DOCKET REPORT
SUPPORTING DOCUMENTS FOR THE REGULATORY ANALYSIS

   OF THE PART 264 LAND DISPOSAL REGULATIONS
                    Volume I
                August 24, 1982
      U.S.  Environmental Protection Agency
               401 M Street,  S.W.
            Washington,  D.C.   20460

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                                 DOCKET REPORT

                SUPPORTING DOCUMENTS FOR THE REGULATORY ANALYSIS
                   OF THE PART 264 LAND DISPOSAL REGULATIONS
                               TABLE OF CONTENTS

Volume I

Chapter I    —   Introduction

Chapter II   —   Profile of Land Disposal Units and Facilities Costed in the
                  Analysis

Chapter III  —   Assumptions/Costs Included in the Baseline

Chapter IV   —   Summary of Part 264 Regulatory Requirements

Chapter V    —   Ground-Water Protection and Corrective Action Costs

Chapter VI   —   Assumptions and Methodology Used to Calculate Annual Revenue
                  Requirements

Chapter VII  —   Results of Cost Analysis

Chapter VIII —   Impacts of the Regulations on Selected Industries


Volume II

Appendix A   —   Regulatory Analysis (Section IX. of the Preamble to the Part
                  264 Regulations)

Appendix B   —   Unit Costs Used to Develop Baselines

Appendix C   —   Part 264 Engineering Costs for Landfills, Surface Impoundments,^
                  Waste Piles, and Land Treatment areas

Appendix D   —   Cost Estimates for Containment of Contaminated Ground-Water
                  Plumes


Volume III

Appendix E   —   Printouts of Annual Revenue Requirements and First Year Cash
                  Requirements for Landfills, Surface Impoundments, Waste Piles,
                  and Land Treatment areas by Size.

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                                                                         2G9S9
                                    CHAPTER I

                                  INTRODUCTION
       ils report  provides complete  background information  on the  underlying

data and assumptions used to  estimate compliance  costs  for the Part  264  land

disposal regulations.   The report systematically  describes the various  steps

that were taken to develop the costs shown in Section IX of the Preamble to the

regulations.  It is organized into 8  chapters  (one  for each major  component  of

the analysis) and 5 appendices.^  Each of these is summarized below.

     o Chapter II defines  the population of land disposal  units and  facilities
       based on information  contained in  the  Hazardous  Waste Data  Management
       System (HWDMS).   Separate size distributions  were  developed for  land-
       fills , surface impoundments, land treatment  facilities, and waste piles
       so that design and  operating (D&O) and  corrective action costs  could  be
       estimated for a  range  of unit  sizes  for  each type  of process.   The
       total number of  units  for each type of  process was  estimated  to provide
       a basis for calculating total D&O costs.

       In order to calculate total corrective action costs on a facility instead
       of a unit  basis,  the  individual  processes  were combined  to develop  a
       distribution of  land disposal  facilities.   This  distribution  depicts
       land disposal facilities  on the basis  of their size and the  particular
       combination of land disposal  units at  the  facility.  For example,  a
       facility might consist  of three  disposal  processes   —  a landfill,  a
       surface Impoundment and a waste pile.
     1 To aid  in understanding this report, definitions  of several key  terms
are provided here.

     (1)  Land disposal process refers  to  a method  of  disposal or a  disposal
     technique.  The disposal  media  focussed on  in  this  report include  land-
     fills, surface Impoundments,  land treatment and  waste piles.

     (2)  Land disposal unit refers  to single  landfill,  surface  impoundment,
     land treatment area  or waste pile.   The analysis examines  both D&O  and
     corrective action  costs  on a  per unit basis  for various  sizes of  each
     process.

     (3)  Land disposal facilities  are combinations of individual  land  disposal
     units.  For example,  a "facility"  may  consist of two  surface  impoundments,
     one waste pile and one land treatment  area.   Total  corrective  action  costs
     were estimated on a facility basis using average facility  sizes.

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                                 1-2

o Chapter III  explains  the methodology used to derive  baseline D&O costs
  for all land disposal  processes.   Baseline  costs  reflect  both normal
  capital and  operating expenses incurred  whether or  not  any regulatory
  system exists, in  addition to  costs incurred as a result of the Interim
  Status Standards (ISS).   Estimating  baseline costs  was a necessary pre-
  requisite to  determining  the  incremental  cost  burden  imposed by  the
  Part 264 requirements.

o Chapter IV describes  the Fart 264  D&O requirements that apply to each
  land disposal  process and how unit costs  for  these  requirements  were
  developed using  engineering  models.   It  also reviews the  treatment  of
  these costs in the analysis.

o Chapter V reviews  the assumptions  and  models used to develop corrective
  action costs for individual units and facilities (combinations of units).
  It also discusses  the  sensitivity  of the  corrective action  costs  to
  changes in some of the key technical assumptions.

o Chapter VI describes  the  economic  assumptions  and methodology used  to
  derive estimates of  the  annual  revenue required to   offset  the incre-
  mental costs of the Part 264 regulations for each land disposal process.
  Estimates of  total D&O  costs  were  obtained by  multiplying the  costs
  estimated for  each unit size by  the number  of  units  in  that size cate-
  gory and summing across all  processes.   Total  corrective  action  costs
  were derived by multiplying  corrective action  costs  estimated  for each
  facility configuration  by  the  number of  facilities  with  that configura-
  tion and summing across  all facilities.  Total  D&O   costs  were merged
  with total corrective action costs  to  calculate total  compliance costs.

o Chapter VII reviews the results of  the  analysis  and shows costs estimated
  by unit size for all  processes, total  costs estimated for each process,
  and total costs for all processes.

o Chapter VIII  reviews   the methodology used  to  estimate the  economic
  impacts of the Part 264 regulations on industries  that  generate signi-
  ficant quantities of hazardous waste.

o Appendix A contains Section  XI (Regulatory  Analysis)  of  the Preamble  to
  the Part 264 regulations.

o Appendix B contains  the  unit  costs used to develop  the  baseline  D&O
  estimates  for all land disposal processes.

o Appendix C  contains   the  detailed   engineering  cost  estimates   for  the
  Part 264 D&O requirements for all  landfill, surface  impoundment, land
  treatment and waste pile unit sizes considered in the analysis.

o Appendix D contains a  copy of the  technical working papers: Cost Estimates
  for Containment  of Plumes  of  Contaminated  Ground Water  prepared  by
  Geraghty and Miller,  Inc.  The report explains in detail  the assumptions
  and models used  to estimate all  corrective action  costs  used in  the
  analysis.

o Appendix E contains tables showing  the baseline and  Part  264 Incremental
  annual revenue requirements  and  first year  cash requirements  for  all
  landfill,  surface Impoundment, land  treatment and waste  pile unit  sizes
  used in the analysis.

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                                      1-3

     It is EPA1 s intent that this  report  be complete enough so that any inter-

ested party  can  use  the  information  it  contains  to reconstruct  any  of  the

costs/results contained in Section IX (The Regulatory Analysis) of the Preamble

to the Part 264 regulations.

     A team  of  consulting  firms  assisted  EPA  with this  Regulatory  Analysis.

Each firm  contributed to different  aspects  of  the  analysis.   The  firms  and

their areas of responsibility are listed below.

     o Development Planning and Research Associates (DPRA)  developed  the  ini-
       tial distributions of land  disposal  units and  facilities by  size  from
       the Part A data in the Hazardous Waste Data Management System.

     o Pope-Reid Associates, Inc.(PRA)  developed detailed  engineering  models
       used to derive unit costs for  landfills,  surface  impoundments  and waste
       piles.

       K.W. Brown provided technical  and  cost  information on  land  treatment.

     o SCS Engineers reviewed PRA's models  and data  Inputs to  those models  and
       contributed technical expertise  on all land disposal processes  for  the
       analysis.   They also  estimated some of  the planning and demonstration
       costs that firms  could  incur as a result of the  Part  264 regulations.

     o Geraghty and Miller (G&M) developed  detailed technical  models used  to
       estimate corrective action  costs under a range of hydrogeologic  condi-
       tions .

     o Industrial Economics, Inc.  (IBc) performed the  industry  impact analysis
       described  in Chapter  VIII.   They also assisted in  developing  the popu-
       lation distributions for the various  land disposal  processes, provided
       estimates  of post-closure costs for  landfills and  surface impoundments,
       and closure and post-closure  financial assurance  costs  for a range  of
       financial  instruments.

     o Sobotka and Company,  Inc. (SCI) developed  the   economic  models used  to
       calculate  the incremental costs of  the Part 264 regulations for individ-
       ual land disposal  units  and for all  facilities  as a  whole.   In this
       capacity,  SCI  was  responsible  for coordinating the  work of  the  other
       team members and  synthesizing  all the separate  efforts into  a  single
       product for the Preamble and this Docket  Report.

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                                   CHAPTER II




      PROFILE OF  LAND DISPOSAL  UNITS AND  FACILITIES  COSTED  IN THE  ANALYSIS






     Four types of land disposal processes are affected by the Part 264 regula-




tions:  landfills, surface  impoundments,  land  treatment areas  and waste piles.




This chapter summarizes the methodology used to estimate, for each process, the




total number of process units  and  their  size distributions.   It also describes




the methodology used to  combine  the different  types  of units to develop  a




distribution of land disposal facilities.




     First, individual landfill, surface  impoundment, land treatment and waste




pile populations were defined.   These populations  provided the basis for costing




the design and operating  (D&O) requirements specified  in the  Part  264 regula-




tiona.  Second, the  distribution of land disposal  facilities  (combinations  of



individual process units) according  to the types of  processes  located at each




facility was estimated.   This  distribution was used  to estimate total correc-




tive action costs that could result from the regulations.




     The methods used to  obtain these distributions and  their  purposes  in the




analysis are described in greater detail below.






A.   Distribution of Land Disposal Units By Size




     The number and  sizes  of existing landfills,  surface  impoundments,  land




treatment areas and  waste piles  were derived  from the Part A data contained in




the Hazardous Waste  Data  Management System (HWDMS).  Adjustments were made to




all data obtained from the HWDMS to account for missing data.




     1.  Landfills.  The  number of landfills  reported  in the Part A  data  was




increased by 23 percent to account for facilities that  did not  report  on their




landfilling activities for reasons  of confidentiality.   Landfills were separated




into off-site and  on-site on the basis of SIC code.  Facilities with a SIC code

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                                      II-2

of 4953  (refuse  systems)  were classified  as  off-site  landfills.   All  other

facilities were classified as on-site.

     Based on  the  Part A  data,  Development,  Planning and  Research Associates

(DPRA) tabulated 24  size  categories of landfills measured  in acrefeet.  Pope-

Reid Associates, Inc. (PRA) then used these categories to obtain a range of eight

landfill sizes measured in terms  of annual  operating capacities.  This  simpli-

fied the analysis by limiting the number of sizes to be costed, and resulted in

a distribution (shown in Table II-l) that  was more  appropriate for costing the

O&O component of the  regulations  than  was  the distribution  based on acre-feet.

The Pope-Reid  distribution was  then used  to  estimate  the  landfill D&O  and

corrective action unit  costs  reported in  Section IX.D of  the Preamble  to  the

Part 264 regulations  and  Section A.I  of  Chapter VII  of this  report.   It  was

also used  to  estimate the total  D&O costs for landfills  reported  in  Section

IX.F of the Preamble and Section C of Chapter III of this report.

                                   TABLE II-l
                       Distribution of Landfills By Size
Unit Size
(MT/Year)
500
2000
5000
7000
15000
35000
60000
123000
Number
Offsite
9
10
4
7
11
9
13
39
of Units
Onsite
246
60
30
36
42
13
15
29

Total
253
70
34
43
53
22
28
68
                      TOTAL            102       471     573


               Estimated Average Annual Capacity =• 21,549 MT/yr.

     2.  Surface Impoundments.   The  HWDMS  provides information  on  the  total

capacity of surface impoundments at each site by  type  of impoundment: storage,

treatment, or disposal.   However,  there is  no data on  the number of  surface

impoundments at each site.

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                                      II-3


     To estimate the total number  of  surface impoundments,  the following steps

were taken.

     o If  the  part A Information indicated  ownership  of  both storage and dis-
       posal impoundments, they were counted separately, unless their capacities
       were the same.

     o Where the  total  capacity of a disposal  or  storage Impoundment was less
       than or equal to 100,000 gallons, the facility was counted as a 1/4 acre
       impoundment.

     o For treatment  impoundments, where the  total  capacity was less  than or
       equal to 10,000 gallons, the facility was counted as a 1/4 acre impound-
       ment.

     o Where a disposal or treatment Impoundment was larger than 100,000 gallons
       or where a  treatment impoundment  was larger  than 10,000 gallons,  but
       where the total  size  was less than  40  acres,1  the facility  was counted
       as two surface impoundments, each with half the total capacity.

     o Where a size greater  than 40 acres  was  Indicated,  the number of surface
       Impoundments was determined  by dividing the total acreage by  20 acres
       and rounding up.

     o The total number of impoundments derived  from this  process was multiplied
       by a factor of  1.11 to account  for firms  that did not submit Part A's for
       reasons of confidentiality.

This process  resulted in  an average of  2.45  surface impoundments per  site.

     The Surface Impoundment Assessment  (SIA)  data base  was  used  to establish

size categories and their means,   which  were  used  to derive point estimates

appropriate for use  in the  analysis.  The  data  base indicated that  about 45

percent of all  hazardous  waste impoundments were smaller than  1/4 acre.  The

analysis treated these facilities as 1/4 acre impoundments.
     1 Forty acres  is roughly equivalent  to  120 million gallons  for disposal
and storage surface  impoundments or  8 million gallons  per day  for  treatment
surface impoundments.

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                                      II-4

     Sizes in the SIA data base reported as greater  than 15 acres  were collapsed

into the 7 to 15 acre category (11  acres is the midpoint) because of uncertainty

regarding the  feasibility of  the  larger  surface  impoundment sizes.   For the

purposes of  estimating  the total  D&O costs  of  the Part  264  regulations, all

surface impoundments  were  assumed to  be  on-site  facilities.   However,  for

purposes of  estimating  industry impacts, Impoundments  were  separated  into on-

site and off-site categories.   (See Chapter VIII.) Table II-2 shows the distri-

bution that  was used to  estimate the  D&O costs  for  surface  impoundments in

Sections IX.D  and  IX.F  of the  Preamble and in Section A.2  of Chapter  VII of

this report.

                                   TABLE II-2
                  Distribution of Surface Impoundments By Size

                        Unit Size
                          (Acres)           Number of Units

                          1/4                    1904
                          1/2                     460
                           1                      393
                           2                      513
                           5                      271
                          11                      699

                          Total                  4240


                      Estimated Average Size =2.63 acres


     3.  Land Treatment  Units.  The total  number and size distribution of land

treatment facilities are  based  on Part A data  contained  in the  HWDMS.   The

total number of land treatment  facilities  was multiplied  by a factor of 1.2 to

account for  firms  that  did not  report  for reasons  of  confidentiality.   Table

11-3 shows  the distribution  of land  treatment  units  used  in the  analysis.

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                                      II-5

                                   TABLE II-3
                 Size Distribution of Land Treatment Facilities
Unit Size
(Acres)
1.7
6.5
20.1
74.3
247.1
Number
of Units
70
56
55
25
35
                            Total             241


                     Estimated Average Size = 50.2 acres


     4.  Waste Piles.  Numbers  and  sizes of  waste piles were based  on Part A

data.  The total  number  of  waste piles  was multiplied  by  a factor  of 1.2 to

account for  nonreporting  firms.    The   frequency  distribution  of waste  pile

sizes obtained  from the Part  A data  was adjusted  by EPA  to  develop a  size

distribution appropriate for this  analysis.   The distribution  used  is  shown

in Table 11-4.

                                   TABLE II-4
                        Size Distribution of Waste Piles
Unit Size
(000 Cubic Feet)
2
10
25
100
500
1000
Number
of Units
306
53
45
107
45
52
                            Total               608


                  Estimated Average Size =  143,000 cubic feet

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                                       II-6

B.   Distribution of Land Disposal Facilities

     To calculate total  corrective action  costs,  EPA used  the  Part A data to

group individual  units  into  facilities  and to estimate the average acreage

required for  different  combinations  of  land disposal  units.  This  was done

because land  area  was used  as a  surrogate  for  plume  size,  and  corrective

action costs  were  estimated  on the  basis  of  plume  size.   Total  corrective

action costs provided  in Section IX.F of the Preamble assumed that plume sizes

were equivalent  to  the  acreage of  the  total  waste management area  at land

disposal facilities.1  The  distribution  of  land disposal facilities  is  shown

in Table II-5.
                                   TABLE II-5
                  Distribution of Land Disposal Facilities by
                      Size and Type of Disposal Activities

                                           Total Number        Average
Type of Facility                           of Facilities       Acreage1

Landfill only                                   267               34
Surface Impoundment only                       1292                9
Land Treatment only                              72              103
Waste Pile only                                 376              1/2
Land Treatment/Waste Pile                        77              309
Landfill/Waste Pile                              24               44
Landfill/Land Treatment                          14              243
Surface Impoundment/Waste Pile                  113                8
Surface Impoundment/Land Treatment               74               76
Surface Impoundment/Land Treatment/              12               80
  Waste Pile
Surface Impoundment/Landfill                    155               45
Surface Impoundment/Landfill/Waste Pile          38               65
Surface Impoundment/Landfill/Land Treatment      35              162
Surface Impoundment/Landfill/Land Treatment/  	5              138
  Waste File

       Total Number of Facilities           ~  2484               32 (average
                                                                      acreage)
     1 Acreages derived  from the  Part  A data were adjusted by a  factor of 1.5
to account  for common  areas between  the individual  land disposal  units and
between the waste disposal area and the property boundary.

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                                  CHAPTER III




                   ASSUMPTIONS/COSTS INCLUDED IN THE BASELINE






     Baseline coses  for landfills,  surface  impoundments,  land treatment areas




and taste piles were developed before  calculating the incremental costs due to




the Part 264  regulations.   The baseline was composed  of  costs attributable to




the interim status  standards (ISS regulations) and basic  operating costs that




facilities would incur  regardless of the existence of federal, state, or local




regulatory programs.




     Baseline costs  for landfills  and  surface  impoundments  were  broken  out




between pre-ISS  costs   (costs  prior  to a  regulatory  program) and  ISS incre-




mental costs  (those  incurred as a result  of the  ISS  requirements).  Baseline




costs for  uaste piles  and  land treatment  areas  consisted  entirely  of  ISS




incremental costs.   This  was  because  detailed  information   regarding  normal




pre-ISS operating practices and costs were not readily available for the latter




two processes.




     Appendix B provides a complete listing  of  the unit baseline costs by type




of process for  all unit  sizes used in  the  analysis.  Baseline  cost elements




and assumptions are summarized below.






A.   Pre-ISS Costs and Assumptions for Landfills and Surface Impoundments




     1.  Landfills.  EPA developed detailed costs  for several different landfill




sizes, attempting to capture all significant  elements that would  be required




for a landfill  to operate.   A fitted  curve (based  on a power  function)  was




used to  Interpolate  costs  for some  intermediate landfill  sizes used  in  the




analysis.  Pre-ISS  costs  were  the  same  for on-site and  off-site landfills,




because the analysis treated all pre-ISS landfills  as if they  were off-site,




grassroots facilities.    As  with  all unit  costs  used in the analysis,  costs




were broken out into:

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                                     III-2

     o capital — depreciable expenses  incurred in the zero year (the year before
       facility operation starts;

     o initial — nondepreciable expenses Incurred in the  zero year;

     o annual —  recurring  operating  costs  and  other nondepreciable expenses;

     o last year capital — depreciable expenses occurring in the  last year  (year
       20 of facility operation); and

     o other  last  year  —  nondepreciable  expenses   occurring  in year 20.

Table III-l  lists the  elements  for  which  pre-ISS costs for  landfills  were

estimated.

                                  TABLE III-l
                     Pre-ISS Cost Components for Landfills

                                 Capital Costs

                     o Office space      o Heavy equipment
                     o Dewatering        o Truck scales
                       pumps             o Water wells
                     o Road gravel       o Utilities
                     o Revegetatlon      o Site clearing
                                           and grading

                                 Initial Costs

                               o Land  acquisition
                               o Cell  excavation

                  Annual Costs Occurring in Years 0 Through 19

                               o Cell  excavation

                  Annual Costs Occurring in Years 1 Through 20

                     o Clerical labor    o Overhead
                     o Operating labor   o Insurance
                     o Labor burden      o G&A
                     o Supervision       o Cell closure
                     o Fuel              o 5% inspection fee
                     o Electricity       o 10% engineering fee
                     o Equipment         o 15% contingency
                       maintenance labor


     The analysis assumed that landfills have a remaining  operating life  of 20

years and that a landfill cell  is opened each year  starting in  year 0 through

year 19, and that a cell is closed each year starting in year  1 through year 20.

Therefore, cell  excavation  and  closure costs,  although  they are technically

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                                     IH-3

capital costs,  were treated  as annual  costs (incurred  and expensed  in each

year).  Appendix  B provides  a complete  listing of  all unit  costs  shown in

Table III-l by landfill size.

