one third of the fractional difference between
the current regulatory level and the proposed regulatory level. For example, D007 wastes (chromium)
must currently be treated to a concentration of 5 ppm. The proposed limit is 2.77 ppm which represents
a 44.6 percent change. One third of this value is 15 percent, or a fraction of 0.15. This fraction is added
to the original cost to obtain a factor of 1.15 increase in treatment and disposal cost
Current Regulations for Sludges • •' • .' ' r -.'.'•.' .. • /• .• .
The basic equations for storage, dewatering, stabilization, and Subtitle D landfill do not change
from those used for current liquid regulations. However, the factors representing changes in volume to
be treated have new values. For dewatering, there is no four percent increase in quantity treated (see
Telecon Between Carolyn Peterson, DPRA, and Jim Turner, RTI. July 19,1996.
Letter from Carol Samat DPRA, to Paul Borst, U.S. Environmental Protection Agency. March 4,
1993.
A-5
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Figure 1). For stabilization, the 0.05 factor applied to Q for liquids is changed to 0.046 for sludges to
represent the different reduction in waste volume to 4.6 tons of wet solids (instead of 5 tons) from 100
tons initially. For landfilling, the quantity disposed of is 7.9 tons, resulting in a factor of 0.079 applied to
the landfill equation.
Proposed Regulations for Sludges
As for current regulations, proposed regulations use the same basic cost functions except for
factors based on changes in quantities of waste entering the various processes. Storage and dewatering
do not change, but stabilization requires a proportionally greater amount of stabilizing agent for a
reduced quantity ofAvet solids compared to liquids. To reiterate:
cost = 0.09439 (8,008 + 3.47 x 0.046 Q) x 1.05
+ 82,748 +5.12 x 0.046 Qx 1.20
+ ((9,806 + 0.19 x 0.046 Q)/(1.0721)) x 0.09439
The term (8,008 + 3.47 x 0.046 Q) was developed for stabilization of residues produced after
neutralizing and dewatering mineral processing wastes. However the term was not used for those wastes
and was not included in the Appendix E description of cost functions.4 the term is used here because of
the residues obtained after TC metals waste treatment, but the factor 0.046 is applied to Q because the
quantity of solids to be stabilized is 4.6 percent of the original mass of material entering the treatment
process. However, a further factor of 1.05 is used for the entire term to account for the 5 percent
increase in capital costs estimated to be required for larger equipment and storage capacity due to
proportionally larger amounts of stabilizing agent. Similarly, the 1.2 factor used in the second line of the
equation represents the proportional increase in O&M costs for the added stabilizing agent.
Landfilling costs for proposed regulations are slightly higher than for current regulations because
of increased stabilizing agent (7.9 tons to be disposed of rather than 7.1 tons). Compared to the function
for current regulations, the factor applied to the equation is 0.079 instead of 0.071.
Current Regulations for Solids
The basic cost functions for solids remain the same for stabilization (no dewatering is required)
and landfilling, but storage equations are different Instead of storage in tanks, small quantities of solids
are stored in drums, while larger quantities are stored in roll-off containers.
Storage—Equation Set 8
cost = 24.589 x<3 + 132.23 for Q < 200 mt/yr
= -0.0022 x Q2 + 29.272 x Q + 4,840.9 for 50
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Stabilization
The stabilization equation for solids under current regulations is the same as for sludge under
current regulations except that the factor 0.046 is not required because there is no reduction in waste
volume before the stabilization step.
Disposal in a Subtitle D Landfill
The disposal cost function remains the same except for a factor of 1.75 to account for the added
75 tons of stabilizing agent required for each 100 tons of waste to be treated (see Figure A-1).
Proposed Regulations for Solids
The only changes under proposed regulations are for factors in the stabilization and landfill
equations. As with sludges, capital costs are assumed to be increased by 5 percent and O&M costs by 20
percent because of proportionally increased stabilizing agent usage. The landfill factor changes to 1.98;
also because of the increased quantity of stabilizing agent.
