Regulatory Impact Analysis
of
Air Pollutant Emission
Standards and Guidelines
for
Municipal Waste Combustors
A Description of the Economic Impacts of, and
Regulatory Options for, Clean Air Act §111(b) New
Source Performance Standards and §111(d) Existing
Source Emission Guidelines
October 1989
This document is printed on recycled paper.
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Regulatory Impact Analysis
of
Air Pollutant Emission
Standards and Guidelines
for
Municipal Waste Combustors
Prepared by
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Research Triangle Park, NC
October 1989
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This Regulatory Impact Analysis was prepared by the Office of Air
Quality and Standards, U.S. Environmental Protection Agency, Research
Triangle Park, NC 27711. Questions and comments should be addressed as
follows:
Overall report—John Robson, MD-13, Standards Development
Branch, phone 919-541-5305 (FTS 629-5305).
Benefits analysis (Chapters 12 and 13)—Bruce Madariaga, MD-15,
Ambient Standards Branch, phone 919-541-5290 (FTS 629-5305).
Substitution analysis (portions of Chapters 9 and 10)—Tom Walton,
MD-13, Standards Development Branch, phone 919-541-5311 (FTS
629-5311).
Research and editorial assistance was provided by Linda Chaput, Virginia
Moyer, Robert Pahel-Short, Tom Walton, and Al Wehe, Standards Devel-
opment Branch, and by Allen Basala, Ambient Standards Branch.
11
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Executive Summary
The Environmental Protection Agency (EPA), under the authority of Clean
Air Act §lll(b) and (d), proposes to regulate air pollutant emissions from new
and existing municipal waste combustors (MWCs). MWC emissions cause, or
contribute significantly to, air pollution that endangers public health and welfare.
EPA's intent is to require new and existing MWCs to control emissions to the
level achievable by applying the best demonstrated system of continuous emission
reductions, considering costs and environmental impacts. Under the proposed
Guidelines, some requirements for existing MWCs are less than those for new
MWCs, largely due to the extra expense of retrofitting, that is, installing, air
pollution control devices at existing plants.
In this document the regulations for new sources are called Standards, and
the regulations for existing sources are called Guidelines.1 The Standards and
Guidelines are parts of an overall approach to addressing the municipal solid waste
(MSW) disposal crisis that confronts the nation. This approach is described in the
recent EPA publication The Solid Waste Dilemma: An Agenda for Action.[i4]
The Standards and Guidelines require the reduction of emissions to the air of
organic compounds (principally dioxins and furans), metals (cadmium, mercury,
chromium, lead, nickel, etc.), acid gases (sulfur dioxide, hydrogen chloride, etc.),
nitrogen oxides, and carbon monoxide. The Standards identify these pollutants
as "MWC emissions" and nitrogen oxides. MWC emissions consist of "MWC
organks," "MWC metals," and "MWC acid gases." "MWC emissions" is the
designated pollutant that triggers application of §lll(d); the Guidelines do not
address nitrogen oxides.
Currently, EPA new source review permitting directives to the states recom-
mend control of most of these pollutants at new, large MWCs. New source perfor-
mance standards that are already on the books have required control of particulate
matter on many MWCs since 1970, but not control of the other pollutants.
Emission limits for large new MWCs (greater than 225 Mg per day capacity)
and for very large existing MWCs (greater than 2,000 Mg per day capacity) are
based on what is achievable with spray dryers followed by fabric filters, while
those for small new MWCs and for existing MWCs with capacities in the 250 to
2,000 Mg per day range are based on dry sorbent injection followed by upgraded
1The Guidelines will not be regulations that are applied directly to existing MWCs.
Instead, the Guidelines will be used by state agencies to develop state regulations that
will be applied to existing MWCs.
ill
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electrostatic precipitators. Emission limits for small existing MWCs (under 225
Mg per day capacity) are based on electrostatic precipitators without acid gas
controls. Operational standards are included in both Standards and Guidelines to
control organic emissions.
The Standards and Guidelines both require the separation from MSW of po-
tentially recyclable items to comprise about 25 percent by weight of the MSW
received at each MWC. Separated items would not be combusted and therefore
would not contribute to MWC emissions. The Standards and Guidelines also
require MWC operator training.
The Standards will cost the nation in excess of $100 million annually, and the
Guidelines, about $300 million annually. If the costs to individual MWCs were
added to MWC tipping fees, the results, averaged across the county, would be
20-plus percent increases—from about $40 to $50 per Mg of MSW combusted at
the MWC. These numbers are based on the selection of regulatory alternative IV
for the Standards, and IIB' for the Guidelines.
Many of the benefits have not been quantified. The absence of sufficient
exposure-response and valuation information precludes a comprehensive benefits
analysis at this time. However, some benefits for reduction of particulate matter
and sulfur dioxide have been quantified. For the Standards, the partial benefits
total $80 to $133 million annually, and for the Guidelines, $107 to $171 million
annually.
Chapters 7 through 13 of this regulatory impact analysis do
not incorporate recent changes in the regulatory packages. Ex-
cept where noted, the costs for control of NOX emissions from
large new MWCs, for Guidelines regulatory alternative IIB' (sim-
ilar to IIB except that very large existing MWCs must have best
particulate matter and acid gas controls and small existing MWCs
need have no acid gas control), and for materials separation at
both new and existing MWCs, are not included in the text and
tables. A change in particulate matter emission requirements for
existing MWCs also is not incorporated into the analysis. The
economic analysis, including the analysis of the distribution of
impacts, was conducted only on regulatory alternatives I, IIA,
IIB, III, and IV, exclusive of these recent additions and changes.
IV
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Contents
Executive Summary Hi
Units and Conversions xiv
Definitions xv
1 Report Summary 1-1
2 Background 2-1
2.1 "An Agenda for Action" 2-1
2.2 Project History 2-2
2.2.1 Existing Regulations and Guidance . 2-2
2.2.2 Report to Congress 2-3
2.2.3 Regulatory Approach 2-4
2.2.4 Litigation 2-4
«
2.3 The Nature^of CAA §111 2-5
2.4 Pending Legislation 2-7
2.5 Regulatory Initiatives Affecting MSW Management . . . 2-7
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2.6 Executive Order 12291 2-10
2.7 Guide to the References 2-10
3 The Standards and Guidelines in Brief 3-1
3.1 Applicability 3-1
3.1.1 Standards 3-1
3.1.2 Guidelines 3-2
3.2 Emission Limits and Other Requirements 3-2
3.2.1 Standards 3-2
3.2.2 Guidelines 3-6
3.3 Recordkeeping and Reporting 3-8
4 The Need for and Consequences of Regulatory Action 4-1
4.1 The Problem 4-1
4.2 Need for Regulation 4-4
4.2.1 Market Failure 4-4
4.2.2 Price Instability 4-7
4.2.3 Insufficient Political and Judicial Forces 4-8
4.2.4 Harmful Effects of MWC Emissions 4-9
4.3 Consequences of Regulation 4-^2
4.3.1 Consequences if EPA's Emission Reduction
Objectives are Met 4-12
4.3.2 Consequences if EPA's Emission Reduction
Objectives are not Met 4-16
vi
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5 Control Techniques 5-1
5.1 Integrated Waste Management 5-1
5.2 Source Reduction 5-2
5.3 Materials Separation and Recycling 5-3
5.4 Good Combustion Practice 5-6
5.5 Post-Combustion Control Devices 5-7
6 Regulatory Options 6-1
6.1 Complementary Approaches 6-1
6.2 No Additional EPA Regulation 6-2
6.2.1 State and Local Action 6-2
6.2.2 Economic Incentives 6-3
6.3 EPA Regulation 6-6
6.3.1 Development of Regulatory Alternatives 6-6
6.3.2 Role of Cost Effectiveness 6-8
6.3.3 Description of the Regulatory Alternatives . . . . 6-11
7 Municipal Waste Combustor
Characteristics and Control Costs 7-1
7.1 Characteristics 7-1
7.1.1 A Basic Classification of MWCs 7-1
7.1.2 Ash Handling 7-3
7.1.3 Model Plants 7-4
7.1.4 Model Plant Throughput 7-5
vii
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7.2 Control Costs , 7-8
8 Characteristics of the
Municipal Waste Combustion Industry 8-1
8.1 Industry Profile 8-1
8.1.1 Generators 8-1
8.1.2 Collection and Disposal 8-3
8.1.3 Decision Making 8-5
8.2 Baseline Projections 8-7
9 Economic Analysis Objectives and Methodology 9-1
9.1 Introduction 9-1
9.1.1 Special Features of the Analysis 9-2
9.2 Objectives 9.3
9.3 Methodology 9,5
9.3.1 Inputs 9.5
9.3.2 Overall Approach 9.5
9.3.3 Assumptions and Conventions 9-7
9.3.4 Substitution Scenarios . 9-10
10 Economic Analysis Findings 10-1
10.1 Scope JQ_J
10.2 Enterprise Costs 10-3
10.2.1 National Enterprise Costs and Tipping Fees . . . 10-3
viii
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10.2.2 Municipalities' Choices of Technology 10-6
10.3 Social Costs 10-8
10.3.1 National Social Costs 10-8
10.3.2 Sensitivity of Costs 10-10
10.4 Emission Reductions 10-12
10.4.1 National Emission Reductions - 10-12
10.4.2 Sensitivity of Emission Reductions 10-12
10.5 Untabulated Costs 10-13
11 The Distribution of Impacts (Regulatory Flexibility) 11-1
11.1 Who Pays How Much? 11-1
11.2 Households and Governments 11-1
11.2.1 Household Impacts 11-2
11.2.2 Local Government Impacts 11-4
11.3 Regulatory Flexibility Analysis 11-5
11.3.1 Small Entity Impacts 11-6
12 Benefits 12-1
12.1 Introduction 12-1
12.2 PM Benefits 12-2
12.3 S02 Benefits 12-5
12.4 Unqualified Benefits 12-8
12.5 Summary 12-9
ix
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13 Weighing Some of the Benefits and Most of the Costs 13-1
13.1 Evaluation Criterion 13-1
13.2 Qualifications 13-1
13.3 Results 13-2
Bibliography B-l
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List of Tables
2.1 Impacts of Regulatory Initiatives in the MSW Area . . 2-9
3.1 Summary of Emission Levels in Standards and Guidelines 3-3
4.1 Materials in the Municipal Waste Stream 4-2
4.2 Pollutants Emitted by Municipal Waste Combustors . . 4-10
4.3 Some Health and Welfare Effects of MWC Emissions . 4-11
6.1 MWC Emissions Control Technology 6-7
6.2 Regulatory Alternatives for the Standards 6-12
6.3 Regulatory Alternatives for the Guidelines 6-13
7.1 Model Plants for the Standards and Guidelines 7-6
7.2 Baseline Model Plant Throughput 7-7
7.3 Model Plant Costs and Energy Revenue
($per Year) 7-10
7.4 Model Plant Costs and Energy Revenue
($per Mg MSW Combusted) 7-11
7.5 Model Plant Control Costs for the Standards 7-12
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7.6 Model Plant Control Costs for the Guidelines 7-15
7.7 Control Costs as Percentages of Baseline Costs 7-18
8.1 Ownership of Municipal Waste Combustors, by Size . . 8-5
8.2 MSW Disposal Projections 8-9
8.3 Model Plant Scaling Factors 8-11
9.1 Assumptions and Conventions
Used in the Economic Analysis 9-8
10.1 National Cost Impacts
(Enterprise Costs for Average Capacity Utilization) . . . 10-4
10.2 Potential Percentage Increases in Tipping Fees 10-5
10.3 Substitution Effects of the Standards 10-7
10.4 Substituted Costs for the Guidelines Analysis 10-7
10.5 National Cost Impacts
(Social Costs for Average Capacity Utilization) 10-9
10.6 National Cost Impacts
(Social Costs for High Capacity Utilization) 10-11
10.7 National Baseline Emissions and Regulatory Emissions
Reductions — Average Capacity Utilization 10-14
10.8 National Baseline Emissions and Regulatory Emissions
Reductions — High Capacity Utilization 10-15
12.1 National Annual Reductions in Adverse Effects
from PM Emissions 12-4
12.2 National Annual PM Emission Reductions
and Associated Benefits 12-6
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12.3 National Annual S02 Emission
Reductions and Associated Benefits 12-7
12.4 Types of Benefits Included in, and Excluded from,
the Benefits Analysis 12-10
12.5 Partial National Annual Benefits
from Reducing MWC Emissions 12-11
13.1 National Social Costs and Partial National Benefits . . 13-3
xm
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Units and Conversions
This report uses metric units, some of which may not be familiar to all
readers. The following is a short guide to the units and their conversions.
Conversions
To
Approximate
Mg
(megagram)
As
Ton
(2,000 Ib)
Multiply
by
1.1
Examples
from Text
225 Mg = 250 tons
2,000 Mg = 2,200 tons
mg/dscm gr/dscf
(milligrams/dry stan- (grains/dry stan-
dard cubic meter) dard cubic foot)
TJ
(terajoule)
km
(kilometer)
109 Btu
(109 British
Thermal Units)
mile
.44 x 10
.95
0.62
_3 34 mg/dscm ^.015 gr/dscf
69 mg/dscm =* .030 gr/dscf
820 TJ = 780 x 109 Btu
3.5 km = 2.2 miles
C
("Celsius)
(° Fahrenheit)
%, then,
add 32
230°G = 450°F
Other Measures
MWh megawatt hour (3.6 GJ) ppmv parts per million by volume
ng nanogram (10~9 gram) /ig microgram (10~6 gram)
Nm3 Normal cubic meter (A normal cubic meter is at 0°C, while a stand-
ard cubic meter is at 20°C; both are at one atmosphere of pressure.)
Opacity A measure of the transparency of a smoke plume
T = 1012 tera = trillion M = 106 mega = million
G = 109 giga = billion k = 103 kilo = thousand
xiv
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Definitions
The following is a short guide to a selection of the abbreviations, acronyms,
and terms used in this report.
Economic Terms
Annual Cost
C/E
National En-
terprise Cost
National
Social Cost
1987$
Per-Mg
Costs
Tipping
Fee
Annualized capital plus annual operating costs
Cost effectiveness; the annual cost of emission control di-
vided by annual emission reductions in megagrams, or by
some other measure of effectiveness
The sum of the regulatory costs incurred by each MWC,
discounted and annualized at rates reflecting estimated
real market interest rates
The sum of the regulatory costs incurred by each MWC,
discounted and annualized at rates reflecting society's esti-
mated real opportunity costs for capital and consumption
Constant (real) dollars at their fourth quarter 1987 value
(A) The cost of combusting MSW, in $/Mg combusted,
after subtracting revenue from the sale of electricity and
steam; (B) the cost of an APCD in $/Mg combusted
The charge for incinerating MSW, usually $/Mg, imposed
by MWCs on MSW collectors (Tipping fees may not re-
flect the full cost of incineration. They never include the
cost of collecting and transporting MSW.)
General Acronyms
APCD Air pollution control device
ESP Electrostatic precipitator
FF Fabric filter
FBC Fluidized bed combustion
GCP Good combustion practice
MSW Municipal solid waste
MWC Municipal waste combustor
(a single combustor or all
combustors at one site)
NIMBY "Not in my backyard"
RDF Refuse-derived fuel
SD Spray dryer
xv
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Regulatory and Legislative Terms
Baseline
CAA
Guidelines
Model
Plant
NSPSs
(Standards)
RCRA
Regulatory
Alternatives
RFA
§Hl(b)
Subtitle C
Subtitle D
Conditions that would exist were there to be no new Clean
Air Act §lll(b) and (d) regulation of MWCs, and no re-
laxation of state regulations of MWCs
Clean Air Act
CAA §lll(d) emission standards for existing sources
A hypothetical MWC plant representative of a class of
plants; used to analyze impacts of regulatory alternatives
CAA §lll(b) new source performance standards, gener-
ally referred to in this document as "Standards"
Resource Conservation and Recovery Act
Sets of performance standards and related requirements
for controlling emissions; used by EPA to help select the
stringency of regulations
Regulatory Flexibility Act; also regulatory flexibility
analysis, a study of the impact of regulations on small
entities (businesses, governments, and organizations)
CAA section mandating emission standards (NSPSs) for
new air pollutant emission sources
CAA section mandating emission standards (guidelines)
for existing air pollutant emission sources
RCRA subtitle governing hazardous waste landfills
RCRA subtitle governing sanitary landfills
Pollutants
CDD/CDF Chlorodibenzo-p-dioxins and Chlorodibenzofurans
CO Carbon monoxide NOX Nitrogen oxides
C02 Carbon dioxide PM Particulate matter
HC1 Hydrogen chloride S02 Sulfur dioxide
HF Hydrogen fluoride
xvi
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Chapter 1
Report Summary
The following paragraphs contain a brief summary of each chapter in the
remainder of this report.
Chapter 2: Background
Chapter 2 presents an overview of the legislative, regulatory, and pol-
icy background for the proposed Standards and Guidelines for municipal
waste combustors (MWC) under §111 of the Clean Air Act (CAA).1 In
February 1989, EPA published The Solid Waste Dilemma: An Agenda for
Action[l4], describing a strategy for improving the nation's management of
municipal solid waste (MSW) that involves minimizing the amount and tox-
icity of waste created and maximizing the amount of waste materials that
are reused or recycled. The MWC Standards and Guidelines are a part of,
and incorporate elements of, the Agenda for Action. They supercede the
1971 and 1986 new source performance standards for particulate matter
(PM) emissions from MWCs. Under CAA §lll(b) and (d), the Standards
and Guidelines will affect both new and existing sources. CAA amendments
being considered by Congress would require EPA to develop standards and
guidelines similar in many ways to those now being proposed. The sched-
ule for the proposed Standards and Guidelines is a result of a settlement
agreement between EPA and NRDC et al. in litigation brought by NRDC
1See the definitions beginning on page xv for a quick reference to the many terms,
abbreviations, and acronyms used in this report.
1-1
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to force EPA to promulgate regulations for MWCs. The Standards and
Guidelines are just one part of the EPA regulatory initiatives affecting
MSW management. They all will have varying impacts on the industry
and on public and private decision makers who are concerned with MSW
management.
Chapter 3: The Standards and Guidelines in Brief
Chapter 3 summarizes the proposed Standards and Guidelines. The
Standards apply to new, modified, and reconstructed MWCs; the Guide-
lines apply to existing MWCs. The emission limits in the standards and
guidelines are summarized in Table 3.1. In addition, there are requirements
for good combustion practice (load levels, PM control device temperature,
etc.), for operator training and certification, and for pre-combustion mate-
rials separation.
Chapter 4: The Need for and Consequences of Regu-
latory Action
Chapter 4 discusses the reasons regulatory action is needed and the
likely consequences if the requirements are met—and if they are not met.
As MSW generation has increased over the years (about 170 million Mg2
is expected for the year 2000), so has MSW combustion. In early 1987,
111 MWCs existed in the U.S., and over 200 were planned or under con-
struction. While combustion is an attractive waste management option, it
causes concern because of potential health and environmental threats from
combustor emissions and ash. There is a need for Federal regulation of the
emissions in that there is no market incentive for the industry to control
its own emissions. Current instability in the market for recycled material
inhibits full use of that option for disposing of MSW. State and local gov-
ernments and the courts can not solve the problem. If there is compliance
with the Standards and Guidelines, there will be improved allocation of
resources in the MSW combustion market; air pollutant emissions will be
reduced and air quality will improve; there will be increases in emission con-
2 Readers accustomed to English units of measure may wish to refer to the conversion
factors given on page xiv for a guide to the metric units used in this report.
1-2
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trol costs; but energy consumption, water, and solid waste impacts will not
be significant; there will be technological innovation; and state regulatory
programs will be strengthened. Impacts on substitution, regionalization,
industry growth, landfill utilization, the distribution of costs, and on Fed-
eral programs are not clear. If there is not compliance with the Standards
and Guidelines, there will be more delays and controversy in the siting
and permitting of new MWCs. Noncompliance will result in less emission
reduction and fewer benefits than projected, as well as lower cost to the
industry. Poor compliance would create the need to review the strategy
and goals in An Agenda for Action, since the Standards and Guidelines are
key elements of an overall nationwide MSW management plan.
Chapter 5: Control Techniques
Chapter 5 reviews the equipment and operating practices that are used
to control air pollutant emissions from MWCs. Source reduction, materials
separation, and recycling are practices that reduce emissions by reducing
the quantity and/or toxicity of waste combusted. Good combustion prac-
tices include proper design, construction, and operation of an MWC. Op-
erating conditions that are important are uniform waste feed rates, amount
and distribution of combustion air, adequate combustion temperature and
residence time, mixing, particulate matter carryover, downstream flue gas
temperature, control, and combustion monitoring and control. It is also
very important that the combustor operator be properly trained in how
to minimize emissions through operation and maintenance of the combus-
tor. Emissions are also reduced through the following technological means:
cooling the flue gas to 230°C or below to minimize formation of MWC or-
ganics; use of electrostatic precipitators (ESPs) and fabric filters (FF) for
PM and metals control; and use of dry sorbent injection and spray dryers
for MWC acid gas control.
Chapter 6: Regulatory Options
Chapter 6 presents the options EPA has for regulating emissions frotn
MWCs. Relying on state and local action is not a viable substitute for
EPA regulation; it would be fractionated, inefficient, and incomplete, and
would be frustrating to industry segments located in different states with
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different requirements. Non-regulatory incentives to minimize wa.ste and
reduce emissions, including educational and research programs and eco-
nomic incentives, are considered complements to, not replacements for the
Standards and Guidelines. Regulation of the emissions as hazardous air
pollutants under CAA §112 would not have allowed the site-specific consid-
eration of appropriate control for MWCs. EPA selected the establishment
of standards and guidelines under CAA §111 as the best means of reducing
emissions from new and existing MWCs. Once this decision was made, EPA
faced numerous secondary decisions, including selection of the pollutants
to control, degree of control, and methods of enforcement.
Chapter 7: Municipal Waste Combustor Characteris-
tics and Control Costs
Chapter 7 describes the different types of MWCs and the costs to control
their emissions. There are three principal types of MWCs: mass burn,
modular, and refuse-derived fuel (RDF) combustors. A less common type
is one that employs fluidized-bed combustion (FBC). Model plants for these
MWC types are used to estimate control costs. The increase in capital costs
for MWCs affected by the Standards and Guidelines will range from $1.1
million for one of the smaller MWCs to $19.7 million for large RDF MWCs.
Total annual costs range from $.45 million to $5.4 million per plant. The
percent increase in costs to combust each Mg of MSW ranges from 22 to 87
percent for the Standards (except for RDF MWCs, for which it is 67 to 275
percent), and from negligible to 520 percent for the Guidelines. (Percentage
increases are over baseline capital and operating costs for the Standards,
but only over operating costs for the Guidelines; hence, percentages for the
Guidelines are somewhat exaggerated.) These numbers are based on the
selection of regulatory alternative IV for the Standards, and I1B for the
Guidelines.
Chapter 8: Characteristics of the Municipal Waste
Combustion Industry
Chapter 8 gives a brief industry profile—strictly from the economists'
perspective—and the baseline projections of MWCs that will be operating
1-4
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or under construction by the end of 1994. The chapter looks at who and
what organizations generate MSW (and thereby "demand" its collection),
who and what organizations supply collection services (and thereby "de-
mand" disposal services), and who and what organizations supply disposal
services, particularly those of MWCs. The unusual features of this market
structure is that the MSW generators—primarily households—pay for dis-
posal in ways (like taxes) that do not encourage them to reduce the amount
generated, even when the cost of coinbustion goes up. The baseline pro-
jections of MWCs through the 5-year analysis period is complicated by the
dynamic nature of the industry and the large number of regulatory actions
in the pipeline. In the first five years the Standards will impact about 65
MWCs, and the Guidelines, about 180.
Chapter 9: Economic Analysis Objectives and Method-
ology
Chapter 9 explains the objectives, special features, and methodology of
the economic analysis of the Standards and Guidelines. Economic analyses
in general tell us something about the affordability of regulations, whether
regulations will be inflationary, whether they will be efficient in achieving
their purposes, whether they will alter production technology or the types
of goods consumers purchase, and whether some groups will be adversely
affected out of proportion to their contribution to pollution. Economic
analyses give EPA insight in how to draft regulations so that positive im-
pacts will be maximized and negative impacts minimized. The analyses
produce much of the input data needed for benefit analyses. The economic
analysis for the Standards and Guidelines is unusual in that it encompasses
simultaneous CAA §lll(b) and (d) actions, and is concerned with impacts
on an industry where ownership of the emission sources is split between
public and private. The myriad assumptions, analytical conventions, and
underlying calculations that form the basis for projecting the economic im-
pacts are explained. The methodology of the analysis includes the usual
tasks related to data collection, projection of future MWC utilization, and
analysis of price increases. The unusual aspect of the methodology, how-
ever, is a procedure to see how the Standards and Guidelines may affect
municipalities' selection of MSW disposal technology.
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Chapter 10: Economic Analysis Findings
Chapter 10 displays the economic analysis findings in several tables. If
the increased costs of combusting each Mg of MSW are added to MWC
tipping fees, the Standards and Guidelines will result in increases, averag-
ing over 20 percent. The national social cost for the Standards will exceed
$100 million, and for the Guidelines, $300 million.3 Emission reductions
are described. The analysis of substitution among combustion technolo-
gies and between combusting and landfilling suggests that some mass burn
refactory wall MWCs now operating may close. It also indicates that the
Standards and Guidelines will cause a little stretching out of construction
schedules, forcing more MSW to be landfilled than might be the case in
the absence of further regulation of MWCs. Sensitivity analyses of two
parameters used in the economic analysis, namely the rates used for an-
nualizing capital costs and the capacity utilization of MWCs, demonstrate
that the economic findings reported in this regulatory impact analysis are
reasonably on target.
Chapter 11: The Distribution of Impacts (Regulatory
Flexibility)
Chapter 11 focuses on possible adverse economic impacts to house-
holds, local governments, and small businesses, and how the standards and
guidelines have been designed to mitigate those impacts. No MWC service
area will experience severe household impacts from the regulation although
smaller service areas may have slightly higher than average household im-
pacts (still not severe). Likewise, no local government will be severely
impacted. The Regulatory Flexibility Act (RFA) requires EPA to prepare
a regulatory flexibility analysis if a proposed regulation will have (1) a sig-
nificant economic impact on (2) a substantial number of small entities. The
impacts will be significant, but only a minor number of small businesses and
small governments have MWCs. Although a regulatory flexibility analysis
is not required, EPA nevertheless has prepared this regulatory flexibility
analysis and is making every effort to involve small entities in the regu-
latory development process and to ensure that the cost burden on small
3These figures do not include costs for control of NOX at large new MWCs, for best
acid gas control at very large existing MWCs, and for materials separation at both new
and existing MWCs.
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entities will not be out of proportion to the pollution they cause.
Chapter 12: Benefits
Chapter 12 presents benefit estimates associated with reduced pollutant
emissions from MWCs. The estimated economic benefits reflect individuals'
willingness to pay for cleaner air. Benefits are estimated for PM and SOj
emissions. Added up for the nation, the annual benefits currently quantified
come to $80 to $133 million for the Standards (regulatory alternative IV),
and $107 to $171 million for the Guidelines (regulatory alternative 1IB).
However, many types of benefits, and benefits associated with reduction of
other pollutants controlled by the regulation, can not be quantified at this
time.
Chapter 13: Weighing Some of the Benefits and Most
of the Costs
The benefits analysis finds plenty of benefits, but is unable to qua,n-
tify and add together enough to produce dollar sums adequate to serve as
the raison d'etre for the Standards and Guidelines. Benefit-cost analysis
uses the principle that society is better off if potential net benefits (bene-
fits minus costs) are positive and potential gainers are able to compensate
potential losers. Unfortunately, data paucities preclude the application of
this principle to the Standards and Guidelines at this time.
1-7
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Chapter 2
Background
2.1 "An Agenda for Action"
Municipal solid waste (MSW) disposal problems are legion. MSW is
overflowing our landfills and municipalities have embarked on a record-
setting construction spree in pursuit of an incineration solution. Municipal
waste combustors (MWCs) reduce the volume of MSW by 70 to 90 percent
and the mass by about 75 percent. These combustors are a principal means
for reducing our dependence on landfill space. But MWCs can pollute the
air. In many locations current emission standards are inadequate to control
the wide range of pollutants to the degree necessary to protect human
health and welfare.
In response to the burgeoning MSW problem, EPA created a Municipal
Solid Waste Task Force early in 1988 and directed it to fashion a strategy for
improving the nation's management of MSW. The result is The Solid Waste
Dilemma: An Agenda for Action[l4], issued in February 1989. The Agenda
calls for a systems approach to managing MSW, that is, the complementary
use of source reduction, recycling, combustion, and landfills. The objective
is to minimize the amount and toxicity of waste created by products we
make and purchase, and to maximize the amount of waste materials that
are reused or recycled. In short, EPA proposes to change the way we do
business when it comes to waste generation and disposal.
EPA recommends integrated waste management at all levels of govern-
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ment for all categories of waste—municipal, infectious, sewer, industrial,
construction and demolition, utility, hazardous, etc. For MSW, integrated
waste management emphasizes a hierarchy of management methods. First
and most important are source reduction measures. These decrease the
volume and toxicity of products, and increase the useful life of products,
in order to reduce the volume and toxicity of waste. Recycling, including
composting, is next in the hierarchy. It will divert MSW from landfills
and combustors, conserve energy, and slow the depletion of nonrenewable
resources. At the bottom of the hierarchy are combusting and landfilling.
EPA is preparing these Standards and Guidelines to decrease adverse health
and welfare effects from combustion, and similar standards and guidelines
to decrease adverse health and welfare effects from landfill gas. EPA also is
revising design and operational criteria for landfills, and working on MWC
ash management plans.
In short, the MWC Standards and Guidelines are a part of, and incor-
porate elements of, the Agenda for Action.
2.2 Project History
2.2.1 Existing Regulations and Guidance
In 1971 and 1986 EPA promulgated NSPSs for PM emissions from,
among other sources, MWCs. The Standards and Guidelines will super-
sede these NSPSs insofar as they apply to MWCs. Neither addresses health
concerns specific to the individual constituents of MWC emissions. To ad-
dress some of these health concerns, and to establish better control over
rapidly increasing numbers of new MWCs, EPA in 1987 issued operational
guidance1 to states for processing applications for the construction of new,
large MWCs. This operational guidance is interim guidance that will termi-
nate when these new §111 Standards are proposed in the Federal Register.
The following are the regulations and guidance.
1The terms "guidance" and "guidelines" have two distinctly different meanings. New
source review operational guidance is a directive that has been issued by EPA to require
the application of good combustion practice, spray dryers, and particulate matter control
on all large new MWCs. The emission Guidelines will be used by states to develop plans
to control existing MWCs.
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40 CFR Part 60 Subpart E covers incinerators built after 1970 with
a capacity to combust more than 45 Mg MSW per day. PM emissions are
limited to 180 mg/dscm corrected to 12 percent C02.
