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 ------- 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. ------- 2G9S9 CHAPTER I INTRODUCTION ils report provides complete background information on the underlying data and assumptions used to estimate compliance costs for the Part 264 land disposal regulations. The report systematically describes the various steps that were taken to develop the costs shown in Section IX of the Preamble to the regulations. It is organized into 8 chapters (one for each major component of the analysis) and 5 appendices.^ Each of these is summarized below. o Chapter II defines the population of land disposal units and facilities based on information contained in the Hazardous Waste Data Management System (HWDMS). Separate size distributions were developed for land- fills , surface impoundments, land treatment facilities, and waste piles so that design and operating (D&O) and corrective action costs could be estimated for a range of unit sizes for each type of process. The total number of units for each type of process was estimated to provide a basis for calculating total D&O costs. In order to calculate total corrective action costs on a facility instead of a unit basis, the individual processes were combined to develop a distribution of land disposal facilities. This distribution depicts land disposal facilities on the basis of their size and the particular combination of land disposal units at the facility. For example, a facility might consist of three disposal processes — a landfill, a surface Impoundment and a waste pile. 1 To aid in understanding this report, definitions of several key terms are provided here. (1) Land disposal process refers to a method of disposal or a disposal technique. The disposal media focussed on in this report include land- fills, surface Impoundments, land treatment and waste piles. (2) Land disposal unit refers to single landfill, surface impoundment, land treatment area or waste pile. The analysis examines both D&O and corrective action costs on a per unit basis for various sizes of each process. (3) Land disposal facilities are combinations of individual land disposal units. For example, a "facility" may consist of two surface impoundments, one waste pile and one land treatment area. Total corrective action costs were estimated on a facility basis using average facility sizes. ------- 1-2 o Chapter III explains the methodology used to derive baseline D&O costs for all land disposal processes. Baseline costs reflect both normal capital and operating expenses incurred whether or not any regulatory system exists, in addition to costs incurred as a result of the Interim Status Standards (ISS). Estimating baseline costs was a necessary pre- requisite to determining the incremental cost burden imposed by the Part 264 requirements. o Chapter IV describes the Fart 264 D&O requirements that apply to each land disposal process and how unit costs for these requirements were developed using engineering models. It also reviews the treatment of these costs in the analysis. o Chapter V reviews the assumptions and models used to develop corrective action costs for individual units and facilities (combinations of units). It also discusses the sensitivity of the corrective action costs to changes in some of the key technical assumptions. o Chapter VI describes the economic assumptions and methodology used to derive estimates of the annual revenue required to offset the incre- mental costs of the Part 264 regulations for each land disposal process. Estimates of total D&O costs were obtained by multiplying the costs estimated for each unit size by the number of units in that size cate- gory and summing across all processes. Total corrective action costs were derived by multiplying corrective action costs estimated for each facility configuration by the number of facilities with that configura- tion and summing across all facilities. Total D&O costs were merged with total corrective action costs to calculate total compliance costs. o Chapter VII reviews the results of the analysis and shows costs estimated by unit size for all processes, total costs estimated for each process, and total costs for all processes. o Chapter VIII reviews the methodology used to estimate the economic impacts of the Part 264 regulations on industries that generate signi- ficant quantities of hazardous waste. o Appendix A contains Section XI (Regulatory Analysis) of the Preamble to the Part 264 regulations. o Appendix B contains the unit costs used to develop the baseline D&O estimates for all land disposal processes. o Appendix C contains the detailed engineering cost estimates for the Part 264 D&O requirements for all landfill, surface impoundment, land treatment and waste pile unit sizes considered in the analysis. o Appendix D contains a copy of the technical working papers: Cost Estimates for Containment of Plumes of Contaminated Ground Water prepared by Geraghty and Miller, Inc. The report explains in detail the assumptions and models used to estimate all corrective action costs used in the analysis. o Appendix E contains tables showing the baseline and Part 264 Incremental