A-7
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APPENDIX B
DEVELOPMENT OF COST FUNCTIONS FOR
CONVERSION FROM IRON FILINGS TO TSP
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As stated in Appendix A of this document, the cost functions developed for toxicity
characteristic (TC) wastes are based on functions used for estimating impacts on mineral processing
wastes. The mineral processing waste regulatory impact analysis (RIA), Appendix D, forms the basis for
cost functions used here and largely explained in Appendix A of this document. The body of this
document further describes functions to obtain cost'differences associated with the change from cement
(used for mineral processing wastes) to trisodium phosphate (TSP) as a stabilizing agent used for
foundry wastes. .
Iron filings, although currently used by some facilities as a stabilizing agent for foundry waste,
are not expected to be effective for meeting the proposed UTS regulations. However, this appendix is
provided to show the changes associated with changing to TSP from iron filings.
"* * ' '
The sets of equations below are a continuation of the equation sets given in Appendix A of this
document and in the body of the document. Explanations for the equation sets are repeated here, but
some of the terms in the equations differ from their counterparts in the rest of the report. The equation
sets are numbered 1 through 8 in Appendix A, 9 through 11 in the body of the document, and 12 through
15 below.
Costs of converting from iron filings under current regulations to TSP under proposed
regulations are found from the following sets of equations. Costs are summed for each process below
(storage, stabilization, and disposal) under current regulations, then under proposed regulations. The
difference in summed costs between the two cases represents the estimated cost increase (or decrease) in
changing from current to proposed regulations.
Current Regulations Using 15 Percent Iron Filings
Storage—Equation Set 12 (Identical to Equation Set 9)
cost = 24,589 Q+132.23 for Q to 200 mt/yr
= -0.0022 Q2 + 29.272 Q + 4,840.9 for 50 < Q < 7,500 mt/yr
These equations, as described above, are taken directly from the February 12, 1997 draft RIA,
p. D-21. They apply to solids in drums and roll-off containers, respectively. Conditions used to develop
equations in the February 12 draft are also used for the equations given here. However, on the basis of
equivalent costs, the drum storage option could be used up to about Q = 2,900 mt/yr.
Stabilization—Equation Set 13 • - \
cost = 207.93 Q07! x 0.9 x 0.09439
• • • ' ' •'.-•."'•••'.-.••• '
+ (87,839 + 52.15 Q)(l -(0.1113 In (Q)-0.3429)
+ (0.1113 In (Q) - 0.3429)(116/67.0QX15/50)) -
+ ((9,806 + 0.19 QV(10721)) x 0.09439
forQ<100,OOOmt/yr
B-l
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= 207.93 Q07«x 0.9x0.09439
+ (87,839 + 52.16 QX( 1 -0.98) + (0.98)( 116/67.00)'
x (15/70)) -fc ((9,806 + 0.19 Q)/(1.0721)) x 0.09439
forQ> 100,000 mt/yr
These equations are taken from the February 12 draft RIA, but are modified by terms
that adjust for different stabilizing agents, different ratios of stabilizing agent to waste quantity, and
different ratios of stabilizing agent cost to total operation and maintenance cost. Each term in the
equations is discussed below. , .
The term 207.93 Qa78 is taken directly from the February 12 draft RIA, p. D-7. It represents the
capital cost required to build a stabilization facility capable of treating Q mt/yr of waste. Because the
quantity of iron filings used for stabilization of foundry wastes is significantly lower than the amount of
cement assumed to be used for mineral processing wastes, the capital costs for the foundry facility are
expected to be lower. This decreased cost is obtained by multiplying the capital cost equation by a factor
of 0.9, A factor of 0.09439 is then applied to obtain an annualization of the capital cost.
The term (87,839.+ 52.15 Q) is taken directly from the February 12 draft RIA, p. D-7. It
represents the operation and maintenance costs associated with stabilizing wastes.