^
40 CFR Part 60 Subpart Db covers industrial, commercial, and
institutional steam generating units built after 1984 with a thermal input
capacity greater than about 30 MW, which translates roughly to 225 Mg
MSW combusted per day. PM emissions are limited to 41 mg/MJ, which
translates roughly to 110 mg/dscm corrected to 12 percent CO2.
New Source Review Operational Guidance[1] was issued by EPA
in 1987 to guide state and local agencies in establishing permit conditions
when processing new source review permits for new MWCs with a capacity
to combust more than 225 Mg MSW per day. In general, the Guidance
calls for emission control on these new large MWCs based on acid gas
dry scrubbers followed by fabric filters or electrostatic precipitators, plus
combustion controls. The Guidance is intended to control PM, metals, acid
gases (HC1 and 802), CO, and most organics. It applies only to new large
MWCs and does not apply to new small MWCs or to any existing MWCs.
2.2.2 Report to Congress
Concern over emissions of chlorodibenzo-p-dioxins (CDD—often called
simply "dioxins") led Congress in 1984 to direct EPA to study emissions
from resource recovery facilities that burn MSW.2 EPA broadened the
study to cover emissions of air toxics,3 including chlorodibenzofurans (CDF),
and then to cover all emissions from all MWCs. In 1987, concurrent with
publication of the results of the selection of a regulatory approach for
MWCs, described below, EPA released a nine-volume report Municipal
Waste Combustion Study[13]. This study represents the collection and or-
ganization of a growing body of technical data. It served as the starting
point for development of the Standards and Guidelines.
2The directive is contained in §102 of the Hazardous and Solid Waste Amendments to
the Resource Conservation and Recovery Act (RCRA).
3The term "air toxics" describes all air pollutants that adversely affect human health
and that are not controlled under CAA §108-110 and §112. Some states have lists of
specific air toxics.
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2.2.3 Regulatory Approach
In 1987 EPA published[8] an assessment of MWC emissions and a notice
of intent to regulate these emissions under CAA §111. At that time the
major question confronting EPA was whether to regulate MWC emissions
under CAA §111 or §112. CAA §112, National Emission Standards for
Hazardous Air Pollutants, mandates the imposition of emission controls on
existing and new sources that emit certain pollutants found to be hazardous
to public health. CAA §111, Standards of Performance for New Stationary
Sources, mandates imposition of emission controls (new source performance
standards or NSPSs) on new sources that emit pollutants not specifically
listed as hazardous under §112, and mandates imposition of emission con-
trols (guidelines) on existing sources whenever (1) such sources would be
subject to an NSPS if the sources were new and (2) the pollutant of con-
cern is not regulated under CAA §108-110 or §112. Regulatory development
under §112 is more involved and time-consuming than it is under §111 be-
cause §112 requires rigorous documentation of health effects for the subject
hazardous pollutant(s). The regulatory development process under §111 is
different because §111 is not primarily focused on health effects, but more
broadly focused on welfare, cost, and other effects of regulation, as well
as on the health effects. EPA rejected §112 for use in controlling MWC
emissions because the diverse health effects of the MWC pollutants are too
small, for some pollutants, or too uncertain, for other pollutants, to justify
a §112 regulation, and because §112 cannot be used to regulate some of the
pollutants of concern, particularly lead and HC1. Regulation under §111 is
now proceeding under a schedule EPA published along with the notice of
options selection.
Although §111 does not place upon EPA the burden of justifying regu-
lations solely on health grounds, Executive Order 12291 does require some
examination of the health benefits of the regulation. This is discussed fur-
ther in Section 2.6.
2.2.4 Litigation
On August 5, 1986, the Natural Resources Defense Council (NRDC)
and the States of New York, Rhode Island, and Connecticut petitioned the
Administrator of EPA to regulate air emissions from MWCs under CAA
2-4
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§111 and §112 (New York et al. v. EPA [B.C.Circuit Nos. 87-1463 and 87-
1466]). As stated in Section 2.2.3, in 1987 EPA published an advance notice
of proposed rulemaking under CAA §lll(b) and (d) but not §112. Then,
in mid-1989, EPA and the petitioners in New York et al. v. EPA agreed to
stay the proceedings in that action pending the Administrator's signature
of the proposal by November 30, 1989, and signature of the final rule by
December 31, 1990. That is the schedule EPA currently is following for the
MWC rulemaking.
2.3 The Nature of CAA
Section 2.2.3 above is a brief sketch of why EPA elected to apply CAA
§111 to control MWC air emissions. A grasp of §111 is essential to under-
stand how EPA has structured regulation under §111, and why the regula-
tion is split into two components—the Standards and the Guidelines.4
CAA §111 Standards of Performance for New Stationary Sources di-
rects EPA to require polluters either to meet emission performance stan-
dards, or to follow design, equipment, work practice, or operational stan-
dards that will accomplish the same objective. The polluters of concern are
non-transportation related activities that individually or collectively emit
enough pollution to contribute significantly to ambient air pollution prob-
lems. These polluters are termed "stationary sources" and they range in
size from oil refineries and power plants on the one hand, to dry cleaners
and homes with wood-burning stoves on the other. Once on the books,
§111 regulations generally are delegated to the states for enforcement.
Most §111 regulations apply to sources that are constructed after the
regulations are proposed by EPA. These regulations are the NSPSs, which
EPA prepares under §lll(b). Over time some states adapt and apply the
emission requirements of NSPSs to existing sources. This latter process
may be accelerated by §lll(d), which directs EPA to adapt certain NSPSs
to the special problems of existing sources and to issue guidelines to the
states on how states should enforce the regulations for existing sources.
For MWCs, the NSPSs are termed "Standards" in this report, and the
«In addition to the Standards and Guidelines, EPA is pursuing separately another reg-
ulatory action applicable to MWC aii emissions. It relates only to emission test methods,
and is not discussed in this regulatory impact analysis.
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guidelines are termed "Guidelines."
CAA §lll(b) can be used only for pollutants that EPA has not listed
as hazardous under §112. (Currently there are eight hazardous pollutants,
another ten that EPA intends to list as hazardous, and many others that are
under study.) Often, as will be the case with the Standards and Guidelines,
a §111 regulation directed at sources of nonhazardous pollutants will, as a
side effect, also serve to control one or more hazardous pollutants. If a
nonhazardous pollutant to be controlled with §lll(b) NSPSs is not one
for which EPA has issued a national ambient air quality standard under
§108-110, the pollutant is called a "designated" pollutant. A designated
pollutant invokes §lll(d) and EPA issues §lll(d) guidelines. The net effect
of designating a pollutant is to use §111 for the control of new and existing
sources. There is no requirement that standards for new sources be the
same as those for existing sources. Indeed, in the case of the Standards and
Guidelines, they are different.
Except for certain situations not related to MWCs, §111 requires EPA
to issue performance standards. A performance standard is an emission
limitation or reduction
. . . achievable through application of the best technologi-
cal system of continuous emission reduction which (taking into
consideration the cost of achieving such emission reduction, any
nonair quality health and environmental impact and energy re-
quirements) the Administrator determines has been adequately
demonstrated.
Only when performance standards are infeasible may EPA promulgate de-
sign, equipment, work practice, or operational standards. §111 further
provides for the replacement of design, equipment, work practice, and oper-
ational standards as soon as performance standards become feasible, and in
certain other situations. While the Standards and Guidelines are predom-
inantly performance standards, they have work practice and operational
components.
CAA §111 regulations are subject to automatic review by EPA every
four years.
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2.4 Pending Legislation
A number of legislative actions that would affect municipal waste com-
bustion are being considered by Congress. The Congressional Office of
Technology Assessment (OTA) has summarized these potential actions in
Facing America's Trash: What Next for Municipal Solid Waste?, Interim
Summary, June 1989.[7] The OTA presents the options that Congress might
consider in addressing the various facets of MSW management issues.
Also in June 1989, a Senate bill (S. 1113) was introduced to amend the
Solid Waste Disposal Act (a forerunner of the Resource Conservation and
Recovery Act—RCRA). It includes provisions that would create CAA §129
"Municipal Waste Combustion." This new section would require EPA to
promulgate, within 18 months of enactment of S. 1113, NSPSs that would
apply to new and modified MWCs and MWCs beginning operation after
July 1, 1989 (unless they were substantially completed before that date).
The pollutants to be regulated and the levels of the emission limits and
other requirements that should be included in the NSPSs are specified in
the bill. Existing MWCs would be required to comply with the NSPS
within time schedules established by EPA but in no event later than four
years after promulgation of the NSPS.
2.5 Regulatory Initiatives Affecting MSW
Management
New regulatory initiatives affecting MSW management are being devel-
oped by EPA. The principal ones are described below. They all affect to
one degree or another the economics of MWCs, and all will complement
the Standards and Guidelines.
Revised RCRA Subtitle D Criteria. RCRA Subtitle D governs
the landfilling of nonhazardous wastes. Revised regulations were proposed
in August 1988; final promulgation is expected in December 1989. The
revised regulations affect the siting of MSW landfills and also require that
new landfills be designed with liners, leachate collection systems, and final
covers to protect ground water.
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Toxicity Characteristic Expansion and Modification of Lead
MCL. Modification of the lead MCL (maximum contaminant level) was
proposed in August 1988; final promulgation is expected early in 1990. The
Toxicity Characteristic expansion was proposed in June 1986, and promul-
gation is expected in 1989. These two rules will affect the classification of
solid wastes as hazardous or nonhazardous. They may result in classifying
lower concentrations of toxic substances, such as MWC ash, as hazardous,
thereby potentially increasing thfe amount of MWC ash that will have to
be disposed of under the more stringent Subtitle C of RCRA.
Superfund Municipal Settlement Policy. An interim policy is ex-
pected in late summer 1989. The policy focuses on the issue of how munic-
ipalities that are potentially responsible parties at Superfund sites should
be handled in the Superfund settlement process.
Municipal Solid Waste Landfill Air Emissions Regulations. With
proposal planned for summer 1990, these will take the same form as the
MWC Standards and Guidelines, and will complement the RCRA Subti-
tle D criteria. The standards may require a regulated landfill to install
a gas collection system that routes the gas to a control device capable of
achieving a 98 percent reduction in non-methane organics.
Municipal Waste Combustion Ash Disposal Regulations. The
timetable is uncertain. For MWC ash disposal, the draft regulation in-
cludes the following requirements for MSW landfills: (1) double liners with
leachate collection systems above and between them; (2) ground-water
monitoring; (3) development of criteria and testing procedures for iden-
tifying characteristics of ash that may pose a threat to human health and
the environment; and (4) closure requirements, post-closure care, corrective
action, and financial assurance for these activities.5
The initiatives and some of their potential impacts are summarized in
Table 2.1.
5For more discussion of MWC ash issues, see Section 7.1.2.
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Table 2.1: Impacts of Regulatory Initiatives in the MSW Area
Initiative
Impacts
Revised Subtitle D
Criteria
Toxicity Characteristic
Expansion
Superfund Municipal
Settlement Policy
MSW Landfill
Air Emissions
Regulations
MWC Ash Disposal
Regulations
Increased cost may induce a small shift away
from MSW landfills to MWCs, source reduction,
and recycling. Will increase cost of MSW land-
fills (ground-water monitoring, liner systems,
leachate collection systems, covers, potential cor-
rective actions).
Regulation of some MWC ash as hazardous may
encourage shift to source reduction, recycling,
and MSW landfilling. Will increase MSW land-
fill costs if leachate and gas condensate exhibit
high toxic characteristics. Will increase MWC
costs if ash exhibits toxic characteristics.
May encourage shift to MWC, source reduction,
and recycling to avoid liability. May increase
costs of MSW landfills.
May encourage shift from MSW landfills to other
technologies. Will increase MSW landfill cost by
requiring gas collection and control systems.
May increase MWC costs. Overall impact diffi-
cult to predict.
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2.6 Executive Order 12291
The President issued Executive Order 12291 in February 1981.[16] It
requires EPA to prepare regulatory impact analyses (RIAs) on all "major
regulations. An RIA describes the benefits and costs of proposed regula-
tions and explores alternative regulatory and non-regulatory approaches to
accomplishing the desired objectives.[11,15] A "major" regulation is one
that, among other things, may have an annual effect on the economy of
$100 million or more, and/or may result in a significant increase in prices.
The Standards and Guidelines each may have social costs to the nation in
excess of $100 million yearly, and each may result in significant increases
in tipping fees in a few local areas. Thus, EPA considers the Standards
and Guidelines to be major regulations and is issuing this RIA to explain
the myriad facts, figures, analyses, and considerations that have gone into
regulatory development.
In addition to asking for an analysis of benefits and costs, the Execu-
tive Order specifies that EPA, to the extent permitted (in this case) by the
Clean Air Act and court orders, demonstrate (1) that the benefits of the
Standards and Guidelines will outweigh the costs and (2) that net benefits
will be maximized. Chapter 12 describes the benefits. As explained in that
chapter, EPA cannot quantify some of the benefits at this time. Conse-
quently, EPA cannot demonstrate quantitatively that the benefits of the
Standards and Guidelines will outweigh the costs. Notwithstanding this
quantification problem, EPA has determined that CAA §111 requires is-
suance of the Standards and Guidelines at the level of stringency described
in the next chapter. For more elaboration on this point, see Chapter 13
and the Federal Register preambles6 to the Standards and Guidelines.
2.7 Guide to the References
Most of this regulatory impact analysis report is a summary of research
reports, analyses, correspondence, minutes of meetings and hearings, policy
directives, legal notices, laws, regulations, and other documents relating to
the development of CAA §111 regulations for MWCs. The principal refer-
9These preambles will accompany proposal of the Standards and Guidelines in the
Federal Register later this year.
*.
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ences are listed in the Bibliography at the end of this report. Consult these
references, as well as the preambles that accompany proposal of the Stan-
dards and Guidelines in the Federal Register, for more detailed information
on the Standards and Guidelines. All references are held in public dockets
and are available for inspection and copying during normal business hours.
Contact:
Air Docket (LE-131)
Room M-1500,
Waterside Mall
401 M Street, S.W.
Washington, B.C. 20460
Hours: 8:30 a.m. to noon, 1:30 to 3:30 p.m.
Phone (202) 382-7549
Refer to Docket A-89-08
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Chapter 3
The Standards and Guidelines
in Brief
3.1 Applicability
3.1.1 Standards
The Standards as proposed would apply to MWCs for which construc-
tion, modification, or reconstruction commences after the date of proposal.
An MWC is defined as a combustion facility used for burning MSW. MSW
is refuse, more than 50 percent of which is waste consisting of a mixture of
paper, wood, yard wastes, food wastes, plastics, leather, rubber, and other
combustible materials, and noncombustible materials such as glass, metal,
and rock. It includes household wastes as well as waste from institutional,
commercial, governmental, and some industrial sources, but does not in-
clude industrial process wastes, or infectious hospital or medical wastes.
MSW also includes refuse-derived fuel (RDF), which is solid waste that is
shredded, classified by size, and/or processed (by removing the noncom-
bustibles such as glass and metal) before combustion.
The Standards categorize new MWCs as large (located at plants with
an aggregate capacity to burn more than 225 Mg MSW per day) or small
(all others). The aggregate capacity of all new, modified, and reconstructed
MWCs at one plant site is used to define MWC plant capacity. New MWCs
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will be subject to the requirements for the size category of the plant they are
in. Units that commenced construction prior to proposal of the Standards
are considered to be existing MWCs and will not be included in measuring
aggregate capacity at a site for the Standards (but their aggregate capacity
is used to determine applicability of the Guidelines).1 Within the first five
years, the Standards are expected to apply to about 150 individual MWC
units located at about 65 different sites.
3.1.2 Guidelines
The Guidelines will be used by states to develop regulations to apply to
existing MWCs that commenced construction prior to the date of proposal.
They are classified as very large (located at plants with the capacity to
burn more than 2,000 Mg MSW per day)2 or large (aggregate capacity
to burn between 225 and 2,000 Mg MSW per day) or small (all others).
The aggregate capacity of all existing MWCs at one site is used to define
MWC plant capacity. Individual combustor units will be subject to the
requirements for the size category of the plant they are in. The Guidelines
will apply to about 450 individual MWC units located at about 180 different
MWC plants.
3.2 Emission Limits and Other Requirements
3.2.1 Standards
The Standards will limit emissions of a number of pollutants. See
Table 3.1. Most are what is termed "MWC emissions." Constituents
are categorized into three subclasses: MWC organics (including dioxins),
MWC metals (trace metals that are condensable on particulate matter),
and MWC acid gases (principally S02 and HC1). (The composite pollutant
"MWC emissions" also is designated for regulation under the Guidelines.)
1In this regulatory impact analysis, "MWC" means both a single combustor and all
combustors comprising one plant site. Where the distinction is important, as it is here in
defining large and small MWCs, it is made.
2 Only regulatory alternative HB' of the Guidelines distinguishes between very large
and large MWCs.
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Table 3.1: Summary of Emission Levels in Standards and Guidelines0
Pollutant
Standards
New MWCs
Guidelines
Existing MWCs
MWC
Organics
MWC Metals
MWC
Acid Gases
NOX
CO
CDD/CDF:
10 ng/Nm3 (large)
75 ng/Nm3 (small6)
250 ng/Nm3 (RDF6)
PM: 34 mg/dscm
10 percent opacity
HC1: 25 ppnav or 95 percent
reduction (large)
25 ppmv or 80 percent
reduction (small)
SOj: 30 ppmv or 85 percent
reduction (large)
30 ppmv or 50 percent
reduction (small)
150 ppmv and mercury limit
of 300 jzg/dscm (large)
50 to 150 ppmv
(depending on type of MWC)
CDD/CDF:
10 ng/Nm3 (very large)
125 ng/Nm3 (others0)
250 ng/Nm3 (RDFC)
PM: 34 mg/dscm (very large)
69 mg/dscm (others)
10 percent opacity (all)
HC1: 25 ppmv or 95 percent
reduction (very large)
25 ppmv or 50 percent
reduction (large)
None (small)
SO2: 30 ppmv or 85 percent
reduction (very large)
30 ppmv or 50 percent
reduction (large)
None (small)
None
50 to 150 ppmv
(depending on type of MWC)
a See the definitions beginning on page xv for a quick reference to the many terms
and abbreviations used here. This table summarizes only emission levels and does
not cover requirements relating to good combustion practices, operator training, and
materials separation.
b Small RDF MWCs (capacities less than 225 Mg/day) are allowed 250 ng/Nm3.
c "Other" RDF MWCs (capacities less that 2,000 Mg/day) are allowed 250 ng/Nm3.
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The Standards will establish emission limits to address the three subclasses
of pollutants, and operating standards to minimize formation of MWC or-
ganics. The Standards also will control nitrogen oxides (NOX)-
The following paragraphs summarize the emission limits and other re-
quirements of the Standards.
3.2.1.1 MWC Organics
A dioxin and furan (CDD/CDF) emission limit of 10 ng/Nm3 at 7 per-
cent O2 will be required at large MWCs, and 75 ng/Nm3 at small MWCs,
except that small RDF MWCs will have a limit of 250 ng/Nm3. These
limits apply to total tetra through octa CDD/CDF.
3.2.1.2 MWC Metals
All MWCs will have to limit emissions of particulate matter (PM) to
34 mg/dscm at 7 percent O2- This PM limit will ensure good control of
metals and is a more practical approach than setting individual limits for
every metal. Also required is a 10 percent opacity limit (6-minute average,
measured continuously).3
3.2.1.3 MWC Acid Gases
Large MWCs will be required to reduce HC1 emissions either by 95
percent or to a level not to exceed 25 ppmv, measured during a compliance
test and annual performance tests. Small MWCs will have to achieve either
an 80 percent reduction or a 25 ppmv HC1 emission level.
Large MWCs will be required to reduce SO<2 emissions by 85 percent or
to a level of 30 ppmv on a daily block4 24-hour average basis, measured con-
3A 10 percent opacity limit requires a smoke plume to be relatively transparent—in
this case so that there is no more than a 10 percent reduction of light intensity when a
beam of light traverses the center of a plume close to the top of a stack.
4When concentrations are averaged over time, block or rolling averages may be used.
For block averages, the time interval and beginning and ending times are defined ahead
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tinuously. Small MWCs will have to achieve either a 50 percent reduction
or a 30 ppmv S02 emission level.
3.2.1.4 Good Combustion Practice
Good combustion practice (GCP) in this case involves operating an
MWC within certain limits to ensure that MWC organics emissions are
minimized on a continuous basis. The operating parameters include CO
emission limits, combustor load levels, and flue gas temperatures.
CO emission limits will vary by type of MWC.5 The limit will be 50
ppmv for modular MWCs; 100 ppmv for mass burn waterwall, mass burn
refactory wall, and fluidized bed MWCs; and 150 ppmv for all other tech-
nologies.
MWCs will not be allowed to operate above 100 percent of maximum
rated capacity on a 1-hour average basis, as demonstrated during a com-
pliance test.
To minimize CDD/CDF formation and vaporization of metals, the Stan-
dards will require all MWCs to maintain a flue gas temperature of 230°C
or less, on a 4-hour block average, at the PM control device inlet.
3.2.1.5 ASME Certification and Operator Training
As a part of GCP, the Standards will require certification of the MWC
shift supervisor and chief facility operator by the American Society of Me-
chanical Engineers (ASME). Also, each MWC owner or operator will be
required to develop a site-specific training manual to be reviewed with all
employees associated with the operation of the MWC. The manual and
training must be updated annually.
of time, such as for 24-hour midnight-to-midnight averages; for rolling averages the time
interval and period of next calculation are defined ahead of time, such as for 30-day rolling
averages recalculated daily.
5See Chapter 7 for a description of the types of MWCs.
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3.2.1.6 Materials Separation
The Standards will require all MWCs to prepare, have approved, and
follow a plan for materials separation. The separation may be on-site me-
chanical separation, on-site manual sorting, a community materials sep-
aration program, or any combination of these procedures. MWCs must
demonstrate removal of one or more of the following materials: paper, pa-
perboard, metals (including appliances), glass, plastics, and household bat-
teries. On an annual average weight basis, these removed materials must
comprise at least 25 percent of the total MSW received at the MWC. (No
credit will be allowed for yard waste in excess of 10 percent of the total
MSW received.) An MWC will receive credit for materials separated off-
site, such as at the curbside, and such materials will be considered part
of the MSW received at the MWC for the purposes of calculating materi-
als separation requirements. Finally, MWCs must not combust lead-acid
vehicle batteries.
3.2.1.7 Nitrogen Oxides
Large MWCs will have to achieve a 150 ppmv NOx emission limit,
corrected to 7 percent 02 on a daily block 24-hour average basis. All MWCs
subject to the NOX standard will also be required to achieve a mercury
emission limit of 300 /ig/dscm. The mercury limit is included because
limited data indicate that there may be a link between NOX control and
a decrease in mercury emission reduction across a spray dryer-fabric filter
system.6
3.2.2 Guidelines
The pollutant to be regulated under the Guidelines is "MWC emis-
sions." NOX is not included. The constituents of MWC emissions are
discussed in the preceding section. The Guidelines are similar to the Stan-
dards in requirements with the main differences being the levels of the
emission limits and the MWC size categories to which the limits apply.
6See Chapter 5 for descriptions of control devices.
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Unless noted in the following paragraphs, the Guidelines' requirements are
the same as the Standards'. See Table 3.1.
3.2.2.1 MWC Organics
A CDD/CDF emission limit of 10 ng/Nm3 at 7 percent O2 will be
required at very large MWCs, and 125 ng/Nm3 at all other MWCs, except
that RDF MWCs with capacities less than 2,000 Mg/day will have a limit
of 250 ng/Nm3.
3.2.2.2 MWC Metals
The Guidelines will limit PM emissions to 34 mg/dscm at 7 percent O2
at very large MWCs, and to 69 mg/dscm at all other MWCs. Opacity will
be limited to 10 percent.
3.2.2.3 MWC Acid Gases
All very large MWCs will be required to reduce HC1 emissions either
by 95 percent or to a level of 25 ppmv. Large MWCs will have to achieve
either a 50 percent HC1 reduction or a 25 ppmv HC1 emission level. Small
MWCs are exempt from HC1 control.
All very large MWCs will be required to reduce S02 emissions either
by 85 percent or to a level of 30 ppmv. Large MWCs will have to achieve
either a 50 percent SO2 reduction or a 30 ppmv S02 emission level. Small
MWCs are exempt from SO2 control.
3.2.2.4 Good Combustion Practice
This is the same as for the Standards.
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3.2.2.5 ASME Certification and Operator Training
This is the same as for the Standards.
3.2.2.6 Materials Separation
This is the same as for the Standards.
3.3 Recordkeeping and Reporting
The recordkeeping and reporting requirements in the Standards are ba-
sically the same as those that will be imposed by the states under the
Guidelines. Owners and operators subject to the Standards will be re-
quired to submit a notification of the intent to construct and to initiate
operation of a new, modified, or reconstructed MWC. All MWC owners or
operators will be required to submit the results of the initial performance
test and performance evaluation of the continuous emission monitoring sys-
tem (GEMS).
The Standards and Guidelines will require quarterly reports of GEMS
drift tests and accuracy determinations, and reports of any periods when
the minimum data requirements for GEMS were not met. Other quarterly
reports that will be required are continuous compliance reports for SOa,
CO, opacity, and combustor operating parameters (load and temperature);
excess emission reports; and for the Standards, compliance reports for NOX-
Annual reports of compliance with the CDD/CDF, PM, and HC1 limits will
be required, except that MWCs that are allowed to skip annual compliance
tests would submit a simplified annual report. For the Standards, annual
reports of mercury emissions also will be required.
Records, including results of emission tests, GEMS data, and documen-
tation of employee training, must be maintained for two years and made
available to enforcement personnel upon request.
3-8
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Chapter 4
The Need for and
Consequences of
Regulatory Action
4.1 The Problem
Americans produce more and more solid waste each year; on a per
capita basis, ihi.s country is among the top four producers of MSW. The
yearly MSW generation rate has increased from 1960 to 1988 both in the
total amount and in the per capita contribution. The rate is expected to
continue to grow from a rate of 145 million Mg per year in 1988 to about 170
million Mg per year in the year 2000. To put it in a personal perspective,
each of us contributes an average of 590 kg a year to the growing mountain
of garbage. In 1960, Americans generated waste at a rate of 1.20 kg per
person per day; by 1986, that figure had jumped to 1.62 kg, and if this
trend continues the projected rate in 2000 is 1.78 kg per day. This 1.78 kg
averages out to 4.4 kg per household per day. About one-half will come
from households themselves, with the other half coming from commercial
and other generators of MSW associated with our lifestyle.
MSW consists of all the major materials used in the modern industrial
state. Table 4.1 presents estimated quantities and shares of these materi-
als. Paper and paperboard products comprise over 35 percent of the total.
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Table 4.1: Materials in the Municipal Waste Stream0
1986
Materials
Paper and Paperboard
Yard Wastes
Metals
Food Wastes
Glass
Plastics
Wood
Rubber and Leather
Textiles
Miscellaneous Wastes
TOTAL
106Mg
45.6
25.8
11.5
11.4
10.7
9.4
5.3
3.5
2.5
2.5
128.1
Percent
35.6
20.1
8.9
8.9
8.4
7.3
4.1
2.8
2.0
1.8
100.0
a The composition of MSW varies widely from locality to locality.
Published reports are inconsistent in their estimates of the compo-
sition.
Glass, metals and plastics are each about one-fifth to one-quarter of the
paper and paperboard amount. Yard waste, for example, grass clippings,
tree trimmings, and leaves, represent the second largest portion of MSW—
about 20 percent.
We are having a very difficult time finding places to put our waste. Old
landfills are filling up and closing rapidly. New solid waste facilities are
difficult to site because of public resistance, commonly known as the "Not
In My Backyard" (NIMBY) syndrome. Public resistance is not limited to
landfills and combustors as even materials recovery facilities and recycling
centers can be difficult to site. Nevertheless, landfills and combustors will
still be necessary for the foreseeable future to handle a significant portion
of wastes; but because of their potential harm to human health and the
environment, and their long-term management costs, landfills and combus-
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tors will be supplemented increasingly with recycling and source reduction.
Problems with MWCs can be minimized through good design and manage-
ment.
Combustion of municipal waste is an attractive waste management op-
tion as it reduces the volume of waste by 70 to 90 percent. This translates
into substantial extensions of the lifetimes of existing and future landfills.
In the face of shrinking landfill availability, municipal waste combustion
capacity in the U.S. is expected to grow rapidly, from the current U.S. ca-
pacity of 41,000 Mg per day to somewhere in the range of 105,000 to 230,000
Mg per day by the year 2000. As of early 1987, 111 MWC facilities existed
in the U.S. and over 200 facilities were planned or under construction.
Direct landfilling accounts for the disposal of about 80% by weight of
waste collected. About 10% of the waste collected in the U.S. was com-
busted in 1988 and 10% was recovered for recycling. Though direct landfill-
ing currently predominates as the method of MSW disposal, it is becoming
less attractive. There has been an increased recognition of the environmen-
tal damage associated with MSW landfills such as leachate contamination of
groundwater and emissions of toxic air pollutants, not to mention unpleas-
ant odors, noise, litter, truck traffic, and depressed land values. Although
health concerns are often cited by the opponents of waste-to-energy facili-
ties, air pollution emissions from MSW landfills-—not from ash landfills—
also represent a public health problem. EPA estimates that 138,000 Mg of
landfill gas are emitted annually, and that number is climbing rapidly. Over
100 specific compounds have been detected in the gas; 11 are carcinogens
and 12 others are the bearers of other adverse health effects. Landfill gas
is one-half methane, a greenhouse gas comparable to the carbon dioxide
(COa) produced by MWCs. Subsurface migration of methane accounts for
28 documented incidences of explosion or fire resulting in 9 deaths and 21
injuries.1
The concerns about potential threats to human health and the environ-
ment from MWCs are due to combustor emissions and ash. Pollutants emit-
ted from MWCs are MWC organics (dioxins and furans, labeled CDD/CDF
in this report, and other products of incomplete combustion), MWC metals
lBy mid-1990 EPA expects to propose air pollution emission standards and guidelines
for landfills. Further information on these standards and guidelines, and on landfills in
general, can be found in EPA Docket A-88-09. See Section 2.7 above on accessing the
docket.
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(mostly trace metals, such as lead, cadmium, and mercury, all of which are
condensable on particulate matter), MWC acid gases (SO2, HC1, and to a
lesser extent, HF), nitrogen oxides (NOX, which also is an acid gas), carbon
monoxide (CO), and particulate matter (PM). C02, a greenhouse gas, is
also emitted, but is not being addressed by the Standards and Guidelines.
The trace organic compounds and all trace metals (except mercury) are
known or suspected carcinogens. Section 4.2.4 provides more detail on the
health risks of these pollutants.
4.2 Need for Regulation
4.2.1 Market Failure
The U.S. Office of Management and Budget (OMB) directs[15] regula-
tory agencies to demonstrate the need for a major rule. The regulatory
impact analysis must show that a market failure exists and that it cannot
be resolved by measures other than Federal regulation. Market failures
are categorized by OMB as externality, natural monopoly, or inadequate
information. The latter includes situations where there may be a need for
controls on entry into employment. The following paragraphs address the
three categories of market failure.