     2.  Surface Impoundments.  Pre-ISS costs estimated for surface impoundments

uere less comprehensive than those  estimated  for landfills,  and consist prima-

rily of facility construction costs.  Surface impoundments are simpler to design

and operate than landfills because  wastes  are piped into instead of physically

placed in the  facility.   Thus, initial capital  costs are less  than  those for

landfills and annual O&M costs are negligible.  Because all surface impoundments

were assumed to be  on-site (i.e., they  are always associated with other indus-

trial or land  disposal processes),  there  was  no need  to  estimate  costs for

offices or  special personnel.   Table  111-2 lists  the  categories  for  which

pre-ISS costs were estimated for surface impoundments.

                                  TABLE III-2
                Pre-ISS Cost Components for Surface Impoundments

                                 Capital Costs

                          o Site clearing and grading
                          o Excavation
                          o Access road
                          o Revegetation
                          o Inlet/outlet valve
                          o 5% inspection fee
                          o 10% engineering fee
                          o 15% contingency

                                 Initial Costs

                          o Land acquisition

                 Depreciable Capital Costs Occurring in Year 20

                          o Fill/compact/slope
                          o Revegetation

                               Intermittent Costs

                  o Dredge and disposal of accumulated wastes

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                                     III-4




     As Table  II1-2  shows, surface  Impoundment excavation Is a  capital cost,




and Is therefore depreciable.  Unlike landfills,  where  new cells must be exca-




vated each year, surface Impoundments are only excavated once In the zero year,




before actual  operation begins.   However,  all surface  Impoundments must  be




dredged periodically to maintain their design capacities.  The analysis assumed




that dredging  frequency Is a  function of surface Impoundment size, although In




practice, other factors  (e.g., production  rates, etc.)  are likely  to  affect




dredging frequency.  Dredging costs  reflect  both the cost to remove (estimated




to be $3 per  metric  ton)  accumulated waste  from the Impoundment and  the cost




to dispose of  the  waste in a  123,000 metric  ton/year off-site landfill.   Ship-




ping costs were not  included  because  assumptions made  regarding hauling dis-




tances would  be extremely arbitrary.   Appendix B provides a  complete listing




of all pre-ISS unit costs  by surface impoundment size.






B.   ISS-Incremental Costs and Assumptions For All Processes




     For the most  part, ISS administrative, monitoring and testing, and record-




keeping and  reporting  costs  were taken from  the Arthur  D.  Little  Economic




Impact Analysis £f_ RCRA Interim  Status  Standards.   Incremental-design costs




resulting from the ISS regulations were estimated by PRA.




     While certain cost elements  were  fixed (independent of facility size and




type), others  varied with  both size  and type of facility.   For  example, ADL's




estimate of the cost  to  prepare an  annual report was  the same  for  all types




and sizes of land disposal units.  However,  the ADL  study used different fenc-




ing and runoff control formulae (which  were dependent  on the amount  of waste




handled) for each type of  process.




     1.  Cost elements that apply to all processes.   Basic  cost  elements that




were generally the  same  for  all  land  disposal  processes are outlined  below.




Exceptions are noted.

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                                III-5

Groundwater Monitoring.  Capital costs for 4 ground-water wells (3 upgrad-
ient and 1 downgradient) were included in the baseline costs for all land-
fills, surface  impoundments,  and  land  treatment  facilities,  consistent
with ISS requirements.

Ground-water sampling and  analysis  costs assumed quarterly testing in the
initial year (year zero) and annual testing thereafter.

Because the ISS regulations do not require waste  piles to undertake ground-
water monitoring, costs  for  this  activity were  not  included  in the waste
pile baselines.

Contingency Equipment.  Capital costs for contingency equipment for clean-
ing up spills, putting out fires, etc. were included in the baseline costs
for all land disposal processes.

Fencing.  Costs  for  fencing were included  for  all  processes.   For land-
fills, fencing  costs  were assumed  to  be annual (surrounding  each cell),
while for the other three types of facilities, fencing costs were included
as depreciable capital expenses incurred in year zero.

Run-off/run-on Control.  The ISS regulations require facilities to collect
run-off and divert run-on from active portions of the facility.  Collected
run-off is to be treated as hazardous.  Baseline  costs for surface impound-
ments , land treatment facilities and waste piles included capital costs in
year 0 for run-off/run-on  control.  Run-on/run-off  control  costs were In-
cluded as annual costs in the landfill baselines.

Planning Costs.  The Part 265 regulations require all facilities to engage
in certain planning  activities.  The  following  types of activities  were
costed for all land disposal processes:

o Contingency plan development
o Closure/post closure plan development
o Waste analysis plan                                                %
o Establishment of a reporting system, operating log, etc. (systems design)
o Training course development

The' analysis assumed  that  all  planning  costs are  nondepreciable expenses
that are incurred in the zero year.

Recordkeeping and Reporting Costs.  The Part 265 regulations impose a num-
ber of reporting costs on land disposal facilities.   Costs for the following
activities were included in the baselines for all land disposal processes.

o Initial Year Costs Only

  - Initial EPA notification
  - Part A administration and recordkeeping and reporting
  - Regulatory review

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                                     III-6

     o Initial Year and Annual Costs

       - Maintenance of detailed disposal records (This was not Included In the
         waste pile cost baseline).
       - Annual report
       - Ground-water sampling and analysis
       - Waste testing
       - Regular inspection
       - Personnel training

     o Last Year Costs

       - Decontamination and certification

     2.  Cost elements that vary by type of process.   The ISS costs  that  were

specific to certain processes are described below.

     Landfill and Surface Impoundment Cap Costs.  The  Part  265 regulations re-
     quire disposal facilities to  close so  as to minimize the need for further
     maintenance and  to  minimize  or  eliminate the  release  of  contaminants.
     PRA estimated the  cost of an ISS  cap for  landfill  cells and for surface
     impoundments.  (The  analysis  assumed  that  surface  Impoundments  close
     as landfills.)

     Post Closure Costs for Landfills and Surface Impoundments.  Costs  for the
     following post closure  activities  were estimated and  included  in the ISS
     baselines for landfills and surface impoundments.  The post closure period
     was assumed to  be  30 years,  consistent  with  requirements  in  Part  265.

     o Capital costs

       - replanting of the facility in the first year of the  post closure period.
       - replacement of  the fence surrounding  the  facility in year  16  of the
         post closure period.
       - correction of damage  to  final  cover expected to  occur  once (assumed
         to be year 15 of post closure period).

     o Annual O&M costs

       - Inspection of the facility
       - grass mowing
       - repair of routine erosion damage
       - fertilization of the groundcover planted at the facility1
       - ground-water monitoring
       - 30% contingency

     Special Requirements for Waste Piles. The ISS regulations require facility
     owner/operators to install sturdy Impermeable bases  for  waste piles or to
     protect the pile from precipitation and run-on.  PRA developed designs and
     estimated costs  for  bases  that would  last for  the  remaining  operating
     life of the waste pile (20 years).
     1 Actually this  cost occurs annually  for the first  three  years  and then
five times in the next 27 years.  These costs were adjusted to derive an equiv-
alent annual cost to simplify the calculations.

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                                III-7
Although the analysis assumed that  waste  pile  bases last for 20 years, it
did not assume that the piles themselves would last for 20 years.  Rather,
it assumed that piles sized  at  2,000, 10,000 and  25,000 cubic  feet would
be completed, removed and  disposed of each year;  that a 100,000 cubic ft
pile would be completed  in two years; that a  500,000  cubic ft  pile would
be completed in  10  years;  and that it  would  take 20 years  to  complete a
1,000,000 cubic ft pile.

The baseline  analysis  also  assumed  that  all disposal  of  piles,  bases,
contaminated soils, etc., took place  in a 123,000 MT/yr  off-site landfill
that was complying with the ISS regulations.

There were no post closure costs for waste piles.

Special Monitoring Requirements for Land Treatment Facilities.  The   Part
265 regulations require land treatment facilities to perform soil core and
soil pore-liquid monitoring  in the unsaturated  zone, below the depth to
which waste is incorporated.  The regulations do not specify the number of
test locations or the required frequency of sampling.  The analysis assumed
an average of 7 samples per year for soil core and soil pore liquid monitor-
ing in the zone  of  aeration using lyslmeters.  The  analysis also assumed
pH analysis of soil  samples, and  treatment  of  surface water runon/runoff.

Closure for  land  treatment  facilities  consists  of revegetation.   Post
closure costs include costs for soil pore liquid and ground-water monitor-
Ing, and wind dispersal control.

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                                   CHAPTER IV




                   SUMMARY OF REGULATORY REQUIREMENTS COSTED






     This chapter  summarizes the  part  264  regulatory requirements the analysis




addressed for each land disposal  process.   It describes the treatment of these




requirements in  the  analysis and  the  assumptions used to  estimate  costs.   It




also indicates which requirements  could not  be  or were not costed in the anal-




ysis and  provides  the  rationale   for  their  exclusion.  Requirements  for each




land disposal process  are described  separately.  The  reader  is cautioned that




this summary is  intended solely to describe the  analysis  that was undertaken.




It should not  be  used  as a guide to  regulatory requirements  under  Part 264.






A.   Landfill Requirements Costed  in the Analysis




     1.  Liners and leachate collection systems.  The  Part  264 regulations  re-




quire that all landfills (except for existing portions) have liners and leachate




collection systems.   The liners  are  to  be  designed,  constructed,  installed




and maintained to  prevent any  migration of  wastes  out of  the landfill  to  the




adjacent subsurface soil, or ground  water  or surface water  at anytime  during




the active life  (including  the closure period) of the landfill.   In addition,




the regulations  provide  that  owner/operators  of double-lined landfills  are




exempt from  ground-water  monitoring  requirements  under  Subpart  F  of  the




regulations, provided  that  a leak detection system is  installed, between  the




liners.  (The exemption ends if  a leak is detected.) Leachate collection  and




removal systems  are  to be located immediately above the  liner and are  to  be




designed, constructed, maintained  and  operated to collect  and remove leachate




from the landfill.




     PRA developed one  single  liner and  two double liner designs  intended  to




satisfy the performance  requirements  specified in the  regulations,  and  to  be



consistent with  the  more  detailed design  suggestions provided  in the  draft

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                                      IV-2

guidance document  that will  support the  regulations.   The  three  designs are

described below.

     o Design  #1  was  a single  synthetic  liner design.   Its top  layer  was a
       leachate collection  system  which  consisted of  30  cm of  gravel inter-
       spersed with drainage  tiles spaced at 15.25 meter  intervals,  and 15 cm
       of sand.  A 30 mil synthetic membrane was located Immediately under the
       leachate collection  system.  The membrane  was  on a 15  cm sand buffer,
       which completed  the  design.  The design  cost  included  sump pumps,  wet
       wells, and  a leachate treatment system.

       This was the lowest  cost design used in the analysis.   It was believed
       to be  capable   of  satisfying the  performance  requirements  provided in
       §264.301(a).  Owner/operators  using  this  design  would  still  need to
       undertake ground-water monitoring.  Design  costs  were  the  same for both
       off-site and on-site landfills.

     o Design //2 was  a double liner system.  A second  drainage layer of 30 cm
       of gravel was included below the primary synthetic liner and sand buffer
       of Design //I.   A secondary liner consisting of 60  cm  of compacted clay
       was then situated under the drainage layer.

       The clay liner resulted in higher design costs for on-site landfills than
       for off-site landfills.  This was because the analysis assumed that clay
       would not be readily available  to on-site  facilities  and  would need to
       be brought  in.   However, off-site landfills were assumed to locate close
       to sources of clay, so  their clay costs were considerably lower, reflect-
       ing the lower shipping expense.

       The analysis assumed that  landfills  using this design  would  still be
       required to undertake ground-water monitoring.

     o Design #3  was  a double  synthetic liner  system  intended  to  satisfy the
       conditions specified in the Guidance  Document for  avoiding ground-water
       monitoring.  It  consisted of  all the items outlined above,  except that
       the clay liner under Design //2 was replaced with a second 30 mil synthe-
       tic liner sitting  on a  15 cm sand  buffer.  The gravel drainage layer
       located between the  two  liners  served as a leak detection system.  De-
       sign costs  were the same for off-site and on-site landfills.

       The analysis assumed that landfills using this design  would  not need to
       do ground-water monitoring.

Appendix C lists  the  detailed  engineering  costs  for  each  of these designs.

     The regulations  provide  that owner/operators  that  can demonstrate  the

ability of alternative  design  and operating practices and/or location charac-

teristics to  prevent  the  migration  of any  hazardous  constituents   into  the

ground water  or  surface  water  at any  future  time can  be exempted  from some

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                                      IV-3




requirements.  However, EPA did  not estimate the cost of  making such a demon-




stration, or  the potential  cost  savings from  successful demonstrations,  or




make assumptions about  the  number  of  facilities  that would attempt  to  obtain




this exemption or succeed in obtaining the exemption.




     2.  Run-on/run-off control.   The Part  264  regulations  require  landfill




owner/operators to design,  construct, operate and maintain run-on and run-off




control systems.  The run-on control  system  must  be  capable  of preventing flow




onto the active portion of the landfill during the peak discharge from at least




a 25-year storm.  The run-off control system must be capable  of collecting and




controlling the  water  volume resulting  from a 24-hour, 25-year  storm.   These




systems are to  be  managed efficiently,  with special attention  required after




storms to maintain design capacity.




     In addition to the ISS run-on/run-off control  costs Included in the base-




line, PRA's  designs  included  costs  for  systems to  meet these  requirements.




As with the liner costs, the analysis assumed that these costs were incurred in




year zero and in each year of operation except year 20, because of the assumption




that a new cell is opened each year.  (No new cells  are opened in the last year




of operation.)




     3.  Wind dispersal control.   The regulations  require owner/operators  of




landfills containing particulate matter which could be subject to wind dispersal




to cover the landfill or use other appropriate means to control wind dispersal.




This requirement was not costed in the analysis, but is likely to be very small




relative to other compliance costs.




     4.  Monitoring and inspection.   Section 264.303  of  the regulations  impose




additional monitoring requirements  on facilities.  Liners are to  be inspected




during and  immediately after  construction  and  installation  for  uniformity,




damage, and  imperfections.   During operation,  landfills  are  to  be  inspected



weekly and  after storms  to detect  problems with  the  run-on/run-off  control

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                                       IV-4

systems, the presence  of  liquids  In the leak detection systems, or malfunction

of  wind  dispersal control measures.   The analysis did  not cost  any of these

incremental monitoring  and  inspection  requirements.    It  assumed  that  these

costs  would be about the  same under FSS as they were under ISS  (i.e., no change

from baseline).   These costs are expected to  be  very small  compared to  other

compliance costs.

     5.  Surveying and recordkeeping.  Section 264.309 requires owner/operators

to maintain a map showing the exact location and dimensions of each cell with

respect to permanently surveyed benchmarks, and records showing the contents of

each cell and the general location of each waste type within each cell.  Again,

costs  for  these  items were not  estimated,  but are  expected to   be  small.

     6.  Closure.  The  regulations  require  owner/operators  to  place a cap  or

final  cover on each cell at closure.   This cap is to be designed and constructed

to minimize the migration of liquids into the landfill.  It  is also to have a

permeability less than or equal to  the permeability of any  bottom  liner system

or natural subsoils present.  PRA developed liner costs  based  on the following

design.

     o The cap  design  included 61 cm  of vegetated  top soil as a  top cover; a
       30.5 cm drainage layer of sand  with perimeter  collection tiles for run-
       off /runon control; and 61 cm of compacted clay to provide the impermeable
       layer.  Costs assumed that the cell  would be  filled and graded to a 3
       percent slope before final  cover is applied.

     The analysis assumed that cap costs are incurred  in each year  of operation

(yrs 1 through 20), because of the assumption that one cell is opened and closed

each year.  Cap costs  were higher for on-site landfills  than for offsite  land-

fills because of the assumption that on-site facilities do not have clay avail-

able on site but must ship it in,  while off-site facilities  are better situated

with respect to clay supplies.  Engineering  costs for caps  for different  land-

fill sizes are listed in Appendix  C.

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                                      IV-5




     7.  Post closure care.  The regulations require owner/operators  to maintain




the Integrity  and effectiveness  of  the final  cover.   In addition,  they must




monitor the leak detection system or the ground-water monitoring system through




the end of the post closure period, operate  the leachate collection and removal




system for at least three years after closure, and protect and maintain surveyed




benchmarks.  Chapter III lists  the activities for which post closure costs were




estimated, and Appendix  B  contains a more detailed breakout  of these costs by




type and size of unit.




     8.  Special requirements for landfills  that were not costed In the analysis.




Sections 264.312  through 264.316 place restrictions  or  prohibitions on  the




disposal of  certain  types  of  wastes  in landfills  (e.g.,  reactive,  ignitable,




and incompatible  wastes  and liquids).   None of these  requirements were costed




In the analysis,  largely because of the lack of  information  regarding current




Industry practices with  respect  to these  activities  and the amounts  of  these




types of wastes relative to total wastes handled at a facility.






B.   Surface Impoundment Requirements Costed in the Analysis




     Existing portions of surface Impoundments are permitted to comply with the




regulations by undertaking  ground-water monitoring  and  by  closing the facility




at the end  of  its useful life  according to Part  264.  Should  no  ground-water




contamination be  detected  through the  end of  the  post closure  period,  these




are the only  significant costs  the  facility will  incur  as  a  result  of  these




regulations.  The low total  cost case depicted in Table  15  of Section  IX of




the Preamble Is based  on ~such  a  scenario.   It  assumes that at the  end of  the




20-year remaining operating  life, all  surface  impoundments close  as disposal




facilities (i.e.,  wastes remain  in  the impoundment  and  it  is capped like  a




landfill) Instead of closing as storage/treatment  facilities  (where all  wastes




and contaminated soil are  removed at  closure and no  cap or  post  closure  moni-



toring is required).

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                                      IV-6

     While existing portions of surface Impoundments do not technically need to

comply with  the  liner  requirements  specified  In  §264.221 and  §264.222  (only

new surface  Impoundments or  lateral  expansions  of existing  impoundments  are

required to  comply),  owner/operators  of existing surface impoundments may wish

to upgrade their  facilities to reduce  the  likelihood  that they will  leak  and

contaminate ground water.  However, surface  impoundments are not like landfills,

where Part 264 liners can simply be applied to new cells.  The owner/operator

of an  existing  surface  impoundment   that  wants to  install a Part  264  liner

system, must either close the impoundment as a  landfill  according  to the Part

264 closure  requirements  under §264.228 and  construct  a  new impoundment,  or he

can close the facility temporarily and retrofit.   Both  of these options  were

costed in the  analysis for  each of  the  3  liner  systems described  below,  in

addition to the case  where  the owner/operator does nothing except  ground-water

monitoring and closure.  As previously discussed, surface impoundment liner and

cap costs are treated as capital expenses instead of  annual  expenses, because

it is assumed that surface impoundments have 20-year operating lives, while In-

dividual landfill cells only have 1-year lives.   The requirements are described

below.

     1.  Liners.  The Part 264 regulations require  that all surface Impoundments

(except for existing portions) must have liners  that are designed,  constructed,

installed and maintained to prevent any migration of wastes out of the Impound-

ment to the adjacent subsurface soil or ground water or surface water at anytime

during the active life (including  the  closure period)  of the impoundment.  The

regulations require that  liners  for  disposal surface  impoundments  (those that

close as landfills) be constructed of  materials that  can prevent  wastes from

migrating into  the  liner during  the active  life of  the facility.1   Storage
     1 This  uas  Interpreted to  mean that disposal  Impoundments must be  con-
structed with synthetic liners.  Because  the  analysis  assumed that all surface
impoundments are  disposal,  all  the  surface  impoundment  designs  included  at
least one synthetic liner.

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                                      IV-7

or treatment impoundment  (where  wastes are removed  at  closure) liners  can be

constructed of materials  that allow wastes to  migrate  into the liner  but  not

into the adjacent subsurface  soil.   In addition, the draft guidance identified

conditions under  which  single and double  liner systems would  be appropriate.

As for landfills, the regulations provide that owner/operators of certain types

of double-lined  surface impoundments  are  exempt from  ground-water  monitoring

requirements under Subpart F of the regulations, provided that a leak detection

system is installed between the liners.

     PRA developed one  single liner and two  double liner designs  intended to

satisfy the performance requirements  specified  in the  regulations, and  to be

consistent with  the  more  detailed design  suggestions   provided  in the draft

Surface Impoundment Guidance Document.   Although leachate collection and removal

systems are not  required  for  surface impoundments,  PRA included  these systems

in all  three  surface  impoundment designs.   The three designs are  described

below.

     o Design #1  was a single synthetic liner  design  that  included 15  cm of
       protective, compacted  soil placed on  a  15 cm sand layer  interspersed
       with drainage tiles  that  serves as the  leachate  collection  and removal
       system.   A 30 mil  synthetic  liner  was   under the  sand  layer  and  was
       situated on a buffer of 15 cm of sand.  The design coated by PRA included
       sump pumps and drainage tiles,  although  these would not be  required to
       satisfy the minimum  requirements  specified in the regulations and guid-
       ance.