annual revenue requirements and first year cash requirements for all landfill, surface Impoundment, land treatment and waste pile unit sizes used in the analysis. ------- 1-3 It is EPA1 s intent that this report be complete enough so that any inter- ested party can use the information it contains to reconstruct any of the costs/results contained in Section IX (The Regulatory Analysis) of the Preamble to the Part 264 regulations. A team of consulting firms assisted EPA with this Regulatory Analysis. Each firm contributed to different aspects of the analysis. The firms and their areas of responsibility are listed below. o Development Planning and Research Associates (DPRA) developed the ini- tial distributions of land disposal units and facilities by size from the Part A data in the Hazardous Waste Data Management System. o Pope-Reid Associates, Inc.(PRA) developed detailed engineering models used to derive unit costs for landfills, surface impoundments and waste piles. K.W. Brown provided technical and cost information on land treatment. o SCS Engineers reviewed PRA's models and data Inputs to those models and contributed technical expertise on all land disposal processes for the analysis. They also estimated some of the planning and demonstration costs that firms could incur as a result of the Part 264 regulations. o Geraghty and Miller (G&M) developed detailed technical models used to estimate corrective action costs under a range of hydrogeologic condi- tions . o Industrial Economics, Inc. (IBc) performed the industry impact analysis described in Chapter VIII. They also assisted in developing the popu- lation distributions for the various land disposal processes, provided estimates of post-closure costs for landfills and surface impoundments, and closure and post-closure financial assurance costs for a range of financial instruments. o Sobotka and Company, Inc. (SCI) developed the economic models used to calculate the incremental costs of the Part 264 regulations for individ- ual land disposal units and for all facilities as a whole. In this capacity, SCI was responsible for coordinating the work of the other team members and synthesizing all the separate efforts into a single product for the Preamble and this Docket Report. ------- 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 ------- II-2 of 4953 (refuse systems) were classified as off-site landfills. All other facilities were classified as on-site. Based on the Part A data, Development, Planning and Research Associates (DPRA) tabulated 24 size categories of landfills measured in acrefeet. Pope- Reid Associates, Inc. (PRA) then used these categories to obtain a range of eight landfill sizes measured in terms of annual operating capacities. This simpli- fied the analysis by limiting the number of sizes to be costed, and resulted in a distribution (shown in Table II-l) that was more appropriate for costing the O&O component of the regulations than was the distribution based on acre-feet. The Pope-Reid distribution was then used to estimate the landfill D&O and corrective action unit costs reported in Section IX.D of the Preamble to the Part 264 regulations and Section A.I of Chapter VII of this report. It was also used to estimate the total D&O costs for landfills reported in Section IX.F of the Preamble and Section C of Chapter III of this report. TABLE II-l Distribution of Landfills By Size Unit Size (MT/Year) 500 2000 5000 7000 15000 35000 60000 123000 Number Offsite 9 10 4 7 11 9 13 39 of Units Onsite 246 60 30 36 42 13 15 29 Total 253 70 34 43 53 22 28 68 TOTAL 102 471 573 Estimated Average Annual Capacity =• 21,549 MT/yr. 2. Surface Impoundments. The HWDMS provides information on the total capacity of surface impoundments at each site by type of impoundment: storage, treatment, or disposal. However, there is no data on the number of surface impoundments at each site. ------- II-3 To estimate the total number of surface impoundments, the following steps were taken. o If the part A Information indicated ownership of both storage and dis- posal impoundments, they were counted separately, unless their capacities were the same. o Where the total capacity of a disposal or storage Impoundment was less than or equal to 100,000 gallons, the facility was counted as a 1/4 acre impoundment. o For treatment impoundments, where the total capacity was less than or equal to 10,000 gallons, the facility was counted as a 1/4 acre impound- ment. o Where a disposal or treatment Impoundment was larger than 100,000 gallons or where a treatment impoundment was larger than 10,000 gallons, but where the total size was less than 40 acres,1 the facility was counted as two surface impoundments, each with half the total capacity. o Where a size greater than 40 acres was Indicated, the number of surface Impoundments was determined by dividing the total acreage by 20 acres and rounding up. o The total number of impoundments derived from this process was multiplied by a factor of 1.11 to account for firms that did not submit Part A's for reasons of confidentiality. This process resulted in an average of 2.45 surface impoundments per site. The Surface Impoundment Assessment (SIA) data base was used to establish size categories and their means, which were used to derive point estimates appropriate for use in the analysis. The data base indicated that about 45 percent of all hazardous waste impoundments were smaller than 1/4 acre. The analysis treated these facilities as 1/4 acre impoundments. 