4.2.1.1 Air Pollution as an Externality
Air pollution is an example of a phenomenon called a "negative exter-
nality." This means that, in the absence of government regulation, market
systems fail to make the generators of air pollution pay for the costs asso-
ciated with that pollution. For an MWC operator, pollution is an unusable
by-product that can be disposed of cheaply by venting it to the atmosphere.
Left to their own devices, probably most MWC operators would treat air-
sheds as free goods and would not "internalize" the damage caused by
emissions. This damage carries a very hefty price tag, and the receptors—
the people who are the ones adversely affected by the pollution—are not
able to collect compensation to offset their costs. They cannot collect com-
pensation because the adverse effects, like materials damage and increased
risks of morbidity and mortality, are by and large, non-market goods, that
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is, goods that are not explicitly and routinely traded in organized free
markets.2
Consider an example. It may be somewhat unreal, but it illustrates
why air pollution is a market externality. A young man estimates that
over his remaining lifetime he has a risk of getting cancer of, let's say, 4
chances in 100. A new MWC is being built in his neighborhood, and he
pessimistically calculates that the added pollution to his own environment
will boost his odds of getting cancer to, say, 5 chances in 100. He walks
up to the people building the MWC and offers to "sell his exposure" to the
MWC's air pollution for a bargain basement price of just $5 a day. For
his efforts he gets no more than a laugh. What's wrong? Most young men
either would be unwilling to even consider such a transaction, or, if they
were willing, they would not know enough about their futures and about
the effects of the pollution to set such a precise price. Furthermore, even if
they were willing and did have a price, they would not have the any good
way of coming to terms with the MWC builders.3 The builders have no
incentive to pay anything to the receptors of the air pollution. No incentive,
that is, unless government requires them to pay or to reduce the pollution.
How would it help to force MWCs either to compensate the people
suffering the consequences of the pollution, or simply to reduce the pollu-
tion? Where there are negative externalities like air pollution, the market
price of goods and services does not reflect the costs, borne by receptors of
air pollution, generated in the course of producing the goods and services.
Government regulation can be used to improve the situation. The Stan-
dards and Guidelines will force MWC owners and operators to reduce the
air pollution they emit. With the Standards and Guidelines in effect, what
MWC owners and operators must spend to combust MSW will more closely
approximate the full social costs of combustion. In the long run, MWCs
will be forced to collect in tipping fees and subsidies sufficient money to
cover total combustion costs. Thus, tipping fees and subsidies will rise,
communities accordingly will reduce their demand for combustion service,
and hence less combustion service will be provided. The more the costs
of pollution are internalized by the MWCs, the greater the improvement
in the way the local MSW disposal market functions. If we could inter-
nalize all negative externalities—including, of course, those from landfilling
2Litigation also is a possible route for collecting compensation, but it is slow and
uncertain, and it may backfire.
3Again, litigation would be a possible route.
4-5
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MSW—society's allocation of resources would be improved.
4.2.1.2 Natural Monopoly
Local disposal markets are "natural" monopolies. There are large econ-
omies of scale in disposal operations; the heavy up-front capital needed to
site and build a combustor acts as a barrier to entry; and in most situa-
tions transportation costs have been too high to ship MSW among regions
for disposal. Unfortunately, the monopolistic (or oligopolistic) local mar-
kets that result from these natural conditions do not have the competitive
market checks and balances that are needed to ensure the best utilization
of society's resources. The Standards and Guidelines are not designed to
address this problem, and will not reduce the tendency of local disposal
markets toward monopoly or oligopoly.4
4.2.1.3 Inadequate Information
The third category of potential market failure that sometimes is used to
justify government regulation is inadequate information. In one key aspect
this imperfection exists in the MWC industry, and justifies one small, but
important, part of the Standards and Guidelines regulatory package.
Some MWCs have not acquired enough workers who have adequate
knowledge of the proper operation of the MWC. Operator training and
certification, which are measures to correct this situation, will improve
the expertise of MWC workers. The existence of both pollution preven-
tion technology and a regulatory mandate (including penalties) to use that
technology does not, by itself, guarantee its use if employees do not have
the skills and motivation needed to apply the technology. For this reason,
and the judgment that operator training and certification in the control
of MWC emissions will make a significant difference, EPA believes MWC
operator training and certification are necessary components of the overall
job of managing this country's air resources.
4Federal legislation on interstate MSW disposal compacts and interstate shipping of
MSW may be proposed to address this problem. Such a proposal is not part of the
Standards and Guidelines.
4-6
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What does operator training and certification involve? Proper operation
of combustors is key to good combustion practice (GCP) and, therefore, is
important to the reduction of organic emissions. Operation of MWCs is
complex, and there are many interrelated parameters that influence emis-
sions. The Standards and Guidelines specify limits for such things as tem-
perature and emissions. Operator training and certification is needed to
go "the extra mile"—to ensure that those who operate MWCs understand
the combustion process and can implement GCP continuously. Thus, the
Standards and Guidelines require (1) certification of the shift supervisor
and chief facility operator by the American Society of Mechanical Engi-
neers, and (2) the development by each MWC owner and operator of a
site-specific training manual for the training of all other employees associ-
ated with the operation of the MWC. These other employees include control
room operators, ash handlers, maintenance personnel, and crane operators.
There are other ways inadequate information could manifest itself. EPA
does not argue that government intervention under the Clean Air Act is
needed to provide households with information on how to find products that
minimize the volume and toxicity of the products' resultant contributions
to MSW, how to generate less waste, how to recycle what can be recycled,
and how to dispose of what is left in a pollution-free manner. This kind of
information flow will help people make wise consumption choices and MSW
disposal choices, and may reduce the fear reflected in NIMBY political
pressure. See Section 6.2.2 below. However, no part of the Standards and
Guidelines is being justified on this aspect of the inadequate information
category of market failure.
4.2.2 Price Instability
Price instability in the markets for recycled materials hinders the de-
velopment of recycling as a vehicle for controlling MWC emissions. Price
instability is not a market failure. The Standards and Guidelines will not
correct it. EPA's requirement that municipalities separate out selected
items before MSW is combusted means that separation costs need not be
considered in deciding whether to recycle or landfill the items. Municipal-
ities therefore will be more willing, but not necessarily happy, to recycle
when the market price for recyclables is low. Thus, the Standards and
Guidelines do not address price instability that indirectly causes higher
4-7
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MWC emissions by hindering recycling, but do counteract the depressing
effects of price instability on recycling.
The circumstances that give rise to price instability are many and di-
verse. Although the demand for goods and services produced from recycled
materials is reasonably firm, the number and type of plants that can pro-
cess recycled materials is small (but growing). This means that a single
plant shutdown or similar event can trigger fluctuations in prices for recy-
cled material. On the supply side, there are numerous independent, small
public and private suppliers of recycled materials. Their resource base,
MSW, exists in abundance regardless of the prices for recycled materials.
Recyclers have no good information base for forecasting prices. Many re-
cyclers are in the market as much for ecological and political reasons as for
economic reasons. The list goes on. Current market conditions illustrate
this instability. In 1989 recyclers in some local areas have been turning
out old newspapers, mixed papers, mixed plastics, used oil, tires, compost,
and ferrous scrap other than tin cans, in greater quantity than buyers are
willing to absorb at a positive price. At the same time, in almost all local
areas prices for old corrugated containers, office papers, single-resin plastics,
glass, tin cans, and aluminum have been climbing.[7] Next year everything
may be reversed. Sometimes oversupplied material is landfilled. In some
respects the market for recycled materials resembles the market for farm
commodities, where over- and under-supply is common.
4.2.3 Insufficient Political and Judicial Forces
Local NIMBY politics has forced some state and local governments, on
their own initiatives, to control MWC emissions, but such efforts have been
spotty. More often than not, NIMBY politics forces state and local gov-
ernments into inaction on MWC siting applications.5 One coherent and
comprehensive approach to emission control (and hence to siting) is needed
for the entire country. The piecemeal approach creates problems when
pollution from a laxly-controlled MWC blows across state lines. It ren-
ders compliance by multi-state waste disposal firms that build and operate
MWCs frustratingly difficult.
5 Language sometimes tells it all. Just as citizens and landowners striving to block
the siting of an MWC have adopted "NIMBY" as their rallying cry, elected officials have
adopted another to signify their desire to avoid siting controversy. It is unpronouncable
but it tells the story: "NDMT"—not during my term! '
4-8
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Citizens, as well as EPA, may sue state and local governments to force
them to control MWC emissions. Litigation under both the CAA and
RCRA is possible. However, such an approach is as piecemeal as is re-
liance on independent action by state and local government. Furthermore,
litigation is expensive and chancy in comparison to direct regulation.
4.2.4 Harmful Effects of MWC Emissions
Health effects associated with municipal waste combustors come from
two areas: air emissions and leachate from landfills that dispose of MWC
ash residue. Leachate currently is controlled under RCRA Subtitle D, which
requires liners for ash landfills along with leachate collection and monitoring
systems. Only the problems due to air emissions are addressed in these
Standards and Guidelines.6 Exposure to air emissions can occur through
inhalation, soil ingestion, the food chain, and dermal contact.
As mentioned in Section 4.1, pollutants that are emitted from MWCs
include MWC organics, MWC metals, MWC acid gases, NOX, CO, and
PM. Table 4.2 lists some of these pollutants. To the credit of MWCs,
combustion destroys pathogens and some harmful organics that otherwise
might find their way to receptors.
Table 4.3 is a summary of the health and welfare effects of the pollutants
that are emitted. Many of the pollutants are known or suspected to cause
cancer (refer to Table 4.3). The acid gases (S02, HC1, HF) and NOX have
adverse health effects, contribute to acid rain, and can cause soiling and
materials damage. PM, NOX, and SO2 contribute to reduced visibility.
Exposure to lead and mercury emissions can result in adverse noncancer
health effects. C02 is of concern as a greenhouse gas. Welfare effects not
listed in Table 4.3 include odor from unburned trash, truck traffic, and
noise.
Combinations of various pollutants may have synergistic effects. Fortu-
nately, most of the pollutants can be substantially reduced or eliminated
with materials separation, good combustion practice, and air pollution con-
trol devices.
6See Section 7.1.2 for further discussion of the ash problem. Fugitive dust from ash
piles is yet another problem, but this fugitive dust is not treated here as air emissions.
4-9
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Table 4.3: Some Health and Welfare Effects of MWC Emissions
• MWC Organics
— Mortality, morbidity
— The following are carcinogens:
* Arsenic
* Beryllium
* Cadmium
* Chromium*6
* Nickel
* 2,3,7,8-tetrachloro-
dibenzo-p-dioxin
* Benzene
* Benzo-a-pyrene
* Hexachlorobenzene
* Trichlorophenol
* Polychlorinated biphenyls
* Formaldehyde
• MWC Metals
— Lead
* Retardation and brain
damage, especially in chil-
dren
* Hypertension
— Mercury
* Central nervous system
injury
* Renal dysfunction
• MWC Acid Gases
- Hydrogen Chloride
* Materials damage
* Dental erosion
* Acid rain
• MWC Acid Gases
(Continued)
— Sulfur Dioxide
* Mortality,
morbidity
* Respiratory tract
problems, perma-
nent harm to lung
* Soiling and mate-
rials damage
* Acid rain
* Reduced
agricultural yield
• Nitrogen Oxides
— Ozone formation
— Acid rain
— NC>2: respiratory
illness and lung disease
• Carbon Monoxide
— Cardiovascular, ner-
vous, and pulmonary
systems effects
- Reduced exercise
capacity
• Particulate Matter
— Mortality, morbidity
- Eye and throat irrita-
tion, bronchitis, lung
damage
— Impaired visibility
— Soiling and materials
damage
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4.3 Consequences of Regulation
4.3.1 Consequences if EPA's Emission Reduction
Objectives are Met
Allocation of Resources. There will be improved allocation of re-
sources in the MSW combustion market. Specifically, more of the costs
of the harmful effects of MSW combustion will be internalized by MWCs.
This, in turn, will affect municipalities' decisions on whether, how, and
how much to combust. To the extent these newly-internalized costs are
then passed along to the people who generate the MSW, and to the extent
these people are free to buy as much or as little combustion service as they
wish, they will purchase less (relative to their purchases of other competing
services). If this same process of internalizing negative externalities occurs
throughout the entire MSW generation and disposal "industry," so that
packaging manufacturers, landfill operators, recyclers, and the like, are all
affected, an economically optimal situation is approached. This is the situ-
ation when the marginal cost of resources devoted to MSW disposal equals
the marginal value of the disposal to the people who are trying to get rid
of the MSW. There are many "ifs" in this chain of events. It is easy to cite
situations where the air pollution control costs will not ripple through as
suggested here and affect decisions by the generators of MSW. Neverthe-
less, in the aggregate and in the long run, the Standards and Guidelines
will move society toward this economically optimal situation.
Emissions Reductions and Air Quality. Emissions of air pollutants
will be reduced. (See Chapter 10.) Air quality will improve. (This analysis
does not translate emission reductions into ambient air quality improve-
ments. However, estimates of air quality improvement are intrinsic to the
benefits analysis. See Chapter 12.)
Costs and Benefits. The national annual cost of emission control
will increase by about $500 million by 1994. Benefits EPA can quantify
and express in monetary terms will exceed $100 million annually for the
nation. These benefits include reductions in some morbidity and mortality
associated with direct inhalation of the pollutants. However, EPA has not
quantified several types of benefits. (See Chapters 10 and 12.)
Energy. A small increase in energy to operate control equipment will
4-12
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be needed. Most MWCs will produce steam that will be used to produce
electricity for sale. The power demand to operate the pollution control
equipment will be less than 3 percent of the electricity an average MWC
generates. In total, the Standards and Guidelines are expected to require
about 650,000 MWh per year, which represents about 25 percent of the
power output of one typical power plant, plus about 820 TJ of natural gas
per year, by 1994.7
H
Water Quality. No significant water pollution impacts are projected
because none of the emission controls on which the Standards and Guide-
lines are based produces a wastewater stream. The potential increased
toxicity of fly ash will not affect ground or surface water because RCRA
Subtitle D regulations (possibly as modified by pending legislation) will
require landfill liners and leachate collection systems where fly ash is land-
filled.
Solid Waste. Solid waste impacts will be minimal. GCP tends to
reduce the generation of ash, but acid gas control will increase it. Overall,
MWC ash generation will increase in mass about 4 percent for existing
MWCs, and about 11 percent for new MWCs. This translates into an
additional 663,000 Mg ash per year by 1994.8 This amount is trivial in
comparison with the 70 to 90 percent MSW volume reduction accomplished
by combustion. In addition to the reducing effect of GCP on ash, materials
separation is likely to further reduce by half ash generation per Mg of MSW
combusted. However, the net impact of materials separation is uncertain
because some separated material may be landfilled.
Source Reduction and Recycling. Political and consumer pres-
sure for source reduction measures (Section 5.2) will increase. Recycling
(Section 5.3) will increase. Once recyclable materials are separated from
combustor feed, there will be an economic incentive to find markets for
them. Such markets exist now on a national scale, and many exist even in
small municipalities. New markets will be created.
Technological Innovation. CAA §111 regulations serve to dissemi-
nate both pollution control and combustion technology, and to stimulate
further technological development. MWC builders have the freedom to seek
7Data are based on the assumption that the Standards and Guidelines will not alter
municipalities' plans to retain and/or build MWCs. This is the no-substitution scenario
and is described in Chapter 9.
8Footnote 7 also applies to these data.
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the most economical way to comply with performance standards. The Stan-
dards and Guidelines may promote the sharing of combustion technology
with Europe and Japan, and probably will open new directions of research
in FBC technology.
Public Awareness. The fact that MWCs will cost more will heighten
public awareness of the MSW disposal problem, and will increase the pub-
lic's acceptance of source reduction and recycling measures.
State Regulation and New Source Review. State regulatory pro-
grams will be strengthened. The Standards and Guidelines will be dele-
gated to the states for enforcement. Assuming states do not pull resources
from other programs to handle their enlarged responsibilities, there will
be a natural strengthening of state air pollution control staffs. Recogni-
tion that the Standards and Guidelines are effectively reducing emissions
will expedite the state process of reviewing applications for new MWCs
and issuing permits for their construction and operation. There will be
less controversy involved. Finally, state regulations will be uniform, and
the disadvantages of the piecemeal approach to emission regulation will be
avoided.
Miscellaneous. For the most part, the potential consequences listed
above are reasonably unambiguous. The following are notes on potential
consequences where impacts are less clear.
Substitution. EPA conducted a limited analysis of how the Stan-
dards and Guidelines might affect municipalities' MSW disposal de-
cisions. The Guidelines will have relatively little impact on existing
MWCs. In a few instances some older MWCs may be closed to avoid
the cost of retrofitting air pollution control devices. The Standards
will cause some shift away from RDF and mass burn MWCs. Also,
the overall construction rate for MWCs may decline slightly from
what it would be if there were to be no regulation. These effects
are heavily caveated, and do not consider some upcoming regulatory
costs for landfills. How municipalities choose among MSW disposal
technologies is changing rapidly. See Chapters 9 and 10.
Regionalization. There may be increased economies of scale for
MWCs. Historically, municipalities have found that the bigger you
build an individual combustor of any particular type (mass burn,
modular, etc.), the cheaper it will be to combust each Mg of MSW.
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With the Standards and Guidelines in force, this will be even more
true. Where municipalities' selections of minimum combustor size
and technology are not influenced by the Standards and Guidelines,
municipalities will feel these added economies of scale and may seek
ways to capitalize on them by building larger MWCs. Thus, local gov-
ernments in some metropolitan regions may have more incentive to
join together in regional authorities that can build and operate large
MWCs. There may be more regionalization of MSW disposal activi-
ties. However, where municipalities' selections of minimum combustor
size and technology are influenced by the Standards and Guidelines,
there may be no additional push toward regionalization of disposal
services. For one thing, some municipalities may downsize new MWCs
as a result of materials separation requirements and possibly, if the
planned MWC size is in the 225 to 300 Mg range, to avoid installa-
tion of best (instead of good) acid gas control.9 For another thing,
some municipalities may switch from a technology with high returns
to scale, such as mass burn, to another with lower returns, such as
modular.
Industry growth. The growth of the MWC industry—MSW
throughput, capacity, capacity utilization, jobs, market share, rev-
enue, etc.—may get a boost from the Standards and Guidelines if
cleaner MWC operations improve the public's acceptance of combus-
tion. On the other side, the cost of air pollution control could depress
MWC industry growth. See the discussion of substitution in Chap-
ters 9 and 10.
Landfill Utilization. The utilization of landfill capacity may
improve if the Standards and Guidelines stimulate the construction
of new MWCs. On the other hand, the utilization of landfill capacity
may worsen if fewer MWCs are built or if MWC ash disposal requires
extra-wide buffer strips, extra soil cover, or extra-safe sites compared
to what is required for "ordinary" RCRA Subtitle D landfills.
Distributional Impacts. The way Americans pay for MSW
disposal, and therefore which firms, municipalities, waste generators,
or other groups will end up paying, may change. EPA has studied
what the distribution of costs would be if households had to pay
everything, and alternatively, if local governments (taxpayers) had
to pay everything. See Chapter 11. However, this analysis does not
9See Chapter 6 for an explanation of "best" and "good" acid gas control.
4-15
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reveal how private firms, consumers, and governments will share the
final burden "after the dust settles."
Other Federal Programs. The effects of the Standards and
Guidelines on other Federal regulatory programs have not been in-
vestigated. These programs include those of the Occupational Safety
and Health Administration, and various EPA activities relating to
the Superfund, to pesticide control, and to treatment of wastes not
covered by RCRA Subtitle D.
4.3.2 Consequences if EPA's Emission Reduction
Objectives are not Met
The most obvious consequence of failure to meet EPA's emission reduc-
tion objectives would be more delays and controversy in the siting and per-
mitting of new MWCs. Another consequence would be the need to revisit
the nation's goals set forth in An Agenda for Action, because the Standards
and Guidelines are key segments of the road to the environmentally sound
MSW disposal practices described in that report.
Poor compliance would result in both emissions reductions and benefits
that are not as large as EPA is projecting. However, costs are not likely to
be as large either. Whether it is noncompliance from ignorance or error, or
from willful intent, or simply slow compliance due to municipalities exer-
cising legal delays, poor compliance can save some MWCs money. Unless
states respond by pouring more resources into enforcement, then poor com-
pliance could bring with it smaller aggregate nationwide control costs. EPA
has not included an allowance for poor compliance in its estimates of emis-
sions reductions. This is because the potential effects of poor compliance
are expected to be minor.
If APCDs degraded rapidly over time or in some other way did not
function as expected, there could be a misallocation of resources. This
situation is very unlikely because the Standards and Guidelines are based
on demonstrated technology. Other ways the regulations could fail are
conceivable. Perhaps some new substance is added to MSW that defeats
APCDs, or future research will reveal that EPA decided to control the
wrong set of pollutants.
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The Clean Air Act provides a remedy for all the above situations,
namely, an automatic review of §lll(b) regulations at least every four years.
Although the automatic review provision is directed only to NSPSs, other
provisions of the Act ensure that noncompliance with the Guidelines would
trigger review and revision of those Guidelines.
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Chapter 5
Control Techniques
5.1 Integrated Waste Management
Integrated waste management[14], like motherhood and apple pie, is
something anyone would support. Unfortunately, until recently ignorance,
not opposition, kept integrated waste management from widespread accep-
tance and use. Not until the current MSW crisis hitched a ride into our
collective consciousness aboard the ill-fated 1987 "garbage barge" have so
many communities recognized the need for a coordinated attack on all as-
pects of the MSW dilemma. As explained above in Section 2.1, integrated
waste management calls for the complementary use of source reduction, re-
cycling, combustion, and landfilling to safely, economically, and effectively
handle MSW with the least adverse impact on human health and the en-
vironment. The goal set by EPA for the nation is to have 25 percent of
the MSW stream diverted by source reduction and recycling by 1992 (up
from just under 10 percent in 1988). Also in the nation's goal: 55 percent
landfilling (down from 80 percent) and 20 percent combusting (up from
slightly over 10 percent). The emphasis on increased source reduction and
recycling ties in with a broader EPA goal of pollution prevention, a goal
the Agency is applying to all types and sources of pollution. EPA believes
that responsibility for meeting MSW goals lies with all of us: producers,
consumers, waste management companies, processors and handlers of sec-
5-1
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ondary materials, and all levels of government.1
The next two sections of this chapter discuss source reduction, materials
separation, and recycling. These components of integrated waste manage-
ment are key to the successful planning and operation of MWCs. However,
except for prohibitions of the burning of selected items, these components
are largely, but not completely, outside the scope of CAA §111 regulation.
Sections 5.4 and 5.5 address control techniques that are the traditional sub-
jects of CAA §111 regulation. The concluding section explores the question
of why our existing economic, political, and legal institutions will not be
able to ensure full application of the control techniques in the absence of
further EPA regulation.
5.2 Source Reduction
Source reduction is a set of strategies relating to the design, manu-
facture, packaging, and use of products so as to reduce the quantity and
toxicity of MSW. It is a part of EPA's national strategy for solid waste
and will be encouraged, but not required, by the Standards and Guidelines.
Its advantages include not just reduced MWC emissions, but lower MSW
disposal costs, and conservation of resources (materials, energy, and land).
Source reduction is the job of consumers, producers, and governments
alike. They can purchase, patronize, and/or use
t Cloth diapers instead of disposable diapers (A staggering 18 billion
of them every year clog our combustors and landfills!),
• Paper bags instead of plastic bags,
• Photocopiers that print on both sides,
• Restaurants that do not use plastic utensils and food containers,
1 EPA's goals for integrated waste management include encouragement of cooperation
among local governments, but do not addiess directly the potential tegionalization of MSW
disposal services. In this regard, the Standards and Guidelines may provide positive eco-
nomic incentive for local governments to go in together if they are considering combustion
of MSW. This is because the cost of emission control per Mg of MSW combusted generally
is smaller for large MWCs than it is for small MWCs.
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• Fewer battery-operated products,
• Degradable products and longer-lasting products (such as degradable
plastics and radial auto tires), and
• Fewer pesticides and organic solvents.
Producers must not wait for regulations that will internalize into production
costs the social costs of disposing of products after they have outlived their
usefulness. The producers' job right now is to design and use packages that
will reduce the resources needed to dispose of used packages, and to pro-
duce products and packages that are degradable, recyclable, and/or more
durable, and are less toxic. Government's role is to encourage research,
provide market incentives, educate, and where all else fails, regulate—all
with source reduction and recycling as goals.
Source reduction affects combustion in the same manner as does recy-
cling. These effects are discussed in the next section.
5.3 Materials Separation and Recycling
Materials separation and recycling involve the removal, processing, and
possible reuse or marketing of glass, metals, paper, and other materials in
the solid waste stream. Materials separation and recycling may be done
by the waste generator on site, or by a service entity at a central site,
which may be a transfer station, the MWC site, the landfill site, or a
site specifically devoted to materials separation and recycling. Recycling
includes composting, but usually is not considered to include the recovery
of electricity and steam from the combustion of MSW, the recovery of useful
or marketable products from MWC ash, or the recovery of landfill gas.2
2There is no generally accepted definition of recycling, or clear distinction between
source reduction and recycling. Some measures, such as container deposit laws, seem to
fall in both categories. On the other hand, some activities seem to fall in neither category.
For example, some call the generation of steam and electricity resource recovery. EPA uses
the term "materials separation" here to focus attention on actions that could be required
under CAA §111 to preclude the introduction into combustors of items, like lead-acid
batteries, that produce undue pollution when heated or combusted, and items that hinder
good combustion.
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Source reduction and recycling occasionally are in conflict with one an-
other. For example, plastic food containers have less weight and volume
than equivalent glass containers, and therefore switching to plastic can be
considered a source reduction measure. However, in many cases glass is
more readily recycled than is plastic.
The Standards will require all MWCs to prepare, have approved, and
follow a plan for materials separation. The separation may be on-site me-
chanical separation, on-site manual sorting, a community materials sep-
aration program, or any combination of these procedures. MWCs must
demonstrate removal of one or more of the following materials: paper, pa-
perboard, metals (including appliances), glass, plastics, and household bat-
teries. On an annual average weight basis, these removed materials must
comprise at least 25 percent of the total MSW received at the MWC. (No
credit will be allowed for yard waste in excess of 10 percent of the total
MSW received.) An MWC will receive credit for materials separated off-
site, such as at the curbside, and such materials will be considered part
of the MSW received at the MWC for the purposes of calculating materi-
als separation requirements. Finally, MWCs must not combust lead-acid
vehicle batteries.
Materials separation will reduce MWC emissions in two ways. First, the
country will not need as much MWC capacity as it would without significant
materials separation.3 If less MSW is burned, MWC emissions will be
reduced. Second, preventing the heating or combusting of the materials to
be separated will reduce emissions from the remaining MSW. Examples of
expected emission reductions:
• MWC Organics
— From yard wastes containing pesticides and chemical products
• MWC Metals
— Lead from lead-acid batteries, lead-based inks on paper, lead
solder and lead plating on ferrous metals, lead-containing glass,
and lead-containing stabilizers in plastics and pigments
— Mercury from fungicides in paper
3The effect of materials separation on the utilization of combustion for disposal of MSW
has not been analyzed. See Section 8.2.
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— Zinc and cadmium from plating on ferrous metals
— Cadmium from stabilizers in plastics and pigments
• MWC Acid Gases
— S02 from sulfur-laden paperboard
— HC1 from chlorine-bleached paper and polyvinyl chloride plastics
. NOX
— From nitrogen in yard wastes
Materials separation will indirectly contribute to emission reductions
elsewhere in the economy by
• Improving energy recovery efficiency at MWCs so that there can be
less reliance on fossil fuel power generation, and
• Reducing energy requirements for extracting and processing virgin
materials.
If materials separation requirements are placed on MWCs but not on all
sizes of landfills, and if materials separation proves to be more costly than
EPA anticipates it will be, then materials separation requirements may have
the perverse effect of increasing landfill air emissions. This would happen
because municipalities would divert MSW from combustors to landfills to
avoid materials separation costs.
Source reduction, materials separation, and recycling may alter the cost
effectiveness of APCDs. There are two separate effects. First, enough lead,
cadmium, or similar material might be eliminated from fly ash to effect
its classification as nonhazardous waste.4 Second, because the cost per
Mg of pollutant removed from flue gas increases as the concentration of
pollution in untreated flue gas decreases, and source reduction will decrease
the concentration of pollution in untreated flue gas, the cost effectiveness
4At the time of this writing EPA and Congress have not resolved a policy for disposal
of MWC ash. This potential effect on cost effectiveness of APCDs is relevant only to
situations where it will cost more to landfill ash after the introduction of an APCD because
operation of the APCD causes an increase in the toxicity of the ash. See Chapter 7 for
more discussion of the ash problem.
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of APCDs will worsen. These two effects on cost effectiveness are not
analyzed here because EPA does not rely on cost-effectiveness criteria to
support regulation of MWCs.5 Cost effectiveness is an elusive measure when
it comes to evaluating MWC control devices because each device controls
more than one pollutant.
Source reduction, materials separation, and recycling also may affect
the selection of combustor and energy recovery technology. In the process
of selecting combustor and energy recovery technology, a decision to em-
ploy centralized materials separation and recycling may tip the scales in
favor of FBC technology over modular or mass burn technology. Removal
of aluminum and glass from MSW allows more efficient grate design. Fur-
thermore, if materials separation and recycling affects the energy content
of the MSW that will be combusted, it may correspondingly affect how
that energy is harnessed. Unfortunately, there is no easily generalizable ev-
idence on how materials separation and recycling affect the energy content
of MSW.
5.4 Good Combustion Practice
Good combustion practices alter the combustion process to reduce emis-
sions of MWC organics. GCP includes the proper design, construction,
operation, and maintenance of an MWC. Organics can originate in waste
feedstreams, combustion reactions, or post-combustion reactions in the flue
gas.
A more thorough combustion process reduces the formation of MWC
organics. GCP promotes proper combustion through attention to the fol-
lowing combustor design and operating conditions:
• Uniform waste feed rates,
• Amount and distribution of combustion air,
• Adequate combustion temperature and residence time,
5See Section 6.3.2. Although EPA does not rely on cost effectiveness to support regu-
lation of MWCs, EPA does consider cost effectiveness in situations where the question is
simply one of identifying the most economical APCD or control method for a particular
pollutant.
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• Mixing,
• Participate matter carryover,
• Downstream flue gas temperature control, and
• Combustion monitoring and control.
The optimal levels of these parameters vary by combustor type. Because of
the complex relationship between these parameters and good combustion,
optimal performance is best determined experimentally for each MWC.
Operator training and certification, and the monitoring of carbon monoxide
emissions, operating loads and PM control inlet temperatures ensure that
GCP is maintained continuously.
The post-combustion formation of MWC organics is minimized through
flue gas cooling to 230°C or below prior to the PM collection device. Flue
gas cooling is achieved through the use of water sprays, dilution air, or a
heat exchanger.