       Owner/operators using this design would  still  need  to  undertake ground-
       water monitoring.

     o Design #2 was a double liner  system.   Its  top  layer consisted  of 15
       cm of soil, as in Design  //I.   This covered  a 30 mil  synthetic liner.
       PRA's design  included  45   cm  of  sand  between the  synthetic liner  and
       the bottom layer  of 61  cm of  compacted  clay.   The  sand between  the
       liners served both as a buffer for the  synthetic  liner  and as a  drainage
       system to  collect  any leachate  that  could pass through the  synthetic
       liner.   PRA's  design includes  drainage  tiles and  sump pumps.   Design
       costs for  all surface  impoundments  assumed  that clay  is  not  readily
       available on-site and must be  brought in.

       Technically,  Design 92 could enable owner/operators to avoid  compliance
       with the ground-water  monitoring  requirements, because it is a double-
       liner design  with  a  30 cm drainage layer  between the  two liners,  a
       drainage  tile system,  and a sump pump  to remove liquid.  However,  the
       analysis  assumed that  Impoundments  using this design  would still need
       to comply with Subpart F.

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                                       IV-8

     o Design  #3 was a  double  synthetic liner  system Intended to satisfy the
       conditions specified  in  the regulations for avoiding ground-water moni-
       toring.   It  consisted of  a  15 cm  top layer  of compacted  soil,  that
       covered  the  first 30 mil  synthetic  membrane.   A 15 cm  sand buffer UBS
       located  immediately  under  the  top liner.   A   full  leachate collection
       system was located  between the two membranes and consisted  of  15 cm of
       gravel with  drainage  tiles and 15 cm of  sand.   Design  costs Included a
       sump pump.   A 15 cm sand  buffer was  located under the  second synthetic
       liner.

     The  regulations  provide  that  owner/operators that  can  demonstrate  the

ability of alternative  design and operating practices and/or  location charac-

teristics to  prevent the  migration  of  any hazardous  constituents  into  the

ground water  or surface water at  any future  time can  be exempted  from  the

requirements.   However,  EPA  did not estimate the  cost of  making such a demon-

stration, or  the potential  cost  savings from  successful demonstrations,  or

make assumptions about the number of surface impoundments that would attempt to

obtain this exemption or succeed in obtaining the exemption.

     2.  Run-on/run-off control.  The Part 264 regulations require that surface

impoundments be  designed and constructed to  prevent  overtopping and  that  im-

poundment dikes  be  designed  and constructed  to prevent massive failure.  PRA's

design costs include costs  for  berms, which act to prevent overtopping during

storms.

     3.  Monitoring and inspection.  Section 264.226 of the regulations impose

additional (above ISS baseline)  monitoring requirements on surface Impoundments.

Liners are to be inspected  during  and immediately after construction and instal-

lation for uniformity,  damage,  and  imperfections.   During operation,  surface

impoundments are to be inspected weekly and after storms to detect sudden drops

in the level  of the Impoundment's contents, evidence of  overtopping, or  the

presence of liquids  in  the leak detection systems.  The analysis did  not  cost

any of these  incremental monitoring and  inspection requirements.  It  assumed

that these costs would  be  about the  same  under Part 264 as  they were under  ISS

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                                       IV-9

 (i.e., no  change  from baseline).   Any incremental  costs are  expected  to be

 very  small compared  to other  compliance costs.

      4.  Emergency repairs and  contingency  plans.   Section  264.227  stipulates

 situations which   would  require  that  a  surface  impoundment be  removed  from

 service and  that  repairs  be  undertaken.   The  frequency and  costs  of  these

 types of  situations  were  not  considered  in  the  analysis.   No  incremental

 (above ISS baseline) contingency planning  or equipment  costs were included to

 meet  Part 264 requirements.

      5.  Closure.  Under the  regulations   surface  impoundment  owner/operators

 can either:  1)  remove and manage as hazardous all  waste residues, contaminated

 containment  system components  (liners,  etc.),  contaminated  subsoils,  and any

 other fixtures  or equipment  that may  be   contaminated;  or   2)  eliminate  free

 liquids by removing  liquid  wastes  or  solidifying remaining wastes  and  waste

 residues and close the  impoundment as a landfill.

      The analysis  considered only  the second  closure option,   because of the

 high  cost of  removing and  landfilling contaminated soils.  It assumed that all

 surface Impoundments  would be capped at closure, just as landfills are capped.

 The regulations place the same requirements  on surface  impoundment caps that are

 placed on landfill caps.  They must be designed and constructed to minimize the

migration of liquids  into the  impoundment.  They must also to have a permeability

 less  than or equal to  the permeability of  any bottom liner  system or natural

 subsoils present.  PRA developed costs for the following design.

      o The surface impoundment cap included  61 cm of vegetated top soil as  a top
       cover; a 30.5  cm drainage layer  of  sand  with perimeter collection tiles
       for run-off/runon control; and 61 cm of compacted clay  to  provide the
       impermeable layer.  Costs  assumed that the  surface Impoundment would be
       filled and  graded to  a  3  percent  slope  before final  cover  is applied.

      The analysis assumed that  cap  costs  are depreciable capital expenses that

are incurred in the last year of operation (year 20).

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                                     IV-10
     6.  Post closure care.  Where  surface  Impoundments close with waste resi-
dues or  contaminated materials  in  place (i.e., they  close  as landfills), the
owner/operator must  comply with all the  post-closure requirements that apply to
landfills.  Where all contaminated materials and soil  are removed, there are no
post-closure requirements.   Because  the analysis  assumed   that  all  surface
impoundments close  as disposal  facilities, all  are  subject  to  post-closure
requirements and costs.  Chapter 111 lists the  activities for which post closure
costs were estimated,  and a more detailed  breakout  of these costs  by type and
size of unit are presented in Appendix B.
     7.  Special  requirements for surface  impoundments that  were not costed in
the analysis.  Sections  264.229  and 264.230 place restrictions or prohibitions
on the disposal  of  certain types of wastes in surface impoundments (e.g., re-
active, ignitable, and incompatible wastes).  None  of these requirements were
costed in the  analysis,  largely because of the lack  of  information  regarding
current industry practices with  respect  to  these  activities  and the amounts of
of these  types  of   wastes  relative to  total  wastes   handled  at a  facility.

C.   Waste Pile Requirements Costed in the Analysis
     The analysis assumed  that  all  waste piles are  treatment or storage piles
as opposed to disposal piles.  Disposal  piles  would  be subject to the same D&O
requirements that  apply   to  landfills.   The regulations stipulate that  piles
that are placed Inside or under a structure that shelters it  from precipitation
can obtain exemptions from both Subpart F and the design and  operating require-
ments listed under  §264.251.  This  compliance" option was  not costed  in the
analysis.
     1.  Liner and leachate collection requirements for waste piles.  If the
pile is not protected from precipitation, the regulations require that the pile
have both a liner and  a  leachate collection and removal system located immedi-
ately above the  liner.   As for landfills and  surface  Impoundments,  waste pile

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                                     IV-11

liners must be designed,  constructed, installed and maintained  to  prevent any

migration of wastes  out  of the pile to the adjacent subsurface  soil  or ground'

water or surface water at anytime during the active life (including the closure

period) of the waste pile.  The leachate collection and removal system is to be

designed, constructed, maintained and  operated to collect  and  remove leachate

from the pile.  The  regulations  provide that  owner/operators of certain types

of double-lined waste piles can  obtain exemptions  from ground-water monitoring

requirements under Subpart F of the regulations, provided that a leak detection

system is installed between the liners.

     The draft guidance for waste piles stated that a base of admixed materials

such as concrete or  asphalt  and  run-off controls could  be  used instead of the

liner/leachate collection system for above grade piles.

     In addition, §264.253 of  the regulations allows  owner/operators  to avoid

ground-water monitoring under  certain conditions if they remove  wastes in the

pile periodically and inspect  the liner or  impermeable base for deterioration,

cracks, or other conditions that may result In leaks.

     PRA developed costs for each of these three compliance options.

     o Liner/Leachate Collection  System:   Costs for a double  synthetic liner
       system were estimated for  waste  piles.   The system consisted of a primary
       30 mil  synthetic liner overlaying  a  leachate  collection system  that
       consisted of a 30 cm  sand layer with drainage tiles and a wet  well and
       sump pump.  Underneath  the leachate collection system there was a se-
       condary 30 mil  synthetic  liner  with  a  15  cm sand  buffer below it.

       Because of the double  synthetic liner, ground-water monitoring  was not
       required.

     o Sturdy Impermeable Base with Ground-Water Monitoring:  Liner costs  used
       here were the same" as  those used for  the ISS baseline.    Capital  costs
       for ground-water monitoring  wells and  initial year and annual  costs for
       ground-water sampling and  analysis  were  included,  consistent with the
       addition of these requirements in Part  264.

     o Sturdy Impermeable Base with Periodic  Inspection:  Liner  costs  assumed
       here were the same  as  those  used  to develop the ISS  baseline.   Annual
       inspection costs to  move the  pile and check the base were added.  Ground-
       water monitoring was not required.

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                                       IV-12




       Costs  to  install  liners or  bases  were  treated  as  depreciable  capital




  expenses, because  the  life  of the  base/liner system was assumed to be 20 years



'  for  all  waste  pile sizes.




       The regulations   provide  that  owner/operators that  can  demonstrate  the



  ability  of  alternative design and operating  practices  and/or location charac-




  teristics to  prevent  the  migration  of  any hazardous  constituents  into  the



  ground water  or surface  water  at  any  future  time can  be  exempted  from  the




  requirements.  However, EPA did  not estimate the  cost  of  making such a demon-




  stration, or  the  potential  cost  savings  from successful  demonstrations,  or



  make  assumptions about the  number of waste  piles  that  would attempt to obtain



  this  exemption or  succeed in obtaining the exemption.




       2.  Run-on/run-off control.  The  Part  264 regulations  require  waste pile



  owner/operators to design,  construct, operate  and  maintain run-on and run-off



  control  systems.   As  for  landfills,  the run-on control system  must  be capable



  of preventing  flow onto  the active  portion of the  landfill during  the  peak



  discharge from at  least a 25-year storm.   The  run-off control  system must be



  capable  of collecting and  controlling the water volume resulting from a 24-hour,



  25-year  storm.   These  systems  are  to  be  managed efficiently,  with  special



  attention required after storms to maintain design capacity.



       Part 264 run-on/run-off control costs were the same as those estimated  for



  the ISS  baseline.  However,  where owner/operators  elected  to comply  by instal-



  ling  a llner/leachate  collection system instead of the hard impermeable  base,



  run-on/run-off control costs were slightly reduced, because of the smaller area



  required for that  containment  system.   As with the liner  and base costs,  run-



 on/run-off control costs are capital expenses Incurred in year zero.



       3.  Wind dispersal control.   The regulations  require  owner/operators  of



  waste piles  containing particulate  matter  which  could   be subject  to  wind

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                                     IV-13



dispersal.  PRA included costs  for a jute mesh placed over the lateral surface



area of the pile to minimize wind dispersal.



     4.  Monitoring and inspection.  Under  §264.253,  owner/operators that move




their wastes periodically to inspect the pile base can be exempted from Subpart




F requirements.  PRA estimated costs for annual inspections that included costs




to move the waste, inspect the base and report on the state of the base.  Other



incremental (above  ISS)  monitoring  and inspection  costs,  such  as  liner/base




inspection during  and  immediately after construction and  installation,  weekly



inspection during  operation,  and  inspection after  storms to  detect  problems



with the  run-on/runoff control systems,  the presence of  liquids in  the leak



detection systems, or malfunction  of  wind  dispersal  control measures,  were not



coated.  As  for the  other facilities,  these costs  are expected  to  be  very



small compared to other compliance costs.



     5.  Closure.  The regulations require owner/operators to remove and manage



as hazardous all  waste  residues,  contaminated  containment system  components



(liners, etc.), contaminated subsoils,  and contaminated structures and equipment



at closure.  If this is not feasible,  the  waste  pile is  subject to the closure



and post  closure  requirements that  apply  to landfills.  The  analysis assumed



that all waste  pile  owner/operators close by removing wastes,  at  closure.  PRA



estimated the costs  to remove the waste and  containment system and  dispose of



them in a 123,000  MT/year off-site  landfill  with  a  Part  264 double  liner



(synthetic/clay) system.   Transportation costs were not included.



     6.  Post Closure Care.   Waste  piles  where  all wastes  and  contaminated



soils, etc. are removed at  closure are not subject to post closure requirements.



Because the analysis assumed that  all wastes,  residues, contaminated soils, etc.



were removed at closure, it was not necessary to  estimate  post closure  costs.



     7.  Special requirements for waste piles.   Section  264.257  prohibits  the



placement of incompatible  wastes  in the same  pile unless  certain  conditions



apply.  Costs were not estimated for this requirement.

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                                     IV-14

D.   Part 264 Land Treatment Requirements

     Costs estimated for  land  treatment areas differ from  costs estimated for

other processes  because there  are no  requirements  for  a  containment  system

under this process.  Rather,  the regulations and  guidance  specify a treatment

program Which, if  followed,  will ensure that hazardous constituents placed on

or in the treatment zone are degraded, transformed or Immobilized.

     The types of compliance activities required under the Part 264 regulations

and their treatment in the analysis are described below.

     1.  Treatment demonstration.   For  each  waste  to  be  applied,  §264.272

requires owner/operators  to  demonstrate that  hazardous   constituents  in the

waste can be  completely degraded, transformed or  immobilized  in the treatment

zone.  Field tests or laboratory analysis can be used to make the demonstration.

The demonstration must be  based on conditions similar to  those present  in the

treatment zone.   The analysis  assumed  that each land treatment area  would

undertake one initial  waste analysis  and demonstration.  The  cost used  repre-

sented an average  of the cost  of  field testing and the cost  of lab analysis.

     2.  Design and operating requirements.   The  regulations  require  owner/

operators to maintain  land treatment  facilities  to maximize  the degradation,

transformation and immobilization  of  hazardous  constituents in  the treatment

zone.  To do this the regulations require that they:

     o control soil pH.   The  analysis  assumed  that 10  percent  of all  land
       treatment areas would require an initial pH adjustment.  The pH adjust-
       ment was attained by applying lime to the area.

     o apply wastes at a specified rate.  The analysis assumed  that  wastes are
       applied at a rate of 206 metric tons per acre per year.

     o fertilize or take other action  to enhance microbial  or chemical reac-
       tions .Annual costs  for ground  cover  planting  and  fertilization  were
       included for 90 percent of the  areas.

     o control moisture content.  The analysis  assumed  that 90  percent of all
       land treatment areas  that are  20 acres or  larger  would  incur  capital
       costs for an  irrigation mobile  pump and spray  nozzle.   Smaller  areas
       were assumed  to  use  garden hoses.   Annual costs  for  irrigation  that
       assumed operation  of the  system for  two  hours  every  three days  were
       applied to 90 of all areas (regardless of size).

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                                     IV-15

     o minimize run-off of hazardous constituents from the treatment zone.   No
       Incremental costs  were  assumed for  run-off  control,  because  it  was
       assumed (based on Part A information) that most areas are already graded
       to the desired slope for proper run-off control.

     o design, construct and maintain a run-on control system  capable  of  pre-
       venting flow onto the treatment zone during peak discharge from at least
       a 25-year  storm.  No incremental  (over  ISS)  costs were assumed for run-
       on control.

     o control wind dispersal of particulate matter.  The analysis assumed that
       the measures  taken  to  control  moisture  content  of the  treatment  zone
       would also satisfy the wind dispersal control requirements.

     o inspect the facility weekly and after storms  to  detect  any  malfunction
       of the run-on/run-off control system  or the wind dispersal control sys-
       tem.  Incremental costs for these inspection activities  were not included
       in the  analysis.   ISS   inspection  costs  were  assumed to  satisfy  this
       requirement.

     3.  Requirements for growing food-chain crops.   Section  264.276 lists re-

quirements for  growing  food-chain  crops  at  hazardous  waste  land treatment

areas.  The  whole area of food chain  crops was not  addressed in the analysis

because of  insufficient  information  regarding  current  practices,  costs  of

complying, etc.

     4.  Monitoring the unsaturated zone.  Section 264.278 requires owner/oper-

ators of land  treatment  areas  to establish  and  carry out an  unsaturated  zone

monitoring program to determine whether hazardous constituents  migrate oat of

the treatment  zone.   The program  is to  consist of  soil and  soil-pore liquid

monitoring using  soil  cores  and lyslmeters.  A  sufficient quantity of samples

is to be obtained to represent background levels and determine  any changes in

these levels.   Information  provided  by R.W.  Brown  indicated that many  land

treatment facilities already engage in  these activities.  Therefore, incremental

costs for these  activities  were  not applied across  all areas.  The  analysis

assumed that 50  percent of all areas would  need  to  add  one lysimeter  per 8

acres (an initial capital expense) and would incur an annual cost to analyze an

additional 5 parameters.  The  analysis assumed  that 25  percent of all areas

would need to increase soil sampling by an additional  soil  core per 4  acres on

an annual basis.

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                                     IV-16




     In addition, the analysis assumed that  10 percent  of  all  areas  would show




a statistically significant  increase  in  hazardous  constituent  levels and would



have to take additional measures (short of corrective action) to respond to the



increases.  Costs  assumed for  evaluating and responding  to  these  situations



were as  follows:  1) additional  annual  pH adjustment costs  were applied  to  3




percent of all areas;  2) capital and annual costs of  expanding the treatment




zone were applied to 5 percent of all areas; and 3) annual costs to  dispose of



overload wastes in an off-site landfill were applied to 2 percent of  all areas.



     5.  Closure.  At closure the area owner/operator is to establish a vegeta-



tive cover on the portion being closed.   The cover must not impede degradation,



transformation or  immobilization of  constituents  and  must  be  able to  grow



without extensive maintenance.   No  incremental  cost (above  the ISS  vegetative



cover) was assumed.




     6.  Post closure care.  The regulations  require owner/operators to continue



all activities  (including pH  control)   necessary  to  enhance   degradation  and



transformation and  sustain  immobilization  of  hazardous  constituents  in  the



treatment zone.   Where  the  owner/operator can demonstrate  that the  level  of



hazardous constituents in the treatment zone does not exceed background levels,



the site can  avoid post-closure requirements.   However, this  alternative  was



not taken into  account  in the  cost analysis.   All land treatment  areas  were



assumed to close  with hazardous constituents in place.  The  analysis assumed



additional post closure costs (over ISS)  for pH control.

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                                   CHAPTER V

                          GROUND-WATER PROTECTION AND
                            CORRECTIVE ACTION COSTS

     Section A  of this  chapter reviews  the  corrective action  scenarios that

were considered  in the analysis.   Section B then briefly summarizes the models

and major  technical  assumptions  that  were used  to  calculate  counterpumping

costs for each of  the scenarios.  Section C examines the sensitivity of correc-

tive action costs  to changes in  some of the underlying  assumptions.   Greater

detail on the technical  aspects of  the  counterpumping costs is provided in the

Geraghty & Miller  (G&M)  working papers entitled  Cost Estimates for Containment

of_ Plumes  of_ Contaminated  Ground-Water,  which  is  included  as Appendix  D to

this report.


A.   Ground-Water  Protection Requirements Considered in the Analysis

     The Ground-Water Protection section of the regulations  (Subpart F) contains

requirements for ground-water monitoring which  specify  procedures that owner/

operators are to follow to determine whether hazardous constituents are leaking

into ground water.   Subpart F also  specifies  what actions owner/operators must

take if any leakage is detected.

     Subpart F requires  facilities  that  are not  currently leaking to undertake

a detection monitoring  program.    Detection  monitoring  requires  the  owner/

operator to monitor  for  the presence  of  any  hazardous  constituents at  the

compliance point  (the  waste  boundary)  through  the  operating  life  and  post

closure period.  The requirements  of  this program are essentially the same as

those under the ISS regulations.

     The regulations require owner/operators that detect hazardous constituents

at the compliance  point  to  undertake  a  compliance  monitoring  program.   The

purpose of the compliance monitoring program is  to determine whether concentra-

tion limits for  specified hazardous constituents  established  in the permit are

exceeded.  This  program  is more  expensive than  the ISS detection  monitoring

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                                       V-2

 program because  testing costs are higher  and samples must  be taken more fre-

 quently.1   Under the  regulations,  corrective action must be taken if hazardous

 constituents  exceed established  concentration limits.

      Four corrective  action  scenarios  were  developed  for  the  cost analysis.

 The  first assumes detection monitoring only  (no corrective action or compliance

 monitoring  necessary)  while the last  three assume  both  compliance monitoring

 and  corrective  action.  A  separate  scenario specifying  compliance monitoring

 without corrective action was not included because the costs  for such a program

 were expected  to be fairly close to the  "Detection  Monitoring Only" scenario.

     The four  ground-water  protection  scenarios  used  in   the  analysis  are

 described below.

      1.  Detection monitoring only.  The lowest cost case examined in the analy-

 sis  assumed that facilities would incur  no incremental costs  (above  ISS) for

 ground-water monitoring.  Part 264 capital costs (to drill 4  wells) and initial

 and  annual  sampling and analysis costs were  the same  as  those included in the

 ISS  baseline  cost streams.  The  tables  of results contained  in Appendix E have

 columns entitled  "No Corrective Action Necessary."  The annual revenue require-

ments listed in  that column assume no Incremental ground-water monitoring costs

over ISS.   The  lower  end of  the total cost  range  estimated  in the  analysis,

 $702 million, also  assumes  no incremental ground-water monitoring  costs (over

 ISS).