* ' ' ,
The term (0.1113 In (Q) - 0.3429) is developed from a series of data points generated from plant
size vs cost of cement as a fraction of total operating and maintenance (O&M) cost.1 The four data sets
are:
Plant size, mt/yr Cement cost, % of O&M cost
426 21.0
4,265 71.5
42,648 \ . 94.9
426,477 " 98.6
This term estimates stabilizing agent cost as a fraction of total O&M cost for any size plant
within the range of sizes given in the February 12 draft RIA (the data points were developed from the
mineral processing waste cost functions). When the mineral processing RIA O&M cost equation is
multiplied by one minus this term (as above), an O&M cost without the stabilizing agent is estimated
based on plant size. To account for the cost of iron filings as a stabilizing agent, this term is added back
into the equation after modification for different reagent costs and application fractions as shown for the
next two terms. • " •• '
•••••• .
Telecon between Caroline Peterson, DPRA and Jim Turner, RTI. September 25, 1996.
B-2
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The term (62.33/67.00) is the ratio of iron filings cost2 to cement cost3 (both in dollars per ton).
The term (15/70) is the ratio of stabilizing agent used for secondary lead smelter wastes4 to the
amount used for mineral processing wastes (as given in the February 12 draft RIA).
The term (9,806 + 0.19 Q) is taken directly from the February 12 draft RIA, p. D-7. It represents
closure costs for the stabilization facility. Because this cost is not incurred until after the 20-year life,
but is spread over that life, it must be divided by the terms that follow (LOT21-and 0.09439) to obtain a
uniform annual reserve. •
For Q > 100,000 mt, the term (0.1113 In (Q) - 0.3429) is replace by 0.98 to prevent obtaining
factors greater than 1. Examination of the data suggests that an asymptote exists near this value.
Landfill—-Equation Set 14
cost = ((25.485 Q)+ 294,701) x 1.20
This equation (for metric quantities) is developed from data for on-site nonhazardous waste
landfill costs.1 The three data sets are: •
Landfill size, short Capital cost, $ Annual O&M Closure cost, $ Annual post-
tons/yr ' cost,$/yr closure cost, $
5,000
25,000
50,000
The equation is multiplied by a factor of 1.20 to account for the difference between added
stabilizing agent quantities in lead wastes and in other TC metals wastes. For the small quantities of
waste disposed of from many foundries, it is likely that offsite disposal would be used as described in
equation set 6 of Appendix A.
2,632,000
7,034,000
10,899,000
114,000
236,000
328,000
434,000
1,547,000
2,675,000
5,000
9,000
12,000
Facsimile message from Lane Tickanen, RMT, Inc., to Paul Borst, U.S. EPA. February
20,1997. .
Supra. Note 1. Value reported as $0.0335/lb taken from R. S. Means Construction Cost
Data for 1995.
Developed from a telecon between Gary Mosher, American Foundrymen's Society, and
Jim Turner, Research Triangle Institute. September 24,1996.
Letter from Carol Samat, DPRA, to Paul Borst, U.S. Environmental Protection Agency.
March 4, 1993. _,'.'.
B-3
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Proposed Regulations Using IS Percent TSP
For this case, only the stabilization term for reagent cost changes. The term for reagent cost
becomes (260/67.00) for TSP cost vs. cement cost. The stabilization equation for Q < \ 00,000 mt/yr
changes to:
Equation Set 15
cost = 207.93 Q078 x 0.9 x 0.09439
+ (87,839 + 52.15 Q)(l - (0.1113 In (Q) - 0.3429)
•• ,\
+ (0.1113 In (Q) - 0.3429)(260/67.00)( 15/70))
+ ((9,806 + 0.19 Q)/( 1.0721)) x 0.09439
for Q< 100,000 mt/yr
The change is only in the ratio of reagent costs.
Storage costs under the proposed regulation for a typical foundry generating 375 tons of waste
sand annually do not increase because the mass of reagent does not change.
Disposal costs are increased using equation set 6 (Appendix A) because of the small quantities
involved. The amount disposed of is increased to 375 x 1.15 tpy (340.2 x 1.15 mt/yr) both at baseline
and for the proposed regulation. .
i
Capital and annual incremental costs can be estimated as shown at the end of section 5.1 in the
body of this report.
B-4
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