5.5 Post-Combustion Control Devices
Electostatic precipitators (ESPs) and fabric filters (FFs) are the most
frequently used PM control device for existing MWCs. Other less effective
devices, such as cyclones, electrified gravel beds, and venturi scrubbers,
have been used at a few MWCs but are not expected in new MWC plants.
ESPs subject the flue gas to a high voltage field, which electrically
charges the dust particles, causing them to migrate to a grounded collection
plate. Periodically the plates are rapped or washed to dislodge the dust
layer and the resulting ash is collected in a hopper.
Fabric filters (also called baghouses) are increasingly popular for PM
control because they offer the potential for acid gas control when used with
a spray dryer. PM collects on filter bags as flue gas flows through the fabric
filter. The resulting filter cake increases the pressure drop across the bags
to a preset limit, at which time the cake is removed by reversing the air flow
or pulsing the bag with compressed air. The pulse jet system is cleaned
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with the fabric filter on-line or off-line. The reverse-air FF is taken off-line
for cleaning.
ESPs or FFs are effective in reducing PM emissions to 34 mg/dscm or
less at 7 percent O2 when they are well designed and operated. Along with
the fine participates from MWC flue gas, ESPs and FFs remove over 97
percent of MWC metals (with the exception of mercury). ESPs and FFs
alone are not effective in removing mercury from MWC flue gas. Some mer-
cury control is achievable using a FF in conjunction with acid gas controls.
Mercury controls on MWCs remain under investigation.
Control of MWC acid gases is achieved by the injection of dry or slur-
ried alkali sorbents (such as lime) into a section of flue gas duct or furnace,
or spray drier. Unreacted sorbent and reaction products (and fine particu-
lates) are collected by an ESP or FF. Dry sorbent injection (DSI) achieves
50 percent SO2 control and 80 percent HC1 control in new MWCs using
duct injection. Furnace injection, considered more of a retrofit technology,
still achieves 50 percent SO2 control, but achieves somewhat lower HC1
control (such as 50 percent).
Spray drying followed by a FF is a higher performance technology for
MWC acid gas control than either duct or furnace DSI. Properly designed
SD/FF systems achieve 85 percent SO2 reduction and 95 percent HC1 re-
duction on a 24-hour average. SDs also control MWC organics and metals
(including mercury) to a greater degree. The spray drying process con-
sists of injecting atomized lime slurry into a SD vessel, where the water
evaporates to cool the flue gas and the lime reacts with the acid gases to
form salts. The salt particles are removed with the fine particulates by a
FF. SD performance is determined by the SD outlet temperature, which
is controlled by the water content of the slurry, and the lime-to-acid stoi-
chiometric ratio. Lower temperatures, favoring effective acid gas removal,
are balanced against the need to adequately dry the SD reaction products
prior to the FF. Generally, SDs operate at temperatures near 150°C.
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Chapter 6
Regulatory Options
6.1 Complementary Approaches
Just as there are several ways to skin a cat, there are several ways to
reduce emissions from MWCs. Chapter 6 describes some of these ways.
First, suppose there is to be no additional arm-twisting, command-and-
control EPA regulation of MWC emissions. What then? Perhaps state and
local governments could shoulder the burden of developing and implement-
ing up-to-date regulations, or perhaps Federal, state, and local governments
could experiment with economic incentives, such as deposit laws or threats
to deny recalcitrant municipalities their shares of highway funds. Second,
suppose there is to be additional command-and-control regulation of MWC
emissions. What then? There are many choices as to which MWCs might
be regulated, how, and to what degree. These with-and-without-direct-
EPA-regulation approaches are the topics of this chapter.
EPA's Agenda for Action[14] and the Congressional Office of Technology
Assessment's Facing America's Trash[7] present a strong case for a compre-
hensive, coordinated, and coherent national attack on the MSW disposal
problem. EPA believes that regulation of MWC emissions through the
Standards and Guidelines is an essential component of the solution to that
problem. State and local action, and economic incentives, are complements
to the Standards and Guidelines—not alternatives. Governmental actions
affecting MSW disposal must be many and coordinated if this country is
to achieve the environmentally sound disposal of MSW.
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6.2 No Additional EPA Regulation
6.2.1 State and Local Action
The CAA requires each state to develop and implement measures to
attain and maintain EPA's national ambient air quality standards. Each
state assembles these measures in a document called the State Implemen-
tation Plan (SIP). SIPs must be approved by EPA, and EPA is empowered
to compel revision of plans it believes are inadequate. EPA may assume
enforcement authority over air pollution control programs any state fails
to implement. The Standards and Guidelines will become parts of each
state's SIP, and enforcement authority will be delegated to the states. If
EPA were not to promulgate the Standards and Guidelines, states could,
in theory, still put the unofficial Standards and Guidelines in their SIPs. In
the past, some CAA §111 regulations EPA has prepared but not promul-
gated have been adopted by some states, but usually only for enforcement
in nonattainment areas. (Nonattainment areas are small regions, generally
not crossing state lines, where air quality is worse than permitted by EPA's
air quality standards.)
All states have in their SIPs procedures for reviewing applications for
permits for the construction and operation of new, large, potential sources
of air pollution, and procedures for attaching conditions to the approval of
those permits. These new source review procedures apply to most MWCs.
As a general rule, states approve applications for new MWCs only if the
MWCs will agree to install and operate best available control technology
(BACT). CAA §111 regulations are used by states to help define BACT.
However, BACT for some types of MWCs, such as those employing flu-
idized bed combustion, for some components of what is called here "MWC
emissions," and for NOX from MWCs, is not fully defined by existing §111
regulations. (See Section 2.2.1 for the current coverage of §111 regulation
of MWCs.) Lack of full and clear definitions of BACT delays the process
of new source review and results in incomplete control of all pollutants of
concern.
Some SIPs contain provision for emission rights trading, emission den-
sity zoning, and other control techniques that could be applied to MWCs.
Most states have programs to control air toxics—toxic organics and metals
that are too numerous in number for all to be effectively addressed by CAA
6-2
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§111 or §112. Some states may employ some of the economic incentives de-
scribed in Section 6.2.2 below.
EPA believes that reliance on state and local action is not a viable
substitute for the Standards and Guidelines. This belief holds even if EPA
were to step up research and technology transfer programs to assist state
and local governments. In the absence of the Standards and Guidelines,
state and local action would be a fractionated, inefficient, and incomplete
societal response to the problem of MWC emissions. The reasons are many.
In brief: Air pollution crosses state lines. MSW and MWC ash is shipped
across state lines. Firms that construct or design plants for many states
have an inordinate burden trying to meet multiple, diverse state and local
regulations. Some states are reluctant to require the best APCDs unless all
states will be requiring them. Finally, EPA regulations, most of which are
enforced by state and local officials, often are needed to give those officials
the clout needed to command the respect of the regulated community.
6.2.2 Economic Incentives
There are probably more ways to use the marketplace to motivate MWC
emission reductions than there are MWCs. This section lists a selection of
economic proposals for doing just that, some tried, some untried.1 Most
of these require more study, and most would need to be based on legal
authorities other than the CAA as it currently reads. Most relate to source
reduction, materials separation, and recycling; comparatively few relate to
GCP and APCDs. Section 4.2 above explains why market forces presently
are not adequate to obviate the need for the Standards and Guidelines. It
will take considerable time to study and select the best economic incen-
tives, to develop suitable statutory authorities, to prepare and promulgate
the incentives, and thence to implement them. Therefore EPA, in evaluat-
ing these economic incentives for their utility as MWC emission reduction
measures, concludes that economic incentives in general should be comple-
ments to, and not replacements for, the Standards and Guidelines.
The following is a partial itemization of the economic incentives EPA
initially considered as possible non-regulatory means for reducing MWC
1See Facing America's Trash[7] for an excellent review of economic incentives related
to MSW disposal.
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emissions. Each has the potential to affect MWC emissions, but true to
the old adage "Everything affects everything else," each has the potential
to affect other things as well. The reader is cautioned that some of these
incentives could have unacceptable downsides.
EPA can develop and disseminate information to
• Facilitate markets for recycling
— Standardization of terms, such as delineation of exactly what is
and is not to be considered MSW in calculations of the percent
of MSW that is recycled
- Periodic inventories of recycling programs and activities
— Statistics on recyclable materials: prices, markets, availability,
quantities, shipping methods, uses, toxicity, etc.
• Advise consumers and MSW generators how to be part of the solution
rather than part of the problem
— Educational and advertising campaigns
— Guide for the on-site composting of yard waste
- Product labels that indicate products' contributions to the MSW
problem
• Advance the technology of combustion, pollution control, and recy-
cling
- Research on GCP, APCDs, and combustion technology
- Research on the separation, processing, and use of recyclable
materials
— Clearinghouse for technology transfer
- Federally funded MWC operator training and certification pro-
grams
EPA (or governments in general) can assess fees, penalties,2 or taxes, or
restructure subsidies, or grant exemptions from regulations, to
• Force producers to internalize the disposal cost of products
2Some fees and penalties are, of course, enforcement tools for direct regulation.
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— A waste added tax somewhat equivalent to a value added tax
• Give households and other MSW generators incentives to generate
less MSW
— Disposal fees to augment sales and use taxes
— Restructuring of local taxes and fees so that households and
other MSW generators pay for MSW disposal according to the
amount of MSW collected from them
• Significantly reduce or eliminate selected items in the MSW stream
— Penalties for combusting lead-acid batteries, or subsidies to not
combust them.
• Encourage recycling
— Tax breaks for producing or using recycled material
— Partial relief from regulations governing the highway transport
of hazardous substances, for salvaged batteries and other items
to be recycled
— Subsidies to export recycled material
— Restructuring of taxes (mineral depletion allowances, capital
gains provisions, investment tax credits, depreciation schedules,
etc.), freight rates (paper, pulp, etc.), international trade quotas
and duties (paper, pulp, etc.), and governmental services (log-
ging roads, forest management services, mineral surveys, etc.)
to ensure that virgin materials are not underpriced vis-a-vis re-
cycled material
— Withholding of highway or other Federal funds where states
and/or local areas fail to prepare and implement recycling pro-
grams
• Reduce MWC emissions
— Tax credits for installation of pollution control equipment
— Emission fees
- Exemption of an individual MWC's ash from hazardous waste
regulations if the hazardous classification results from operation
of an EPA-approved APCD
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Governments can purchase, have others purchase, or ban products ac-
cording to whether and how the products affect the amount of MSW, the
toxicity of MSW, the use of recycled material, and/or MWC emissions, to
• Stimulate source reduction, materials separation, and recycling
- Procurement of items made from recycled material, perhaps by
allowing the cost to be 10 percent over that for items made from
virgin material
— Procurement of less-toxic products
• Stabilize recycling markets
— Price supports and other analogs of farm support programs
• Reduce MWC emissions
— Revision of PURPA3 avoided-cost calculations to establish more
favorable sales prices for electricity cogenerated by MWCs that
reduce emissions
Governments can implement deposit laws to
• Reduce MWC emissions and achieve other environmental goals
— Beverage container deposits
— Battery deposits
6.3 EPA Regulation
6.3.1 Development of Regulatory Alternatives
EPA elected to use CAA §111 as the basis for controlling MWC emis-
sions. This decision triggered a long research effort to identify and classify
3The Public Utility Regulatory Policies Act of 1978 (PURPA) stipulates that electric
utilities must puichase electricity generated by MWCs, paying a rate that equals, but does
not exceed, the utility's avoided cost of generating or purchasing that electricity. Needless
to say, there is extensive leeway and controversy in calculating the avoided cost.
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MWCs by type and size, to list all the emission control devices and prac-
tices applicable to each type and size of MWC, to arrange the emission
controls in order of effectiveness (which usually means in order of cost) for
each type and size of MWC, and then to collapse these bewildering ma-
trices that match MWCs with controls into a short, understandable, and
coherent list of regulatory alternatives. Types and sizes of MWCs are ex-
plained in Chapter 7. Table 6.1 shows in very general terms a hierarchy
Table 6.1: MWC Emissions Control Technology
Technology" Cost Pollutant
GOP: Good
Combustion Low ~
Urganics
Practice
PM
Control
Good Acid Gas Controls A • j /-i
Acid Gases
&: Organics
(Dry Sorbent Injection &:
ESP or Fabric Filter)6
Best Acid Gas Controls T A -j n
Acid Gases
(Spray Dryer & High &
Fabric Filter)
PM&
Metals
a These technologies generally are used in combination.
& This principally applies to retrofit of existing MWCs. ESP = elec-
trostatic precipitator.
of combustion and post-combustion controls. EPA decided to keep NOX
controls separate from this regulative alternative structure, and to keep
pre-combustion controls (materials separation) separate as well. From this
beginning, the regulatory alternatives were formed. The process of their
development is described in more detail in the Federal Register preambles.4
4These preambles will accompany proposal of the Standards and Guidelines in the
Federal Register later this year.
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Once defined, the regulatory alternatives went through numerous revisions
before assuming their present form.
Normally, EPA relies heavily on cost/effectiveness (C/E) analysis not
just in the development of regulatory alternatives, but in selecting the regu-
latory alternative that will constitute the basis for a regulation.5 If the reg-
ulation will constitute a major rule within the meaning of Executive Order
12291, EPA supplements C/E analysis with a benefit-cost methodology.6
Neither procedure has fit well with the Standards and Guidelines. The
problems with benefit-cost analysis are discussed in Chapters 12 and 13.
Section 6.3.2 below recounts some of the thinking that has caused EPA to
turn away from traditional C/E analysis for selecting regulatory alterna-
tives for promulgation. Without definitive C/E and benefit-cost findings
to support the Standards and Guidelines, EPA instead relies on judgment
about how the regulatory alternatives are constructed and about which
regulatory alternatives are the most protective of health and welfare, yet
affordable and equitable.
6.3.2 Role of Cost Effectiveness
EPA has used C/E analysis to identify regulatory alternatives that con-
trol pollutants at an incremental cost in the range of values some analysts
believe reflect the value to society of the associated incremental reduction
in the pollutants. Incremental C/E ratios are calculated for each step up
the stringency ladder, from the baseline through the regulatory alterna-
tives. For CAA §111 decisions, EPA then chooses a regulatory alternative
considering cost effectiveness (along with other factors such as affordability,
equity, and feasibility). However, for the Standards and Guidelines, there
are several analytical problems that have rendered this C/E approach less
reliable.
5 EPA also considers affordability, equity, and other factors when designing regulatory
alternatives and when selecting particular alternatives as the basis for regulation.
6Recall from Section 2.6 that Executive Order 12291 specifies that EPA demonstrate (1)
that net benefits of regulation are positive, and (2) that the selected regulatory alternative
maximizes the net benefits. The Order also stipulates that net costs be minimized. In
practice, this latter criterion cannot be considered unless there are at least two regulatory
alternatives that maximize net benefits, the net benefits are identified, and they are fully
quantified and monetized. Because EPA cannot quantify all the benefits, minimization
of net costs is only of academic concern and is not considered in this regulatory impact
analysis.
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Lack of Quantified C/E Criteria. For some emissions—volatile
organic compounds, S02, and PM—EPA has come up with ranges for social
values of each Mg of emission reduction, and has used these dollars-per-
Mg figures as C/E criteria to help in setting the stringency level for §111
regulations. (In one or two cases these social values have been less based
on analysis than on somewhat arbitrary policy determinations made in an
effort to maintain consistency in the regulatory process.) Unfortunately,
with the Standards and Guidelines there are many pollutants for which
there are no available dollars-per-Mg criteria. Development of each criterion
requires years of research.
Multiple Pollutants. The Standards and Guidelines take aim at a
bundle of pollutants. Materials separation and each APCD and GCP apply
to several of these pollutants. A spray dryer-fabric filter combination, for
example, will control acid gases, metals, and particulates. GCP will control
most of the organics. NOX controls may affect mercury emissions. Possibly
with the exception of materials separation, it is relatively easy to establish
the cost of these controls, that is, the numerators of the C/E ratios. But
what are the measures of effectiveness that go in the denominators? Where
a §111 regulation is for the control of only one pollutant, it may be possible
to find a denominator. Where there are several pollutants to be controlled,
it is very difficult to calculate a denominator. Adding emission reductions
of the various pollutants by weight is of no value, because equal weights
of different pollutants often have dramatically different effects on health
and welfare. The only theoretically defensible way to add the emission
reductions is to add the benefits of the emission reductions. The problems
with the benefits approach are reviewed in Chapter 12.
Uncertain and Shifting Baseline. The MWC industry currently is
in a very dynamic growth phase, rendering the baseline uncertain. It has
been very difficult for EPA to pin down an acceptable baseline against which
initial incremental C/E ratios can be computed. Furthermore, the substi-
tution analysis reveals that the stringency of the Standards, and probably
also that of the Guidelines, will determine how many MWCs will be built
and/or left operating over the next few years. The more stringent the reg-
ulations, the fewer will be the number of MWCs affected by the Standards
and Guidelines, because to cut costs municipalities will return to, or will
continue, landfilling their MSW.7 This leads to a shifting baseline—one that
7EPA has not studied the question of whether materials separation requirements may
place a disproportionate burden on certain types or sizes of MWCs, causing them to shut
6-9
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is different, for each regulatory alternative—in which C/E ratios behave un-
predictably and generally are useless for selecting regulatory alternatives.
With sufficient data and analytical effort this problem can be overcome.
The numerators must be corrected to add in loss of what economists call
the consumer surplus (something akin to the loss of the option to use MWCs
that are closed or are not built), and the denominators must be corrected
to account for emissions from landfilling (or recycling) MSW that otherwise
would have been combusted.
Multiple Pathways. Achieving emission reductions from MWCs can
be a mixed blessing, because much of what is pulled out of the stack goes
into the ash. Normally, this is of no concern. However, for the Standards
and Guidelines, the potential toxicity of fly ash and its potential pathway
through ground water into water supply systems and the food chain is
a problem. Thus, allowing emission reductions to stand alone in the de-
nominator of a C/E ratio is not an altogether good way of measuring the
beneficial effectiveness of an MWC regulatory alternative.
Spatial and Temporal Patterns. C/E ratios do not contain infor-
mation on the spatial (stack height and locational) and temporal (hourly,
daily, weekly, and seasonal) patterns of emissions and emissions reductions.
All-Or-Nothing. The economically optimal use of cost effectiveness is
to help the economy reach a point where the last dollar spent on emission
control returns just one dollar in effectiveness. Unfortunately, under §111
EPA must require emission standards based on the best available control
technology (considering cost), or EPA must issue no emission standards at
all. It is technically feasible to design most air pollution control devices
for a range of costs and a matching range of effectiveness levels, and it
may be legal to interpret the word "cost" as it appears in §111 as "cost
effectiveness." Thus, it is conceivable that EPA could, if such action were
indicated by application of C/E and other criteria, base emission standards
on an APCD like fabric filters designed to remove only, say, 50 percent of
the PM. However, in practice §111 is construed as precluding such a half-
way approach because 50 percent removal is not up to what the best fabric
filter can do. This attribute of §111 has many advantages, but in some
situations such as with the Standards and Guidelines, it diminishes the
potential utility of the C/E method for selecting a regulatory alternative.
down or to not be built, and therefore may aggravate the "shifting baseline" problem
described here.
6-10
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6.3.3 Description of the Regulatory Alternatives
EPA selected five regulatory alternatives for use in evaluating a range
of stringency levels for the Standards, and six regulatory alternatives for
the Guidelines. The regulatory alternatives (see Tables 6.2 and 6.3), plus
a regulatory baseline, reflect a range of control levels for MWC organics,
MWC metals, and MWC acid gases.8 For new MWCs, the baseline includes
good combustion practices for all combustors with capacities greater than
45 Mg per day and PM control as required by Subparts Db and E. For
existing MWCs, the baseline level of GCP and PM control varies by type,
size, and age of combustor. In general, the regulatory alternatives increase
in stringency from alternatives I to IV; however, alternative III is less strin-
gent than IIB for small MWCs, and more stringent for large MWCs. The
alternatives categorize MWCs into large and small combustors because (1)
large combustors account for 90 percent of planned capacity (such that
they have a larger emissions potential) and (2) control costs increase a
small combustor's cost per Mg by a significantly larger factor. A third cat-
egory for very large MWCs applies only to regulatory alternative IIB' for
the Guidelines. Small MWCs have capacities less than or equal to 225 Mg
per day, and very large MWCs (in reference only to the Guidelines) have
capacities above 2,000 Mg per day.
Regulatory alternatives for new MWCs are described first, followed by a
discussion of differences between alternatives for new and existing MWCs.
Regulatory alternative I requires GCP and PM control to achieve re-
ductions in MWC organics and PM for new MWCs. For small MWCs,
this alternative effectively drops the lower size cutoff for PM emissions un-
der Subpart E. The current emission limit of 180 mg/dscm, Subpart E, is
required for all small MWCs. Large MWCs are required to achieve PM
control to 34 mg/dscm. MWC organics are controlled to 500 ng/Nm3.
No emission reductions are required (or control costs incurred) for MWC
metals and acid gases.
Regulatory alternative IIA requires more stringent control on new large
MWCs than does I, but there is no change for new small MWCs. Beyond I,
alternative IIA includes requirements for good acid gas controls (50 percent
SO2 and 80 percent HC1 reduction) based on dry sorbent injection. MWC
8EPA elected to handle materials separation and control of NOX outside this regulatory
alternative structure.
6-11
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Table 6.2: Regulatory Alternatives for the Standards
For Combustion and Post-Combustion Control of MWC Emissions*
Regulatory
Alternative
MWC
Small
(<225 Mg/D)
Plant Size
Large
(>225 Mg/D)
GCP
Moderate PM
II A
II B
GCP
Best PM
GCP
Best PM
Good Acid Gas
IV
GCP
Best PM
Good Acid Gas
GCP
Moderate PM
GCP
Best PM
Good Acid Gas
GCP
Best PM
Best Acid Gas
a Materials separation and control of NOX are not included in this
regulatory alternative framework.
& This is the total capacity of all combustors at the plant site.
c This is the current operating guidance for new large MWCs.
DEFINITIONS: (See text for greater detail.)
GCP = Good combustion practice
Moderate PM =182 mg/dscm maximum emission rate
Good PM = 69 mg/dscm maximum emission rate
Best PM = 34 mg/dscm maximum emission rate
Good acid gas = Use of dry sorbent injection
Best acid gas = Use of spray dryer and fabric filter
6-12
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Table 6.3: Regulatory Alternatives for the Guidelines
For Combustion and Post-Combustion Control of MWC Emissions*
Regulatory
Alternative
MWC
Small
(<225 Mg/D)
Plant Size
Large
(>225 Mg/D)
II A
II B
II B'
III
IV
GCP
Moderate PM
GCP
Good PM
Good Acid Gas
GCP
Moderate PM
GCP
Moderate PM
GCP
Good PM
Good Acid Gas
GCP
Good PM
GCP
Good PM
Good Acid Gas
GCP
Good/Best PM
Good/Best Acid Gas
GCP
Best PM
Best Acid Gas
a Materials separation and control of NOX are not included in this
regulatory alternative framework.
b This is the total capacity of all combustors at the plant site.
c Large MWCs less than 2,000 Mg per day capacity must have good
PM and acid gas control. Very large MWCs (greater than 2,000 Mg
per day capacity) must have best PM and acid gas control.
DEFINITIONS: See Table 6.2.
6-13
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organics are reduced to 75 ng/Nm3.
Regulatory alternative IIB extends IIA to apply to small MWCs as well
as large MWCs. All new MWCs are subject to GCP, PM control to 34
mg/dscm, and moderate acid gas controls (see IIA above). Again, MWC
organics are controlled to 75 ng/Nm3.
Regulatory alternative III is also similar to IIA. It has the same require-
ments for new small MWCs. New large MWCs, however, are required to
achieve a more stringent level of acid gas control. Based on spray drying
followed by a fabric filter, III requires the best control of acid gases (85
percent SO2 and 95 percent HC1 reduction). Regulatory alternative III,
therefore, is more stringent than IIB for large MWCs and less stringent
than IIB for small MWCs.
Regulatory alternative IV is the most stringent (lowest emissions and
highest costs) alternative considered. It requires GCP and the best PM
control on all new MWCs. The stringency of acid gas control varies by
combustor size. Alternative IV requires the best control of acid gases for
large MWCs (as in Alternative III) and good control for small MWCs (as
in IIB).
For the Guidelines, the regulatory alternatives are structured in a sim-
ilar manner. In most cases, where differences occur, the Guidelines alter-
natives are less stringent than those for the Standards. Regulatory alter-
natives I, IIA, and III for new and existing small (less than or equal to 225
Mg per day capacity) MWCs are the same. For large MWCs, Alternatives
III and IV are the same for both new and existing MWCs.
What are the differences between the alternatives for new and existing
combustors? Regulatory alternative I requires good, not the best, PM con-
trol on existing large MWCs. PM emissions are controlled to 69 mg/dscm
based on an ESP upgrade.
Regulatory alternative IIA also requires good (not best) PM control for
Guidelines MWCs, based on an ESP upgrade. Alternative IIA, however,
also relaxes controls on MWC organics to 125 ng/Nm3 and HC1 to 50
percent reduction for existing large MWCs compared to the requirements
for new large MWCs.
Regulatory alternative IIB, which is the same for existing small and
6-14
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large MWCs, is slightly less stringent for existing MWCs than it is for new
combustors. Alternative IIB requires GCP, good PM control, moderate
MWC organics control, and good acid gas control. Alternative IIB is an
extension of IIA large MWC requirements to all existing MWCs.
Regulatory alternative IIB' applies only to the Guidelines. It requires
very large MWCs—those with capacities greater than 2,000 Mg per day—
to install best PM and acid gas control. For large MWCs, IIB' requires
the same level of control as alternative IIB. For small MWCs, IIB' requires
the same level of control as alternative III which is less stringent than
alternative IIB.
Regulatory alternative IV requires less stringent controls for existing
small MWCs than for new small MWCs. For existing small MWCs, IV
requires the same level of control as alternative IIB.
6-15
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Chapter 7
Municipal Waste Combustor
Characteristics and Control Costs
7.1 Characteristics
Combustion was once a principal way of disposing of MSW in metropoli-
tan areas of the U.S. These MWCs, along with many burning dumps, were
dirty, and virtually all were closed in the two decades following World War
II. A renewed interest in the technology, coincident with reductions in
available, convenient landfill capacity and the search for alternative energy
sources, occurred in the mid-1970s. In the early and mid-1980s, new MWC
capacity was added rapidly. The amount of waste combusted increased
by a factor of three or four from 1980 to 1986, and MWCs took on the
characteristics that we observe today.
7.1.1 A Basic Classification of MWCs
There are three principal types of MWCs: mass burn, modular, and
refuse-derived fuel (RDF) combustors. A fourth type, combustors that em-
ploy fluidized-bed combustion (FBC), is less common. There are variations
within these categories, and there are designs that incorporate features of
more than one type. Regardless of the technology, each MWC plant site
has one, or most likely more than one, individual component combustor.
7-1
-------
Some air pollution control devices (APCDs) control emissions from indi-
vidual components, while others control emissions from all components on
the site.
Mass burn combustors are field-erected and span a wide size range. In-
dividual combustors range in capacity from 45 to 900 Mg MSW combusted
per day. There are typically two or three individual combustors per plant
site, and plant capacities range from about 90 to 2,700 Mg MSW per day.
The technology is called mass burn because the waste is burned without any
processing other than removal of bulky noncombustible material and items
too large to squeeze through the entrance to the combustion chamber. In
addition to size, wall and grate design define the types of mass burn com-
bustors. Essentially all new mass burn combustors will have waterwalls for
energy recovery. Some older mass burn combustors have refractory-lined
walls without any energy recovery.
Modular combustors also burn waste without much processing, but are
usually shop-fabricated. Components range in capacity from 5 to 110 Mg
MSW per day. There are typically one to four or more individual com-
bustors per plant site, and plant capacities typically range from about 15
to 360 Mg MSW per day. Generally, modular units are dual-chambered
combustors. Depending on the design, the volume of combustion air sup-
plied to the primary chamber either is greater than the amount needed
for complete combustion—these are called modular excess air MWCs—or
less than the amount needed for complete combustion—these are modu-
lar starved air MWCs. A secondary combustion chamber is used after the
primary chamber to complete the combustion process. Although many ex-
isting modular combustors do not have energy recovery, the majority of
new modular combustors will incorporate energy recovery.
RDF combustors burn processed and shredded MSW. The degree of
processing varies from simple removal of bulky items accompanied by shred-
ding of the remaining waste, to removal of most noncombustible material
and processing of the residue into fine particles. The sorting and separating
typically is accomplished by a process line of shredders, magnets, screens,
and air classifiers. The resulting RDF has a higher energy value and lower
ash content than less-processed MSW, and it burns more completely. Some
RDF MWCs are designed to combust only RDF, while others combust a
mixture of RDF and other fuel such as wood or coal. Most RDF compo-
nents range in capacity from 270 to 900 Mg MSW per day. Plants typically
7-2
-------
have two to four combustors, and plants handle from 550 to 3,600 Mg MSW
per day.
The last class of MWCs is combustors employing FBC. In FBC, the
RDF, sometimes mixed with other fuels, burns in a turbulent bed of heated
noncombustible material, generally sand or limestone. There are two basic
designs: bubbling-bed and circulating-bed. The former operates with rela-
tively low turbulence to minimize entrainment of solids in the flue gas. The
latter operates with relatively high turbulence and employs a cyclone sep-
arator to capture and return unburned and inert particles to the bed. By
making the waste behave as a liquid or gas, FBC ensures good fuel mixing,
good heat transfer, and efficient combustion. At present, however, applica-
tion of the technology to MWCs is relatively new. Typical FBC component
combustor capacities for planned units are 180 to 450 Mg MSW per day,
and total plant capacities range from 270 to 900 Mg MSW per day.
7.1.2 Ash Handling
Municipal waste combustors decrease the volume of municipal solid
waste by 70 to 90 percent. The remaining waste, MWC ash, consists of
bottom ash from the combustion chamber and fly ash from the stack gas.
At most existing MWC sites, the two types of ash are combined prior to
disposal. Historically, disposing of MWC ash (like its precursor MSW)
means landfilling.
The potential toxicity of MWC ash is a cause of public concern. This
ash contains varying quantities of toxic materials including lead, mercury,
and cadmium, which are concentrated in the fly ash. These MWC metals
condense on the fly ash particles and are collected by the APCD. These
toxic materials may leach into ground and surface water supplies through
inadequate disposal of MWC ash. Human exposure to the toxic constituents
of the MWC ash also can be through airborne particles. The culprit is wind-
blown ash dust at the combustor site or the landfill, and in transit from
the combustor to the landfill.
Current ash management is regulated by the EPA under RCRA, which
is directed at solid wastes in general and not specially at MWC ash. RCRA
classifies solid wastes as either hazardous or nonhazardous based on four
characteristics: corrosiveness, ignitability, reactiveness, and toxicity. The
7-3
-------
results of toxicity tests on selected samples of MWC ash are mixed. Some
samples indicate toxicity and others do not. Furthermore, the results of
tests on the same samples are not always reproducible.