     2.  Corrective action required in the zero year, continuing for 150 years.

This scenario  was developed  to provide a  "worst  case" estimate of  corrective

action costs.  It covers  situations  where facilities must pump indefinitely in

order to maintain concentrations  of hazardous constituents at acceptable levels.
     1 The annual  compliance  monitoring cost estimate includes the  cost  to do
a scan of  all Section VIII constituents ($3,500 every three years),  the cost
to take quarterly ground-water samples ($6,000 per year), and the cost to analyze
the ground water for the  presence of specific hazardous constituents ($2,800 per
year for on-site facilities and $12,480 for off-site facilities).

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                                       V-3

 In this  scenario,  150 years  was used as a surrogate for  "forever," as the dis-

 counting factor  for anything  greater than 150 years  rapidly approaches zero.

 Cost streams  for this  scenario  reflect:

     o higher annual  costs  because of compliance monitoring (instead of detec-
       tion monitoring)  starting  in year  one and  continuing  for  150 years;

     o an  initial  cost of $25,000 in year zero to develop a corrective action
       plan;

     o capital costs  in year zero  to  drill  wells and construct the fluid recov-
       ery and  treatment  systems.   The analysis  assumed complete replacement
       of the fluid  recovery  system  every 30  years,  so capital  costs  were
       repeated in years 30, 60, 90 and 120.

     o annual operating  and maintenance  costs for  the counterpumplng program
       starting in year 1 and continuing for 150 years.

 Section IX.F  of  the Preamble to the regulations lists an estimated  range  for

 Part 264 incremental  compliance costs.  The high estimate — $1,145 million —

 Includes $677  million  In  corrective  action  costs,  which  assumes that  all

 facilities must take  corrective action immediately and continue for 150 years.

     3.  Corrective  action required  in the zero year, continuing for 20 years.

 This scenario represents  a mid-cost  case.  Facilities  are  still  required  to

 take action Immediately but all contamination is  effectively removed (concen-

 trations of hazardous constituents  drop  below specified levels)  by the  end

 of year 20.   The analysis assumes  that  the  facility  continues to operate while

 it undertakes  corrective  action.   Cost streams under this  scenario  include:

     o higher  annual   costs  for  compliance monitoring  in  lieu of  detection
       monitoring starting in  year one and continuing through year 20.   Annual
       costs  for detection monitoring from year 21 through year 50 (the end  of
       the post closure period).

     o an initial  cost of  $25,000 in year  zero to develop a corrective action
       plan;

     o capital costs in year zero to drill wells for the counterpumping program
       and to construct the fluid recovery and treatment systems; and

     o annual operating and maintenance  costs for the  counterpumplng  program
       starting in year 1  and continuing for 20 years.

     4.  Corrective action required in year 49, continuing for 20 years.   This

scenario assumes that  no  leakage is  detected  until  the last year of  the  post

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                                      V-4

closure period.   Only  detection  monitoring costs  are  incurred  in  years  0

through 48.  Although contamination is not detected until year 49, the  facility

must still undertake corrective action.  The analysis assumed that counterpump-

ing can  effectively remove  the  contaminant  plume in  20 years.   Because all

costs under this scenario  are  incurred  far in the future, discounting  signifi-

cantly reduces  their  impact.  For example,  the  present  value of  a  $100 cost

that will be incurred 50 years  from  now is only $22.81 assuming a real rate of

return of 3 percent and an inflation rate of 8 percent.  Therefore, the annual

revenue requirements for  this  scenario  are much lower than  those calculated

for scenario  3, where  the high  capital  costs  were incurred  Immediately and

were not discounted.  Cost streams for this scenario assume:

     o higher annual  costs for  compliance monitoring  starting in  year 50 and
       continuing through  year  69. Annual costs  for detection monitoring from
       year 0 through year 49.

     o a fixed  cost of  $25,000 in year 49 to develop a corrective action plan;

     o capital  costs in year  49 to drill  wells for  the counterpumping program
       and to construct a treatment plant; and

     o annual operating and maintenance  costs  for the counterpumping program
       starting in year 50 and continuing for 20 years.


B.   Assumptions/Models Used to Develop Corrective Action Cost Estimates

     The analytic approach used to estimate  corrective action costs  is  fully

described in Appendix D of this  report.   The analytic approach  is summarized

belov.

     G&M used a model plume approach  to  estimate the costs of corrective action.

They developed  cost estimation  algorithms  for a  range  of  simplified  plume and

hydrogeological conditions  for  systems designed  to  remove  contaminant plumes

(counterpumping) and systems  designed to  only  Isolate plumes  (slurry walls).

The costs used in Section  IX of  the Preamble  were based on earlier  versions of

the Part 264  regulations  that differed  from the proposal  published in  the

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                                       V-5

 July 26,  1982 Federal Register.  The  earlier  versions  appeared  to  preclude  the

 use of  slurry walls as a corrective action technique,  so  slurry walls  were  not

 fully analyzed.   Therefore,  the discussion below focuses only on G&M's method-

 ology for estimating  counterpumping costs.  Slurry wall costs are  discussed in

 a  later section  of  this  chapter (Section D) and  in G&M's report.

      All  of  G&M's algorithms estimated costs for containing plumes  rather than

 removing  them.   (The  Preamble used these  containment cost estimates as surro-

 gates for removal  costs.)   The primary variables affecting  the costs and  the

 relative  effectiveness of containment  techniques are:

      1) plume dimensions.  G&M's report considered a  range of plume dimensions.
        Plume widths  ranged  from 100  to  2000  feet;  lengths  ranged  from 200 to
        10,000 feet.  Two  width to  length ratios were  considered — 1  to 5  and
        1  to  2.   Plume depth ranged from 25 to 200 feet.

        All cost estimates developed for the Preamble assumed a  width to length
        ratio of 1 to   2,  to  be consistent  with  assumptions  made regarding
        facility size and  shape.  It  was  assumed that  all land disposal units
        and facilities are  rectangular, with the length being two  times longer
        than  the width.  Plume dimensions were assumed to be equivalent to  the
        dimensions  of the facility,  because of requirements in the  regulations
        that  the plume  must  be  "stopped"  at  the waste  boundary.    Dimensions
        and areas  estimated   for the different  types  of  units  and  facilities
        are provided in  Tables  V-l and V-2.

        In estimating  costs   for  the  Preamble, depth was  held  constant  at   75
        feet.  As stated in Section IX.D  of the Preamble, this depth is likely
        to be typical only for well-established plumes.  New plumes  are  expected
        to be shallower  and,  therefore,  less expensive  to  control.

        As shown in Table V-l, the smallest plume for which costs were estimated
        was 108  ft  x 217  ft,  while the largest plume costed  was  2,333  ft x
        4,666 ft.   Plumes  smaller or larger than these fell  outside the range
        of G&M's  cost  model.   For these plume sizes,  costs  estimated  for  the
        extremes  were used.

      2) hydraulic gradient.   Hydraulic  gradient measures  the change in total
        headl with  a  change in  distance  in  a  given direction.   While  G&M's
        report considered a   range  of   .5 to 500 feet  per mile  for hydraulic
        gradient, corrective  action costs  estimated  for  the Preamble assumed
        a  constant  gradient of  5  feet  per mile.  This was selected as represen-
        tative of mid-range   conditions,  while more  extreme  values  were  con-
        sidered in  the sensitivity analysis.  See Section C below.
     1 G&M defines  total  head as  the  sum of the  elevation head,  the pressure
head and the velocity head at a given point in an aquifer.

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                                      V-6

     3) transmissivity.   Transmissivity measures the rate at  which water of a
        specific density  and viscosity  moves through a unit width of an aquifer
        under a unit hydraulic  gradient.   The  G&M report used a range of  1,000
        to  1,000,000  gal/day/foot  for  transmissivlty  to estimate corrective
        action costs.   For  the  counterpumping  costs  used  in  the Preamble,
        transmlssivity was  held  at  100,000  gal/day/foot,  again  a mid-range
        value.  The  extreme values  were  treated in the  sensitivity analysis.

     4) aquifer discharge.   Aquifer discharge  is defined as the  quantity  of
        water moving  across a  one-mile wide  section  of an aquifer  per day.
        Both transmlssivity  and hydraulic  gradient affect  aquifer discharge.
        Aquifer discharges  used in  G&M's  study  ranged  from  .05 to  5 million
        gallons per day across a one-mile wide section of the aquifer.  A value
        of  .5 million  gallons  per day  per mile  was  used  to  estimate costs for
        the Preamble.  The  analysis assumed  that the plume discharge  was di-
        rectly proportional  to  the  discharge   through  a  unit  width  of the
        aquifer.  For  counterpumping this  is  important  because the  quantity
        pumped must be at least as great as the  plume discharge.

     5) treatment required.  Both the G&M Report and the Preamble used an aver-
        age of the  costs  for three different types  of  treatment technology as
        estimates of the  costs  of treating  contaminated ground  water  pumped
        through the  counterpumping system.  The three  types of treatment are
        reverse osmosis, activated carbon filtration, and coagulation/floccula-
        tion/sedimentation/filtration.  Capital  and  annual  O&M  costs  for each
        technology were treated  only as functions of total discharge  from the
        fluid removal  system.   All  treatment  costs assume low concentrations
        of contaminants because the  level of   hazardous  constituents  in the
        pumped ground  water is expected to  be  fairly low  over the life  of  a
        corrective action program.  The Implications of using an average treat-
        ment cost assumption are addressed in the sensitivity analysis (Section
        C below).

     G&M estimated  counterpumping costs for  both a uni-directional hydraulic

gradient (Strategy  1)  and  a radially-directed  gradient  (Strategy 2)  across

plume boundaries.1   Both  were   cos ted  for the Preamble,  although the  total

costs presented in Table 15, Section IX.F of the Preamble reflect only Strategy

2 conditions.   Strategy   1  was  used  to represent  "simple"  ground-water  flow

conditions, where the  plume elongates  only  in  the  direction of ground water

flow.  Strategy 2 is the higher cost  case  and represents  a  situation where the

plume spreads in  all directions  and is therefore  more difficult  to  control.

For Strategy 1,  containment is  achieved  by using a  recovery well  (or  wells)

to create a limiting  flowline around the  plume.   For  Strategy  2,  containment
     1 Unlike  Strategy 1,  plume discharge under  Strategy  2  is  not  directly
related to aquifer discharge as defined above.

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                                      V-7




Is achieved by creating a ground-water divide around the plume.  Total discharge




from the  wells must  be at least  as large as  the  total  discharge through the



plume.




     Under Strategy  1 conditions,  recovery wells are located at the toe of the



plume in  the traverse  direction  to ground-water  flow.   The  number  of wells




increases as  hydraulic gradient and plume discharge increase,  as plume width



increases, as  plume  depth decreases, and  as  aquifer transmissivity decreases.



The number of  recovery wells  required is not  sensitive to plume length.  G&M's



report states  that decreases  in depth or  transmissivity  or  increases in plume



discharge influence  the  number of  recovery  wells  because  they  increase the



pumping rate required.  Changes in  width or transmissivity affect the number of



wells because they limit  the effective drawdown at plume boundaries.



     Under Strategy 2 conditions, wells are placed along the length of the-plume.



In general, more  wells and higher  pumping  rates are required to control plumes



under Strategy 2 conditions.  Under  Strategy 2 conditions, the number of recov-



ery wells Increases as hydraulic gradient and plume discharge increase, as plume



perimeter (a function of  width and length) increases, as plume depth decreases,



and as aquifer transmissivity decreases.



     Capital and  annual  costs  for different  plume  sizes under each strategy



are presented  in  Tables  V-l  and  V-2.  Table  V-l provides  the costs  used  to



calculate the  corrective  action  annual  revenue  requirements   for  individual



land disposal units  provided  in Section IX.D of the  Preamble.   Table V-2 pro-



vides the backup  costs used to  estimate total  corrective  action costs for land



disposal facilities  (combinations  of units).   This  distribution  was  used  to



derive the total  corrective action  cost  estimate  provided in  Section  IX.F  of



the Preamble (Table 15).



     Capital costs are composed of infrastructure construction costs  (roads,



electric power, manifold  and  service piping,  and  treatment  plant),  costs  for

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                                                     TABLE V-l
                                       Plume Sizes and Counterpumplng Costs
                                      By Type and Size of Land Disposal Unit
                                                      ($ 000)
Type of Unit

Landfill (LF)
500 MT/Yr
2000
5000
7000
15000
35000
60000
123000
Surface Impoundment (S
1/4 Acre
1/2
1
2
5
11
Land Treatment (LT)
1.75 Acres
6.63
20.30
75.25
250.00
Waste Piles (WP)t
2,000 cu. ft.
10,000
25,000
100,000
500,000
1,000,000
Plume
Dimensions

236 x 471
372 x 745
577 x 1154
623 x 1246
833 x 1665
1178 x 2355
1442 x 2884
1747 x 3493
1)1
74 x 148
118 x 236
167 x 333
225 x 450
340 x 680
500 x 1000

195 x 390
380 x 760
665 x 1330
1280 x 2560
2333 x 4666

27 x 54
44 x 87
59 x 117
90 x 180
152 x 304
189 x 378
                                            Plume Size
                                              (Acres)

                                                 2.6
                                                 6.4
                                                15.3
                                                17.8
                                                31.8
                                                63.7
                                                95.5
                                               140.1
                                                  .3
                                                  .6
                                                 1.3
                                                 2.3
                                                 5.3
                                                11.5
                                                 1.7
                                                 6.6
                                                20.3
                                                75.2
                                               249.9
                                                      Strategy  1
Capital
160
180
230
240
290
350
400
450
130
130
140
160
180
225
150
180
240
370
540
140
140
140
140
140
145
Annual
43
47
54
56
60
66
70
76
38
38
40
43
47
53
42
49
56
69
85
40
40
40
40
40
41
                     Strategy 2
Capital
270
340
380
390
440
560
660
770
180
180
225
270
340
370
240
340
400
600
1000
212
212
212
212
212
240
Annual
63
71
87
90
102
118
125
132
53
53
58
63
71
85
60
76
90
120
140
56
56
56
56
56
59
                                                                                                        <
                                                                                                        00
                                                 *
                                                  .2
                                                  .4
                                                 1.1
                                                 1.6
* plume size Is less than .05 acres.
1 plumes for 1/4 acre surface Impoundments  fell below G&M's range.   Costs  used are those estimated for a  1/2 acre
  surface Impoundment.
t _i
    ume«
 r—* •<•<> p-ii«. sir"0
f ___ 5C_,__0 c_. _t
                                      tb*»n SQO-000 cu- ft. foil
G&M'B range.  Costs used are those

-------
                                                     TABLE V-2
                                       Plume Sizes and Counterpumplng Costs
                                    By Type and Size of Land Disposal Facility
                                                      ($ 000)
Type of Facility


Landfill only

Surface Impoundment only

Land Treatment only

Waste Pile only

Landfill & Surface
 Impoundment

Landfill & Land Treatment*

Landfill & Waste Pile

Surface Impoundment &
 Land Treatment

Surface Impoundment &
 Waste Pile

Land Treatment & Waste Pile*

Landfill, Surface Impoundment
 & Land Treatment

Landfill, Surface Impoundment
 & Waste Pile

Surface Impoundment, Land
 Treatment & Waste Pile

Landfill, Surface Impoundment,
 Land Treatment & Wast Pile
Plume
Dimensions
861 x
446 x
1495 x
108 x
987 x
2303 x
977 x
1282 x
410 x
2593 x
1875 x
1188 x
1321 x
1736 x
1722
892
2990
217
1973
4606
1953
2565
820
5185
3750
2376
2642
3471
Plume Size
(Acres)
34.1
9.1
102.6
.5
44.7
243.5
43.8
75.5
7.7
308.6
161.4
64.8
80.1
138.3
Strategy 1
Capital
265
200
400
128
340
540
340
420
210
540
540
390
420
480
Annual
58
50
69
38
65
85
65
70
52
85
85
68
72
78
Strategy 2
Capital
435
330
600
170
520
1000
520
625
350
1000
1000
595
660
860
Annual
98
76
127
52
115
140
115 <
VO
130
78
140
140
125
130
140
* These sizes were outside the range of G&M's model.
  Costs used were those calculated for a  1875 x 3750 ft plume.

-------
                                       V-10




 plume  delineation,  design  engineering,  well  construction,  and  construction




 engineering.  Annual  costs  include  O&M costs  for  fluid  removal,  infrastructure,



 and  treatment systems.   These costs are detailed  in Appendix D.






 C.   Sensitivity of Corrective Action  Costs to Changes  in Technical Assumptions




     This section summarizes the effects of changing  the "base  case" assumptions




 regarding aquifer transmissivity and gradient, and type of treatment technology




 that were used  to  develop per unit and total corrective action costs for the




 Preamble.  Appendix  D  examines the   sensitivity of  counterpumping  costs to



 changes in these variables in greater  detail.




     The effects of  changing these  base case assumptions were examined for two



 plume  sizes  to  indicate the range of costs  for each set  of hydrogeologlc



 assumptions.  The  small plume (100 ft x  200  ft)  is approximately the size of




 the plume used  to estimate  corrective action  costs for  a  half acre surface



 impoundment.  The large  plume (1000 ft x  2000 ft) falls between the plume size



 estimated for a 15,000 MT/yr landfill  and a 35,000 MT/yr landfill.



     1.  Sensitivity to  Changes in Gradient and Transmissivity.  Table V-3



 shows  the effects on costs of changing assumptions regarding transmissivity and



 gradient under Strategy 1 and Strategy  2 conditions.  The annual revenue require-



ments  Included in the table assume counterpumping  begins  in year  0 and continues



 until  year 20.  They do  not include treatment costs.



     As the table  indicates, changing gradient   or  transmissivity  assumptions



has almost no  effect on costs  for small  plumes  under  Strategy 1  conditions.



However, for large plumes under Strategy  1  conditions,  increasing  the  gradient



 from the base case level of 5 feet per mile to 50 feet per  mile or increasing



the transmissivity from  100,000 to 1,000,000 gallons per day  per foot increased



costs  by  about  50  percent.  Decreasing  the  gradient  or  the  transmissivity



below base case levels had no significant Impact  on costs.

-------
                                       V-ll
     Under  Strategy  2  conditions,  increasing transmissivity  from  base case

levels  increased  costs  for small  plumes  by  42  percent and  for  large  plumes

almost  150  percent.   Decreasing  transmissivity  had little  Impact  for  small

plumes  under Strategy  2  conditions,  but reduced costs for large plumes by about

30 percent.  The greater sensitivity of costs to changes in hydrogeologic assump-

tions under Strategy 2  conditions  is largely due to the higher  pumping rates

required.

                                     TABLE V-3
                 Effects of Varying  Gradient and Transmissivity
      Assumptions on  Counterpumping  Costs Under  Strategy  1 &   2  Conditions
                            Hydraulic
                            Gradient
STRATEGY 1

Small Plume (100 x 200 ft)

  Low Gradient
  Base Case
  High Gradient

  Low Transmissivity
  Base Case
  High Transmissivity

Large Plume (1000 x 2000 ft)

  Low Gradient
  Base Case
  High Gradient

  Low Transmissivity
  Base Case
  High Transmissivity
              Trans-
             missivity
             (gallon/
 Aquifer
Discharge
(ft./mile)    day/ft)
Ann. Revenue
(106 gal/   Requirement
day/mile)     ($ OOP)
0.5
5.0
50.0
5.0
5.0
5.0
100,000
100,000
100,000
10,000
100,000
1,000,000
0.05
0.5
5.0
0.05
0.5
5.0
21
21
22
21
21
22
0.5
5.0
50.0
5.0
5.0
5.0
100,000
100,000
100,000
10,000
100,000
1,000,000
0.05
0.5
5.0
0.05
0.5
5.0
29
30
47
29
30
44
STRATEGY 2

Small Plume (100 x 200 ft)

  Low Transmissivity            5.0         10,000    Varies
  Base Case                     5.0        100,000    Varies
  High Transmissivity           5.0      1,000,000    Varies

Large Plume (1000 x 2000 ft)

  Low Transmissivity            5.0         10,000    Varies
  Base Case                     5.0        100,000    Varies
  High Transmissivity           5.0      1,000,000    Varies
                                          21
                                          21
                                          30
                                          28
                                          37
                                          91

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                                      V-12

     2.  Sensitivity to Type of Treatment.   Treatment  costs  are  an important

factor in determining total counterpumping costs.  Under Strategy  1  conditions,

about 40 percent  of the capital  costs  and 60 percent  of  the annual O&M costs

estimated for counterpumping are attributable to treatment costs.  Under Strat-

egy 2  conditions,  the  portions  attributable  to  treatment  costs  increase to

about 55-60 percent for capital costs and about 70  percent  for annual O&M costs.

Because treatment costs play such a significant role in estimating total count-

erpumping costs,  it  is  important  to  understand how they  were  developed.

     All corrective action  cost estimates  in  the Preamble assumed  a mid-case

cost; i.e., a simple  average  of the costs of  three types  of treatment:  acti-

vated carbon; reverse osmosis;  and  coagulation,   flocculation,  sedimentation

and filtration.   Table V-4  compares  corrective action  costs  using each of the

three types  of  treatment separately with  corrective  action  costs  using the

average of the  three.  Hydraulic  gradient and transmissivity  are  held  at base

case levels for all examples.  The  annual revenue  requirements shown  in the

table assume that counterpumping  starts in year 0 and  continues for 20 years.

