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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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
-------
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
-------
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.
-------
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.
-------
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
-------
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
-------
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
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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.
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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.
-------
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.
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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).
-------
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,
-------
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.
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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.
-------
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.
-------
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.
-------
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.
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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
------- |