Because of the uncertainties surrounding the toxicity of MWC ash and
the RCRA language pertaining to a household waste exclusion, MWC ash
is typically managed and disposed of as a nonhazardous waste. While the
majority of existing landfills are unlined, it is likely that disposal of MWC
ash in lined landfills will be required by environmental legislation. Several
bills are being considered during the 101st Congress that would classify
MWC ash as nonhazardous, while requiring special handling provisions
such as disposal in lined landfills. The bills impose less costly requirements
for disposal of MWC ash in monofills where MWC ash is not commingled
with other MSW.
The technology debate focuses on the level of leachate containment con-
trols and groundwater monitoring requirements. Reliable leachate data are
needed to provide a scientific basis for the containment debate. Again,
reproducibility is a problem. Improvements in the testing methods may
help; however, the high variability in the composition of MWC ash and
the difficulty in duplicating actual long-term conditions will continue to
complicate the gathering of reliable data. The debate may be settled on
legislative rather than purely scientific grounds.
Other strategies are based on reducing the toxicity of the MWC ash.
This can be accomplished through the removal of problem materials prior
to combustion, or the post-combustion extraction or stabilization of toxic
residues. Productive use of detoxified MWC ash holds promise as a partial
solution to disposal. In Europe MWC ash is used for construction fill,
concrete blocks, and road beds. The concentration of toxic constituents is
reduced by the current practice of combining bottom ash and fly ash. This
practice, however, creates a larger volume of contaminated waste while
doing nothing to reduce the amount of toxic metals and organics.
7.1.3 Model Plants
To analyze the impacts of alternative regulations, and to help select the
appropriate level of stringency for regulations, EPA creates "model plants"
that are prototypes of the plant's of facilities that will be regulated. See
7-4
-------
Table 7.1. For the development of the Standards, 12 model plants are
defined, and for the Guidelines, 17. Combustion technology is advancing
so rapidly that it has not been possible to use the same set of model plants
for both the Standards and the Guidelines. The "transitional" prefix to
some Guidelines model plant titles indicates that the model plants have
more advanced design and air pollution control than do others of the same
types.
7.1.4 Model Plant Throughput
Table 7.2 gives throughput data for the model plants. (Data in this and
most other tables in this document are rounded results of calculations using
unrounded inputs.) Design capacity (second column) normally is expressed
as a daily rate for combustion of MSW. All combustors, regardless of type,
operate at or close to their maximum design rate for the hours or days they
are burning MSW. The daily capacity figure also represents the amount
of MSW received at the MWC; in the economic analysis no allowance is
made for removal of noncombustible material and items too large to fit
in the combustor, items that cannot be processed into RDF, or items to
be recycled.1 The annual hours of operation (third column) are based on
recent industry experience in capacity utilization. (The special conditions
referred to in note a reflect increased downtime for some old plants and
some small plants, and allowances for stand-by units and the co-firing of
other materials.) In 1988, capacity utilization, which may be thought of as
the percent of days a plant or combustor operates, averaged
• Mass burn: 85 percent,
• RDF and FBC: 83 percent, and
• Modular: 82 percent.
These rates are expected to continue into the near future. Thus, each entry
in the third column of Table 7.2 is the total number of hours in a year (8,760)
lA.n RDF MWC with the same combustion capacity as a mass burn MWC may accept
more MSW than the mass burn MWC. This is because a larger share of the RDF plant's
input is separated out for recycling or landfilling. It is possible to calculate all MWC
emission factors on the basis of MSW received rather than combusted. However, this
is not done here because too little is known about the amount and destination of the
separated items, and what air pollution they ultimately generate if landfilled.
7-5
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Table 7.1: Model Plants for the Standards and Guidelines
Model
Plant
Abbreviation
Description
1
2
3
4
5
6
7
8
9
10
11
12
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
MB/WW (small)
MB/WW (mid-size)
MB/WW (large)
MB/REF
MB/RC
RDF
RDF/CF
MOD/EA
MOD/SA (small)
MOD/SA (mid-size)
FBC/CB
FBC/BB
MB/REF/TG
MB/REF/RG
MB/REF/RK
MB/WW (large)
MB/WW (mid-size)
MB/WW (small)
RDF (large)
RDF (small)
MOD/SA/TR
MOD/SA/G
MOD/EA
MB/RWW
TRANS MOD/EA
TRANS MB/WW
TRANS RDF (large)
TRANS RDF (small)
TRANS MB/RWW
Standards
Mass burn waterwall, small
Mass burn waterwall, mid-size
Mass burn waterwall, large
Mass burn refactory wall
Mass burn rotary combustor
Refuse-derived fuel
Refuse-derived fuel, co-fired
Modular excess air
Modular starved air, small
Modular starved air, mid-size
Fluidized bed combustion, circulating bed
Fluidized bed combustion, bubbling bed
Guidelines
Mass burn refactory wall traveling grate
Mass burn refactory wall rocking grate
Mass burn refactory wall rotary kiln
Mass burn waterwall, large
Mass burn waterwall, mid-size
Mass burn waterwall, small
Refuse-derived fuel, large
Refuse-derived fuel, small
Modular starved air, transfer rams
Modular starved air, grates
Modular excess air
Mass burn rotary waterwall
Transitional modular excess air
Transitional mass burn waterwall
Transitional refuse-derived fuel, large
Transitional refuse-derived fuel, small
Transitional mass burn rotary waterwall
7-6
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Table 7.2: Baseline Model Plant Throughput
Model
Plant
Daily
Capacity
(Mg/day)
1
2
3
4
5
6
7
8
9
10
11
12
180
730
2,040
450
950
1,810
1,810
220
45
90
820
820
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
680
220
820
2,040
980
180
1,810
540
140
45
180
450
380
180
1,810
540
450
Annual Hours Annual MSW
in Operation Combusted
(Hours /year) (Mg/year)
5,000a
7,420
7,420
7,420
7,420
7,250
3,620a
7,160
5,000a
7,160
7,270
7,270
X^l J CMlflf^E
6,500a
6,200a
7,420
7,420
7,420
7,420
7,250
7,250
4J70a
6,500a
7,160
7,420 •
7,160
7,420
7,250
7,250
7,420
37,800
224,000
631,000
140,000
294,000
548,000
274,000
64,900
9,450
27,000
247,000
247,000
184,000
56,800
254,000
631,000
303,000
55,700
546,000
163,000
27,800
12,200
53,700
139,000
113,000
55,700
546,000
163,000
139,000
Ash
Output
(Mg/year)
12,100
71,600
201,000
44,700
94,000
80,900
77,900
20,700
2,840
8,120
18,700
18,700
92,300
19,200
75,900
202,000
91,100
17,900
81,100
16,500
8,140
6,690
16,300
42,200
36,300
17,900
81,100
16,500
42,200
See text for an explanation of this table.
a These values reflect special conditions.
7-7
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multiplied by the capacity utilization percentage, and rounded. The annual
MSW combusted (fourth column) is the daily capacity divided by 24 and
multiplied by the annual hours of operation, and rounded. The last column
gives the ash output, which includes some residual quench water. These
throughput data are used in subsequent chapters, along with throughputs
based on higher alternative rates that reflect more optimum conditions, to
project the impacts of regulatory action.
7.2 Control Costs
Tables 7.3 and 7.4 list the estimated baseline capital and annual op-
erating costs and annual energy recovery revenues for the model plants.
Baseline costs provide a perspective for evaluating the costs of the regu-
latory alternatives. Total annual costs for publicly and privately owned
plants are presented less the revenues for energy recovery. Capital costs
are annualized at 4 percent for publicly owned plants and 8 percent for pri-
vately owned plants. Tables 7.3 and 7.4 differ in the presentation of costs:
dollars per year versus dollars per Mg of MSW combusted, respectively.
The dollars-per-Mg values2 can be used to compare public and private
ownership. The values indicate what an MWC must receive per Mg of MSW
to cover combustion or control costs. Model plants with higher capital cost
components shift the cost comparison in favor of public ownership. For the
12 model plants analyzed for the Standards, the baseline cost per Mg is
0.2 to 434 percent higher for private ownership. The cost of control for the
same model plants is 12 to 43 percent higher for private ownership. These
results, however, do not reflect sectorial differences in productivity. Nor do
the results reflect variation in financial parameters within the public sector
and private sector. The actual financial parameters may, in fact, overlap
over some range of values. Nonetheless, these data support the contention
that publicly owned MWCs will become the norm. Therefore, the cost
impacts of the Standards and of the Guidelines are based in this regulatory
impact analysis on public ownership.
2The terminology "$/Mg" or "cost per Mg" is somewhat awkward. A simpler term,
"unit cost," is not used because in another context it means the cost associated with an
individual combustor at an MWC plant site with several combustors.
7-8
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Table 7.5 lists by model plant and regulatory alternative the estimated
enterprise3 costs for the Standards. Table 7.6 gives the same information
for the Guidelines.4 The enterprise costs are the actual costs faced by the
plant in complying with the Standards or the Guidelines. The capital and
annual operating cost components are zero if the MWC plant qualifies for
an exemption from regulation beyond baseline. Capital costs for APCDs
are annualized over a 15 year equipment life. Total annual costs divided by
model plant throughputs, costs per Mg, provide a good basis for comparing
regulatory alternatives. Note that regulatory stringency and costs per Mg
do not increase in going from alternatives IIB to III for some model plants.
Under the Standards, capital costs for APCDs range from zero (for some
small MWCs) to $19.7 million (for large RDFs under alternatives III and
IV). Annual operating costs for environmental controls range from zero to
$3.6 million. Similarly, capital costs under the Guidelines range from zero
to $53.6 million. Annual operating costs range from zero to $5.1 million.
Table 7.7 lists the percent increase, over baseline, in model plant costs
per Mg for each regulatory alternative for both new MWCs and existing
MWCs. In general the percent increase over baseline is higher for existing
MWCs, because of lower baseline costs, than for new combustors of equiva-
lent size. Excluding RDF, the percent increase under the Standards ranges
from zero to 83 percent. RDF costs increase by 200 to 275 percent for
alternatives beyond regulatory alternative I. Under the Guidelines annual
costs per Mg increase by zero to 175 percent typically, however, some model
plants show percent increases in the 300 to 520 range.
Tables 7.5, 7.6, and 7.7 do not include costs for materials separation,
NOX control, and Guidelines regulatory alternative IIB'. The cost of ma-
terials separation and revenue from recycling probably will balance one
another in the long run for both new and existing plants. NOX controls ap-
ply to new MWCs only. Capital costs for NOX range from $616,000 to $3.7
million per model plant. Total annual costs range from $190,000 to $1.2
million per model plant, or from $1.70 to $3.60 per Mg of MSW combusted.
Costs for alternative IIB' are those shown for IIB in Table 7.6 except model
plant 4 which has the costs shown for alternative III and model plants 2,
6, 9, 10, 11 and 14 which have costs shown for IIA.
'Enterprise costs of regulation are costs experienced by each MWC. In Chapter 10
enterprise costs are compared with social costs, which are costs of regulation experienced
by society as a whole. See page xv and Sections 9.3, 10.1 and 10.2 for more explanation
of the cost terminology.
4EPA has not estimated all costs of regulation. See Section 10.5.
7-9
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Table 7.3: Baseline Model Plant Costs and Energy Revenue
(1987$ per Year)
Model
Plant
first
Initial Annual
Capital Operatin
($103) ($103/yr
1
2
3
4
5
6
7
8
9
10
11
12
19,700
53,200
117,000
40,400
73,300
143,000
152,000
14,500
1,270
5,880
73,900
73,900
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
2,680
7,610
16,200
6,750
10,200
15,300
15,900
2,490
439
1,050
8,720
8,720
8,550
3,560
9,910
16,500
10,600
3,130
12,200
6,340
1,130
292
1,510
5,720
4,540
3,130
32,700
12,200
5,720
Annual
Energy
Recovery
5 Revenue
) ($io3/yr)
1,040
6,160
17,300
3,020
8,310
21,800
24,200
1,400
0
582
9,860
9,860
I -in ir\ oli noc _ _
0
0
0
17,300
8,290
1,540
21,800
6,550
873
0
1,160
3,840
2,440
1,540
21,800
6,550
3,840
Annualized Capital Plus
Annual Operating Costs
Net of Energy Revenue
Private MWC Public MWC
($io3/yr) ($io3/y)
4,260
8,580
14,300
9,360
11,700
11,600
10,700
3,140
605
1,310
8,460
8,460
8,550
3,560
9,910
-1,980
1,540
1,370
-10,800
-812
140
292
183
1,470
1,620
1,370
7,780
4,500
1,470
2,850
4,640
5,930
6,170
6,260
1,961
4,850
1,980
512
845
3,250
3,250
See text for an explanation of this table.
7-10
-------
Table 7.4: Baseline Model Plant Costs and Energy Revenue
(1987 $ per Mg MSW Combusted)
Model
Plant
Orxst
Initial Annual
Capital Operatin
($103) ($/Mg)
Annual
Energy
Recovery
? Revenue
($/Mg)
Annualized Capital Plus
Annual Operating Costs
Net of Energy Revenue
Private MWC Public MWC
(S/Mg) ($/Mg)
1 .
2
3
4
5
6
7
8
9
10
11
12
19
53
117
40
73
143
152
14
1
,700
,200
,000
,400
,300
,000
,000
,500
,270
5,880
73,900
73
,900
71
33
25
48
34
27
29
38
46
38
35
35
.00
.90
.70
.10
.60
.90
.00
.40
.50
.60
.20
.20
27.40
27
27
21
28
39
44
21
.50
.40
.50
.20
.90
.20
.50
0
21.50
39.90
39.90
113.00
35.50
21.00
61.90
36.80
19.11
17.75
43.30
64.00
43.40
31.10
31.10
75.40
20.70
9.40
44.00
21.30
3.58
17.70
30.40
54.20
31.20
13.20
13.20
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
—
—
—
—
46
63
36
24
.40
.30
.40
.20
— 32.50
— 51.90
— 20.30
— 35.20
— 24.40
0
0
0
46.40
63
.30
36.40
27.40
27.40
27.60
40.00
40.20
19.20
— 23.80
— 25.10
— 37.80
— 35.80
— 51.90
— 54.00
— 67.60
37.
80
0
21.70
27.60
21.60
27.
40.
40.
27.
60
00
20
60
-3
5
24
-19
-4
4
23
3
10
14
24
14
27
.13
.08
.40
.70
.94
.17
.80
.39
.50
.20
.40
.20
.40
10.50
See text for an explanation of this table.
7-11
-------
Table 7.5: Model Plant Control Costs for the Standards
(Enterprise Costs for Publicly Owned Plants, 1987 $)a
Model
Plant
Capital
Costs6
($103)
1
2
3
4
5
6
7
8
9
10
11
12
0
480
1,350
620
540
1,240
1,240
0
532
0
0
0
if acri! In
1
2
3
4
5
6
7
8
9
10
11
12
0
3,370
7,830
2,780
3,820
7,660
7,660
0
532
0
450
450
Annual Total
Operating Annual
Costsc Costs'*
($io3/yr) ($io3/yr)
latory Alternative
0
39.0
114
50.0
35.2
109
49.8
0
72.0
0
0
0
itory Alternative I'
0
1,260 1
2,890 3
1,070 1
1,640 1
3,250 3
1,290 1
0
72.0
0
919
1,520 1
T - -
0
82.0
236
106
84.0
220
161
0
120
0
0
0
FA - - - -
0
,560
,600
,320
,990
,940
,980
0
120
0
959
,560
Annual
Costs per
Mg MSWe
($/Mg)
0
0.37
0.37
0.75
0.28
0.40
0.59
0
12.70
0
0
0
0
6.97
5.69
9.38
6.75
7.20
7.25
0
12.70
0
0
0
See notes at end of table.
7-12
-------
Table 7.5: Model Plant Control Costs for the Standards
(Continued)
Model
Plant
Capital
Costs6
($103)
. ..... Recri
J**cel
1
2
3
4
5
6
7
8
9
10
11
12
1,100
3,370
7,830
2,780
3,820
7,660
7,660
1,260
1,400
1,260
450
450
JXCg
1
2
3
4
5
6
7
8
9
10
11
12
0
8,870
18,300
8,820
11,500
19,700
19,700
0
532
0
8,560
8,560
Annual Total
Operating Annual
Costsc Costs'*
($103/yr) ($103/yr)
ilatory Alternative
540
1,260
2,890
1,070
1,640
3,250
1,290
460
322
347
919
1,520
ulatory Alternative
0
1,450
3,260
1,310
1,900
3,630
1,480
0
72 .0
0
1,340
1,340
TTTJ
639
1,560
3,590
1,320
1,990
3,940
1,980
573
448
460
959
1,560
m. . .
0
2,250
4,910
2,100
2,940
5,400
3,240
0
120
0
2,110
2,110
Annual
Costs per
Mg MSWe
($/Mg)
16.90
6.97
5.69
9.38
6.75
7.20
7.25
8.83
47.40
17.00
3.88
6.30
0
10.00
7,78
15.00
9.97
9.86
11.90
0
12.69
0
8.54
8.54
See notes at end of table.
7-13
-------
Table 7.5: Model Plant Control Costs for the Standards
(Concluded)
Model
Plant
Capital
Costs6
($103)
_______ U acrnl
1
2
3
4
5
6
7
8
9
10
11
12
1,100
8,870
18,300
8,820
11,500
19,700
19,700
1,260
1,400
1,260
8,560
8,560
Annual
Operating
Costsc
($103/yr)
atory Alternat
540
1,450
3,260
1,310
1,900
3,630
1,480
460
322
347
1,340
1,340
Total
Annual
Costs'*
($io3/yr)
tv*> TV
639
2,250
4,910
2,100
2,940
5,400
3,240
573
448
460
2,110
2,110
Annual
Costs per
Mg MSWe
(S/Mg)
16.90
10.00
7.78
15.00
9.97
9.86
11.90
8.83
47.40
17.00
8.54
8.54
a Control costs are costs over the baseline model plant costs. Control costs
are incurred to meet the emission requirements of the Standards. Materials
separation and NOx control costs are not included in this table. Materials
separation costs are expected to be negligible in the long run for the average
MWC. NOX costs will affect only model plants 2 through 7, 11, and 12.
Capital costs for NOX range from $616,000 to $3.7 million per model plant.
Total annual costs range from $190,000 to $1.2 million per model plant, or
from $1.70 to $3.60 per Mg of MSW combusted.
& Capital costs are for one APCD lifetime of 15 years and are untouched by
discounting procedures.
c Annual operating costs are assumed to be constant from year to year.
d Total annual costs are annual operating costs plus capital costs annualized
at 4 percent.
e Annual costs per Mg are costs from the preceding column divided by the
annual throughput from Table 7.2.
7-14
-------
Table 7.6: Model Plant Control Costs for the Guidelines
(Enterprise Costs For Publicly Owned Plants, 1987 $)°
Model
Plant
Annual Total
Capital Operating Annual
Costs6 Costs0 Costs'*
($103) ($103/yr) ($103/yr)
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
16,000
5,850
1,240
5,540
86
991
10,900
4,330
270
716
0
2,880
1,830
0
0
0
2,850
i
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18,500
5,850
8,820
10,500
8,160
991
16,400
11,000
270
716
0
5,030
3,200
0
5,500
6,090
4,730
y Alternative
-190
461
246
288
127
186
235
168
131
171
0
121
76
0
0
0
136
Alternative ]
580
461
1,580
2,240
1,540
186
1,980
1,200
131
171
0
825
515
0
1,870
1,160
842
1,250
987
358
787
135
275
1,210
557
155
235
0
379
241
0
0
0
368
IA
2,250
987
2,370
3,190
2,270
275
3,450
2,190
155
235
0
1,280
805
0
2,360
1,610
1,270
Annual
Costs per
Mg MSWe
($/Mg)
6.80
17.60
1.42
1.25
0.45
4.90
2.21
3.39
5.73
19.20
0
2.71
2.12
0
0
0
2.63
12.20
17.60
9.39
5.05
7.51
4.90
6.31
13.30
5.73
19.20
0
9.11
7.09
0
4.31
9.78
9.04
See notes at end of table.
7-15
-------
Table 7.6: Model Plant Control Costs for the Guidelines
(Continued)
Model
Plant
Capital
Costs*
($103)
r> „„..!
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18,500
7,560
8,820
10,500
8,160
4,540
16,400
11,000
2,870
1,570
2,280
5,030
3,220
4,050
5,500
6,090
4,730
34,150
5,850
31,040
36,750
22,400
991
53,600
24,200
270
716
0
11,500
7,380
0
29,500
15,100
11,200
Annual Total
Operating Annual
Costs0 Costs'*
($103/yr) ($103/yr)
atory Alternative
580
1,010
1,580
2,240
1,540
786
1,980
1,200
468
452
363
825
515
676
1,870
1,160
842
atory Alternative
2,090
461
3,660
4,740
2,940
186
5,050
2,270
131
171
0
1,470
939
0
4,620
2,000
1,460
TTTl
2,250
1,690
2,370
3,190
2,270
1,190
3,450
2,190
727
593
568
1,280
805
1,040
2,360
1,610
1,270
m. ......
5,160
987
6,460
8,050
4,960
275
9,870
4,450
155
235
0
2,500
1,600
0
7,270
3,340
2,460
Annual
Costs per
Mg MSWe
($/Mg)
12.20
30.00
9.39
5.05
7.51
21.30
6.31
13.30
26.90
48.30
10.50
9.11
7.09
18.50
4.31
9.78
9.04
28.00
17.60
25.60
12.80
16.40
4.90
18.00
27.10
5.73
19.20
0
17.80
14.10
0
13.30
20.40
17.60
See notes at end of table.
7-16
-------
Table 7.6: Model Plant Control Costs for the Guidelines
(Concluded)
Model
Plant
Capital
Costs6
($103)
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
34,100
7,560
31,000
36,800
22,400
4,500
53,600
24,200
2,870
1,570
2,280
11,500
7,380
4,050
29,500
15,800
11,200
Annual
Operating
Costs0
($103/yr)
atory Alterne
2,090
1,010
3,660
4,740
2,940
787
5,050
2,270
468
452
363
1,470
939
676
4,620
2,000
1,460
Total
Annual
Costs'*
($103/yr)
f iVA T"\7"
5,160
1,690
6,460
8,050
4,950
1,190
9,870
4,450
727
593
568
2,500
1,600
1,040
7,270
3,340
2,460
Annual
Costs per
Mg MSWe
($/Mg)
28.00
30.00
25.60
12.80
16.40
21.30
18.00
27.10
26.90
48.30
10.50
17.80
14.10
18.50
13.30
20.40
17.60
a Control costs are costs over the baseline model plant costs. Control costs
are incurred to meet the emission requirements of the Guidelines. Materials
separation and regulatory alternative IIB' control costs are not included
in this table. Materials separation costs are expected to be negligible in
the long run for the average MWC. Costs for regulatory alternative IIB'
are those shown for IIB except that model plant 4 has the costs shown for
regulatory alternative III and model plants 2, 6, 9, 10, 11 and 14 have the
costs shown for regulatory alternative IIA.
& Capital costs are for one APCD lifetime of 15 years and are untouched by
discounting procedures.
c Annual operating costs are assumed to be constant from year to year.
d Total annual costs are annual operating costs plus capital costs annualized
at 4 percent.
e Annual costs per Mg are costs from the preceding column divided by the
annual throughput from Table 7.2.
7-17
-------
Table 7.7: Control Costs as Percentages of Baseline Costs"
Model
Plant
Baseline
Costs
(t/Mg)
1
2
3
4
5
6
7
8
9
10
11
12
75.40
20.70
9.40
44.00
21.30
3.58
17.70
30.40
54.20
31.20
13.20
13.20
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
46.40
63.30
36.40
-3.13
5.08
24.40
-19.70
-4.94
5.17
23.80
3.39
10.50
27.40
14.20
24.40
14.20
10.50
I
(%)
0
1.77
3.97
1.72
1.34
11.20
3.33
0
23.40
0
0
0
14.70
27.70
3.90
c
8.80
20.10
c
c
111.00
80.60
0
25.90
0
14.90
0
0
25.10
Regulatory Alte
IIA IIB
(%) (%)
0
33.7
60.60
21.30
31.80
201.00
40.90
0
23.40
0
29.50
47.90
26.30
27.70
25.80
c
148.00
20.10
c
c
111.00
80.60
0
87.10
35.70
49.80
0
30.40
86.50
22.40
33.70
60.60
21.30
31.80
201.00
40.90
29.00
87.40
54.50
29.50
48.00
26.30
47.40
25.80
c
148.00
87.40
c
c
520.00
203.00
310.00
87.10
35.70
50.00
76.10
30.40
86.50
rnative - -
HI
(%)
0
48.50
82.80
34.10
46.90
275.00
66.90
0
23.40
0
64.90
64.90
60.40
27.70
70.20
c
322.00
20.10
c
c
111.00
80.60
0
171.00
74.60
99.20
0
93.40
168.00
IV
(%)
22.40
48.50
82.80
34.10
46.90
275.00
66.90
29.00
87.40
54.50
64.90
64.90
60.40
47.40
70.20
c
322.00
87.40
c
c
520.00
203.00
310.00
171.00
74.60
99.20
76.10
93.40
168.00 ,
a Control costs used for calculating percentages are enterprise costs (1987 $)
from Tables 7.5 and 7.6.
& Baseline costs are 1987 $/Mg from Table 7.4. For the Standards, the costs
are capital and operating costs. For the Guidelines, they are operating
costs only.
c Percentages are not meaningful because the baseline cost is negative.
7-18
-------
Chapter 8
Characteristics of the
Municipal Waste Combustion
Industry
The demand for MWCs is derived from the demand for services that collect
and dispose of the large volume and variety of wastes Americans produce.
This chapter looks into the market structure for these services: who and
what organizations generate MSW (and thereby "demand" its collection),
who and what organizations supply collection services (and thereby "de-
mand" disposal services), and who and what organizations supply disposal
services, particularly those of MWCs. The term "MSW industry" includes
the generation, collection, and disposal of MSW. The municipal waste com-
bustion industry is a major component of the MSW industry. This chapter
concludes with projections of the numbers of MWCs that will be affected
by the Standards and Guidelines over the next five years.
8.1 Industry Profile
8.1.1 Generators
MSW generators demand—in the economic sense of the word—services
that collect and dispose of MSW. These generators provide most of the
8-1
-------
demand for MWC services. This demand is called a derived demand be-
cause the generators generally do not directly purchase MWC services, but
instead leave the purchase up to the collectors. There are four broad cate-
gories of MSW generators:
• Residential: Waste from single- and multiple-family homes.
• Commercial: Waste from retail stores, shopping centers, office build-
ings, restaurants, hotels, airports, wholesalers, auto garages, and
other commercial establishments.
• Industrial: Waste such as corrugated boxes and other packaging,
cafeteria waste, and paper towels from factories or other industrial
buildings. Industrial MSW does not include waste from industrial
processes, whether hazardous or nonhazardous.
• Other: Waste from public works such as street sweepings and tree
and brush trimmings, and institutional waste from schools and col-
leges, hospitals, prisons, and similar public or quasi-public buildings.
Infectious and hazardous waste from these generators are managed
separately from MSW.
Households are the primary direct source of MSW, followed by the com-
mercial sector. On average, each U.S. household directly generated 790 kg
of solid waste in 1986. The commercial, industrial, and other sectors each
directly generate smaller portions of MSW than households. The industrial
sector manages most of its own solid residuals, whether MSW or industrial
process wastes, by recycling, reuse, or self disposal. For this reason indus-
try directly contributes only a small share of the MSW flow, although some
industrial process wastes do end up as MSW.
Little empirical evidence is available about the factors that affect waste
generation rates. However, without substantial changes in market condi-
tions or policies that promote more recycling and the use of less residual-
intensive production, packaging, and consumption methods, increases in
economic activity and in the population indicate that MSW will increase
in the future. Franklin Associates[12] estimates that MSW will increase
at an annual rate of approximately 1.5 percent over the 1984-2000 period.
This growth rate is slightly more than the population growth rate, indicat-
ing an increase in expected per-capita waste generation.
8-2
-------
8.1.2 Collection and Disposal
Governments—local, state, and federal—play a large role in regulating
and operating MSW management systems. Governmental influence, how-
ever, is limited. Material, engineering, geographic, cost, and other technical
and economic conditions spell out some of the limits.
In addition, all MSW management systems ultimately involve private
decision makers. Households and private firms generate most MSW, col-
lect and transport MSW, build and operate MSW disposal systems, pro-
vide financing, and provide markets for recycled material. In some settings
these private activities compete with public operations; in others, they pro-
vide factors of production and demand for outputs from public operations.
Whatever the case, these technical and market relationships are important
factors in conditioning the influence of local governments on MSW man-
agement generally and the economic impact of changes in the cost of MWC
in particular.
8.1.2.1 Collection
Local governments, especially in more urbanized areas, often take the
lead in organizing MSW management and, in many cases, providing collec-
tion and disposal services. A wide variety of reasons explain this involve-
ment: concern for the public health threat of uncollected or improperly dis-
posed MSW, natural economies of scale in organizing and performing MSW
collection and disposal, and a concern for the negative externalities—litter,
noise, smells, traffic—sometimes associated with private collection and dis-
posal. These negative externalities are not necessarily unhealthy, but they
are detractions from public welfare.
How extensive is the local government role? Four market structures for
MSW collection predominate:
• Public monopoly—public agency collects all MSW.
• Private monopoly—private firm(s) collect(s) all MSW in a specific
area under a franchise agreement and is (are) reimbursed by the local
government.
8-3
-------
• Competitive—public agency and private firm(s) both collect MSW.
• Self service—generators haul their MSW to disposal sites.
Most residential refuse is collected under the first three market struc-
tures; about 50 percent is collected under the first. A large fraction of
private service is provided by contractors selected by local governments.
In such cases, the government plays a role in selecting the private collec-
tion firm, specifying the terms and conditions of collection, and paying the
private collector for the service.
8.1.2.2 Disposal
Waste disposal facilities, especially landfills, are more likely to be owned
or operated by local governments than are collection services.1 In general,
local governments feel a strong responsibility to ensure that MSW generated
and collected in their jurisdiction has a proper place to go. Owning or
operating the disposal facility provides them with the necessary control.
Table 8.1 shows the ownership pattern for combustors. A sizable fraction
of combustors and landfills are owned or operated by a regional service
district. For example, the combustor in Duluth, MN, is owned and operated
by a special service district created by the state legislature. This district
has responsibility for wastewater and MSW treatment of some half dozen
municipalities in the Duluth area. There is a trend—due to economies of
scale in MSW management operations, and state government policy and
legislation—toward forming sanitation authorities that encompass multiple
local government jurisdictions.
In recent years, states have taken a more active role in shaping the
MSW management practices in their jurisdiction. While the nature and
level of state initiatives vary tremendously, many states have become ac-
tive in providing a framework for organizing and planning local MSW man-
agement. States most prominent in this area are those confronting serious
MSW management problems due to dense populations, large amounts of
waste, limited space for disposal sites, and the vulnerability of their natural
environment.
1 For waste disposal facilities it is common for the operator of the facility to be different
from the owner.