                                   TABLE V-4
                 Annual Revenue Required For Corrective Action
                 Using Various Types of Treatment Technologies

                                     Average of
                       Quantity     3 Treatment
                       Treated         Cases          Type of Treatment
                     Pump   MT Per  (Base Case)            ($ 000)
                     Rate*   Year     ($ OOP)    Carbon  Osmosis   Filtration
Strategy 1

  Small Plume
    (100 x 200 ft)      8   15,828       49         28      49        69
  Large Plume
    (1000 x 2000 ft)   41   81,116       92         61     115        97

Strategy 2

  Small Plume
    (100 x 200 ft)     80  158,280       67         40      80        79
  Large Plume
    (1000 x 2000 ft)  413  817,099      154        102     232       128
  In gallons per minute.

-------
                                      V-13



     The table shows significant variation in the treatment costs and indicates




that the type of  treatment  technology used  can have a big Impact on corrective



action costs.  Activated  carbon systems appear to  be the cheapest alternative



under all  conditions.   Reverse osmosis  costs appear  to  be comparable to other



types of treatment  for small plumes and under  simple ground-voter flow condi-




tions, but  is  the most  expensive  treatment alternative  when plumes are large



or when flow conditions are complex.




     Table V-4 also  indicates that the average treatment  cost used to develop



the corrective action  cost  estimate for the Preamble appears to be reasonably



close to  the individual  treatment  costs.   Other  potentially  less  expensive



alternatives, such  as  air  stripping or  using contract  services  rather than



constructing permanent on-site facilities, were not fully analyzed.



     The higher costs  under  Strategy 2 conditions  reflect  the higher pumping



rates used.  All  treatment  costs assume low concentrations of contaminants and



constituents.  Complex or highly contaminated plumes could significantly affect



treatment costs.



D.   Use of Slurry Walls



     The Preamble provides  a  complete analysis of  costs for  only  one type of



corrective action technology  — counterpumping.  However, owner/operators  may



find it advantageous to use slurry walls  or other techniques to isolate plumes



or to control their growth.   Slurry  walls  are composed of  bentonite  or other



admixed materials, and are constructed in the  ground to completely  surround



and contain the plume.   Walls  can  be used under a large  range of hydrogeologic



conditions and  up to  depths  of 150  feet.   However,  as  with counterpumping,



their actual feasibility will  depend  on  site-specific   conditions.   Capital



costs for  slurry  walls depend  primarily  on plume perimeter,  plume depth,  and



plume area (where surface sealing is done).



     This section compares the costs of slurry walls  with the costs for counter-



pumping on a total  cost  basis  as  well  as  on  a site-specific  basis.   It also

-------
                                       V-14

examines the cost effectiveness of adding a small capacity fluid removal system

inside the  wall to manage  water levels  and  prevent  outward  leakage of plume

fluids.  More  detailed  information on the  assumptions and  unit  costs used to

develop cost estimates for slurry walls can be found in Appendix D.

     1.  Comparison of Slurry Wall and  Counterpumping Annual  Revenue Require-

ments .  Table  15 in  Section  IX.F  of the  Preamble provided  an  estimate  for

total corrective  action costs  of $677  million.   This  cost  estimate assumes

that  2,484  facilities  will use  Strategy  2 counterpumping beginning  in year 0

and continuing  for  150 years.   Effects on total  costs  of  using  slurry walls

instead of  counterpumping  were  not  estimated  for  the Preamble,  although  G&M

examined this  approach in their analysis.  Table V-5 compares total corrective

action costs assuming  the use  of slurry  walls  with  total  corrective action

costs assuming Strategy 2 counterpumping.

     Surface seals  were  Included  in  the  slurry  wall design  to  limit  fluid

buildup inside  the  wall,  thus  reducing  outward  leakage.   The   surface  area

sealed equalled the area of  the plume (the area of waste management facility)

and the slurry  wall's  dimensions  equalled the perimeter  of  the plume.  Slurry

wall costs  assumed G&M's mid-wall  cost of $5 per vertical  foot and their high

surface seal cost of $.75 per square foot.

                                   TABLE V-5
                  Comparison of Total Corrective Action Costs
                     Using Counterpumping and Slurry Walls
                                  ($  000 000)

                             Low Estimate:               High Estimate:
                           Detect in Year 49            Detect in Year 0
                       Take Action for 20 Years     Take Action for 150 Years
                                         Slurry                        Slurry
                       Count erpumping     Wall      Counterpumping      Wall

Total Corrective Action
 Costs for 2,484
 Facilities:                  51           104           677            473-758r
t The low  end  of the range assumes  that  slurry walls are  not  replaced during
  the 150  year  period.   The high end  of  the range  assumes that they  must  be
  replaced every 30 years.

-------
                                      V-15

     The low end  of  the cost range  ($473  million)  estimated for slurry  walls

assumes that the  mil does not  need  to  be replaced during the 150-year period.

The high end of  the  range ($758 million)  assumes  that walls must  be  replaced

every 30 years, and is consistent with the assumption used to estimate counter-

pumping costs  that  the fluid  removal and  treatment  system  would  need  to  be

replaced every 30 years.1

     For the high cost scenario, if it is assumed that slurry walls  do not need

replacement during the  150 year period,  they appear  to  be much cheaper than

counterpumping.  This is largely due to:   1) the lower annual  O&M  costs  esti-

mated for  slurry walls  ($10,000  per year no matter  how big  the  wall  is  to

check for major leaks or significant plume migration  beyond  the wall)  compared

with $50,000 to $150,000 per year  for counterpumping,  depending on  plume  size;

and 2) the  fact  that these costs  (and  the cost differences) occur every year

for 150 years.  For  the low cost scenario, slurry walls appear to be more than

twice as  expensive  as  counterpumping.    This  is  because the  costs  for both

strategies occur  so  far out  in the future (50-70 years) that discounting prac-

tically eliminates the disparity  in  the  O&M costs between  the two.  However,

the discounting can  not fully eliminate the difference between  the  two sets of

capital costs.   Slurry  wall  capital  costs are 2 to 7 times more expensive than

the capital  costs  for  a   counterpumping  system, depending   on   plume  size.

     Table V-6 indicates how slurry  wall  and  counterpumping costs  compare for

specific plume sizes.  The low  ends of the ranges indicate the low cost correc-

tive action  scenario (beginning in year 49 and  continuing  for  20 years)  while

the high estimates assume action for  150 years beginning in year 0.
      1 Although  slurry  wall capital costs are  incurred  five times in the high
cost  case  and  only once  in the low cost  case,  the annual revenue requirement
for the  high estimate is less  than  twice  that  for the low estimate because of
discounting  far  into the future  and  because  of  additional  depreciation tax
shields.

-------
                                       V-16

                                   TABLE  V-6
    Comparison of  Slurry Wall  and Counterpumping  Annual Revenue Requirements
                           For  Small and  Large Plumes
                                    ($  000)

                                        Small Plume     	Large Plume
                                     (100 ft.x 200  ft.)   (1,000 ft. x 2,000 ft)
 Slurry Wall

 - Wall is not Replaced                   7-44                69 - 305
 - Wall Replaced Every 30 Years           7-58                69 - 497

 Counterpumping

 - Strategy  1                             11-102                21 - 187
 - Strategy  2                             16 - 141                36 - 314

     The table shows  that  walls tend to  be cheaper for smaller plumes but are

 much more expensive  for  larger  plumes.  For a small plume under the 0/150 year

 scenario, Strategy  2  counterpumping is about 2.5  times  more expensive than a

 slurry wall  (even  assuming wall  replacement  every 30  years).  However,  for a

 large plume, the slurry wall is more than  1.5 times  more expensive  than counter-

 pumping (where it is assumed that  both must be replaced every 30 years).  This

 is because slurry wall costs are more dependent on  plume size than are counter-

 pumping costs.   As  plume  sizes increase the ratio  of  slurry  wall  costs  to

 counterpumping costs will also increase.

     2.  Combining  a Small Capacity Fluid  Removal  System  With a Slurry Wall

 Under certain  conditions,  it may be  attractive for  facilities  to  install  a

 small capacity fluid  removal  system inside the wall to prevent outward leakage

 of plume fluids.  Owner/operators may find this approach financially attractive

 where the alternative is to  pump  at a high rate (due to high aquifer discharge

 rates) for a long period of  time.   It  is  also  likely to be more attractive for

 small plumes  than for  large plumes.   Permit  writers may  find   the  approach

 attractive because it  provides  containment  while  minimizing  impacts on  sur-

 rounding ground-water systems.

     Table V-7 compares  the cost  of  the  slurry wall  and small  fluid  removal

system to the  cost  of  a  full-scale  fluid  removal  (counterpumping)  system.

-------
                                       V-17

                                    TABLE V-7
                Cost of Counterpumping Compared to Slurry Wall Cost
     Where Low Pumping  Rate is used  to  Limit Fluid Migration  Through the Wall
                                      ($ 000)

                                               Small Plume (100x200)
                                           Strategy 2       Slurry Wall +
                                         Counterpumping  Pumping at Low Rate

 1. Amount of Contaminated Ground
      Water Requiring Treatment (MT/Year)*    189               <.5

 2. Annualized Corrective
      Action Costt                            140                83

 3. Annualized Funds Available
      For Shipping/Treatment                    -                57

 4. Annual Funds Available
      For Shipping/Treatments                   -                26

 S. Distance Pumped Water Could Be
      Shipped with Available Funds**            -               517
 * These quantities reflect pumping  rates  of 22 million gallons per year (coun-
   ter pumping only)  and  50,000  gallons  per  year  (slurry  wall  +  pumping).

 t Annualized costs based  on  corrective action beginning  in  Year Zero and con-
   tinuing 150 years.

 § Assumes 150 years  of annual  shipping and treatment costs at  3 percent real
   discount rate.

** Assumes $.15  per  ton-mile  shipping cost and  $60 per  MT treatment  feost.


      The table assumes that  for a small plume (100 ft x 200 ft)  with a slurry

 wall in place, pumping rates  of about 50,000 gallons per year* «.5 metric tons

 per year) would be  sufficient  to  control any leakage of  plume  fluids through

 the wall.  This pumping rate compares  to  an annual rate of  22 million gallons

 (189 metric  tons)  per year,   which would be required where Counterpumping  is

 the only  corrective  action  measure used.   Line  2  of  the table  compares  the

 costs of the two  options  and line  3  indicates the cost savings  to  the owner/

 operator of   selecting the  "slurry  wall plus  pumping"  option.  Because  the
      1 Based on information provided by Geraghty & Miller.

-------
                                      V-18



quantity of liquid requiring treatment  would  be  so small under the slurry wall




plus pumping  option,  on-site  treatment would probably  not  be cost-effective.



Therefore, it  was assumed  that  the site  owner/operator would ship  the water




off-site for treatment.  Line  4  shows the  annual funds that  would be available




(savings) each  year  over the  150-year  corrective action period  that  could  be



used to offset  costs  to ship the contaminated ground water off-site for treat-



ment.  Line 5 indicates that the owner/operator could afford to ship the ground



water 517 miles  (assuming  a shipping cost of $.15 per mile  and treatment cost



of $60 per metric ton)  with the money saved by selecting the slurry wall option



in lieu of counterpumping.




     Reducing the pumping rates  even more would enable contaminated liquids to



be shipped even  further.   For example, if pumping  rates  could  be  reduced  to



10,000 gallons  per  day, an owner/operator could  afford to  ship contaminated



ground water up to 4,126 miles before the wall/pumping combination would become



less attractive than counterpumping  alone.  The  costs  of the  slurry wall/pump-



ing option would  be  even  more  attractive  under more  pessimistic assumptions



regarding gradient and  transmissivity  because these  changes  would not  affect



the costs of  the  combination approach.   However,  the  slurry  wall/pumping com-



bination would be much less attractive with  deeper plumes,  and  infeasible  at



depths greater than 150 feet.

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                                   CHAPTER VI

                        ASSUMPTIONS AND METHODOLOGY USED
                    TO CALCULATE ANNUAL REVENUE REQUIREMENTS


     This chapter  describes  the methodology and economic  assumptions  SCI used

to convert  the ISS baseline cost  streams,  the Part 264 D&O  cost streams, and

the Part  264 corrective action cost streams  (described  in  Chapters  III, IV,

and V)  into annual revenue  requirements.  Annual  revenue  requirements measure

the incremental  revenues  that an  Individual  landfill,   surface Impoundment,

land treatment areas, or  waste piles would need to obtain — through increased

prices  for  its products or for  its waste management services — in each year of

operation to  offset the  costs of  the regulations.   SCI  developed models  to

calculate annual revenue requirements for the baseline cost streams and for the

baseline plus Part 264 cost  streams.  The difference between the two was deter-

mined to be the Incremental  annual revenue requirement resulting from the Part

264 regulations.

     The models also  calculated first year  cash requirements as a  measure  of

what the maximum impact of the  regulations could be for an individual land dis-

posal unit  or a facility  in  any single year.   Both the annual revenue require-

ments and the  first  year  cash  requirements were used  to determine the impacts

of the  regulations on  specific industries,  as  will  be  described  in  Chapter

VIII.

     The economic  assumptions  and the discounted cash  flow methodology used  in

the models are summarized below.  An example of how the annual revenue require-

ments was  calculated  for  a 35,000  metric ton/year  on-site landfill  is  also

presented.  The example includes only costs incurred during the operating lives

of each  facility.   Post  closure  cash  flows, and  any cash  flows  that  would

result from  corrective  action  are  excluded  from  the  simplified  example.

-------
                                       VI-2

A.    Economic Assumptions  Used  In Calculating Annual  Revenue  Requirements

      1.   Remaining  operating  life.   All units  and facilities  were assumed  to

have  20-year  remaining operating lives.  Baseline and Part 264 initial  capital

costs uere  always  Incurred  in Year  0,  and plant  O&M costs  were incurred  in

years 1  through  20.   Closure  of the  unit always occurred  in year  20.  All

baseline  costs and costs resulting from the Part 264 requirements were annualized

over  the  20-year  remaining operating  life.

      2.   Types of costs considered.   Costs  were broken  out into several cate-

gories for  purposes  of  calculating  net  present  values  and annual   revenue

requirements.  Categories  used  were as  follows:

      Capital:       Costs such as infrastructure construction or surface
                     impoundment  capping  that  are  depreciable.   Most   capital
                     costs occurred  in year  0, although for  some facilities
                     capital  costs  also  occurred  in  year  20,   at  closure.

      Initial Year:  Costs such  as  initial reporting  requirements that occur
                     in year  zero and cannot be depreciated.

      Annual:        Costs that occur in each operating year such as ground-
                     water sampling and analysis.

      Last Year:     Costs such as decontamination and closure certification
                     that occur  in year  20 and  that  cannot  be  depreciated.

      Intermittent:  Costs  such as dredging  that occur  periodically through-
                     out the  operating  life  or  post  closure  period   of  the
                     facility.

      3.  Depreciation Method Used.  Using the straight-line depreciation method,

capital costs were depreciated over five years.

      4.  Tax Rate.  An effective tax rate of 50  percent was assumed.  No invest-

ment  tax credits  were applied.

      5.  Inflation Rate.   All costs  incurred after the  zero  (base)  year were

inflated at a rate of 8 percent per year.

      6.  Discount Rate (Rate of Return).  A real rate of  return of 3 percent was

used.  Adjusting  for inflation, the discount rate was 11.24 percent.

-------
                                      VI-3

     7.  Capital Recovery Factor (annuity factor for repaying a present value).

The equation used to calculate the Capital Recovery Factor (CRF) is:

                                CRF = i*(l+i)n
     where i = 3 percent; and
           n =  the  remaining  operating  life  of  the  facility  (20  years).

     This results in a capital recovery factor (CRF) of 0.0672.

B.   Methodology for Annual Revenue Requirement Calculations

     The models performed the following calculations to derive the annual reve-

nue requirements for the  baseline costs and Part 264 costs  for  all unit sizes

and types of processes included in the analysis.  The results are summarized in

Chapter VII, and are presented in greater detail in Appendix D.

     1.  All costs were categorized as capital, initial, annual, etc., as shown

in Appendix B.  Costs  incurred after the zero (base) year were inflated, using

the 8 percent inflation rate.

     2.  All capital costs were depreciated using a 5-year straight line depre-

ciation schedule.

     3.  Aftertax cash flows for each year were calculated as follows:

     (Tax Rate * Depreciation) - Capital Costs - [(1 - Tax  Rate) *  (Initial Costs
+ Annual + Intermittent Costs + Last Year Costs)]

     4.  The present value was obtained by discounting  the aftertax cash flows

using a nominal discount rate of 11.24 percent.

     5.  The annualized aftertax cost was calculated by multiplying the present

value by the capital recovery factor (0.0672).

     6.  The beforetax revenue requirement was obtained by  dividing  the  annu-

alized cost by (1 minus the tax rate).


C.   Calculating First Year Cash Requirements and Annual Revenue Requirements

     This section provides examples  of how first year  cash  requirements (FYC)

and annual revenue requirements (ARR)  were  calculated for a  35,000 metric ton/

year landfill and  a 1/4 acre surface Impoundment.

-------
                                      VI-4

     1.  Landfill example.  The cash flows attributable to baseline requirements

and Part 264 requirements for a typical 35,000 metric  ton/year on-site landfill

are provided in  Table VI-1.  Part 264  costs  in the Table assume the  use of a

single synthetic liner design.  The first five columns show the capital, depreci-

ation, initial, annual, and  last  year cash flows, and the year in which they are

incurred during  the  operating life of the landfill.  The sixth column provides

the discounted present value (after  taxes)  of these cash flows.  For each year

(N), column (6) was calculated as  follows:


    (6) -   [(1)-(2)*TAX+(3)*(1-TAX)+(4)*(1-TAX)-(5)*(1-TAX)1    ;  where  TAX-.5
                                 1.1124"

     Inputs used to  derive  these  numbers  were  taken  from Appendices  B  and  C.

The Part 264 inputs  reflect "full cost"  scenarios (i.e. costs input  for Part

264 reflect  the  baseline  plus   incremental Part  264 costs).  As  Table  VI-1

indicates, there are  no  incremental  (above  the  baseline)  Part  264  capital

costs.  Capital costs under  the baseline as well as under Part 264  are $240,000..

This is because  Part 264 liner  costs are  included  as annual  expenses  rather

than capital costs.  Baseline initial costs are $363,000 while Part  264 initial

costs are $616,000.  The Part 264  initial  costs  were calculated by  backing out

Pre-ISS excavation ($189,000) from the baseline initial costs and  adding in the

Part 264 liner  system  ($442,000  including fees).   Baseline  annual costs  are

$822,000 and Part 264  annual  costs are $1,091,000.  The Part 264 annual costs

were calculated by backing out Pre-ISS excavation and Fre-ISS and ISS incremental

closure costs ($39,000 and  $297,000  respectively), and adding in the  Part 264

liner and cover  systems ($442,000  and $352,000  respectively).   Last year costs

under the  baseline  and Part  264  represent decontamination and  certification

costs ($6,000), and an  adjustment  to the  year 20 annual  costs.  The adjustment

is necessary because the annual  costs include construction and closure  of one

-------
                                      VI-5




cell; however, in the last year, no cell Is constructed.   Thus,  last  year costs




for the baseline are -$183,000 ($6,000 less a backing out  of  $189,000  for  cell



excavation).  Last year costs for Part 264 are -$436,000  ($6,000 less a backing



out of $442,000 for excavation and liner).

-------
Year
  0
  1
  2
  3
  4
  5
  6
  7
  8
  9
 10
 11
 12
 13
 14
 15
 16
 17
 18
 19
 20
   (1)
 Capital
Base;264

  240
                                                   TABLE  VI-1
                             Cash Flows  and Present Values Over 20-Year Operating Life
                                        For 35,000 Metric  Ton/Year Landfill
                                                      ($ 000)
                                                                                  (5)
                                                                               Last Year
(2) (3)
Depreciation Initial Yr.
Base; 264 Base; 264
363; 6 16
240/5; 240/5
240/5;240/5
240/5:240/5
240/5;240/5
240/5;240/5















(4)
Annual Costs
Base ; 264

822*1. 081 I1091M.081
822*1. 082 ; 1091*1. 082
822*1.083 ; 1091*1. 083
822*1. 084 ; 1091*1. 084
822*1. 085 ; 1091*1. 085
822*1. 086 ; 1091*1.08°
822*1. 087 ; 1091*1. 087
822*1. 088 ; 1091*1. OS8
822*1. 089 ; 1091*1. 089
822*1. 0810; 1091*1. 0810
822*1. 0811; 1091*1. 0811
822*1. 0812; 1091*1. 0812
822*1. 0813; 1091*1. 0813
822*1. 0814; 1091*1. 0814
822*1. 0815; 1091*1. 0815
822*1. 0816; 1091*1. 0816
822*1. 0817; 1091*1. 0817
822*1 . 0818; 1091*1. 0818
822*1. 0819; 1091*1. 0819
822*1. 0820; 1091*1. 0820
                                                                               Base;264
                                        (6)
                                        PV
                                                                183*1.0820;436*1.0820
                                     Base;264

                                      421;548
                                      378;508
                                      368;495
                                      359;482
                                      349;469
                                      340;456
                                      344;457
                                      334;444
                                      324;431
                                      315;418
                                      306;406
                                      297;394
                                      288;383
                                      280;371
                                      272;361
                                      264;350
                                      256;340
                                      249;330
                                      241;320
                                      234;311
                                      217;276
                                                                                                           I
                                                                                                          cr>
              Total Aftertax NPV

              Beforetax Annual Revenue
              '  Requirements               865/1149
                              •

              First Year Cash
                Requirement                603/856
                                                Incremental
                             Baseline/Part 264   Part 264
                                 64367,8550    *
21.14.
                                                     284
                                                     253
NOTE: Results of above calculation may differ slightly from those shown in Appendix E because of rounding.