8-4
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Table 8.1: Ownership of Municipal Waste Combustors, by Size
(Number of MWC Plants, 1988)
Ownership
Public
Private
Unknown*
TOTAL6
Waste
<10 10-30
7 12
5 5
Received (103 Mg per Year)
30-50 50-100 100-250 >250
8
1
8 14.. 10
401
ALL
59
16
31
106
Ownership data currently are not available.
Total represents number of respondents in a survey, not the total
number of plants in the country.
The Federal Government, through legislation, regulation, demonstra-
tion, and guidance influences solid waste management in a variety of ways.
Two laws that have been especially important to MWC activity have been
the Public Utility Regulatory Policy Act of 1978 (PURPA) and the Tax
Reform Act of 1986. Under PURPA regulations, independent small power
generators have better opportunities, under more favorable financial terms,
to provide electricity to electric utilities. This has spurred the development
of MWCs that produce electricity. The Tax Reform Act of 1986, on the
other hand, has reduced the tax and financing advantages available to pri-
vate owners of new MWCs. Although many upcoming MWC projects are
"grandfathered" under the Act, in the long run the Tax Reform Act will
promote municipal ownership.
8.1.3 Decision Making
The design and operation of a MS W management system requires many
decisions. These decisions are constrained by technical and economic fac-
tors and have implications for generators and managers of solid waste as
8-5
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well as for suppliers of inputs of MSW management services (labor, land
owners, etc.) and area residents.
For example, governments decide which institutional arrangement to use
for waste collection and disposal. Depending on the institutional arrange-
ments, public and private decision makers must choose the amount and
type of solid waste to generate (the demand side) and disposal processes
to provide—recycling, combustion, and landfilling (the supply side). For
each process they must determine the appropriate locations, scales, and de-
sign lifetimes. Imposition of the Standards and Guidelines will affect these
choices.
8.1.3.1 Private Decision Making
Households and firms that generate waste respond to increases in the
price of waste collection by reducing the amount of waste generated. The
proportionate reduction may not be large, but if the price increase is large
enough, the effect will be noticeable. By the same token, however, if cost
increases in the MWC portion of the management system are not fully
reflected in prices or are not tied to the amount of waste generated, there
will be little or no change in waste generation attributable to the Standards
and Guidelines beyond that associated with "income effects" due to changes
in taxes.
Similarly, firms that collect, transport, and/or dispose of waste are as-
sumed to respond to changes in the cost of production by adjusting their
input mix to keep costs down and by passing as much of the remaining cost
increase on to their customers (as price increases) as market conditions
and contractual arrangements allow. In the case of a new MWC plant, the
prospective owner has a broader set of available options for reducing cost,
including changing the disposal technology selected or not building a plant
at all. In the end, however, local market conditions must be seen by the
prospective owner as supporting a disposal price that covers the minimum
cost method of providing disposal services. The extent that MWC owners
can raise prices and the degree to which this is accompanied by a change
in the amount of waste combusted depends on the demand for combustion
services in the local market. This demand depends on the share of com-
bustion services used, the availability of substitutes, and the demand for
disposal services generally. While institutional conditions associated with
8-6
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local, state, or federal policies will affect these determinants of demand, in
this analysis private parties accept such institutional conditions as given
and make production and investment decisions so as to maximize profit or,
equivalently in a competitive market, minimize the cost.
8.1.3.2 Government Decision Making
Government decision making is of particular concern in this analysis
due to the large role that government plays at every level, especially the
local level, in shaping MSW management systems. Theoretical and applied
economic literature does not provide much positive guidance on the be-
havior of governments. On the other hand, normative literature on MSW
management decision making, much of it aimed at decision making by pub-
lic officials, often assumes that cost minimization, sometimes referred to
as "project economics," is the implicit basis on which decisions regard-
ing MSW management are reached. Consequently, this literature addresses
methods and means by which the decision maker can make the correct, cost-
minimizing choice. Authors who are not enthusiastic about conventional
waste disposal options couch their arguments against extensive MSW com-
bustion and for recycling in cost-minimizing terms. Thus, it seems that
local or municipal MSW system decision making represents cost minimiza-
tion, subject to the constraint that all MSW must be collected and properly
disposed. It differs from private decision making in that the minimum cost
is assessed based on centralized accounting of costs of various combinations
of MSW management alternatives, some of which may not be feasible for
a private firm due to institutional or financial constraints.
8.2 Baseline Projections
To analyze the impact of the Standards and Guidelines, estimated levels
of new activity in relevant markets must be compared before and after
regulation. The baseline is what the world would be like if there were
no Standards and Guidelines. The baseline conditions are compared with
conditions as they are projected to be under various regulatory alternatives.
The baseline level of MWC activity depends on how much solid waste is
generated and what other waste disposal methods are available and in use,
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including landfilling and recycling. Thus, baseline projections should take
into account not only solid waste combustion but also solid waste generation
and the amount of solid waste managed by other major methods.
EPA compiled MSW data for 1986, the last year for which such data
are reasonably complete. EPA adjusted the 1986 data for differences in def-
initions and coverage. This meant subtracting auto bodies, sewage sludge,
some construction waste, some recycled items, and the like from the 1986
data, and making other adjustments to bring the data in line with the def-
inition of MSW used for the Standards and Guidelines. It was not possible
to identify and subtract out items littered and self disposed; such items are
ignored in the projections. MWC ash that was not landfilled with MSW in
1986, that is, ash that was "monofilled" in landfills dedicated to ash, was
subtracted, and the assumption made that all future increases in MWC ash
will be monofilled and not treated as MSW.
Included in the collected data are several published projections of MSW
generation and disposal. The most useful projections, and the ones that
form the basis of the baseline projections for the Standards and Guide-
lines, were prepared by Franklin Associates for EPA.[12] The adjustments
made to the 1986 data were applied to the Franklin Associates projections,
and values for 1991 and 1996 were interpolated. MWCs affected by the
Guidelines are those existing and those placed under construction by the
end of 1989, all of which should be operating in 1991.2 Similarly, MWCs
affected by the Standards in the first five years will be those operating in
1996, less MWCs covered by the Guidelines. The adjusted projections for
MSW to be landfilled holds reasonably constant, and therefore was set at a
constant value. The remainder is projected to be recycled or combusted.3
The projections are in Table 8.2.
(EPA's goal for the nation for 1992, set in the Agenda for Action, is to
reduce MSW by 25 percent using source reduction and recycling techniques.
In the Agenda EPA projects that 20 percent of MSW will be combusted
and 55 percent will be landfilled in 1992.[14] The Standards and Guidelines
2The substitution scenario for the Guidelines allows for the closure of some existing
MWCs. This is explained in the next chapter.
3At the same time EPA was nailing down baseline projections for the Standards and
Guidelines, it also was preparing baseline projections for the parallel landfill air emission
CAA §111 standards and guidelines. Fixing the amount of MSW to be landfilled and
assuming the remainder will be recycled or combusted is an analytical convenience that
appears to be a pretty good guess of what actually will happen.
8-8
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Table 8.2: MSW Disposal Projections
Disposal
Method
Landfilling
Recycling
Combusting
TOTAL
1986
(106 Mg)
188.1
15.3
14.4
217.8
1991
(106 Mg)
188.1
17.2
29.4
234.7
1996
(106 Mg)
188.1
19.7
44.3
252.1
require substantial materials separation. Table 8.2 shows 17.2 and 19.7
million Mg for recycling in 1991 and 1996, or 7.3 and 7.8 percent of the
totals, respectively—not exactly the desired 25 percent. Similarly, only 12.5
and 17.6 percent of MSW is projected in this regulatory impact analysis
to be combusted in 1991 and 1996, respectively. This situation may seem
to be a paradox. However, the baseline projections for the Standards a.nd
Guidelines are only for analytical purposes, and should not be interpreted as
alternatives to the goals and projections used in the Agenda. To the extent
the nation recycles more than 7.3 and 7.8 percent of MSW in 1991 and
1996, there will be a reduced demand for MWC and landfill services, and
the nationwide costs and emission reductions associated with the Standards
and Guidelines will be smaller. On the other hand, to the extent the nation
combusts more than 12.5 and 17.6 percent of the MSW in 1991 and 1996,
the demand for MWC services will be larger, and the nationwide costs and
emissions associated with the Standards and Guidelines will be larger.)
EPA inventoried all MWCs operating or under construction in 1988, and
collected announcements of new MWCs planned for construction through
1994. The total capacity of these plants substantially exceeded what would
be needed to combust 44.3 million Mg of MSW. (See Table 8.2.) The
announced but not yet begun MWCs therefore were cut back, but the
proportion of each type and size of announced plants was held constant.
To arrive at the final baseline projection numbers of MWCs that will be
affected by the Standards and Guidelines, EPA applied the two different
capacity utilization assumptions described above in Section 7.1.4 and below
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in Table 8.3.
The baseline projections are summarized in Table 8.3 in the form of
scaling factors. Each factor is the number of "real world" MWCs repre-
sented by the matching model plant. (It may appear odd to have fractional
numbers of plants, but the factors that result from the baseline projection
process does not produce whole numbers.) There will be about 65 MWCs
affected by the Standards. (The Series A total for Table 8.3 is about 67
and the Series B total, which is smaller because each MWC is assumed
to combust more MSW by operating more hours, is about 63.) There are
about 113 existing MWCs that are projected to remain open, and another
67 that will begin construction in time to bring the total number of MWCs
affected by the Guidelines to about 180. (The Series A total is about 184
and the Series B total, about 177.)
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Table 8.3: Model Plant Scaling Factors
Model
Plant
1
2
3
4
5
6
7
8
9
10
11
12
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
—
Abbreviation
^Z -f ftf\f\ £>¥**"! G
MB/WW (small)
MB/WW (mid-size)
MB/WW (large)
MB/REF
MB/RC
RDF
RDF/CF
MOD/EA
MOD/SA (small)
MOD/SA (mid-size)
FBC/CB
FBC/BB
• viiifi 0 lin**c
MB/REF/TG
MB/REF/RG
MB/REF/RK
MB/WW (large)
MB/WW (mid-size)
MB/WW (small)
RDF (large)
RDF (small)
MOD/SA/TR
MOD/SA/G
MOD/EA
MB/RWW
TRANS MOD/EA
TRANS MB/WW
TRANS RDF (large)
TRANS RDF (small)
TRANS MB/RWW
Unassigned
Scaling
Series Aa
16.81
7.28
8.49
3.24
3.24
5.29
3.31
3.35
1.80
7.13
2.06
4.54
5.53
22.75
4.78
11.05
17.51
9.30
5.00
14.10
19.56
46.60
8.38
2.43
2.11
2.91
4.22
2.64
4.27
1.087
Factor
Series B6
16.81
6.75
7.88
3.00
3.00
4.88
3.00
3.00
1.80
6.38
1.88
4.13
5.53
22.75
4.78
10.13
15.39
9.30
5.00
14.10
18.75
46.50
8.38
2.43
1.64
2.34
3.31
2.08
3.44
1.090
Series A is based on the annual operating hours given in Table 7.2.
Series B is based on 8,000 annual operating hours, except that model plants with
the special conditions noted in Table 7.2 have the annual operating hours given in
that Table.
8-11
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Chapter 9
Economic Analysis Objectives
and Methodology
9.1 Introduction
Economic analyses serve a variety of functions. They can tell us some-
thing about the affordability of regulations, whether regulations will be
inflationary, whether they will be efficient in achieving their purposes,
whether they will alter production technology or the types of goods con-
sumers purchase, and whether some groups will be adversely affected out
of proportion to their contribution to pollution. Economic analyses give
EPA insight in how to draft regulations so that positive impacts will be
maximized and negative impacts minimized. The analyses produce much
of the input data needed for benefit analyses. The degree any and all of
these functions are met depends on many factors. Although the resources
devoted to conducting an economic analysis generally are in proportion to
how costly the regulation might be to the economy, the usefulness and ac-
curacy of the economic findings relate as well to the availability of reliable
data and the predictability of the sector(s) of the economy that will be
regulated.
The reader is encouraged to read the economic analysis reports[4,5] for a
complete description of the economic analysis objectives and methodology.1
1The Research Triangle Institute (RTI) prepared two separate economic analyses for
9-1
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This chapter begins with a look at some of the special features that have
influenced both how the detailed analytical and procedural objectives were
formulated, and what the analysis is able to show.
9.1.1 Special Features of the Analysis
The economic analysis conducted for development of the Standards and
Guidelines has some special features that make it different from other analy-
ses for CAA §111 actions. These features relate to the nature of the eco-
nomic activity surrounding MWCs, to the types of pollutants and their
control devices, and to an internal EPA desire to coordinate its regulatory
activities. The features:
• A mix of public and private MWCs will be regulated. Most regula-
tions apply to public enterprises or to private businesses, but not to
both. The two types of owners experience different market conditions
and react to regulation differently.
• MWCs operate as components of mostly-integrated MSW collection
and disposal systems in local, partly-regulated markets. There are
almost as many different market structures as there are local areas.
The relative absence of a free competitive market, and the great di-
versity of local conditions, make it difficult to predict what prices are
likely to change and who will be most affected. This means that no
market mechanism will cause control costs to be passed through in a
particular manner, such as by increases in MWC tipping fees, prop-
erty taxes, or MSW collection charges. It has been difficult for EPA
to speculate about average potential tipping fee increases, and all but
impossible to say anything at all about the statistical distribution of
potential absolute or percentage tipping fee increases.
• Each air pollution control measure targets a handful of pollutants, so
that traditional cost/effectiveness measures are of questionable use-
fulness. This is because the only meaningful way to add up reductions
EPA, one for the Standards and one for the Guidelines. A substantial effort was made to
integrate the two studies, for example, by using consistent projections of MSW flows to
combustors. However, EPA and RTI have not analyzed the interrelationship of the Stan-
dards and Guidelines. The economic and environmental impacts of the Guidelines depend
to some degree on the stringency of the Standards, and vice versa. This interrelationship
is particularly important in the substitution scenarios described in Section9.3.4.
9-2
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of different pollutant emissions into a measure of effectiveness is to
add up the benefits of the emission reductions, and most of these
benefits can not be quantified, let alone monetized.
• Simultaneous with development of the Standards and Guidelines,
EPA and some states are developing other regulations for various
facets of MSW disposal operations. This creates real problems in
defining the baseline conditions for the Standards and Guidelines,
and it creates real problems in coordinating regulations. The base-
line is supposed to reflect what the world would be like if there were
no Standards and Guidelines. But it seems as though everything re-
lating to MSW generation and disposal is changing all at once. The
regulations EPA has promulgated and has in the pipeline are a big
part of the reason for that change. Without a well defined and reason-
ably stable baseline it is hard to isolate and understand what changes
may be spawned by the Standards and Guidelines. The fact that so
many regulatory (and legislative) initiatives are in the mill makes it
hard to be sure that all interactions have been considered and that
unintended effects will be avoided.
• EPA is initiating a new, improved, but not yet widely understood pro-
cedure for discounting and annualizing regulatory costs. It is called
two-stage discounting. In it, capital control costs are discounted and
annualized differently from operating control costs. Fortunately for
the Standards and Guidelines, the new procedure produces almost
the same results as the old procedure, assuaging the concerns of some
analysts not yet convinced that two-stage discounting is proper.
9.2 Objectives
EPA attempts to develop regulations that are protective of the environ-
ment and the public health and welfare, that are the the least disruptive to
the economy, and that do no undue harm to small entities. To do this, EPA
analyzes the potential economic and environmental impacts of regulatory
alternatives, and uses the findings to help shape the form and content of
the final regulatory package. For the Standards and Guidelines, this broad
objective translates into specific analytical and procedural objectives:
• To analyze market response to regulation
9-3
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— How might prices in general, and MWC tipping fees in particular,
change after the Standards and Guidelines take effect?
— How might regulation affect preferences for one or another MWC
technology, and affect the balance among landfilling, combust-
ing, recycling, and other MSW disposal activities?
— What will the national costs and environmental impacts be?
— Who will pay, how, and how much?
• To aid in regulatory decision making
— Are there economic—cost/effectiveness, benefit-cost, cost-distri-
butional (equity), or economic efficiency—arguments for favor-
ing one or another regulatory approach or regulatory alterna-
tive?
— Should different sizes of MWCs be regulated differently? Should
there be a cutoff size below which MWCs would not be regu-
lated?
• To facilitate coordination
— How should the Standards and Guidelines affect or be affected
by parallel air regulations being developed for MSW landfills?
How should the Standards and Guidelines relate to other ongoing
EPA regulatory activities relating to MSW disposal?
— How can the Standards and Guidelines best fit into and promote
EPA's national MSW disposal goals advanced in An Agenda for
Action[U}t
— Does economic modeling reveal or highlight problems with engi-
neering data? If so, how significant are the problems and what
corrective action is warranted?
— Is the regulatory baseline, including the baseline projections of
MWCs (number, type, capacity, capacity utilization, etc.), rea-
sonable and suitable?
The objectives of the benefits analysis are discussed in Chapter 12.
9-4
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Table 8.2: MSW Disposal Projections
Disposal
Method
Landfilling
Recycling
Combusting
TOTAL
1986
(106 Mg)
188.1
15.3
14.4
217.8
1991
(106 Mg)
188.1
17.2
29.4
234.7
1996
(106 Mg)
188.1
19.7
44.3
252.1
require substantial materials separation. Table 8.2 shows 17.2 and 19.7
million Mg for recycling in 1991 and 1996, or 7.3 and 7.8 percent of the
totals, respectively—not exactly the desired 25 percent. Similarly, only 12.5
and 17.6 percent of MSW is projected in this regulatory impact analysis
to be combusted in 1991 and 1996, respectively. This situation may seem
to be a paradox. However, the baseline projections for the Standards and
Guidelines are only for analytical purposes, and should not be interpreted as
alternatives to the goals and projections used in the Agenda. To the extent
the nation recycles more than 7.3 and 7.8 percent of MSW in 1991 and
1996, there will be a reduced demand for MWC and landfill services, and
the nationwide costs and emission reductions associated with the Standards
and Guidelines will be smaller. On the other hand, to the extent the nation
combusts more than 12.5 and 17.6 percent of the MSW in 1991 and 1996,
the demand for MWC services will be larger, and the nationwide costs and
emissions associated with the Standards and Guidelines will be larger.)
EPA inventoried all MWCs operating or under construction in 1988, and
collected announcements of new MWCs planned for construction through
1994. The total capacity of these plants substantially exceeded what would
be needed to combust 44.3 million Mg of MSW. (See Table 8.2.) The
announced but not yet begun MWCs therefore were cut back, but the
proportion of each type and size of announced plants was held constant.
To arrive at the final baseline projection numbers of MWCs that will be
affected by the Standards and Guidelines, EPA applied the two different
capacity utilization assumptions described above in Section 7.1.4 and below
8-9
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the analysis, and thereafter was used in all calculations presented in this
regulatory impact analysis. The cost-per-Mg figures then were used, both
on the model plant level and aggregated to the national level, as surrogates
for MWC tipping fee increases. The distributional impacts on local govern-
ments and households were calculated, as reported below in Chapter 11.
EPA studied municipal decision making in the area of MSW disposal,
and constructed two models to predict how municipalities might react to the
Standards and Guidelines. For the Standards, the model is an econometric
equation that predicts the likelihood that any particular local government
will landfill or combust MSW, and if the selection is combustion, the like-
lihood of selecting a particular type of MWC. Unfortunately, this model
is not able to predict whether existing MWCs might be closed. Therefore,
for the Guidelines, the decision model is a least-cost simulation model that
predicts only whether an existing MWC will be closed in favor of a new
but more economical MWC of like size. Both models operate on the cost-
per-Mg figures developed as described in the preceding paragraph, and are
used in the analysis of substitution.
In the next step, EPA switched from an enterprise accounting base to
a social accounting base. In enterprise accounting, the real (constant dol-
lar) municipal bond rate of 4 percent is used as the rate for annualizing
capital costs of control. In social accounting, the capital costs of control
are annualized at a rate reflecting society's real opportunity cost of capital,
which is assumed to be 10 percent. (If the operating costs had not been
expressed as annual costs, EPA would have annualized them using society's
real opportunity cost of consumption, which is assumed to be 3 percent.)2
The national social cost of the Standards and Guidelines were computed
for the no-substitution and substitution scenarios. For the no-substitution
scenario and the Guidelines substitution scenario, the scaling factors in Ta-
ble 8.3 were used to aggregate model plant data up to the national scale.
For the Standards substitution scenario, different scaling factors were used,
as explained in Section 9.3.4 below. Emission reductions and other environ-
mental impacts also were aggregated to the national scale with the scaling
factors.
Finally, many inputs, such as the rates used for discounting and annu-
2The computational difference between enterprise costs and social costs results in espe-
cially large differences in the present values of control costs. See references [4,5]. However,
no present value statistics are used in this regulatory impact analysis.
9-6
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alizing, were changed for a sensitivity analysis. Such analyses indicate how
sensitive national regulatory costs are to changes in input values.
9.3.3 Assumptions and Conventions
Myriad assumptions, analytical conventions, and underlying calcula-
tions form the basis for projecting the economic impacts of EPA regulations.
Table 9.1 summarizes the principal assumptions, conventions, and calcu-
lated values used in this regulatory impact analysis. As just mentioned,
EPA conducted numerous computer sensitivity analyses to see whether and
how projected impacts would be different if some of these items are changed.
The first two entries in the table are self-explanatory. The third entry,
the date for which impacts are evaluated, is January 1, 1995, five years after
the assumed effective date of both the Standards and Guidelines. Except
in unusual circumstances, EPA's horizon for projecting total annual costs
of air regulations is five years. Because no closures of existing MWCs are
projected after the initial adjustment to the Guidelines is made, the total
annual costs for the Guidelines remain constant for essentially all years
of the first equipment lifecycle of 15 years. For the Standards, the total
annual costs will change year-by-year at least through the first equipment
lifecycle, so the fifth year is only one "snapshot" of annual costs. Only
MWCs projected to begin construction during the five years are analyzed.
This is mathematically consistent with a projection that the annual amount
of MSW combusted after 1996 (when MWCs begun in 1994 come on-line)
will remain constant at 1996 levels in perpetuity.
The next five entries may be somewhat confusing to those unfamiliar
with analytical protocols. EPA assumes that all capital costs of control
for each model plant are incurred at the outset of an equipment lifecycle
(equipment lifetime) of 15 years, that annual operating and maintenance
expenditures and annual recovery credits are unchanging over the cycle,
and that salvage value at the end of the cycle equals the cost of removing
the worn-out equipment and restoring the site. To ensure that the length
of the cycle does not unnecessarily cause cost and revenue profiles among
cycles to be different, EPA has adjusted estimated plant life so that the
duration of an equipment cycle is divisible into the economic lifetime of a
plant a whole number of times. (If this were not done, it would be necessary
9-7
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Table 9.1: Assumptions and Conventions Used in the Economic Analysis
Effective date for Standards and Guidelines: January 1, 1990
Affected MWCs: All MWCs placed under construction (A) on or after the effec-
tive date (Standards), or (B) before the effective date (Guidelines)
Date for which impacts are evaluated: January 1, 1995—5 years after com-
pliance costs begin (MWCs begun after 1994 are not analyzed. The timing of
construction of new MWCs over this 5-year analysis period is ignored.)
Lifetimes of physical facilities
— MWCs: Standards—30 years after compliance costs begin
Guidelines—15 years after compliance costs begin
- APCDs: 15 years
% utilization of daily capacity (There are some exceptions. These percents
remain constant over time.)
- Mass burn: 85% - RDF and FBC: 83% - Modular: 82%
Monetary unit: Constant (real) fourth quarter 1987 dollars
Capital costs for each MWC and APCD
- Incurred only at the outset of operation of the MWC or APCD
- Amortized over the lifetime of the MWC or APCD
Annual operating costs and revenues for each MWC and APCD
- Invariant over the lifetime of the MWC or APCD
- Proportional to MWC capacity utilization (for analysis purposes when alter-
native capacity utilization rates are introduced)
Market interest (discount) rate for computing potential tipping fee increases
and analyzing the distribution of costs (Rate is for public MWCs. Allowance for an
equivalent rate for private MWCs would not change economic findings.)
- 4% real municipal revenue bond rate
Social interest (discount) rates for computing social costs
- 10% for capital
— 3% for consumption
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to use plant life, rather than the equipment cycle, as the analysis unit,
because the last equipment cycle in the life of a plant would have more
or fewer years to amortize capital costs. EPA believes this adjustment
does not introduce bias into the calculations.) For MWCs, EPA assumes
that the equipment cycle is exactly one-half of the economic lifetime of
new plants and equal to the remaining economic lifetime of existing plants.
None of these assumptions and procedures is needed to avoid computational
complexity. However, the detail and accuracy of the engineering cost data
are inadequate to support greater realism.
EPA further assumes that model plant capacity utilization, and its an-
alytical counterparts employment and annual emission reductions, remain
unchanged through an equipment cycle. This assumption avoids compu-
tational complexity as well as controversy relating to the evaluation of an
uneven flow of emission reductions over time. The assumption that annual
operating costs and revenues vary in proportion to capacity utilization is
needed only for investigating the sensitivity of the economic findings to the
assumed model plant capacity utilization percentages.
These assumptions lead to an analytical convenience, namely, annual air
pollution control costs, for both model plants and for the nation as a whole,
are independent of the number of equipment cycles analyzed. All findings
reported in this regulatory impact analysis are based on the analysis of only
one equipment cycle, but are equally valid for two, three, or any number of
cycles.3
The economic analysis reports[4,5] give the derivation of the interest (or
discount) rates shown as the last two items in Table 9.1. In addition to
the rates shown, EPA developed the weighted average cost of capital for
private MWCs, which is, in the terminology of Table 9.1, the real market
interest (or discount) rate for private MWCs. Because this private rate is
not used in calculating national social costs, and has only a small effect
on the results of an analysis of the distribution of costs, it is not used in
this regulatory impact analysis. EPA uses the new two-stage discounting
procedure for computing national social costs; hence two social rates are
shown in the table. (The term "social costs" refers to the regulatory costs
3Some baseline capital costs—not APCD costs—for new MWCs are amortized in this
regulatory impact analysis over the expected 30-year lifetime of the MWC. Also, the eco-
nomic reports[4,5] have some present value calculations of APCD costs where the number
of equipment cycles analyzed does make a difference.
9-9
-------
to the nation as a whole. Largely due to the combined effects of taxes and
interest (or discount) rates, national social costs are not the sum of costs
felt by each affected MWC. Costs felt by each affected MWC are called
"enterprise costs" in this regulatory impact analysis.)
Additional assumptions are mentioned below as they relate to substitu-
tion.
9.3.4 Substitution Scenarios
9.3.4.1 Concept
The second of the analytical objectives listed above is to find answers
to the question:
How might regulation affect preferences for one or another MWC
technology, and affect the balance among landfilling, combust-
ing, recycling, and other MSW disposal activities?
If the regulatory costs might cause municipalities to do more landfilling and
less combusting of MSW, the result might in the long run be neither cheaper
for society nor environmentally safer. Furthermore, regulatory costs might
cause municipalities to stop building, say, RDF MWCs and to build mass
burn MWCs in their places. The consequences of such a switch also could be
of concern. EPA therefore uses two scenarios in the economic analysis. In
the first, municipalities do just as projected in the baseline. The Standards
and Guidelines are assumed to not cause any change in the types of MWCs
used. In the second, municipalities are allowed to change their minds. Two
substitution decision models are used, one for the Standards and a different
one for the Guidelines.
0.3.4.2 No-Substitution Scenario
In this scenario municipalities continue to operate existing MWCs, and
build new ones, as described in the baseline projections (Chapter 8). The
costs of the regulatory alternatives are as depicted in Tables 7.5 and 7.6.
9-10
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The demand for combustion services is assumed to be perfectly inelastic,
that is, constant in the face of rising costs. The inelasticity could be due to
inelastic demand per se, or to institutional arrangements that do not allow
any increase in costs to be passed on directly to waste generators. Thus,
this no-substitution scenario is a reasonably worst-case scenario in that it
leads to projections of higher national costs of control than are likely to
occur. It also leads to projections of greater emission reductions than are
likely.
9.3.4.3 Substitution Scenario
Standards. The substitution scenario for analysis of the Standards
employs an econometric model and many ratios to arrive at new scaling
factors to replace those for Series A, Table 8.3. There are new scaling
factors for each regulatory alternative. EPA reran most of the economic
analysis models with the new scaling factors to obtain the results for the
substitution scenario reported in the next chapter.
The econometric model is based on data on actual municipal choices to
build landfills, mass burn MWCs, modular MWCs, and RDF MWCs. Engi-
neering cost data, MWC financial and operating parameters, landfill costs,
site information, educational attainment of residents, population density,
and manufacturing intensity for many local areas have been processed into
a set of equations that can be used to produce probabilities. For a munici-
pality with a given set of these attributes and an MSW disposal decision to
make, the model indicates the probability that landfilling will be selected,
the probability that a mass burn MWC will be selected, and so on. EPA
aggregates these probabilities across municipalities to estimate the shares of
yearly MSW processing capacity for each of the four technologies. Changes
in costs due to regulation result in new share estimates.
The next step for EPA is to decide how much MSW is available for dis-
posal. The annual fill rate for landfills that are expected to close during the
5-year analysis period is added to the baseline combustion rate used in the
no-substitution scenario. With this information, EPA applies a sequence
of ratios to convert the estimated technology share numbers into revised
scaling factors.
The substitution scenario findings are examined in Chapter 10. The
9-11
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reader should be aware of the uncertainties involved when interpreting
these findings. First, the econometric model has shortcomings. It could
not incorporate recent technology, such as FBC MWCs, or some upcoming
regulatory costs, such as those that will result from the landfill air emission
CAA §111 standards and guidelines. (EPA is able to account for RCRA
Subtitle D regulatory costs.) Econometric models by their nature use ob-
servations from the past to develop relationships to be used in projections
of the future. The MSW disposal industry is very dynamic; past relation-
ships may be altered and therefore may not be the best predictors of future
decisions. Second, there is no easily definable baseline for the substitution
scenario. As each successive regulatory alternative is studied, the number
and mix of MWCs changes. There is no good way to find the incremental
costs and emission reductions associated with moving from one regulatory
alternative to another without tabulating emissions and costs for MSW
that is not combusted, and that is outside the scope of this analysis. In
short, the substitution scenario findings are informative but not adequate
by themselves for selecting a regulatory alternative.
Guidelines. When the operating costs of an existing MWC exceed
the operating costs plus capital amortization for a new MWC on a per-Mg
combusted basis, it usually is time to retire the old plant. EPA makes these
comparisons for Guidelines model plants under baseline conditions and for
each regulatory alternative. The findings, described in Chapter 10, are that
the three refactory wall mass burn MWCs, which have no energy recovery,
are likely to shut down and be replaced by mass burn and modular MWCs
even in the absence of the Guidelines. After this adjustment, EPA finds
no case where the Guidelines costs would induce the closure of an existing
plant.
The costs for a new MWC comparable to an existing MWC are esti-
mated using regression analysis applied to new plant cost data for (1) mass
burn technology for consideration as a substitute for large existing plants,
and (2) modular technology for consideration as a substitute for small ex-
isting MWCs. Baseline capital costs, operating costs, and energy recovery
credits are regressed on plant capacity. A good fit between estimated and
actual values is obtained.
The regression equations are used to estimate the per-Mg costs of new
MWCs identical in size to each of the mass burn and modular model plants
9-12
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for the baseline and each regulatory alternative.4 Wherever the per-Mg
costs for the existing plant exceed 115 percent of the per-Mg costs for the
comparable new plant, a substitution is assumed. The scaling factors in
Table 8.3 are retained.
Just as a few cautionary notes are needed to interpret the substitution
findings for the Standards, so too with the Guidelines. While the engineer-
ing cost estimates used in this analysis are suitable for comparing costs of
slightly different sizes and features for one particular type of plant, they
are not as suitable for comparing costs of different types of MWCs. In-
deed, RDF and FBC MWCs are excluded from the substitution analysis
for just this reason. EPA believes the RDF and FBC APCD costs are
valid, but recognizes that the baseline plant cost data are not adequate for
comparisons among combustor types. Furthermore, it is not clear that cost
minimization is the sole criterion in local MSW disposal decisions. Exist-
ing institutional arrangements, such as legal agreements to deliver certain
quantities of MSW to existing combustors, may preclude the closure of old
plants even when they are money losers. (Recall that the Standards substi-
tution econometric model is based on how local governments actually have
behaved in a world where cost minimization is only one of many considera-
tions.) Finally, the cost comparisons do not include landfills as alternatives
to MWCs.
4 At this step in the analysis, EPA assumed that the level of control for the new re-
placement MWC would be the same as that for the existing MWC, both in the baseline
and for each of the Guidelines' regulatory alternatives. This simplification overlooks the
probability that there will be many situations where the new MWC would be required to
have more stringent controls that would the existing MWC of similar size.
9-13
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Chapter 10
Economic Analysis Findings
10.1 Scope
The economic analysis accomplished many, but not all, of the objectives
listed above in Section 9.2. The principal findings are highlighted here; the
reader is encouraged to read the separate economic analysis reports (refer-
ences [4] and [5]) for details. Regulatory costs are presented in two forms:
enterprise costs (experienced by the MWCs) and social costs (experienced
by society as a whole). Enterprise costs yield insights about potential tip-
ping fee increases at MWCs. Enterprise costs also yield insights about
how the Standards and Guidelines might influence municipalities' choices
of MSW disposal technology in the years ahead. The national social costs
are the national costs traditionally associated with emission regulations. In
a very general way they can be compared with the emission reductions re-
sulting from regulation. Chapter 10 presents both the national social costs
and the national emission reductions, and describes how sensitive these
numbers are to the analysis inputs of (1) rates used for annualizing capital
costs and (2) MWC capacity utilization percentages. Finally, Chapter 10
discusses some of the costs that are not included in the tabulations.
Economic analysis findings regarding the distribution of costs are in
Chapter 11.
10-1
-------
The tables in Chapter 10 present data according to scenario and regu-
latory alternative. The no-substitution scenario is the way the world would
be if municipalities proceeded just as depicted in the baseline projections.
That is, there is an assumption that the baseline projections are accurate
and that the Standards and Guidelines will not influence the number and
type of MWCs that will be built and/or used over the analysis period. The
substitution scenario for the Standards is a projection of what the world
would be like if municipalities allow the EPA regulation to influence their
decisions on whether to landfill or combust MSW, and where decisions
are to combust, on what types of MWCs to select. The substitution sce-
nario for the Guidelines gives municipalities only the decision of whether
to replace existing MWCs with new MWCs. More information on how the
substitution scenarios are constructed is in Section 9.3.4.
Control costs for materials separation, NOX, and regulatory
alternative IIB', as well as associated emission reductions, are
not included in the tabular results. Revised PM emission limits
for existing MWCs have not been used in generating the tables.
Materials separation costs are expected to be negligible in the long run for
the average MWC. Emission reductions attributable to materials separa-
tion have not been calculated. Total national annual social NOx control
costs in the fifth year after the Standards are proposed will be about $30
million, or about $2 per Mg of MSW combusted. Capital costs will be about
$97 million. National NOX emissions will drop by about 12,000 Mg/year,
or by about 40 percent. For the Guidelines, regulatory alternative IIB'
national annual social costs will be about $20 million less than equivalent
costs for regulatory alternative IIB, or about a decrease of $0.70 per Mg of
MSW combusted. Capital costs will be about $60 million less than those
for regulatory alternative IIB. National emissions of MWC organics, HC1,
and PM will be about the same from regulatory alternative IIB levels.1
National emissions of SO2 will be about five percent higher than regulatory
alternative IIB levels.
1 Costs and emission reductions described in this paragraph are based on the
capacity utilization assumption used in Table 10.6.
10-2
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10.2 Enterprise Costs
Table 10.1 shows, for the fifth year after the Standards and Guide-
lines are proposed, the national enterprise costs by scenario and regulatory
alternative. Capital costs are annualized at an estimated 4 percent real mu-
nicipal bond rate and added to annual operating costs to derive the annual
costs. Calculations are performed for each model plant, and the results
are scaled to the national level using the Series A scaling factors from Ta-
ble 8.3. In most cases, national enterprise costs are not good measures of
national costs of regulation, because taxes and market interest rates distort
the calculations. Here, however, public ownership of MWCs is assumed, so
that taxes never directly enter the calculations. As a result, the difference
between these enterprise costs and the social costs in Table 10.5 is entirely
due to selection of an interest rate for annualizing capital costs.
10.2.1 National Enterprise Costs and Tipping Fees
Enterprise costs indicate how municipalities may react to the Standards
and Guidelines. If localities were to pass control costs along to MSW col-
lectors through tipping fees, the result would be a substantial jump in those
fees. See Table 10.2. The national average potential percentage increase in
fees is 23 percent for the Standards (regulatory alternative IV), and about
the same for the Guidelines (regulatory alternative IIB). For equivalent
numbers on the model plant scale, see Table 7.7. MWC costs, including
ash disposal costs, very roughly average only one-half of total MSW dis-
posal costs. The other one-half is for collection and transportation of MSW.
Thus, a 23 percent tipping fee increase probably would be no more than
a 10 to 15 percent increase in overall MSW disposal costs. In any event,
it is unlikely that all control costs would be passed along through tipping
fee increases. Some of the costs may be picked up by local taxpayers, and
some by private firms that own or operate MWCs.
10-3
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Tab it 10.1: National Cost Impacts
(Enterprise Costs," ir>87 $, for Average Capacity Utilization )
Scenario
and
Regulatory
Alternative
No-Substitution
RAI
RAIIA
RAIIB
RAIII
RAIV
Capital
Costs
($106)
Scenario
30.5
183
216
514
548
- - - ot&nu&rcis -
Annual
Costs4
(SlOVyr)
5.15
89.6
106
128
145
Annual Costs
per Mg MSWe
($/Mg)
0.37
6.45
7.10
9.23
9.69
Substitution Scenario
RAI
RAIIA
RA IIB
RAIII
RAIV
29.7
121
149
321
347
5.02
62.5
75.8
80.5
93.0
0.37
6.35
7.11
9.09
9.65
Scenario
and
Regulatory
Alternative
Capital
Costsc
($106)
Annual
Costs4
($io6/yr)
Annual Costs
per Mg MSWe
($/Mg)
No-Substitution Scenario
RAI
RAIIA
RAIIB
RAIII
RAIV
Substitution Scenario
RAI
RAIIA
RAIIB
RAIII
RAIV
517
978
1,190
2,370
2,580
275
713
913
1,970
2,170
82.2
229
294
484
550
49.3
198
264
424
490
2.82
7.84
10.00
16.60
18.70
1.78
7.14
9.01
15.30
16.70
a National enterprise costs are the sum of the regulatory costs incurred by er Jo.
MWC, with capital costs annualized at the estimated 4 percent real municipal
bond rate. Control costs for materials separation, NOX, and regulatory alternative
IIB' are not included in this table. See text page 10-2.
& Cost impacts are based on Series A scaling factors from Table 8.3. Most MWCs
are assumed in Series A to operate about 7,300 hours per year.
c Capital costs are for one A.PCD lifetime of 15 years and are untouched by dis-
counting procedures.
d Annual costs a.T~:. annual operating costs plus capital costs annualized at 4 percent.
e Annual cr.^-.s per Mg are costs from the preceding column divided by the annual
amou-,: jf MSW combusted.
10-4
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Table 10.2: Potential Percentage Increases in Tipping Fees
Based on Full Pass Through of Enterprise Costsa
Scenario
and
Regulatory
Alternative
No-Substitution Scenario
RAI
RAIIA
RAIIB
RAIII
RAIV
Substitution Scenario
RAI
RAIIA
RAIIB
RAIII
RAIV
Standards
Percentage
Price
Increase
0.86
15
17
22
23
0.86
15
17
21
23
Guidelines
Percentage
Price
Increase
6.6
18
23
39
44
4.2
17
21
36
39
a These percentages are computed by dividing the annual costs per Mg
in Table 10.1 by the average 1988 tipping fee at resource recovery
MWCs. Converted to fourth quarter 1987 dollars, that fee is $42.70.
Control costs for materials separation, NOX, and regulatory alterna-
tive IIB' are not included in this table. See text page 10-2.
10-5
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10.2.2 Municipalities' Choices of Technology
Standards. Model plant enterprise costs are used to analyze substitu-
tion effects. For the Standards, the effects of substitution are summarized
in Table 10.3. As the regulatory alternatives become progressively more
stringent, the share of MSW going to mass burn and RDF MWCs declines,
the share going to modular MWCs remains about constant, and the share
going to landfills increases. In this regulatory impact analysis, MSW di-
verted to landfills carries with it no emission control costs and no emission
reductions. For this reason, and because municipalities tend to behave in a
cost-minimizing manner, the enterprise costs for the substitution scenario
in Table 10.1 are less than those for the no-substitution scenario. Control
costs for NOX and materials separation have not been incorporated into
this substitution analysis.
Guidelines. For the Guidelines, the substitution analysis consists of a
cost-minimizing model that reviews the enterprise costs and "allows" mu-
nicipalities to scrap existing MWCs and build replacements of comparable
size if it will save money. The analysis reveals only three likely substitu-
tions, and all three take place in the baseline. The refactory-walled mass
burn MWCs are shutdown. Model plants 1 and 3 are replaced by new mass
burn MWCs, and model plant 2 is replaced by a new modular MWC. All
costs in Chapter 7 are before-substitution costs. Table 10.4 is an update of
Table 7.7 for the three new MWCs, which retain the model plant number
of the original MWCs. Comparison of Tables 10.4 and 7.7 reveals the cost
savings behind the substitutions. These cost savings account for the differ-
ences between the two scenarios in Table 10.1. Control costs for materials
separation and regulatory alternative IIB' have not been incorporated into
this substitution analysis.
10-6
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Table 10.3: Substitution Effects of the Standards:
Percent of MSWa Allocated to Each of Four Disposal Technologies
Disposal
Technology
Mass Burn
Modular
RDF
Landfill
TOTAL"
Baseline
(%)
12
1
5
82
100
I
(%)
12
1
5
82
100
IIA
(%)
9
1
3
87
100
liory Alte
IIB
(%)
9
1
3
87
100
rnative - -
HI
(%)
8
1
2
89
100
IV
(%)
8
1
2
89
100
a Percentages apply only to MSW allocated in this analysis to these
four technologies; this MSW does not include waste for recycling,
for existing MWCs, or for other technologies, such as FBC.
Table 10.4: Substituted Costs for the Guidelines Analysis:
Percent Change in Enterprise Control Costs over Baseline
After Substitution
Model
Plant0
1
2
3
Baseline
Costs
(S/Mg)
25.20
56.90
28.90
I
(%)
1.39
0
1.44
IIA
(%)
38.1
0
24.5
itory Alternative
IIB III
(%) (%)
38.1
23.0
24.5
53.7
0
36.5
IV
(%)
53.7
23.0
36.5
a All other model plant costs remain as shown in Tables 7.3, 7.4, 7.6,
and 7.7.
b Baseline costs are 1987 $ per Mg of MSW combusted, and in the
substitution scenario replace the figures given in Table 7.7.
10-7
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10.3 Social Costs
10.3.1 National Social Costs
Table 10.5 shows, for the fifth year after the Standards and Guidelines
are proposed, the national enterprise costs by scenario and regulatory al-
ternative. Capital costs are annualized at an assumed 10 percent social
opportunity cost for capital and added to annual operating costs to derive
the annual costs. Calculations are performed for each model plant, and the
results are scaled to the national level using the Series A scaling factors
from Table 8.3. The annual cost of the Standards in the fifth year of imple-
mentation will lie in the $107 to $168 million range (regulatory alternative
IV), while the corresponding annual cost of the Guidelines will lie in the
$302 to $343 million range (regulatory alternative IIB).
10-8
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Table 10.5: National Cost Impacts
(Social Costs," 1987 $, for Average Capacity Utilization6)
Scenario
and
Regulatory
Alternative
Capital
Costsc
($106)
- - Standards -
Annual
Costs'*
($io6/yr)
Annual Costs
per Mg MSWe
($/Mg)
No-Substitution Scenario
RAI
RAIIA
RAIIB
RAIII
RAIV
Substitution Scenario
RAI
RAIIA
RAIIB
RAIII
RAIV
30.5
183
216
514
548
29.7
121
149
321
347
6.41
97.2
115
150
168
6.26
67.6
82.0
93.8
107
0.46
6.99
7.70
10.80
11.20
0.46
6.86
7.69
10.60
11.10
Wf*Af| aptn
kJ vCHdl 1\J
and
Regulatory
Alternative
No-Substitution
RAI
RA IIA
RAIIB
RAIII
RAIV
Capital
Costs
($106)
Scenario
517
978
1,190
2,370
2,580
f-ir inn f* linc*c
Annual
Costs
($106/yr)
104
269
343
583
657
Annual Costs
per Mg MSWe
($/Mg)
3.55
9.23
11.70
20.00
22.40
Substitution Scenario
RAI
RAIIA
RAIIB
RAIII
RAIV
275
713
913
1,970
2,170
60.7
228
302
506
580
2.19
8.20
10.30
18.20
19.80
a National social costs are the sum of the regulatory costs incurred by each MWC,
with capital costs annualized at the assumed 10 percent social opportunity cost for
capital. Control costs for materials separation, NOX, and regulatory alternative
IIB' are not included in this table. See text page 10-2.
b Cost impacts are based on Series A scaling factors from Table 8.3. Most MWCs
are assumed in Series A to operate about 7,300 hours per year.
c Capital costs are for one APCD lifetime of 15 years and are untouched by dis-
counting procedures.
d Annual costs are annual operating costs plus capital costs annualized at 10 per-
cent.
e Annual costs per Mg are costs from the preceding column divided by the annual
amount of MSW combusted.
10-9
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10.3.2 Sensitivity of Costs
Interest (Discount) Rate. The annual costs of the Standards and
Guidelines decline as the rate used for annualizing the capital cost compo-
nent declines. Compare Tables 10.1 and 10.5. Table 10.1 is based on a 4
percent rate, while Table 10.5 is based on a 10 percent rate. The drop in
annual costs between the social and enterprise accounts is in the 8 to 20
percent range, depending on the relative size of the capital component of
the annual cost for each regulatory alternative. This comparatively small
change in annual costs for a proportionately much larger change in the rate
used for annualization indicates that national costs are reasonably insensi-
tive to small variations in rates.2
MWC Capacity Utilization. Table 10.5 is based on the average
(Series A) MWC capacity utilization factors described in Sections 7.1.4
and 8.2. Table 10.6 presents the national social costs for the no-substitution
scenario for the Series B high capacity utilization factors. This increase in
capacity utilization means fewer MWCs are needed to combust the same
quantity of MSW, and hence, fewer APCDs are needed. A comparison
of Tables 10.5 and 10.6 shows that national social cost impacts decline as
capacity utilization increases. The changes are modest; this means that
projected cost impacts are relatively insensitive to small, but reasonable,
changes in capacity utilization.
2 Present values of control costs for the Standards and Guidelines are more sensitive to
discounting procedures and rates than annual costs are sensitive to annualization proce-
dures and rates. Present values are not necessary to a basic understanding of cost impacts,
and therefore are omitted from this regulatory impact analysis.
10-10
-------
Table 10.6: National Cost Impacts
(Social Costs," 1987 $, for High Capacity Utilization6)
Srpnario
and
Regulatory
Alternative
No-Substitution
RAI
RAIIA
RAIIB
RAIII
RAIV
Capital
Costs
($106)
Scenario
28.1
168
200
472
504
Annual
Costs
($106/yr)
6.10
96.3
114
145
163
Annual Costs
per Mg MSW
($/Mg)
0.44
6.93
7.63
10.40
10.90
Scenario
and
Regulatory
Alternative
No-Substitution
RA I
RA IIA
RAIIB
RAIII
RAIV
..
Capital
Costs
($106)
Scenario
509
936
1,140
2,240
2,440
Guidelines -
Annual
Costs
($106/yr)
103
264
339
566
641
Annual Costs
per Mg MSW
($/Mg)
3.54
9.05
11.60
19.40
21.80
a Social costs are computed as in Table 10.5. Control costs for materi-
als separation, NOX, and regulatory alternative IIB' are not included
in this table. See text page 10-2.
b Cost impacts are based on Series B scaling factors from Table 8.3.
Most MWCs are assumed in Series B to operate 8,000 hours per
year.
10-11
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10.4 Emission Reductions
10.4.1 National Emission Reductions
Table 10.7 shows, for the fifth year after the Standards and Guidelines
are proposed, projected national emission reductions by regulatory alter-
native and scenario.3 The PM, S02, and CDD/CDF columns are used in
Chapter 12 for calculating benefits. Baseline emissions are shown. Emis-
sion reductions for the substitution scenario for the Standards are hard
to interpret because the number of affected MWCs declines as the regula-
tory alternatives become more stringent. In some places increased strin-
gency brings smaller national emission reductions with larger national costs.
(Even where increased stringency results in smaller emission reductions, in-
creased stringency should not result in increased emissions. The smaller
emission reductions would be due to a decline in the number of MWCs.
MSW would be diverted to recycling markets and landfills, which have
emission characteristics altogether different from MWCs. If this regulatory
impact analysis were able to include disposal costs and emissions associated
with the MSW diverted to recycling markets and landfills, this odd result
might not occur.)
10.4.2 Sensitivity of Emission Reductions
Interest (Discount) Rate. For the no-substitution scenario, emission
reductions projected by economic modeling are insensitive to changes in the
rates used for discounting and annualizing. To the extent the rates affect
enterprise costs it may indirectly influence substitution among technologies
and, therefore, emission reductions. Such affects are likely to be minor.
MWC Capacity Utilization. MWC capacity utilization has mini-
mal effects on emission reductions. See Table 10.8, which shows emission
reductions for the no-substitution scenario under the high capacity utiliza-
tion Series B assumption. Data for the substitution scenario have not been
analyzed for sensitivity to capacity utilization. The capacity utilization
assumption has a much larger effect on costs than on emission reductions,
and therefore would be of concern if EPA were relying on cost/effectiveness
'For NOx emission reductions see page 10-2.
10-12
-------
arguments to support the Standards and Guidelines. Emission reductions
for the Standards are unaffected by capacity utilization. For the Guide-
lines, higher capacity utilization yields slightly greater emission reductions.
For both the Standards and Guidelines there is no difference in the flow of
MSW between the average and high capacity utilization assumptions.4
10.5 Untabulated Costs
Costs for NOX control and Guidelines regulatory alternative IIB' became
available too late to be incorporated into this regulatory impact analysis.
Materials separation requirements were added to the Standards and Guide-
lines after most control costs had been developed, and for that reason ma-
terials separation costs have not been developed fully. Materials separation
may be self-supporting for some MWCs, but not for others. Preliminary
analysis indicates that, as recycling markets develop, the average MWC will
experience little or no cost, and may even turn a profit on materials sep-
aration operations. If further analysis reveals potentially significant costs
for some types or sizes of MWCs, incorporation of those costs into the reg-
ulatory impact analysis might require some restructuring of the computer
models, baseline projections, and substitution scenarios. In addition to the
NOxj IIB', and materials separation costs, there are other categories of
costs for which impacts have not been analyzed here. These categories are
explained below.
4The small change in emission reductions for the Guidelines is attributable to the way
capacity utilization data are used to generate the Series A and B scaling factors. For both
series (in the no-substitution scenario) the number of MWCs in existence by mid-1988
is fixed, and the MSW flow is fixed. All adjustment for capacity utilization is made for
MWCs to be constructed in late 1988 and in 1989, and these MWCs generally are different
from the older MWCs. This difference causes the small difference in emission reductions
for the Guidelines between Tables 10.7 and 10.8.
10-13
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Table 10.7: National Baseline Emissions and Regulatory
Emissions Reductions — Average Capacity Utilization
(Mg per Year)
and
Regulatory
Alternative
CDD/CDF
CO
PM
SO2
HC1
Pb
No-Substitution Scenario
Baseline
RAI
RA IIA
RAIIB
RA III
RAIV
Substitution
Baseline
RAI
RAIIA
RAIIB
RAIII
RAIV
0.0152
0
0.0107
0.0115
0.0139
0.0146
Scenario
—
0
0.00781
0.00841
0.00916
0.00974
5,470
0
0
0
0
0
—
0
0
0
0
0
7,540
5,220
5,220
5,960
5,220
5,960
—
5,120
3,440
4,040
2,980
3,550
42,000
0
18,300
19,300
35,400
36,400
—
0
13,700
14,500
22,400
23,100
49,300
0
36,700
39,500
44,400
47,200
—
0
25,700
27,900
27,700
29,900
127
88.5
108
124
108
124
—
86.3
77.9
90.3
68.6
81.6
scenario
and
Regulatory
Alternative
. .
CDD/CDF
CO
PMC
S02
HC1
Pb
No-Substitution Scenario
Baseline
RAI
RAIIA
RAIIB
RAIII
RAIV
Substitution
Baseline
RAI
RAIIA
RAIIB
RAIII
RAIV
0.193
0.140
0.175
0.180
0.186
0.191
Scenario
0.120
0.0719
0.105
0.108
0.115
0.118
25,600
10,700
10,700
10,700
10,700
10,700
16,400
3,560
3,560
3,560
3,560
3,560
11,300
6,520
6,520
8,230
6,520
8,230
7,400
2,480
2,480
4,350
2,480
4,350
86,200
0
30,700
34,500
69,100
72,900
84,600
0
30,400
33,900
68,400
71,900
108,000
0
75,500
86,300
91,600
102,000
105,000
0
74,400
84,100
90,300
99,900
247
154
192
240
192
240
169
82
120
163
120
163
a Emissions and emissions reductions are reported only for affected MWCs. MSW
diverted to landfills in the Standards substitution scenario is not considered. Data
are based on Series A scaling factors from Table 8.3. Most MWCs are assumed to
operate about 7,300 hours per year.
b There is no baseline per se for this substitution scenario. Each successive regula-
tory alternative affects progressively fewer MWCs. Incremental analysis with this
scenario is inadvisable.
c Revised PM emission limits for existing MWCs have not been incorporated in this
table.
10-14
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Table 10.8: National Baseline Emissions and Regulatory
Emissions Reductions — High Capacity Utilization"
(Mg per Year)
Scenario
and
Regulatory
Alternative
CDD/CDF
c
CO
/
Standards - -
PM S02
HC1
Pb
No- Substitution Scenario
Baseline
RA
RA
RA
RA
RA
I
HA
IIB
III
IV
0
0
0
0
0
.0152
0
.0107
.0115
.0139
.0146
5,470
0
0
0
0
0
7
5
5
5
,540
,220
,220
,960
5,220
5
,960
42,000
0
18,300
19,300
35,400
36,400
49
36
39
,300
0
,700
,500
44,400
47
,200
127
88.5
108
124
108
124
and
Regulatory
Alternative
CDD/CDF
CO
PM6
S02
HC1
Pb
No-Substitution Scenario
Baseline
RAI
RAIIA
RAIIB
RAIII
RAIV
0.203
0.149
0.185
0.190
0.196
0.201
26,400
11,200
11,200
11,200
11,200
11,200
11,400
6,520
6,520
8,290
6,520
8,290
86,600
0
30,800
34,700
69,200
73,100
108,000
0
75,300
86,500
91,300
102,000
248
155
192
241
192
241
a Emissions and emissions reductions are based on Series B scaling
factors from Table 8.3. Most MWCs are assumed in Series B to
operate 8,000 hours per year.
b Revised PM emission limits for existing MWCs have not been incor-
porated in this table.
10-15
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Operator training. Operator training and certification is essential
to ensure proper operation of MWCs in accordance with good combustion
practice. Operation of MWCs and the associated APCDs is complex, re-
quiring qualified operators and supervisors. The Standards arid Guidelines
require certification of the shift supervisor and chief plant operator and
development of a site-specific training manual for use in training all plant
operators. The annual cost of operator training is expected to be minor.
Governmental administration and enforcement. Federal, state,
and local governments incur costs to issue permits, monitor performance,
and enforce compliance with current environment regulations for new and
existing MWCs. The additional costs associated with the Standards and
Guidelines have not been quantified; however, these costs are considered to
be insignificant.
Adjustment costs for displaced resources. Three types of costs
may occur while the economy adjusts to new regulations: underutilization
of resources from lost output, resource reallocation costs (such as moving
to a new location), and the operation of programs to help the unemployed.
These costs are considered to be insignificant.
Dead-weight welfare losses. These costs are defined as the net losses
in consumers' and producers' surplus that occur when the output of goods
and services decreases in response to a regulatory action.5 Because the
costs of readily available substitutes, such as landfilling, are also increasing
in response to environmental regulation and decreasing availability, insuf-
ficient change is expected in the baseline utilization of MWCs to warrant
investigation of dead-weight welfare losses. The utilization of MWCs may
change significantly, however, in response to increased social consciousness
of the value of recycling and source reductioii.
Paperwork. The resource cost for reporting and recordkeeping as re-
quired by the Standards (see Section 3.3 for requirements) is expected to
be 65 person-years per year for the first three years following promulgation.
The supporting statement for Standard Form 83, an OMB requirement un-
der the Paperwork Reduction Act, discusses these costs in further detail.
No paperwork burden costs have been estimated for the Guidelines.
5Just as dead weight welfare losses from reduced combustion of MSW are not tabulated
in this analysis, the emission reduction benefits that would accompany the reduction in
combustion are not tabulated.
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Chapter 11
The Distribution of Impacts
(Regulatory Flexibility)
11.1 Who Pays How Much?
It is not clear how the Standards and Guidelines might change the way
Americans pay for MSW disposal, and therefore which firms, municipalities,
waste generators, taxpayers, users, or other groups will end up paying,
and in what proportion. EPA has looked into impacts on households and
local governments in detail, using impact measures developed in two other
studies.[6,10] The results indicate that regulation is not likely to have severe
adverse economic effects on any group. The household and governmental
impact analyses are reported in Section 11.2. The Regulatory Flexibility
Act (RFA) requires a broader look into whether there will be significant
adverse economic effects and, if so, how those impacts will be distributed
among small entities. The RFA and its associated regulatory flexibility
analysis are the subject of Section 11.3.
11.2 Households and Governments
Analyzing the economic impacts of the Standards and Guidelines on
households and governments is difficult because households and govern-
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merits come in all sorts of sizes and income brackets and are, or will be,
served by MWCs with widely varying compliance costs and financial struc-
tures. For each existing and planned MWC on file, EPA identified
• Ownership,
• Mg of MSW combusted annually,
• Type, and which model plant best represents the MWC, and
• Geographic location.
This information was merged with data from the 1980 Census of Popula-
tion and Housing. Household income data from the census were recast in
1987 dollars with the GNP implicit price deflator. Because of difficulties
in matching MWCs with service areas, the default procedures used had an
underestimation bias for service area size to keep impact estimates conser-
vative. Specifically, where the input data indicated an obvious mismatch—
MWC capacity utilization less than about 50 percent or greater than 400
percent—the MWCs were excluded from this household and government
impact analysis. (The fact that most areas have grown in population since
the 1980 census has relatively little effect on this analysis because the re-
sulting increase in generation of MSW should be offset by an enhanced
financial base to pay for the controls.) Costs of the various regulatory
alternatives were assigned to MWC plants based on the model plant desig-
nations. Because model plant costs are based on the assumption that the
plants are just meeting federal standards (exclusive of the 1987 Guidance)
for emissions in the baseline, there is an additional inherent upward, or
conservative, bias in these impact estimates.
11.2.1 Household Impacts
Most MWCs, whatever their ownership, will try to pass increased costs
on to their customers. Among these customers are households, which gen-
erate much of the MSW. Two indices are used by EPA's Office of Solid
Waste in its Subtitle D Landfill Regulatory Impact Analysis.[6] They are
a rough measure of the household burden associated with the regulation
of things such as MWCs and landfills. The first index is an absolute mea-
sure of the cost of regulation per household, while the second is a relative
11-2
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measure of the cost of regulation per household. In the landfill analysis, a
service area is defined as having severe household impacts if either
• Compliance cost per household exceeds $220, or
• Compliance cost per household exceeds 1 percent of median household
income.
Based on either criterion, no MWC service area will experience severe
household impacts under any of the regulatory alternatives. However, be-
cause of census data limitations this household impact analysis does not in-
clude service areas with a population less than 2,500. Additionally, results
are based on the national average amount of waste generated per house-
hold, and on an assumption that all served households share equally in
paying for compliance. In practice, the impact of the regulation on individ-
ual households would depend on actual waste generated, actual household
income, and the method by which individual jurisdictions pass on costs to
their customers. While these average impacts of compliance are not severe,
there well may be special contractual or technical conditions, especially for
small communities and service areas, where these MWC compliance costs,
in combination with the costs of other environmental regulations, may im-
pose unusual hardships.
For the Standards, under regulatory alternative IV, no service area will
average control costs greater than $89 per household per year, or 0.5 percent
of median household income. Costs for 90 percent of all households will
average less than $30 per household per year, and less than 0.13 percent
of median household income. The average annual household control cost is
$20, translating to 0.08 percent of median household income.
For the Guidelines, under regulatory alternative IV, no service area
will average control costs greater than $93 per household per year, or 0.5
percent of median household income. Costs for 90 percent of all households
will average less than $58 per household per year, and less than 0.29 percent
of median household income. The average annual household control cost
is $27, translating to 0.12 percent of median household income. Impacts
under regulatory alternative IIB' would, of course, be significantly less.
For both the Standards and Guidelines, smaller service areas have slightly
higher household impacts.
11-3
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Under rare circumstances these results could be additive. That is, if a
service area will have an old MWC subject to the Guidelines and a new
MWC subject to the Standards, the adverse impacts could be greater than
those reported for the Guidelines. EPA did not analyze this possibility.
However, even where a service area is affected by both the Standards and
Guidelines, the household impacts should be less than severe.