-------
                                  CHAPTER VII




                            RESULTS OF COST ANALYSIS






     This  chapter  presents the  results of  the  cost  analysis  for individual




disposal processes.   First,  for  different  sizes of landfills, surface impound-




ments, land  treatment areas, and  waste piles, the incremental  annual revenue




required and  first year  cash required  to offset  costs  of  Part  264  D&O and




corrective action  regulations are reviewed.   Second,  the aggregate  costs for




each of the different processes based on the distributions discussed in Chapter




II are  presented.   Finally,  the  range of  total  incremental costs  that  could




result from the Part 264 regulations is reviewed.






A.   Cost  Estimates For Individual Processes By Size




     1.  Landfill Costs.  Table  VII-1  presents the  Part  264  incremental annual




revenue requirements  for  the  eight different  sizes of  landfills studied.  For




each size,  annual  revenue requirements  for  single  synthetic  liner,  double




liner, and double  synthetic liner designs1 are  given  on a per  ton as well as




on a per year  basis.  The  estimates  are for D&O costs only and  do  not include




corrective action costs.




     The table indicates the  Increased  costs  that individual  landfill units of




different sizes are  likely to face as  a result  of the Part 264 regulations.




The costs presented in Table  VII-1 assume  that owner/operators  would incur the




cost of the liner system (liner and cap) every year for 20 years because of the




assumption that a  new cell  is  opened and  closed  each year  of  the facility's




remaining operating life.  Thus,  if  the owner/operator  of a 7,000 metric ton




per year (MT/yr)  landfill elects  to  comply with the  Part 264  regulations  by




installing a double liner  system in each new cell he opens  over the next  20
     1 Liner designs  as used  in  this chapter  include both  liners and  caps.

-------
                                      VII-2
 years, he  can expect  to Incur annualized  incremental costs  (above the  base-

 line) of $207,000  per  year, or  $30 per ton.

                                   TABLE VII-1
                       Annual Revenue  Required  to  Offset
               Incremental Costs Due to Part  264 O&O Regulations:?
                             Landfills by Unit  Size
                   Single
                Synthetic Liner
       SIZE   per  year
      MT/yrt  ($000)  $ per MT*
500
2,000
5,000
7,000
15,000
35,000
60,000
123,000
31
49
79
98
149
277
379
566
62
25
16
14
10
8
6
5
   Double Liner
 (Synthetic/Clay)
 per year
($000)  $ per MT*
52
94
164
207
323
622
862
1,306
104
47
33
30
22
18
14
11
            Double
        Synthetic Liner
        per year
       ($000)  $ per MT*
                                                          43
                                                          82
                                                         145
                                                         184
                                                         290
                                                         561
                                                         779
                                                        1,180
                                 86
                                 41
                                 29
                                 26
                                 19
                                 16
                                 13
                                 10
t Costs shown are those estimated for on-site landfills in these size categories.
  They are  slightly different  from costs estimated for off-site landfills.  If
  costs were  for  off-site landfills,  double liner (synthetic/clay) costs would
  be lower  than double synthetic liner costs.

* MT indicates metric ton.

     Table  VII-2  shows the  additional  annual  revenue required  if  corrective
action is needed.
                                  TABLE VII-2
                       Annual Revenue Required to Offset
       Incremental Costs  Due  to  Part  264  Corrective
                             Landfill Units by Size
                                     Detect Year 0
                                     Pump 20 Years
Detect Year 0
Pump 150 Years
SIZE
MT/yr
500
2,000
5,000
7,000
15,000
35,000
60,000
123,000
per year
($
138
149
172
178
194
216
232
252
000)
- 198
- 225
- 267
- 275
- 309
- 361
- 391
- 422
$ per
276 -
75 -
34 -
25 -
13 -
6 -
4 -
2 -
MT
396
113
53
39
21
10
6
3
                                   per year
                                   ($ OOP)   $ per MT
                         Action  Regulations:t
                          Detect Year  49
                          Pump  20  Years
                         per  year
                         ($ OOP)    $ per MT
                                   65
                                   71
                                   82
                                   85
                                   93
                                  104
                                  113
                                  123
        95   130
       109   36
       128   16
       132
       148
       174
       190
    - 206
12
 6
 3
 2
 1
190
 55
 26
 19
 10
  5
  3
  2
17
18
21
21
24
26
28
30
- 24
- 27
- 31
- 32
- 36
- 42
- 46
- 50
34 -
9 -
4 -
3 -
2 -
1 -
* _
* -
48
14
6
5
2
1
1
*
t Ranges  reflect  difference  in   costs  between  counterpumping  strategies  1
  and 2.  (See Chapter V for a description of the strategies.)

* Less than 50 cents.

-------
                                      VII-3

 For  the  example  given above,  if  the  facility initiates a counterpumping  program

 that starts  in year zero and continues for 20 years, the additional annualized

 costs  would  be  $85,000  to $132,000, or  $12  to $19 per ton,  depending on the

 counterpumping strategy  employed.

       Table  VII-3  shows  the  Incremental  first year cash requirements for each

 landfill size  due to the  Part  264  regulations.  These represent  the maximum

 impact the  regulations  are likely  to have in any given year.   For  the 7,000

 MT/yr  landfill,  first year  costs  would  be $196,000 more  than  under  the ISS

 baseline, assuming a double liner system  is installed.  If corrective action is

 needed immediately, first  year costs would increase by  an  additional $265,000

 to $415,000.

     First year  cash and  annual revenue  required to  offset  incremental Part

 264  D&O  costs  are  very  similar  for  landfills.   This is  because of the assump-

 tions  that a new cell is opened every year and must be  constructed with a Part

 264  liner design.

                                  TABLE VII-3
             First Year Costs Resulting from Part  264 Regulations:
                              Landfills by Unit Size
                                     ($ 000)

                                     First Year Costs For:


SIZE (MT/Yr)
500
2,000
5,000
7,000
15,000
35,000
60,000
123,000
Basic D&O
Double Liner
System
50
91
156
196
305
584
810
1,226
Corrective Action
Immediate
Count er pumping*
185
205
255
265
315
375
425
475
- 295
- 365
- 405
- 415
- 465
- 585
- 685
- 795
* Range  of  counterpumping  costs  reflects cost  difference between  Strategy  1
  and Strategy 2

-------
                                     VI1-4

     2.  Surface Impoundment Costs.  Table  VII-4 shows the  incremental annual

revenue required to  offset costs of the part  264 O&O regulations for six dif-

ferent sizes of surface Impoundments.  Costs  are given for the three alternative

compliance paths available to surface impoundment owner/operators:

     o no action, where a surface impoundment that shows no evidence of leakage
       merely continues ground-water monitoring activities;

     o retrofitting the facility, where  the  facility is closed temporarily and
       relined according to the  requirements specified  in the Part 264 regula-
       tions; or

     o closing  the  present impoundment  permanently, and  replacing it  with a
       new impoundment that is constructed according  to  Part 264 specifications.

For both the retrofit and  close/replace  cases, annual revenue requirements are

estimated for the same  three  liner  systems costed for  landfills.  Thus,  a one

acre facility that chooses to  retrofit using a double liner would incur incre-

mental annualized costs of  $37,000.   This compares to an annual revenue require-

ment of $10,000 to  $16,000,  if the  same size facility continues ground-water

monitoring and never detects leakage from the Impoundment.

                                  TABLE VI1-4
                       Annual Revenue Required to Offset
              Incremental Costs Due to Fart 264 D&O Regulations:t
                       Surface Impoundments by Unit  Size
                                    ($ 000)

                            Retrofit Cases	  	Replacement Cases
No Single
Size Action Synthetic Double
(Acres) Case* Liner Liner
1/4
1/2
1
2
5
11
. 4 -
6 -
10 -
16 -
48 -
95 -
6
9
16
25
81
157
9
15
25
48
92
228
13
22
37
71
148
348
Double
Synthetic
Liner
9
18
34
71
157
374
Single
Synthetic
Liner
19
26
35
59
106
252
Double
Liner
23
31
45
78
153
354
Double
Synthetic
Liner
18
27
42
76
156
367
t Because the landfill  annual  revene requirement estimates do not  account  for
  the cost transfers resulting  from  surface impoundment dredging disposal,  the
  costs in Table VII-1 are. somewhat overstated.

* For the no action  case,  it was assumed that dredged  material  is  disposed of
  in a  123,000  MT/yr off-site  landfill  with  any one  of the  three Part  264
  liners costed.   For  the retrofit  and replace  cases, the landfill  disposal
  sites were assumed  to have the  same liner  as  the surface Impoundment.   In
  all cases, no corrective action  at the landfill was  assumed.   If corrective
  action was assumed, costs would be slightly higher.

-------
                                      VII-5

     Table  VII-5 gives the additional annual revenue required  If surface  Impound-

ments must undertake corrective action.  In the example above, If the  facility

needs to  take corrective action Immediately and  pumps  for 20 years, the addi-

tional  annual revenue requirement  would be  $61,000  to $86,000, depending on the

counterpumplng strategy used.

                                   TABLE VII-5
                       Annual Revenue Required to Offset
        Incremental  Costs  Due   to Part  264  Corrective  Action  Regulations:
                       Surface  Impoundments by Unit Size
                                    ($ 000)

                              Range of Counterpumplng Costs*
Size
(Acres )
1/4 & 1/2T
1
2
5
11
Detect Year 0
Pump 150 Years
122 - 163
128 - 180
138 - 198
149 - 225
169 - 261
Detect Year 0
Pump 20 Years
58 - 77
61 - 86
65 - 95
71 - 109
81 - 125
Detect Year 49
Pump 20 Years
15 - 19
16 - 22
17 - 24
18 - 27
20 - 31
t Costs  for  plumes  associated   with  surface  Impoundments  smaller than  1/2
  acre were not estimated.  Cost reported Is for a 1/2 acre facility.

* Range  of counterpumplng  costs  under  each  option reflects  cost difference
  between Strategy  1 and Strategy 2.


      Table VI1-6  shows the  additional  first year  cash required  for  surface

Impoundments of different  sizes  assuming no  action,  corrective  action,  unit

retrofitting, and unit  replacement.  For the 1 acre surface impoundment,  first

year costs would be $2,000 if no action Is taken.  Where the facility retrofits

to comply with the Part 264 requirements, incremental first year costs would be

$442,000.  First year  costs  would be $390,000  if  the  facility is  replaced.

Where corrective action must  be undertaken immediately,  first  year  costs  would

increase by an additional $169,000 to $254,000.

-------
                                     VII-6

                                  TABLE VII-6
              First Year Costs Resulting from Part 264 Regulations:
                       Surface Impoundments by Unit Size
                                     ($ 000)

                         Incremental First Year Costs For:

Size
(Acres)
1/4
1/2
1
2
5
11


No Action
*
1
2
3
8
18
Corrective Action
Immediate
Count er pumping t
159 - 209
159 - 209
169 - 254
189 - 299
209 - 369
254 - 399
Facility
Retrofit
Liner
123
226
442
862
2,141
4,622
Alteration
Replace
Facility
142
220
390
718
1,765
3,868
t Assumes corrective  action begins in year zero.   The range of counterpumping
  costs reflects cost difference between Strategy 1 and Strategy 2.

* Less than $500.
     3.  Land Treatment Costs.   Table VII-7  shows  the incremental  annual re-

venue requirements  that would  be  incurred  by  five sizes  of  land  treatment

units due to  the  Part 264  regulations.   The table  shows  that  a 74  acre unit

would need incremental  annual  revenues of $122,000  to  recoup  the D&O costs of

the regulations.
                                  TABLE VII-7
                       Annual Revenue Required to Offset
               Incremental Costs Due to Part 264 D&O Regulations:
                          Land Treatment by Unit Size
                                    ($ 000)

                                      Basic D&O Cost
                      Size      Per Land Treat-
                    (Acres)        ment Unit      $ Per Ton*

                      1.7             17              48
                      6.5             19              14
                     20.1             45              11
                     74.3            122               8
                    247.1            361               7
* Based on an average application rate of 206 MT per acre per year.  In practice
  the annual amount of waste applied per acre is highly variable.

-------
                                     VII-7

     Table VII-8  shows  the  additional  revenue required if corrective action is

needed.  For the  74 acre unit discussed above, if counterpumping is required in

year zero and  continues for 20 years,  the additional annual!zed costs would be

$109,000 to  $180,000,  depending  on  the  counterpumping  strategy  employed.

                                  TABLE VII-8
                        Annual Revenue Required to Offset
        Incremental Costs  Due  to  Part  264  Corrective  Action  Regulations:
                          Land Treatment Units By Size
                                    ($ 000)

                              Range of Counterpumping Costs*
SIZE
(Acres)
1.7
6.5
20.1
74.3
247.1
Detect Year 0
Pump 150
134 -
154 -
178 -
225 -
285 -
Year
187
236
276
371
472
Detect Year 0
Pump 20 Years
63 - 89
73 - 114
85 - 133
109 - 180
140 - 234
Detect Year 49
Pump 20 Years
16 - 22
19 - 28
21 - 33
27 - 44
34 - 56
* Range  of counterpumping  costs  under each  option reflects  cost difference
  between Strategy 1 and Strategy 2.


     Table VI1-9 gives the Part 264 incremental first year costs for land treat-

ment areas.

                                  TABLE VII-9
             First Year Costs Resulting from Part 264 Regulations:
                          Land Treatment by Unit Size
                                    ($ 000)

                                 First Year Costs For:

SIZE
(Acres)
1.7
6.5
20.1
74.3
247.1


Basic D&O
76
81
103
134
226
Corrective Action
Immediate
Counterpumping*
175 - 265
205 - 365
265 - 425
395 - 625
565 - 1,025
* Assumes corrective action  begins in year zero.  The  range  of counterpumping
  costs reflects cost difference between Strategy 1 and Strategy 2.

-------
                                     VI1-8

For the  74 acre unit,  $134,000  would  be spent in the first year because of the

regulations.  If corrective action is  necessary  in the  first year for the same

facility, an additional $395,000 to $625,000 more would be spent.

     4.  Waste Pile Costs.  Annual  revenue  requirements due  to the Part  264

D&O requirements for  waste piles are  presented  in Table VII-10.  For  each  of

the six  pile  sizes,  three compliance  options were  costed:  ground-water moni-

toring, base  Inspection,  and  installation of  a  double  synthetic liner  base

system.  Thus, the owner/operator of  a  10,000  cubic  foot  pile  choosing  the

ground-water monitoring option  would  require annual revenues  of about  $17,000

over the  remaining life  of  the  facility (20 years)  to  offset his Part  264

compliance costs.

                                  TABLE VII-10
                       Annual Revenue Required to Offset
               Incremental Costs Due to Part 264 D&O Regulations:!
                           Waste Piles by Unit Size*
                                    ($ 000)

                                   Compliance Options


SIZE
(OOP ft3)
2
10
25
100
500
1,000

Ground-
Water
Monitoring
15
17
21
27
27
26


Base
Inspection
7
9
13
20
23
27
Liner and
Leachate
Collection
System
7
9
13 ,
19
17
15
t Because the landfill  annual  revene requirement estimates do not  account  for
  the cost transfers  resulting from  waste  pile disposal,  the  costs in  Table
  VII-1 are somewhat overstated.

* Costs for  waste piles sized  at  2,000 to  25,000  cubic feet assume a  1 year
  pile life (i.e. piles are built up and disposed of every  year).   Costs  for a
  100,000 cubic foot pile assume a 2 year pile life, costs  for a  500,000  cubic
  foot pile assume a  10 year  pile life, and  costs  for a 1,000,000  cubic foot
  pile assume a 20 year pile life.   All sizes retain their base  for  20  years.
  Completed piles are assumed to be  disposed  of  In  a 123,000  MT off-site  land-
  fill with a Part 264  double  liner.  At closure, the pile,  base and contami-
  nated subsoils are disposed  of similarly.

-------
                                     VII-9

     Table VII-11  shows  the additional annual  revenue requirements associated

with corrective  action for  each  pile  size  if it  is needed.  For  the 10,000

cubic foot pile, if pumping is necessary from year zero to year 20, the maximum

costs Incurred  would be  $71,000  to $93,000,  depending on  the counterpumping

strategy used.

                                  TABLE VII-11
                       Annual Revenue Required to Offset
        Incremental Costs  Due  to  Part  264  Corrective  Action  Regulations:
                           Waste Piles by Unit Sizet
                                    ($ 000)

         SIZE      Detect Year 0      Detect Year 0     Detect Year 49
       (OOP ft3)   Pump 150 Years     Pump 20 Years     Pump 20 Years
2
- 500
1,000
[150
153
- 196]
- 207
[71
72
- 93]
- 98
[18
18
- 23]
- 24
t Costs  for plumes  associated  with waste  piles smaller  than  500,000  cubic
  feet were not  estimated.  Cost  reported is  for  a 500,000  cubic  foot  pile.

     Table VII-12  shows  the Part 264 incremental first  year cash requirements

by size  for the  three  waste  pile  D&O  options  and  for  counterpumping.   The

table shows that  the  owner/operator of a  10,000  cubic  foot pile who elects to

comply with the Part  264 regulations  by initiating a  ground-water monitoring

program would spend $44,000  in the first year.   If  corrective action is needed

Immediately, an additional  $165,000 to $237,000 (as  upper  bounds) would  be

spent in the first year.

                                  TABLE VII-12
             First Year Costs Resulting from Part 264 Regulations:
                            Waste Piles by Unit Size
                                     ($000)
                                              Double
           SIZE      Ground-water  Inspect   Synthetic     Immediate
          (OOP ft3)   Monitoring     Base     Liner       Counterpumping
2
10
25
100
500
1,000
44
44
44
44
44
44
4
4
4
4
4
4
12
12
12
12
14
17
*
*
*
*
165 - 237
170 - 265
  Counterpumping  costs  were  not estimated  for  these pile  sizes.   Costs  for
  500,000 cubic foot pile provide an upper bound.

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                                      VII-10

B.   Total Cost Estimates

     1.   Landfill Total Costs.  Table VII-13 lists the total ISS and  incremental

Part 264  costs  for all landfills units.   Total  landfill costs  were calculated

by multiplying the  number  of landfills in each size category by the unit costs

that were provided in the previous section,  and summing  across  all landfill

sizes.  Table VII-13  lists total costs  for  basic D&O as  well  as  for D&O plus

corrective action.  Total  costs are provided for  all three  sets  of counterpump-

ing timing assumptions for both  Strategy 1 and  Strategy 2 conditions, as well

as for the three landfill  liner systems.

                                  TABLE VII-13
                       Total ISS and Incremental  Part 264
                   Annual  Revenue Requirements for Landfills*
                             (in Millions of Dollars)

                                     Incremental  Costs of Part 264 Designs
ISS
Costs
300.6
-
-
-
Single
Synthetic
Liner
81.4
93.5
99.6
129.2
155.3
181.4
234.7
Double
Liner
157.2
169.2
175.3
204.9
231.1
257.2
310.5
Double
Synthetic
Liner
159.4
171.5
177.6
210.0
236.2
264.4
317.6
Basic D&O

D&O plus CP-1  49-69
         CP-2  49-69

D&O plus CP-1   0-20
         CP-2   0-20

D&O plus CP-1   0-150
         CP-2   0-150
* These  cost estimates do  not  account  for  transfer  payments  resulting  from
  either dredged material  from  surface  impoundments  or  waste  pile disposal,
  and are therefore overstated.
The Table shows,  for  example, that  if all  landfills  complied  with the Part 264

regulations by installing  double liner  designs,  the total incremental  annual

revenue required would be $157 million.   If all landfills needed to take correc-

tive action immediately  and had  to  counterpump  for 20 years,  total Incremental

costs would be $205 to $231  million, depending on the  counterpumplng strategy

employed.

-------
                                     VII-11

     Table VII-14  shows  the  total  ISS  and Part  264 incremental first year cash

requirements for landfills.   Corrective action timing and liner design assump-

tions are the same as in Table VI1-13.  For the example used above, Incremental

first year cash  requirements for D&O alone would be $147.5 million.  Costs for

D&O plus  corrective  action starting in year  0 would be  $313  to $405 million,

depending on the pumping strategy used.