11.2.2 Local Government Impacts
Criteria different from those used for households were used to judge
whether there might be severe impacts on local governments. //
• The sum of (1) the average sewerage and sanitation cost per house-
hold and (2) the average MWC control cost per household, exceeds 1
percent of median household income, and if
• The sum of (1) total current debt service and (2) additional debt
service associated with capital costs for MWC control, exceeds 15
percent of total general revenue,
then the impacts are considered severe for the local government. This crite-
rion matches one used in EPA's Municipal Sector Study.[W] It is a measure
of a local government's ability to issue revenue bonds or obtain loans to
raise the capital needed to comply with the Standards and Guidelines. A
second criterion is derived from the Subtitle D landfill study. [6] If
• MWC control costs exceed 1 percent of total general expenditures,
then the impacts are considered severe for the local government. This
criterion is a measure of a local government's ability to meet the yearly
cost burden associated with the Standards and Guidelines.
To apply these two criteria, the MWCs owned by municipalities or coun-
ties, or jointly owned by municipalities and counties, were identified. For
each of these public MWCs, the data collected for the household impact
analysis were added to data from the 1982 Census of Governments. Gov-
ernment financial figures were inflated from 1982 to 1987 dollars using the
11-4
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State and Local Government Expenditure Deflator. The criteria were ap-
plied only to publicly owned MWCs for which ownership and service area
were specified in the data base as being the same. Assigning only one gov-
ernmental unit to a facility may tend to overestimate government impacts
for those MWCs that serve several jurisdictions by underestimating the fi-
nancial base of the communities served. If assigning a single government to
an MWC does not give severe impacts, the full assignment of all relevant
governmental units with their greater combined resources to the plant is
unlikely to give severe impacts. As in the case of the household analysis,
application of the criteria was further limited to those service areas whose
estimated waste generation roughly matched the capacity of the associated
plants.
No local government will have severe impacts under the Municipal Sec-
tor Study criterion. However, under the Subtitle D criterion, the initial
analysis indicated that many local governments will be severely affected.
Each severe-impact case was investigated and in every case EPA found that
the MWC served, or will serve, more than one jurisdiction, and that the fi-
nancial base in the analysis is substantially smaller than the actual financial
base for the MWC. With this supplementary information, EPA concludes
that no local government will be severely impacted by the Standards and
Guidelines.
Unfortunately, due to data limitations, local governments with fewer
than 10,000 inhabitants could not be analyzed. For areas with larger pop-
ulations, the analysis shows a very weak relationship between size and the
severity of impacts using the second criterion. Specifically, smaller gov-
ernments may have to devote a slightly larger proportion of their general
expenditures to the control of MWC emissions than will larger governments.
11.3 Regulatory Flexibility Analysis
The RFA (Public Law 96-354, September 19, 1980) requires Federal
agencies to give special consideration to the impact of regulations on small
businesses, small organizations, and small governmental units. Small or-
ganizations are not affected by the Standards and Guidelines, and are not
examined further here. The major purpose of the Act is to keep paperwork
and regulatory requirements from getting out of proportion to the scale
11-5
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of the entities being regulated, without compromising the objectives of, in
this case, the CAA. Another purpose is to involve the small entities in the
regulatory development process. The paperwork burden on small entities
has not been analyzed separately from that for all affected entities.
11.3.1 Small Entity Impacts
The RFA specifies that a regulatory flexibility analysis must be pre-
pared if a proposed regulation will have (1) a significant economic impact
oil (2) a substantial number of small entities. Section 11.2 above addresses
the severity of impacts on households and governments. For the RFA,
however, the question is whether impacts are significant—not severe. One
criterion that EPA has used specifies that economic impacts are significant
whenever compliance costs will increase production costs by more than five
percent. Chapter 10 indicates that on average the combustion costs per Mg
MSW, as well as tipping fees, may increase by more than five percent for
most regulatory alternatives for both the Standards and Guidelines. EPA
has other criteria of significance. These relate to the availability of capi-
tal for small entities, possible closures among small entities, and whether
compliance costs as a percent of sales for small entities are at least 10 per-
cent higher than the same costs for large entities. These other criteria are
not addressed here; EPA presumes from the first criterion that economic
impacts are significant.
Will these significant economic impacts be felt by a substantial number
of small entities? For regulations like the Standards and Guidelines, EPA
often has applied a 20 percent rule: if more than 20 percent of small en-
tities are significantly impacted, the specific concerns of the RFA must be
addressed. Unfortunately, it is rarely clear what the 20 percent should be
of. In this case it could be 20 percent of the small entities with MWCs—
but almost by definition 100 percent of those entities will be significantly
impacted—or 20 percent of small entities in the "industry," whatever that
means. Regardless of how the criterion is viewed, EPA finds only one small
business and only a handful of small governments with MWCs.
As described below, EPA has taken appropriate steps to involve small
entities in the regulatory development process, and to mitigate potential
adverse effects for small entities. This section of Chapter 11, together with
the relevant portions of references [4] and [5], constitute the regulatory
11-6
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flexibility analysis required by the RFA.
Small entities that own or operate MWCs most likely will have small
modular MWCs. For that reason the mitigation measures discussed at the
end of this section focus on small MWCs as surrogates for small entities.
11.3.1.1 Small Businesses
Size Standards. Small businesses are identified by the Small Busi-
ness Administration general size standard definitions. These vary by Stan-
dard Industrial Classification (SIC) code. For SIC code 4953, Refuse Sys-
tems, small business concerns are those receiving less than $6 million per
year averaged over the most recent three fiscal years.
Inventory and Projections. Using the 1988-89 Resource Recovery
Yearbook and data gathered under CAA §114, EPA has compiled a list
of firms with MWCs.1 This list includes owners of MWCs currently in
operation as well as owners of MWCs now in planning stages and MWCs
under construction. Telephone contacts were made with those firms for
which data were insufficient, to obtain annual sales figures and to confirm
information about the firm's line of business and organizational structure.
Approximately one third of the firms have been identified as publicly
held corporations; the remaining majority are privately held firms including
corporations and limited partnerships. Some are very large and diversified
firms, for example General Motors Corporation. Only one firm appears to
have less than $6 million in annual sales, suggesting that small businesses
will not be significantly impacted by the Standards and Guidelines. This is
less than the "substantial number" criterion to trigger a regulatory flexibil-
ity analysis; therefore, a regulatory flexibility analysis for small businesses
is not required.2
1See references [4] and [5].
2The Standards and Guidelines may be applied to thousands of small commercial and
institutional waste disposal incinerators, such as those at some shopping centers and office
complexes. If this happens, it is resonable to assume that a substantial number of small
businesses would be affected, and therefore, the provisions of the RFA would apply.
11-7
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Regulatory Impacts. Impacts of the regulation on private firms may
be direct or indirect in nature. Owners who must purchase and install con-
trol equipment, train employees, or change operating practices will be di-
rectly impacted. On the other hand, firms that supply services or equipment
but do not own an MWC will be indirectly impacted, and may actually ben-
efit from the regulation as demand for air pollution control technology and
equipment increases. The extent of impacts for a specific MWC owner or
supplier is dependent on the level of pollution control in place at the time
of the regulation, local market conditions and contractual arrangements,
the size of the MWC, and financial status of the firm.
Many of the privately-owned MWCs are large and were built (or are
about to be built) under much more favorable tax and financing conditions
than would likely apply to control equipment used to meet the Standards
and Guidelines. The control costs for private owners will be higher than
for public owners of MWCs. For private MWCs that have long term waste
disposal contracts that include escalator provisions to cover contingencies
such as pollution control equipment, these higher costs can be passed on
to waste collectors and generators. Private MWCs generally have such
arrangements.
In contrast, privately owned MWCs that do not have such long-term
contracts will be adversely affected by the Standards and Guidelines. How
adverse the effect will be depends on the cost of production of the private
MWC relative to other local means of solid waste disposal. If, after the
Standards and Guidelines, the private MWC still has relatively low costs
of production, the Standards and Guidelines will reduce expected profits
but will not force sale or closure of the MWC. If, however, control costs
are large enough to increase costs of production beyond prevailing tipping
fees at landfills or public MWCs, the private MWCs may have to close or
may have to operate at a loss in the hope that tipping fees increase in the
future.
Data from EPA's study suggests a great disparity in annual revenues
between the smallest and the largest of firms. The relationship between
impacts, MWC size, and firm size was examined. Impacts are greater for
small model plants than for large model plants. Because of this indica-
tion of a relationship between the size of the plant and the severity of the
impact, EPA has provided greater regulatory flexibility for small plants.
Specific measures to address the needs of small MWCs include: size cut-
11-8
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offs built into the regulatory structure, less stringent requirements for small
plants, and permission for states to make case by case judgements under
the Standards and Guidelines.
Adverse impacts on related industries that may be affected by the Stan-
dards and Guidelines—such as APCD suppliers, trash collectors, recyclers,
engineering consultants, and supporting technologies—are not expected;
these firms will likely benefit from increased demand for their services.
11.3.1*2 Small Governments
Size Standards. The Regulatory Flexibility Act has defined the term
"small governmental jurisdiction" to mean governments of cities, counties,
towns, townships, villages, school districts, or special districts, with a pop-
ulation of less than 50,000.
Application of the RFA Criterion. The number of governmental
jurisdictions having MWCs for which household impacts were estimated
is 72. Of these, 12 are in communities with populations less than 50,000.
This represents approximately 17 percent of the publicly owned facilities.
The percentage probably applies to the entire population of MWCs. As is
the case with small businesses^ this is less than the "substantial number"
criterion that would trigger a Regulatory Flexibility Analysis.
Involvement and Financing For a discussion of how local govern-
ments make financial decisions, see Chapter 8. Mitigation measures that
can be taken by small governments to offset costs are discussed below.
11.3.1.3 Small Entity Involvement
EPA has encouraged the involvement of all concerned parties in the
development of the Standards and Guidelines. On July 7, 1987 EPA pub-
lished in the Federal Register[8] a notice of intent to develop the Standards
and Guidelines. Early in 1988 EPA sent questionnaires to owners and op-
erators of existing MWCs. The purpose was to obtain information not just
11-9
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on the engineering configurations of the plants, but to obtain detailed fund-
ing and other financial information to give EPA insight into the financial
implications of alternative control measures. In the spring of both 1988 and
1989 EPA presented status reports on the Standards and Guidelines at the
annual public meetings of the National Air Pollution Control Techniques
Advisory Committee. The function of the Committee is to serve as a fo-
rum for involving industry and the public in the regulatory development
process for air pollution emission controls. Owners of all existing MWCs,
all firms involved in owning or operating MWCs, and a wide selection of
public interest groups were invited to attend and participate in the Com-
mittee's meetings. In the autumn of 1988 EPA mailed a package of about
a dozen documents covering most aspects of development of the Standards
and Guidelines. The mailing went to substantially the same parties—over
300 in total. Recipients were invited to comment on all aspects of the
development of the Standards and Guidelines.
When the Standards and Guidelines are proposed in the Federal Regis-
ter, EPA will set a date and place for a public hearing on the proposals.
Public comments on the proposals will be invited, and interested persons
may present their comments in writing or in person at the public hearing.
11.3.1.4 Mitigation Measures
There are several ways potentially significant adverse economic impacts
on small entities will be mitigated. First, the Standards and Guidelines
themselves contain mitigation measures. Several of the requirements are
more lenient for smaller MWCs, particularly in the case of the Guidelines.
To the extent the proportion of small-entity owners and operators of small
MWCs exceeds the proportion of small-entity owners and. operators of large
MWCs, this leniency translates into an easing of the economic burden on
small entities relative to large entities. Implementation of the Standards
and Guidelines will include an appeals process for unusual or hardship
situations. If the Standards or Guidelines will force an MWC to close, or
will preclude construction of a new MWC, or will assign to a small entity
control costs that are disproportionate to the pollution, then the entity will
have the opportunity to appeal to the state for relief from the full burden
of compliance.
Second, there are several things small governments can do in the face of
11-10
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steep compliance costs. In almost all cases these governments have available
to them alternative waste disposal technology—landfilling—and many ways
to expand source reduction, materials separation, and recycling programs.
Small governments have the opportunity to join in, or join in forming, in-
tergovernmental service districts, or to contract with neighboring waste dis-
posal operations for disposal services. Whenever intergovernmental agree-
ments lead to the construction of MWCs of larger capacity than otherwise
would have been constructed, air pollution control costs per Mg MSW will
shrink. In some instances small governments can exercise monopoly mar-
ket power to restrict competition among landfills and MWCs to improve
the financial viability of particular MWCs. Finally, small governments that
want to combust MSW have the option of building and operating MWCs
as public ventures, or arranging for the MWCs to be built and operated
as private ventures. The small governments can investigate both financial
markets and then select whichever approach offers the best terms.
Third, the Standards and Guidelines, as have standards and guidelines
in the past, will stimulate advancement of both combustion and control
technologies. Improved technology will, over the long run, make it cheaper
for small entities to build and operate small MWCs. (Improved technology,
of course, also will help owners of large MWCs, and thereby may not prove
to be more helpful to small entities that it will be to large entities.)
Finally, the Public Utility Regulatory Policy Act of 1978 assures inde-
pendent small electricity generators reasonably favorable terms when they
sell power to electric utilities.
11-11
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Chapter 12
Benefits
12.1 Introduction
This chapter presents benefit estimates for each of the regulatory al-
ternatives with and without substitution. The estimated economic benefits
associated with reduced pollutant emissions from MWCs reflect individuals'
willingness to pay for cleaner air.
This analysis is not intended to serve as a comprehensive and rigor-
ous quantification of all of the benefits associated with the Standards and
Guidelines. The absence of sufficient exposure-response and/or valuation
information prohibits a comprehensive benefits assessment from being un-
dertaken at this time. Further, time and resource constraints restricted the
level of rigor in this analysis. Finally, as with other analyses performed
for this RIA, controversy exists regarding some of the specific techniques
employed in this chapter. Nevertheless, substantial benefits were quanti-
fied based on the best physical effects and valuation information currently
available, and on peer-reviewed evaluation procedures.
12-1
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12.2 PM Benefits
This section summarizes the analysis undertaken to develop a valua-
tion factor (benefit per Mg estimate) and presents benefit estimates for PM
emission reductions. For a detailed description of the procedures employed,
see Revised Benefit Analysis of Hypothetical Particulate Matter Control
Regulations for Selected Municipal Waste Combustors.[3]
The PM benefit analysis employed the following three step procedure:
• Development of an exposure estimate for a given emissions change at
selected MWCs,
• Estimation of health and welfare changes, and
• Valuation of the health and welfare changes and calculation of an
estimate of the average PM benefit per Mg reduced.
Each of these steps is discussed in turn.
Previous PM benefit analyses have employed the linear rollback ap-
proach to calculate the magnitude of air quality improvements that would
result from air pollution controls. This approach assumes concentration
changes are strictly proportional to emission reductions. To avoid this sim-
plifying assumption, the Model City Program (MCP) was employed in this
assessment. The MCP is a database management system that imitates the
performance of full-scale industrial source complex (ISC) modeling, and
does so with a substantial savings of time and cost. The MCP models
the dispersion of air pollutants throughout a defined region based on ISC
simulation, thus allowing the conversion of emission rates into incremental
ambient concentration data. These ambient concentration data are then
combined with population data to obtain exposure estimates.
Forty-four sites existing in 1986 were selected for analysis. The selection
of sites was based primarily on the availability of data. The 44 MWCs
studied represented over half of the total emissions from all MWCs in 1986.
The next step in the benefit analysis was to estimate the health and wel-
fare effects resulting from the estimated exposure. Quantitative concentra-
tion-response functions were obtained for the following effects categories:
12-2
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• Mortality (from Schwartz and Marcus (1986))1
• Acute Morbidity (from Ostro (1987))2
• Household soiling and materials damage (from Mathtech (1983,1986))3
Table 12.1 presents effects estimates from PM reductions for each regulatory
alternative and scenario examined.
The final step in the benefit analysis was the valuation of effects. For
mortality risk, a range of $1.6 to $8.5 million (1986 dollars) per statistical
life saved4 was employed to calculate mortality reduction benefits. This
range was taken from Fisher, Chestnut, and Violette.[2] A best point esti-
mate of $4.4 million was employed. This estimate was derived by averaging
estimates from the 13 studies used by Fisher et al. to develop the $1.6 to
$8.5 million range.
A cost of illness approach was employed to value morbidity effects. Com-
ponents valued were
• Work loss days (valued at the wage rate),
• Reduced activity days (valued at half the wage rate), and
• Direct medical expenditures.
Household soiling and materials effects were valued using a supply and
demand model for goods purchased to maintain a desired level of cleanli-
ness. Benefit estimates were derived by comparing expenditures for laundry
and cleaning products, and gas and electricity, before and after PM reduc-
tions were imposed.
Since actual control strategies were not yet defined at the time of this
analysis, a hypothetical complete shutdown scenario was examined. Esti-
mated PM benefits from this scenario ranged from a low estimate of $5,503
to a best point estimate of $15,912, to a high estimate of $38,241 per Mg.
1See reference [3].
2 See reference [3].
3See reference [3].
4 For example, one statistical life would be saved if a one-in-a-million chance of dying
were eliminated for a million people.
12-3
-------
Table 12.1: National Annual Reductions
in Adverse Effects from PM Emissions
Scenarios
and
Regulatory
Alternative
CZr a i"i fi sif fl 6
Mortality Work Loss Restricted
Days Activity Days
(103 days) (103 days)
Medical
Expenditures
(106 1987 $)
No-Substitution Scenario
RAI
RAIIA
RAIIB
RAHI
RAIV
Substitution
RAI
RA IIA
RAIIB
RAHI
RAIV
11.1
11.1
12.7
11.1
12.7
Scenario
10.9
7.3
8.6
6.3
7.6
41
41
47
41
47
41
27
32
24
28
226
226
258
226
258
222
149
175
129
154
1.5
1.5
1.8
1.5
1.8
1.5
1.0
1.2
0.9
1.1
Scenarios
and
Regulatory
Alternative
f^rlllfl Ol11~ftf*
-------
To facilitate comparison with costs, all estimates were inflated to fourth
quarter 1987 dollars using the GNP implicit price deflator for personal
consumption expenditures. These benefit per Mg estimates were then mul-
tiplied by estimated PM emission reductions to estimate national benefits.
Table 12.2 presents national PM benefit estimates for each regulatory al-
ternative and scenario examined.
12.3 SOo Benefits
The SC>2 benefit estimates presented in this section were derived from
earlier EPA-directed studies. In particular, benefit results presented in
Chapter 6 of the Industrial Boiler SO2 RIA[9] were employed. The Indus-
trial Boiler SO2 Benefit Analysis developed SO2 benefit per ton valuation
factors that, after adjustment, were multiplied by the MWC SO2 emission
reduction estimates to obtain MWC SC>2 benefits.
There are direct and indirect benefits associated with 80*2 emission re-
ductions. Benefit estimates presented in the Industrial Boilers SC>2 RJA
reflect direct SO2 effects (morbidity, soiling and materials damage [residen-
tial facilities], and agricultural yield [soybeans, wheat, and oats]), as well
as indirect SO4 and other PM effects (visibility, morbidity, and soiling and
materials damage). SC>2 benefit per ton estimates reported in this analy-
sis ranged from $510 to $710 ($1983) depending on the control scenario
selected.
Several adjustments were made to the SO2 valuation factors presented
in the Industrial Boilers SOj RIA. First, they were adjusted downward to
remove the PM chronic morbidity benefit component. PM concentrations
around the MWCs studied in the MWC PM benefit analysis were not above
the estimated threshold level for which chronic morbidity effects begin to
occur. Second, the valuation factors were adjusted upward by including
mortality benefits from reduced PM. The estimated ratio of PM mortal-
ity to total PM benefits from the MWC PM benefit analysis was used to
make this adjustment. Third, all benefit per ton estimates were converted
to benefit per Mg estimates. Last, the valuations were inflated to 1987
dollars. The final valuation factors calculated ranged from $876 per Mg to
$1,201 per Mg. The mid-point of this range, $1,038 per Mg, was used as a
best estimate. Table 12.3 presents national S02 benefit estimates for each
regulatory alternative and scenario examined.
12-5
-------
Table 12.2: National Annual PM Emission
Reductions and Associated Benefits
Scenarios
and
Regulatory
Alternatives
No-Substitution
RAI
RAIIA
RA IIB
RAIH
RAIV
Emission
Reductions
(Mg)
Scenario
5,220
5,220
5,960
5,220
5,960
^5 1" si itff *"l
- - Ol/dllUcl
_ _ - -
Low
28
28
33
28
33
rds -
- Benefits -
Best
(106 1987 $)
83
83
95
83
95
...
_ _ _
High
200
200
228
200
228
Substitution Scenario
RAI
RAIIA
RAIIB
RAIII
RAIV
5,120
3,440
4.040
2,980
3,550
28
19
22
16
20
81
55
64
47
56
196
132
154
114
136
Scenarios
j
Regulatory
Alternatives
No-Substitution
RAI
RAIIA
RAIIB
RA IIB'
RAIII
RAIV
Guidelines
t^ iTYll CEQ1 fll"!
JJJllll OOl L/J.1
Reductions
(Mg)
Scenario
6,520
6,520
8,230
8,300
6,520
8,230
Low
36
36
45
45
36
45
TJ £|
Best
- (106 1987 $
104
104
131
132
104
131
High
)----
249
249
315
318
249
315
Substitution Scenario
RAI
RAIIA
RAIIB
RAIII
RAIV
2,480
2,480
4,350
2,480
4,350
14
14
24
14
24
39
39
69
39
69
95
95
166
95
166
12-6
-------
Table 12.3: National Annual SO2 Emission
Reductions and Associated Benefits
Scenarios
n n H
CLJ.IU.
Regulatory
Alternatives
No-Substitution
RAI
RA IIA
RAIIB
RAIII
RAIV
HitTTI QdlrtTl
J_JlillDDlVll
Reductions
(Mg)
Scenario
0
18,300
19,300
35,400
36,400
Cltnnrl
- ~ kDLclIlL
Low
0
16
17
31
32
ards
H*^T1 f3T1 4* C
- - DdlC.lJ.lD ""
Best
- (106 1987 $)
0
19
20
37
38
...
High
0
22
23
43
44
Substitution Scenario
RAI
RAIIA
RAIIB
RAIII
RAIV
0
13,700
14,500
22,400
23,100
0
12
13
20
20
0
14
15
23
24
0
16
17
27
28
Scenarios
and
Regulatory
Alternatives
No-Substitution
RAI
RAIIA
RAIIB
RA IIB'
RAIII
RAIV
Emission
Reductions
(Mg)
Scenario
0
30,700
34,500
37,000
69,100
72,900
T"l J2 A
„ _ _ H*»Tltf»TI TC .
Low
0
27
30
32
61
64
Best
- (106 1987 $
0
32
36
39
72
76
. _ _ _ _
High
)----
0
37
41
44
83
88
Substitution Scenario
RAI
RA IIA
RAIIB
RAIII
RAIV
0
30,400
33,900
68,400
71,900
0
27
30
60
63
0
32
35
71
75
0
37
40
82
86
12-7
-------
12.4 Unquantified Benefits
The national benefit analysis presented in this chapter for the Standards
and Guidelines is incomplete in coverage. The analysis is incomplete in
three ways:5
• Coverage of pollutants is limited,
• Coverage of effects categories from pollutants covered is limited, and
• The valuation of effects covered is sometimes incomplete.
Two potentially important pollutants for which emission reduction es-
timates have been obtained, but for which valuation factors do not exist,
are CO and HC1. Adverse health effects that can result from low level CO
exposure include aggravation of angina and other cardiovascular diseases,
effects on the central nervous system, and reduced exercise capacity. A po-
tentially major adverse effect from HC1 exposure is materials degradation.
In addition, two epidemiological studies have linked HC1 exposure to den-
tal erosion and high level exposures have been linked to adverse respiratory
effects. HC1 is also a minor contributor to acid rain.
Organics emission reductions were not valued in this analysis. This is
not expected to be a major omission since cancer risks from MWC organics
is expected to be small. Metal emission reductions were also not directly
valued in this analysis. However, some of the benefits, such as mortality
risk, most likely have been quantified within the PM benefit assessment. To
the extent that categories of adverse effects from metal emissions were not
covered within the PM benefit analysis, additional unquantified benefits
may exist.
5There is a fourth way this analysis might be considered to be incomplete. The analysis
focuses on benefits associated with emission reductions, and does not itemize or evaluate
benefits accruing simply from having uniform regulations in place. Many of these latter
benefits are itemized in Section 4.3.1 above. They include technological innovation in
combustion technology and pollution control, improvements in (and strengthening of) state
permitting procedures for siting new MWCs, mitigation of NIMBY political pressure on
public officials, and less frustration for private waste disposal firms that operate in several
states and must comply with each state's requirements
12-8
-------
Coverage of the effects from the pollutants studied in this report is also
incomplete. Table 12.4 summarizes the potential effect categories and the
effect categories valued in this analysis for each MWC pollutant.
Finally, even for effects valued, coverage is sometimes incomplete. For
example, the PM and SO2 morbidity valuations do not account for residual
pain and suffering, the SO2 agricultural effects valuation only covers three
crops, and all of the mortality and morbidity valuations do not fully account
for hardship on other family members. Given the limited coverage of this
analysis, the national benefit estimates reported in this chapter may be
best interpreted as low-end estimates and may not be directly comparable
to national cost estimates.
12.5 Summary
Table 12.5 presents partial national MWC benefit estimates from PM,
and S(^estimated emission reductions for each regulatory alternative and
scenario under study. The ranges presented should be interpreted with cau-
tion since they were calculated from the benefit ranges on each individual
pollutant and these ranges are based on different uncertainty factors. For
example, the SC<2 benefit range only reflects uncertainty over the control
scenario selected in the Industrial Boilers SO2 RIA, whereas the PM benefit
range reflects uncertainty over the dose-response and valuation information
employed.
12-9
-------
Table 12.4: Types of Benefits Included in, and Excluded from,
the Benefits Analysis
Benefit Category
Health Effects
Mortality due to chronic exposure
Mortality due to acute exposure
Morbidity due to chronic exposure
Morbidity die to acute exposure
Soiling and Materials Damage
Residences
Commercial and Industrial Sites
Visibility Climate Effects
Local visibility
Non-local visibility
Visibility at national parks
Climate
Non-Human Biological Effects
Agriculture
Forestry
Fisheries
Ecosystem
SO2 SO4
— —
- -
X —
X
X
- -
NA X
NA X
NA
NA NA
X
- -
- -
— —
PM CO
X
X
- -
- -
X NA
- NA
- NA
- NA
- NA
- NA
NA NA
NA NA
NA NA
NA NA
HC1 Organics
— —
- -
- -
— —
NA
NA
NA NA
NA NA
NA NA
NA NA
NA
NA
NA
NA
X = Included in this benefit analysis
- = Excluded from this benefit analysis
NA = Not applicable
12-10
-------
Table 12.5: Partial National Annual Benefits
From Reducing MWC Emissions
Scenarios - Standards -
and Benefits
Regulatory Low Best High
Alternatives - (106 1987 $) -
No- Substitution Scenario
RA I 23 83 200
RAIIA 44 102 223
RAIIB 50 115 251
RAIII 59 120 243
RA IV 65 133 272
Substitution Scenario
RAI 28 81 196
RAIIA 31 69 148
RAIIB 35 79 172
RAIII 36 70 141
RAIV 40 80 164
Scenarios - Guidelines
and Benefits - -
Regulatory Low Best High
Alternatives - (106 1987 $) -
No-Substitution Scenario
RA I 36 104 249
RA IIA 63 136 286
RA IIB 75 167 356
RAIIB' 77 171 362
RA III 97 176 332
RA IV 109 207 403
Substitution Scenario
RA I 14 39 95
RA IIA 41 71 132
RA IIB 54 104 206
RAIII\ 74 109 178
RAIV 87 144 252
12-11
-------
Chapter 13
Weighing Some of the Benefits
and Most of the Costs
13.1 Evaluation Criterion
Benefit-cost analysis provides a framework for assessing the potential
changes in society's well-being under each of the regulatory alternatives
of the Standards and Guidelines. Using the Hicks-Kaldor compensation
principle, society is judged to be better off if potential net benefits (bene-
fits minus costs) are positive and potential gainers are able to compensate
potential losers.
13.2 Qualifications
Because of data paucities, the application of the benefit-cost methodol-
ogy to evaluation of the regulatory alternatives results in a comparison of
some of the potential benefits with almost all of the potential costs. Con-
sequently, a regulatory alternative that has quantified potential benefits
less than the quantified potential costs does not necessarily imply society's
well-being is worsened. Furthermore, the regulatory alternative that yields
the greatest level of quantified potential net benefits does not under these
conditions imply the greatest improvement.
13-1
-------
The estimated costs and benefits for the substitution scenario are not
compared in this section because of severe lack of coverage. Calculated
benefits for this scenario reflect only emission reductions from remaining
MWC sites and do not credit emission reductions for sites that "switch" to
landfilling. Furthermore, landfilling costs and emissions are not included in
the estimates.
13.3 Results
The estimates of some of the potential benefits and most of the po-
tential costs for the Standards and Guidelines are displayed in Table 13.1.
Despite incomplete coverage of the benefits, regulatory alternative I results
in predicted positive net benefits for both the Standards and Guidelines.
This indicates an unambiguous improvement in society's well-being for this
alternative. Unfortunately, the benefit analysis is particularly incomplete
for the more stringent regulatory alternatives, since potentially large bene-
fits from acid gas control are not quantified. Without complete coverage of
the benefits, EPA cannot conclude anything about the net benefits of the
other alternatives. Hence, it is not possible to identify the alternatives that
result in the greatest improvement in society's well-being.
13-2
-------
Table 13.1: National Social Costs and Partial National Benefits
From Reducing MWC Emissions (106 1987 $)a
Scenario
and
Regulatory
Alternative
- - - Standards - - -
Annual
Costs
No-Substitution Scenario
RAI
RAIIA
RAIIB
RAIH
RAIV
6.41
97.2
115
150
168
No-Substitution Scenario
RAI
RAIIA
RAIIB
RAIII
RAIV
6.41
90.8
17.8
35.0
18.0
Partial
Annual
Benefits
- - - Guidelines
Partial
Annual Annual
Costs Benefits
— Costs and Benefits over Baseline
83
102
115
120
133
104 104
269 136
343 167
583 176
657 207
— Incremental Costs and Benefits
83
19
13
5
13
104 104
165 32
74 31
263 9
74 31
a Costs are from Table 10.5. Benefits are the best estimates (mid-
range values) from Table 12.6. This table does not incorporate (1)
costs for NOX control, (2) costs for materials separation, (3) costs for
best acid gas controls on existing MWCs with capacity of 2,000 Mg
per day or greater (Regulatory Alternative IIB'), and (4) revised
PM emission reduction estimates for the Guidelines. These costs
and revisions were developed too late to be incorporated into the
economic and benefit analyses.
b Values are the costs and partial benefits over those of the baseline.
c Incremental values are the costs and partial benefits over those of
the preceding regulatory alternative, which in the case of regulatory
alternative I is the baseline.
13-3
-------
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