                                  TABLE VII-14
                       Total ISS and Incremental Part 264
                   First Year Cash Requirements for Landfills
                            (in Millions of Dollars)

                                           Part 264 Incremental Costs
Basic D&O
D&O plus CP-1
CP-2
D&O plus CP-1
CP-2
D&O plus CP-1
CP-2

49-69
49-69
0-20
0-20
0-150
0-150
ISS
Cost
260.9
-
-
-
2. Surface Impoundment Total
Single
Synthetic
Liner
75.4
75.4
75.4
240.5
332.9
240.5
332.9
Costs. Table
Double
Liner
147.5
147.5
147.5
312.6
405.0
312.6
405.0
VII-15 shows
Double
Synthetic
Liner
147.5
147.5
147.5
312.6
405.0
312.6
405.0
the total IS!
incremental Part 264 costs for surface impoundments, based on the unit costs by

size contained in Section A.2 of  this chapter and on the distribution of surface

impoundments by size described in Chapter 2.  The table  includes  Part 264 D&O

costs for three compliance options: perform detection monitoring only, retrofit

the existing  impoundment, and   replace  the  current  impoundment.  The  three

different liner designs are costed for both the retrofit and replace cases.  In

addition, costs for both Strategy 1 and Strategy 2 counterpumplng for the three

different time periods studied are included in the table.   Thus, if all facili-

ties chose to retrofit with double liners, and all needed  to perform corrective

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                                     VII-12

action (under strategy one)  for years 0 through 20, the total incremental Part

264 annual revenue requirement would be about $639 million.
                                  TABLE VII-15
                       Total ISS and Incremental Part 264
              Annual Revenue Requirements for Surface Impoundments
                            (in Millions of Dollars)

                                          Part 264 Incremental Costs
      Basic D&Ot

      Retrofit D&O

      Replace D&O

      CP-1  49-69
      CP-2  49-69

      CP-1   0-20
      CP-2   0-20

      CP-1   0-150
      CP-2   0-150
ISS
Cost
534.0
-
-
-
-
-
Single
Synthetic
Liner
101.9
242.8
297.0
69.3
94.9
270.3
381.5
568.0
807.4
Double
Liner
139.8
369.2
404.7
69.3
94.9
270.3
381.5
568.0
807.4
Double
Synthetic
Liner
166.4
379.2
401.0
69.3
94.9
291.5
402.7
606.2
839.2
t Costs  for  basic D&O  differ  with  liner  type because  of different costs  of
  disposal in offsite landfills (assumed to have different liners).


     Table VII-16 shows the total ISS and Part  264  incremental  first year cash

requirements for surface impoundments.   As with  Table VII-15 above, requirements

for corrective action are  shown separately  from  D&O costs.  Total  first year

costs for the example given above would be about $5.3 billion ($4.5 billion for

D&O plus $.8 billion for counterpumping).

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                                     VII-13

                                  TABLE VII-16
                       Total ISS and Incremental Part 264
             First Year Cash Requirements for Surface Impoundments
                            (in Millions of Dollars)

                                          Part 264 Incremental Costs
ISS
Cost
Basic D&O 1001.9
Retrofit D&O
Replace D&O
CP-1 49-69
CP-2 49-69
CP-1 0-20
CP-2 0-20
CP-1 0-150
CP-2 0-150
I. Land Treatment Total Costs.
Single
Synthetic
Liner
17.5
3325.6
3129.6
0.0
0.0
773.4
1126.2
773.4
1126.2
Table VII-17
Double
Liner
17.5
4569.4
4077.5
0.0
0.0
773.4
1126.2
773.4
1126.2
shows the
Double
Synthetic
Liner
17.5
4765.0
4075.2
0.0
0.0
773.4
1126.2
773.4
1126.2
total ISS ai
cremental Part  264  costs for  land  treatment areas.  Total  costs  were derived

by multiplying  the  first year  unit costs  calculated  for each  land  treatment

size by the number of units in  each  size  category,  and summing across all size

categories.  The table lists total Part 264 D&O costs and total D&O plus correc-

tive action costs, assuming three counterpumping  timing periods for both strate-

gies 1 and 2.   The table indicates that  total incremental Part  264 D&O costs are

estimated to be $20 million.  If all  land  treatment  areas needed to take correc-

tive action immediately and counterpumped  for 20 years,  total  annual  revenue

requirements could range from  $41  to  $53 million, depending on  the  pumping

strategy used.

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                                      VII-14

                                  TABLE VII-17
                       Total ISS and  Incremental Part  264
           Annual Revenue Requirements for Land Treatment Facilities
                            (in Millions of Dollars)

                                       ISS             Fart 264
                                      ' Costs        Incremental Costs

             Basic D&O                 51.1             20.4

             D&O plus CP-1  49-69       -               25.6
                      CP-2  49-69       -               28.4

             D&O plus CP-1   0-20       -               41.2
                      CP-2   0-20       -               53.0

             D&O plus CP-1   0-150      -               63.8
                      CP-2   0-150      -               87.7
     Table VI1-18 shows  the  total  ISS and Part 264 incremental first year cash

requirements for  land treatment  areas.   For  the example  used  above,  total

incremental Part 264  first year cash requirements could range from $96 million

to $142 million depending on which counterpumping strategy is used.  About $27

million of the total would be for D&O.

                                  TABLE VI1-18
                       Total ISS and Incremental Part 264
           First Year Cash Requirements for Land Treatment Facilities
                             (in Millions of Dollars)

                                       ISS            Part 264
                                      Costs       Incremental Costs

             Basic D&O                 47.5             26.9

             D&O plus CP-1   49-69       -               26.9
                      CP-2  49-69       -               26.9

             D&O plus CP-1   0-20       -               95.8
                      CP-2   0-20       -              141.7

             D&O plus CP-1   0-150      -               95.8
                      CP-2   0-150      -              141.7


     4.  Waste Pile Total Costs.  Table VII-19 shows  the  total  ISS and incremen-

tal Part 264 costs  for  waste piles,  derived  by multiplying the unit  costs by

size calculated in Section A by the number of  waste piles in each size category,

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                                      VII-15

 and  summing  across all  size cateogories.  The  table includes  total  Part 264

 incremental  D&O  costs  for  three  different  compliance  options:  ground-water

 monitoring,  base  inspection, and  double  liner and  leachate detection system.

 The  table  also provides  total D&O  plus  corrective  action costs  using three

 counter pumping timing assumptions for the two counter pumping strategies examined

 in the analysis.   All costs in the table assume that wastes are disposed of at

 closure1 in  a 123,000 MT  offsite  landfill with a  double liner (synthetic and

 clay).  Based on  the  costs presented in Table VII-19, if all waste pile owner/

 operators choose  the  base Inspection  option,  total incremental annual revenue

 requirements for  D&O  would be about $8 million.  If  all waste pile units need

 corrective action  immediately and  counterpump for  20 years, total Incremental

 costs would  be $48 to $61  million, depending  on the pumping strategy employed.

                                   TABLE VII-19
                       Total  ISS and  Incremental Part 264
                   Annual Revenue Requirements for Waste Piles
                             (in Millions of Dollars)
ISS
Costs
16.4
-
-
-
Part
H?0 Mon.
11.9
21.6
24.7
49.0
62.6
89.9
118.3
264 Incremental Costs
Inspect
7.8
17.5
20.6
48.0
61.5
91.2
119.6
Liner /Leach.
6.8
16.5
19.6
47.0
60.5
90.2
118.6
Basic D&O

D&O plus CP-1  49-69
         CP-2  49-69

D&O plus CP-1   0-20
         CP-2   0-20

D&O plus CP-1   0-150
         CP-2   0-150
     Table VI1-20 shows the total  ISS  and  Part  264 incremental  first year cash

requirements for  waste  piles.   For the example given  above,  incremental first
     1 Closure  can occur each year  for  small piles, although the  life  of the
base is assumed to be 20 years for all waste pile sizes.

-------
                                     VI1-16

year D&O  costs  would be  about $2 million  without any  corrective action, and

about $105 million assuming Strategy 1 counterpumping.

                                  TABLE VII-20
                       Total ISS and Incremental Part 264
                  First Year Cash Requirements for Waste Piles
                            (in Millions of Dollars)
Basic D&O
D&O plus CP-1
CP-2
D&O plus CP-1
CP-2
D&O plus CP-1
CP-2

49-69
49-69
0-20
0-20
0-150
0-150
D. v Calculating Total
ISS
Costs
55.0
-
-
-
Incremental
Part
HjO Mon.
26.8
26.8
26.8
129.8
174.7
129.8
174.7
Costs of the
264 Incremental Costs
Inspect
2.4
2.4
2.4
105.4
150.4
105.4
150.4
Regulations
Liner/Leach.
7.6
7.6
7.6
110.7
155.6
110.7
155.6

     Total D&O  costs  calculated for  each  of the four disposal  processes were

summed to estimate a range  of  possible  total  D&O  costs  imposed by the Part 264

regulations.  Total D&O costs  needed  to be adjusted  for  the internal transfer

payments or "doublecounting" Which resulted because the annual revenue require-

ments calculated for landfills did not account for the moneys paid to landfills

by surface Impoundments and waste piles to have wastes disposed of.

     Total corrective action costs were  calculated on a facility basis. Counter-

pumping costs calculated  for each  average  facility  size were multiplied by the

number of  facilities  in  that  size category, and  summed across  all  facility

sizes to derive total corrective action  costs. This total was  then added to the

adjusted D&O total  cost  to arrive at the  total  cost of  the regulations.  The

range of total incremental  costs of the Part  264  regulations is shown in Table

VII-21.

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                                     VII-17

                                  TABLE VII-21
          Total Annual Revenue Requirements for Part 264 Regulations:
                          All Land Disposal Facilities
                            (in Millions of Dollars)

                        BASELINE        INCREMENTAL PART 264
                     (Pre-ISS+ISS)t  LOW ESTIMATE   HIGH ESTIMATE

Landfill D&O              301             81            159

Surface
 Impoundment D&O          534            102            401
(adjustment for
 landfilled material)    (190)          ( 57)          (118)

Waste Pile D&O)            16              7             12
(adjustment for
 landfilled material)     (10)            (3)            (6)

Land Treatment D&O         51             20             20

Corrective Action        	-           	0            677

TOTAL                     702            150          1,145
t The  total  baseline costs  of $702  million includes  pre-ISS  costs of  about
  $181 million for landfills and $180 million  for  surface impoundments.   Simi-
  lar data are  not available  for  waste piles  and land  treatment  facilities.
  Pre-ISS costs include land,  excavation,  and  infrastructure costs  incurred in
  establishing a  land  disposal facility.   ISS  cost include  more  than  "good
  housekeeping" requirements.  Approximately  72 percent  of the  ISS  costs  of
  $341 million Included in  the baseline are due to  ISS closure ($82  million),
  post closure ($40  million),  ground-water monitoring  ($42 million), and  fi-
  nancial assurance ($82 million)  requirements.

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                                  CHAPTER VIII

                IMPACT OF THE REGULATIONS ON SELECTED INDUSTRIES


     This chapter  reviews  Che  impacts  of  the  land  disposal regulations  on

selected industries.  The  impact  analysis  includes the  following  major steps:

     o Definition of the affected population,
     o Calculation of the costs of compliance by industry, and
     o Measurement of the cost impact.

Each of these  steps  is  reviewed in more detail  below.  The limitations of the

analysis are then discussed.


A.   Definition of the Affected Population

     While the cost portion of this analysis  was concerned with estimating the

total Incremental costs that the Part  264  regulations  would impose on individ-

ual land  disposal  units   (e.g.,  individual  landfills  or  individual  surface

impoundments), this portion of the analysis  addressed  the costs that the regu-

lations will impose on  specific  industries and  the Impacts  that  are likely to

result.  To perform the  industry impact analysis, it  was  necessary to define

two new populations (as opposed  to the populations of land  disposal units and

facilities defined in Chapter  II)  that are directly affected  by  these regula-

tions:

     o Industrial establishments that  generate hazardous wastes and dispose of
       these wastes on-site; and

     o Industrial establishments that  generate hazardous wastes but dispose of
       these wastes at off-site (commercial) land disposal facilities.

Establishments with on-site land  disposal  facilities will be  required to make

expenditures In order to bring their  facilities  into compliance with the regu-

lations.  Generators of  hazardous wastes who dispose of these wastes at off-site

land disposal  facilities   are  likely  to   face  Increased  prices   for  disposal

services.

-------
                                     VIII-2

     To determine  the number  and  size  of  existing land disposal  facilities

by Industry,  It was  necessary to  first determine  which industries  maintain

on-site disposal facilities  and  Which industries tend to generate  waste that

is disposed  of off-site.   A  list  of all  establishments  with  land  disposal

facilities by  standard  industrial  classification (SIC)  code  was  derived from

the Part  A data.   The  following adjustments  were then  made to  these data.

     o Classification of On-site and Off-site Facilities

       Facilities were  classified  as  on-site  or  off-site  in the  following
       manner:

       —Facilities within SIC code 4953 (refuse systems) were  classified  as
         off-site.

       —Facilities owned by  a known hazardous  waste contract disposal firm1
         were classified  as  off-site  regardless  of  the  SIC  code  reported.

       —All other facilities were designated as on-site.

     o Exclusion of Certain Facilities

       Facilities owned by establishments in SIC codes 333 (primary non-ferrous
      .metals), 10 (metal mining),  and 4911 and  4931  (electric and  gas utili-
       ties) were excluded from the analysis since the wastes from these indus-
       tries are not thought to be  hazardous.   Facilities  owned by the federal
       government were excluded.2   Waste water treatment  plants  were  excluded
       since it is  unclear  whether the  regulations will  affect  these plants.

     o Estimation of the Number of Surface Impoundments

       The Part A's  provided  only  total capacity  of  surface  impoundments  at
       each establishment by  type—storage, treatment or  disposal.   They  did
       not provide data  on  the number of  surface impoundments at  each estab-
       lishment .

       The same methodology was used to calculate  the number of surface  impound-
       ments by industry that  was used  to  calculate the total number  of sur-
       face Impoundments for the cost analysis.   That methodology was described
       in Chapter II (Section A.2).
     1 For a  list of  contract  disposal firms,  see  Booz, Allen  and Hamilton,
Inc. and  Putnam,  Hayes  and  Bartlett,  Inc.,  Hazardous   Waste  Generation  and
Commercial Hazardous Waste Management Capacity;   An  Assessment,  November 1980.

     2 These facilities are mostly ammunition plants.

-------
                                      VIII-3

      o Determination of Affected Industries

        The following guidelines  were used  to determine which Industries1  were
        likely to be affected  by the regulations.

        —If a significant amount of  hazardous  waste generated by the  industry
          was disposed of  at  off-site land disposal  facilities,  the  Industry
          was included in the  analysis.2

        —Industries where 3  or more establishments reported on-site landfills
          or land treatment areas were included  in  the  analysis.

        —Industries where 7  or more establishments  reported on-site waste
          piles or surface impoundments were included in  the  analysis.

        The industries Included  in the analysis  are  listed in Table  VIII-1.
        (Tables in this  chapter  follow the text.)

      o Adjustments for Missing  Data

        For reasons of confidentiality, Part A  data were not available  for all
        establishments.   To account  for the  missing data, the number of  facili-
        ties within each SIC  code was  scaled upwards by the following  factors:

                    Type  of Facility                     Factor

                    Landfills                               1.23
                    Land  Treatment Areas                    1.20
                    Surface Impoundments                    1.11
                    Waste Files                             1.20

      The  adjusted total  number  of landfills, surface impoundments, waste piles,
                 i
and -land  treatment units by  industry'is  shown in  Table VIII-2.   These totals

are smaller than the total number  of  land  disposal units used to  estimate the

total  costs  of the  regulations,  because they reflect only on-site land disposal

units.  Table VIII-3 provides  data,  for each industry, on the  number of hazardous
     1 Industries were defined by 4-digit SIC codes.

     2 Estimates of the amount of waste generated by industries going to off-site
disposal were estimated using the reported volumes and waste disposal practices
in Development Planning and  Research Associates,  Summary jsf_ Data for Selected
Hazardous Wastes Generator Industries, October 1981; Arthur D.  Little, Economic
Impact Analysis of RCRA Interim Status Standards, November 1981;  and Booz, Allen
& Hamilton  and  Putnam, Hayes and  Bartlett,  Op.  Git.  Where discrepancies  in
the figures exist, the higher number was used~IrT tEIs analysis.

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                                     VIII-4

waste generators that  ship  their  waste off site for disposal and the amount of

waste shipped.1

     As explained  in Chapter  II,  to  estimate  corrective action costs  it was

necessary to determine  the  total  acreage of land disposal facilities (combina-

tions of individual  land disposal  units) at each establishment.   The number of

establishments within  each  SIC  code  with  hazardous  waste facilities  and the

total acreage of these  facilities are  provided in Table VIII-4.


B.   Calculations of the Costs of Compliance

     The cost of compliance with the regulations Includes:

     o The  cost  of meeting  the required  design and operating  standards, and
     o The cost of any necessary corrective action.

The unit costs  of  compliance  by  size  and  type of  facility are  detailed in

Chapters IV and V.  The annual revenue  requirements  and first year cash require-

ments derived from these  unit  costs  for  each  size and  type  of land disposal

unit are summarized in Chapter VII and are listed in detail in Appendix E.  The

two cost components are discussed in more detail below.

     1.  Design and Operating Costs.   To  determine  the  costs  of  meeting the

design and operating  (D&O)  standards  by industry, the number  of land disposal

units of each type and  size  category within the industry  was multiplied by the

corresponding annual  revenue  requirement  calculated  to  recover D&O  costs for

that size and type of  unit,  and  summed to arrive  at the total D&O  costs for

on-site facilities within each industry.
     1 The number  of generators  within each  industry  was derived  from EPA's
Notification data.   Only 26,700  generators  of the  63,000 notiflers  had  been
assigned to SIC  codes at  the time of  this  analysis.   However, the  number  of
generators was not scaled upwards to account for the missing data.  EPA assumed
that most of  the manufacturing  plants  of concern  had  been  identified.   This
assumption is supported  by the fact that  the  number of generators  within the
SIC codes of  concern  did  not increase when  an  additional 7,000  plants  were
assigned SIC codes recently.

-------
                                      VIII-5

      The annual  revenue requirements  calculated for  off-site facilities  were

 allocated to generators who dispose of  their  wastes at off-site land  disposal

 facilities in the  following manner.

      o  The total  D&O  costs for  the off-site  facilities were  divided by  the
        annual capacity  of these off-site  facilities 1  to arrive at the  average
        price increase per  ton of waste required to recover the compliance costs.

      o  The potential cost increase for  off-site disposal  for each generator
        industry  is the  average price increase  per  ton multiplied by the  total
        tons of waste disposed of off-site by that industry.   (See Table  VIII-3.)

      The costs borne by the generators  disposing of wastes  off-site were  then

 added to the D&O costs  faced by owners  and operators of on-slte facilities  to

 arrive  at the total  D&O  costs  for each  industry.   These costs are shown  in

 Table VIII-5.

      2.   Corrective Action Costs.    To   estimate corrective   action  costs  by

 industry, "worst case"  corrective  action costs  (counterpumping  for  ISO  years

 under Strategy 2 conditions) estimated for all  types and sizes of land  disposal

 facilities were  distributed  across  industries as follows:

      o  First, the  number and average acreage of facilities within each  industry
        were derived by  type of  facility from  the Part  A data as described  in
        Chapter II, Section  B.   If  an  establishment reported  both  a  landfill
        and a surface impoundment,  it was  treated as a single facility with  an
        estimated acreage of  45 acres (from Table II-5).

      o  Second,  the annual  revenue  required  to  offset  Incremental   corrective
        action costs was calculated  for each facility type and  size based on the
        corrective  action unit costs  shown  in Table V-2.

      o  Third, these annual revenue requirements  were  multiplied by  the number
        of facilities of that type and size within the  industry to arrive at the
        total cost  of corrective action by  type  and size  of facility.

      o  Fourth, these corrective action costs were summed for all facility  types
        and sizes within each industry to estimate total  corrective action  costs
        for the industry's  on-site facilities.

      Corrective  action  costs calculated  for off-site facilities were allocated

 to generators who  dispose  of their  wastes  at off-site land disposal facilities.
     1 The total  annual  capacity of off-site land disposal facilities is esti-
mated to be 6.15 million metric  tons.

-------
                                     VIII-6

The allocation method  used for  corrective action  costs  was  the same  as the

method used  to  allocate D&O  costs.   The  tons  of waste disposed  off-site for

each industry UBS multiplied  by the  price increase  per ton required to recover

the costs of corrective action for the off-site facilities.

     The off-site corrective  action  costs for each industry were then added to

the corrective action  costs  for the on-slte facilities  within  the Industry.

Total corrective  action  costs  by  Industry  are  provided  in  Table  VIII-6.


C.   Measurement of the Cost Impact

     Four measures of Impact were used in this analysis.

     o The ratio of  annual compliance costs to the Industry's cost of production
       was employed as an  estimate of the increase  in production  costs of that
       industry.

     o The ratio of  annual compliance costs to the industry's value of shipments
       was employed as an  estimate  of the Increase in product  prices which may
       occur in  that  industry  should the industry  pass along the  compliance
       costs to its customers.

     o The ratio of annual compliance  costs  to the  industry's value added was
       employed as an estimate  of the potential  decrease  in the  profitability
       of the industry should  the industry be unable to pass along the increased
       costs in product prices.

     o The cash  expenditures  required in the first year  the  regulations take
       effect were compared to  the  industry's annual capital  expenditures to
       determine the ability  of the industry  to  finance the required' expendi-
       tures .

     The calculation of these four ratios is  fairly straightforward.  The cost

of production, value  added,  value  of  shipments  and capital  expenditures for

each of the Industries were derived by multiplying the industry totals provided

by the Census of Manufacturers by the proportion of the industry establishments

that are  generators  of hazardous wastes.   For  example,  the  value  added for

industry "1" is as follows:
                                         Number of Generators!
     Value Addedi =• Total Value Added^ x Number of Establishments j

     The effect of this calculation is to eliminate an estimate of the portion of

the Industry's value added attributable  to establishments which do not generate

-------
                                     VIII-7

hazardous  wastes.   If the economic variables  were not  scaled  in this manner,

the value added, cost of production, value of shipments, and capital expenditures

would be  overstated.  This would  lead  to  an understatement of  the  impacts of

the regulations.

     Estimates of  1981  cost  of production,  value added, value  of shipments and

capital expenditures  were derived  by applying an estimated real growth rate and

an estimated inflation  rate to the 1977 Census values.  The estimated inflation

and real growth  rates by industry were set  equal  to  the compound annual rates

experienced by the Industry from 1972 to 1977.1

     The compliance costs derived  for each industry were compared to these four

adjusted economic  measures  to determine the magnitude  of  the  impact.  Impacts

by industry are  listed  in  Tables  VIII-7 through  VIII-9.  These are the same

tables that appeared in Section IX.6 of the Preamble to the  Part 264 regulations.


D.   Limitations of the Analysis

     In addition to the limitations presented in other chapters of this report,

there are  specific limitations which  should be kept in mind  when  evaluating

the impacts on specific  industries.   These  limitations are discussed  below.

     o Discrepancies between databases.

       The number  of generators  was derived from  the Notification data, while
       the number of land disposal facilities was derived from the Part A data.
       These databases  have not been  reconciled so there  may  be discrepancies
       and inconsistencies between the two.   In addition,  neither database has
       yet been  verified.2   Some  attempt  was  made   to  adjust  the data  for
       obvious inaccuracies but errors may still exist.

     o Inaccuracy of Part A data.

       As mentioned  above,  the Part  A data has  not yet  been verified.   In
       particular, EPA  believes  three  problems exist  with the Part A data.
     1 These real growth  rates  and inflation rates are provided in Development
Planning and Research Associates, Op. Git.

     2 EPA is now in the process of verifying both the Part A and the Notifica-
tion data.

-------
                                VIII-8

  First, many  establishments  have submitted data on land disposal facili-
  ties  even though hazardous wastes are not present in their waste streams.
  These facilities would  not  be subject to the regulations and therefore,
  this  could seriously overstate  the impact of the regulations.

  Second, some  facilities  that  are  not  subject to hazardous waste regula-
  tions for  other reasons may  be included  in the Part A  data  and again
  this  will result in an overstatement of  the impacts.

  Third, preliminary  results  from the verification indicate  that  many of
  the reported  facilities  do not  currently exist.   Firms  have  sometimes
  filed Part A applications if they  are  planning to  add  a land disposal
  facility.  These planned facilities should not be included in an analysis
  of the impacts of the regulations on existing facilities.

o Updating of Part A and Notification data.

  EPA has also been continually  updating and correcting  the Part  A and
  Notification data as more  and better data become  available.   This ana-
  lysis has  attempted to  keep pace  with these  updates  to the  extent
  practical but the most recent updates have not been incorporated in the
  analysis.

o No change in generation or disposal practices assumed.

  EPA assumed that Increased  costs resulting  from the Part  264  require-
  ments would  not  change  the  hazardous   waste   generation or  disposal
  practices of  the  industries  for  this  analysis.    However,  firms  can
 .choose to  decrease the  amount  of  hazardous waste  generated  or  alter
  their disposal practices in order to minimize  the  costs  of compliance.
  Because no  such changes are assumed,  the  resulting impacts  will  be
  overestimated.

o Off-site facilities will be able to recover costs.

  EPA assumed  that the off-site  facilities will be  able  to recover  the
  costs of compliance through increased  prices.   This  may  not prove  to be
  true  for some of  the  smaller  or less  efficient  off-site  facilities.
  However, most facilities  should be  able to recover their costs  since
  there are significant barriers  to  entry in this industry  and  since on-
  site disposal is not an economically  viable option  for  many  hazardous
  waste generators.

o Existence of other  processes on site.

  This analysis includes only the effect of the  regulations on land disposal
  facilities.  Some firms  will  have  other types  of  facilities—storage,
  incineration, and so forth—at the same site as well.  Regulations  which
  affect these other types of facilities will also increase  the  costs of
  hazardous  waste disposal.  These  other costs are not included  here and
  therefore,  this analysis  does  not represent the total impact of  hazardous
  waste regulations on industry.

-------
                                VIII-9

o Analysis based on average plant within the industry.

  This analysis is designed  to provide an indication of  the  magnitude of
  the impact on an "average" plant within specific  industries.   As such,
  the analysis will  fail  to  indicate more or less severe  impacts  felt by
  some subsegments of an  industry.   Further  analysis of individual plants
  within an industry  would have to be undertaken to  derive more specific
  impacts.

o Accuracy of data and assumptions.

  Many data and assumptions were necessary in the course of this analysis.
  The sources  of  the data  employed  are  provided in this chapter.   The
  assumptions used in the analysis  are also  provided.  To the extent that
  the data or  assumptions are  Inaccurate,  the impacts will also  be inac-
  curate.

-------
                                    VIII-10

                                  TABLE VIII-1

                      Industries Included in This Analysis
0721
1300
2491

2812
2816
2819
2821
2822
2823
2824
2833
2851
2861
2865
2869
2873
2874
2879
2892
2899

2911
2992

3312
3313
3315
3321&5
3341
3351&6

3471&9
3711
3714
Industry

Crop Planting & Protections
Oil and Gas Extraction
Hood Preserving

Alkalies & Chlorine
Inorganic Pigments
Industrial Inorganic Chemicals
Plastic Materials & Resins
Synthetic Rubber
Cellulosic Manmade Fibers
Organic Fibers, Noncellulosic
Medicinals & Botanicals
Paints & Allied Products
Gum & Wood Chemicals
Cyclic Crudes & Intermediates
Industrial Organic Chemicals
Nitrogenous Fertilizers
Phosphatic Fertilizers
Agricultural Chemicals
Explosives
Chemical Preparations, NEC

Petroleum Refining
Lubricating Oils & Greases

Blast Furnaces & Steel Mills
Electrometallurgical Projects
Steel Wire & Related Products
Gray Iron Foundries & Steel Foundries, NEC
Secondary Nonferrous Metals
Cooper Rolling & Drawing & Nonferrous Rolling & Drawing,

Plating & Polishing, and Metal Coating
Motor Vehicles and Bodies
Motor Vehicles Parts & Accessories
NEC
NEC = not elsewhere classified

-------
                                     VIII-11

                                  TABLE  VIII-2

                 Number  of Land  Disposal Facilities by  Industry
                                                     Land
                                   Surface         Treatment       Waste
                 Landfills       Impoundments      Facilities      Piles

0721                 0                43                1             3
1300                 15                68                4             3
2491                 0                121                54

2812                 5                68                0             10
2816                 2                49                0             4
2819                 29                314               12             21
2821                 13                108                5             13
2822                 1                33                0             2
2823                 3                16                0             2
2824                 1                30                0             0
2833                 0                25                1             2
2851                 0                24                1             10
2861                 2                18                0             2
2865                 4                55                1             3
2869                 10                120                5             8
2873                 3                34                1             2
2874                 0                13                1             4
2879                 5                49                0             11
2892                 6                40                1             3
2899                 4                38                0             6

2911                34                370              83            30
2992                 2                 702

3312                44                65                3            51
3313                 3                12                0             0
3315                 6                24                3             7
3321&5               9                 919
3341                11                40                1            24
3351&6               6                49                0            12

3471&9              13                107               0            14
3711                 0                50               0             3
3714                 3                44               0             6

TOTAL              288              2268             155           325

-------
                                    VIII-12

                                  TABLE VIII-3

            Number of Hazardous Waste Generators and Amount of Waste
             Going to Off-Site Land Disposal Facilities by Industry
SIC                   Number of                   Amount of Waste
Code                  Generators               Disposed Off-Site (MT)

0721                      170                          17,173
1300                      243                               0
2491                      163                           4,378

2812                       42                          54,561
2816                       49                           2,071
2819                      391                          17,352
2821                      285                          22,962
2822                       39                           2,475
2823                       10                          35,280
2824                       24                          38,977
2833                       75                           6,961
2851                      610                         119,430
2861                       24                             548
2865                       45                           4,464
2869                      130                          19,490
2873                       91                               0
2874                       41                               0
2879                      107                          38,202
2892                       35                             985
2899                      224                               0

2911                      239                         212,492
2992                       76                          86,505

3312                      177                          90,000
3313                       15                          27,500
3315                       60                          16,750
3321&5                    131                          32,000
3341                       90                          62,898
3351&6                     85                         503,557

3471&9                  1,168                         698,666
3711                       83                               0
3714                      343                               0

-------
                                    VIII-13

                                  TABLE VIII-4

                Acreage of Land Disposal Facilities by Industry
                       Number of Establishments         Total Acreage
                    With Land Disposal Facilities       of Facilities

0721                              26                          0.9
1300                              21                        108.5
2491                              76                         64.3

2812                              23                        361.7
2816                              13                        421.7
2819                             128                      2,259.3
2821                              46                        645.5
2822                               5                        260.3
2823                               8                        150.5
2824                              10                         96.2
2833                              14                         10.4
2851                              20                         93.0
2861                              12                         99.4
2865                              25                        503.6
2869                              47                        530.0
2873                              16                        187.5
2874                              10                         13.8
2879                              23                        218.0
2892                              21                        153.7
2899                              21                        147.1

2911                             148                        670.0
2992                               9                        125.0

3312                              80                        670.0
3313                               8                         61.8
3315                              14                         42.9
3321&5                            19                        282.5
3341                              30                        191.5
3351&6                            27                        106.2

3471&9                            59                        259.9
3711                              17                         46.2
3714                              26                         44.9

-------
                                    VIII-14

                                  TABLE VIII-5

                    Design and Operating Costs for Part 264
                            Regulations by Industry
                          (Thousands of 1981 Dollars)
                  Annual Revenue Requirements
0721
1300
2491

2812
2816
2819
2821
2822
2823
2824
2833
2851
2861
2865
2869
2873
2874
2879
2892
2899

2911
2992

3312
3313
3315
3321&5
3341
3351&6

3471&9
3711
3714
Low Estimate
322
1,392
774
2,187
3,204
11,079
4,896
2,484
1,640
1,303
218
996
1,037
2,517
3,756
1,003
151
2,595
850
1,322
23,939
1,068
8,495
593
1,037
1,327
1,984
4,721
6,208
930
716
High Estimate
784
3,354
2,001
10,813
12,077
36,027
13,215
9,248
4,997
4,524
573
2,800
3,567
8,746
11,222
3,267
424
7,969
2,253
3,435
69,285
2,750
17,317
1,868
2,382
2,460
4,008
14,145
18,001
3,248
2,113
First Year Expenditures
Low Estimate
182
991
474
995
754
4,556
3,090
590
869
435
141
774
333
698
1,719
376
106
1,115
433
787
15,049
863
6,671
297
889
949
1,380
3,216
4,424
155
265
High Estimate
6,440
31,858
23,899
119,146
145,141
402,346
106,101
111,114
42,445
49,453
5,633
10,872
40,283
105,028
118,125
37,150
4,605
76,657
23,663
24,940
705,099
7,942
50,471
16,595
12,922
8,082
14,289
75,712
83,430
40,905
21,929

-------
                                    VIII-15

                                  TABLE VIII-6

                       Remedial Action Costs for Part 264
                           Regulations by Industry *
0721
1300
2491

2812
2816
2819
2821
2822
2823
2824
2833
2851
2861
2865
2869
2873
2874
2879
2892
2899

2911
2992

3312
3313
3315
3321&5
3341
3351&6

3471&9
3711
3714
Annual Revenue
 Requirement

 2,525
 4,750
13,571

 6,131
 4,241
37,007
11,263
 1,728
 2,245
 2,854
 2,133
 2,939
 3,008
 7,139
12,213
 3,934
 1,923
 4,824
 5,197
 4,380

47,402
 2,480

19,836
 2,142
 3,118
 4,538
 6,329
 5,940

13,519
 3,838
 4,929
  First Year
 Expenditures

 2,990
 7,139
19,001

 9,661
 7,102
59,356
17,493
 2,915
 3,607
 4,532
 2,874
 4,010
 4,675
11,512
19,079
 6,083
 2,753
 7,227
 8,002
 6,493

78,214
 3,941

30,613
 3,349
 4,641
 6,957
 9,365
 8,885

20,387
 5,720
 7,093
 * High  estimate  shown here only;  low estimate of  remedial action costs is zero,

-------
                                    VIII-16

                                  TABLE VIII-7

                Comparison Of Annual Revenue Requirements Due to
       Part 264 Land Disposal Regulations to Selected Industry Measures,
                                  By SIC Code

                           (Low and High Cost Cases)
Annualized
SIC
Code
0721
1300
2491
2812
2816
2819
2821
2822
2823
2924
2833
2851
2861
2865
2869
2873
2874
2879
2892
2899
2911
2992
3312
3313
3315
33215
3341
33516
34719
3711
3714
Cost
<$ 000)
322 -
1,392 -
774 -
3,187 -
3,204 -
1,079 -
4,896 -
2,484 -
1,640 -
1,303 -
218 -
996 -
1,037 -
2,517 -
3,756 -
1,003 -
151 -
2,595 -
850 -
1,322 -
23,939 -
1,068 -
8,495 -
593 -
1,037 -
1,327 -
1,984 -
4,721 -
6,208 -
930 -
716 -
3,309
8,104
15,572
16,944
16,318
73,034
24,478
10,976
7,242
7,378
2,706
5,739
6,575
15,885
23,435
7,201
2,347
12,793
7,450
7,815
116,687
5,230
37,153
4,010
5,500
6,998
10,337
20,085
31,520
7,086
7,042
Annualized Cost as a
Cost of
Production
*
*
.16 -
.20 -
.44 -
.15 -
.04 -
.18 -
.12 -
.05 -
.02 -
.03 -
1.74 -
.12 -
.04 -
.05 -
.01 -
.23 -
.36 -
.23 -
.02 -
.28 -
.04 -
.13 -
.20 -
.12 -
.24 -
.22 -
.65 -
.00 -
.01 -
Percentage of
Value
Added
*

3.17
1.09
2.26
.97
.22
.78
.53
.27
.23
.20
11.03
.73
.27
.36
.15
1.13
3.19
1.37
.08
1.35
.19
.86
1.07
.66
1.23
.92
3.31
.02
.09
i
.38 -
.26 -
.68 -
.19 -
.08 -
.46 -
.33 -
.08 -
.02 -
.06 -
2.44 -
.21 -
.07 -
.07 -
.02 -
.38 -
.38 -
.33 -
.09 -
.66 -
.10 -
.38 -
.39 -
.16 -
.94 -
.79 -
.84 -
.01 -
.02 -
k
7.61
1.37
3.49
1.27
.41
2.03
1.46
.46
.19
.34
15.45
1.35
.42
.49
.31
1.86
3.35
1.94
.43
3.24
.44
2.59
2.06
.85
4.91
3.37
4.24
.07
.16
Value of
Shipments
*
*
.13 -
.13 -
.31 -
.10 -
.03 -
.14 -
.11 -
.04 -
.01 -
.02 -
1.15 -
.08 -
.03 -
.03 -
.01 -
.18 -
.24 -
.15 -
.01 -
.21 -
.04 -
.11 -
.16 -
.09 -
.20 -
.19 -
.47 -
.00 -
.01 -


2.58
.68
1.57
.64
.16
.62
.48
.20
.12
.14
7.31
.53
.18
.23
.10
.87
2.06
.90
.07
1.04
.16
.76
.84
.48
1.06
.79
2.41
.02
.07
* Necessary data unavailable

-------
                                     VIII-17

                                   TABLE VIII-8

                   Comparison of  First Year Expenditures  Due  to
           Fart  264 Land  Disposal Regulations to  Yearly Capital  Outlays
                                   By SIC Code
                                             )
                            (Low and High Cost  Cases)
First Year Expenditure
       ( $ OOP)
                                           First Year Expenditure as  % of
                                             Yearly Capital  Expenditures
 0721
 1300
 2491
 2812
 2816
 2819
 2821
 2822
 2823
 2824
 2833
 2851
 2861
 2865
 2869
 2873
 2874
 2879
 2892
 2899
 2911
 2992
 3312
 3313
 3315
33215
 3341
33516
34719
 3711
 3714
182 -
991 -
474 -
995 -
754 -
4,556 -
3,090 -
590 -
869 -
435 -
141 -
774 -
333 -
698 -
1,719 -
376 -
106 -
1,115 -
433 -
787 -
15,049 -
863 -
6,671 -
297 -
889 -
949 -
1,380 -
3,216-
4,424 -
155 -
265 -
9,430
38,997
42,900 -
128,807
152,243
461,702
123,594
114,029
46,052
53,985
8,507
14,883
44,958
116,540
137,204
43,233
7,358
83,884
31,665
31,433
783,313
11,883
81 ,084
19,944
17,563
15,039
23,654
84,597
103,817
46,625
29,022
*
*
2.37 -
.25 -
.73 -
.72 -
.23 -
1.14 -
1.51 -
.11 -
.07 -
.12 -
5.31 -
.84 -
.10 -
.04 -
.10 -
.78 -
3.03 -
1.97 -
.35 -
4.97 -
.52 -
.49 -
3.48 -
8.39 -
3.31 -
1.02 -
1.33 -
.02 -
.05 -


124.75
41.58
141.54
65.01
8.05
219.32
90.74
24.31
3.49
4.27
648.31
131.04
6.90
4.17
4.52
64.21
166.98
62.38
17.42
40.56
3.83
50.22
52.33
68.53
34.61
105.25
98.34
4.68
4.38
* Necessary data unavailable.

-------
                                     VIII-18
 0721
 1300
 2491
 2812
 2816
 2819
 2821
 2822
 2823
 2924
 2833
 2851
 2861
 2865
 2869
 2873
 2874
 2879
 2892
 2899
 2911
 2992
 3312
 3313
 3315
33215
 3341
33516
34719
 3711
 3714
                                   TABLE VIII-9

                 Comparison Of Annual Revenue Requirements Due to
                        Part 264 Land Disposal Regulations
                      And Fart 265 Land Disposal Regulations
                          To Selected Industry Measures
                                   By SIC Code

                            (Low and High Cost Cases)
             Annualized
                Cost
             ($ 000,000)
 2
 6
 6
12
12
 4
17
 9
 5
 5
 1
 4
 4
10
15
 4
 1
 9
 4
 5
89
 3
23
 2
 4
 4
 7
15
21
 4
 3
  5
 13
 21
 26
 25
106
 36
 18
 11
 11
  4
  8
  9
 23
 35
 10
  4
 19
 10
 11
181
  7
 52
  6
  8
 10
 15
 31
 46
 11
 10
Annualized Cost as a
Cost
of
Production
*
*
1.24 -
.78 -
1.65 -
.59 -
.15 -
.64 -
.38 -
.19 -
.12 -
.13 -
6.35 -
.45 -
.18 -
.06 -
.82 -
1.63 -
.80 -
.06--
.77 -
.12 -
.46 -
.72 -
.37 -
.78 -
.69 -
.96 -
2.20 -
.01 -
.04 -


4.25
1.66
3.46
1.42
.32
1.25
.79
.41
.34
.29
15.64
1.07
.41
.20
1.72
4.45
1.94
.12
1.84
.26
1.20
1.59
.90
1.78
1.39
2.09
4.86
.03
.13
Value
Added

*
Percentage of

Value
of
Shipments


2.96 - 10.19
.99 -
2.54 -
.77 -
.28 -
1.68 -
1.04 -
.31 -
.10 -
.21 -
2.10
5.34
1.85
.60
3.25
2.17
.69
.28
.49
8.91 - 21.93
.84 -
.27 -
.29 -
.12 -
1.34 -
1.71 -
1.13 -
.33 -
1.84 -
.27 -
1.39 -
1.38 -
.48 -
3.11 -
2.55 -
2.81 -
.05 -
.08 -
1.98
.62
.71
.42
2.82
4.68
2.74
.67
4.42
.61
3.60
3.05
1.17
7.08
5.13
6.22
.11
.22
*
*
1.01 -
.49 -
1.14 -
.39 -
.11 -
.51 -
.34 -
.14 -
.06 -
.09 -
4.21 -
.33 -
.12 -
.13 -
.04 -
.63 -
1.06 -
.53 -
.05 -
.59 -
.10 -
.41 -
.57 -
.27 -
.67 -
.60 -
1.60 -
.01 -
.03 -


3.46
1.05
2.41
.93
.23
.99
.71
.30
.17
.21
10.37
.78
.27
.33
.13
1.32
2.88
1.28
.11
1.41
.22
1.06
1.25
.66
1.53
1.21
3.53
.03
.10
 * Necessary data unavailable

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