1 Forty acres is roughly equivalent to 120 million gallons for disposal and storage surface impoundments or 8 million gallons per day for treatment surface impoundments. ------- II-4 Sizes in the SIA data base reported as greater than 15 acres were collapsed into the 7 to 15 acre category (11 acres is the midpoint) because of uncertainty regarding the feasibility of the larger surface impoundment sizes. For the purposes of estimating the total D&O costs of the Part 264 regulations, all surface impoundments were assumed to be on-site facilities. However, for purposes of estimating industry impacts, Impoundments were separated into on- site and off-site categories. (See Chapter VIII.) Table II-2 shows the distri- bution that was used to estimate the D&O costs for surface impoundments in Sections IX.D and IX.F of the Preamble and in Section A.2 of Chapter VII of this report. TABLE II-2 Distribution of Surface Impoundments By Size Unit Size (Acres) Number of Units 1/4 1904 1/2 460 1 393 2 513 5 271 11 699 Total 4240 Estimated Average Size =2.63 acres 3. Land Treatment Units. The total number and size distribution of land treatment facilities are based on Part A data contained in the HWDMS. The total number of land treatment facilities was multiplied by a factor of 1.2 to account for firms that did not report for reasons of confidentiality. Table 11-3 shows the distribution of land treatment units used in the analysis. ------- II-5 TABLE II-3 Size Distribution of Land Treatment Facilities Unit Size (Acres) 1.7 6.5 20.1 74.3 247.1 Number of Units 70 56 55 25 35 Total 241 Estimated Average Size = 50.2 acres 4. Waste Piles. Numbers and sizes of waste piles were based on Part A data. The total number of waste piles was multiplied by a factor of 1.2 to account for nonreporting firms. The frequency distribution of waste pile sizes obtained from the Part A data was adjusted by EPA to develop a size distribution appropriate for this analysis. The distribution used is shown in Table 11-4. TABLE II-4 Size Distribution of Waste Piles Unit Size (000 Cubic Feet) 2 10 25 100 500 1000 Number of Units 306 53 45 107 45 52 Total 608 Estimated Average Size = 143,000 cubic feet ------- II-6 B. Distribution of Land Disposal Facilities To calculate total corrective action costs, EPA used the Part A data to group individual units into facilities and to estimate the average acreage required for different combinations of land disposal units. This was done because land area was used as a surrogate for plume size, and corrective action costs were estimated on the basis of plume size. Total corrective action costs provided in Section IX.F of the Preamble assumed that plume sizes were equivalent to the acreage of the total waste management area at land disposal facilities.1 The distribution of land disposal facilities is shown in Table II-5. TABLE II-5 Distribution of Land Disposal Facilities by Size and Type of Disposal Activities Total Number Average Type of Facility of Facilities Acreage1 Landfill only 267 34 Surface Impoundment only 1292 9 Land Treatment only 72 103 Waste Pile only 376 1/2 Land Treatment/Waste Pile 77 309 Landfill/Waste Pile 24 44 Landfill/Land Treatment 14 243 Surface Impoundment/Waste Pile 113 8 Surface Impoundment/Land Treatment 74 76 Surface Impoundment/Land Treatment/ 12 80 Waste Pile Surface Impoundment/Landfill 155 45 Surface Impoundment/Landfill/Waste Pile 38 65 Surface Impoundment/Landfill/Land Treatment 35 162 Surface Impoundment/Landfill/Land Treatment/ 5 138 Waste File Total Number of Facilities ~ 2484 32 (average acreage) 1 Acreages derived from the Part A data were adjusted by a factor of 1.5 to account for common areas between the individual land disposal units and between the waste disposal area and the property boundary. ------- 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: ------- III-2 o capital — depreciable expenses incurred in the zero year (the year before facility operation starts; o initial — nondepreciable expenses Incurred in the zero year; o annual — recurring operating costs and other nondepreciable expenses; o last year capital — depreciable expenses occurring in the last year (year 20 of facility operation); and o other last year — nondepreciable expenses occurring in year 20. Table III-l lists the elements for which pre-ISS costs for landfills were estimated. TABLE III-l Pre-ISS Cost Components for Landfills Capital Costs o Office space o Heavy equipment o Dewatering o Truck scales pumps o Water wells o Road gravel o Utilities o Revegetatlon o Site clearing and grading Initial Costs o Land acquisition o Cell excavation Annual Costs Occurring in Years 0 Through 19 o Cell excavation Annual Costs Occurring in Years 1 Through 20 o Clerical labor o Overhead o Operating labor o Insurance o Labor burden o G&A o Supervision o Cell closure o Fuel o 5% inspection fee o Electricity o 10% engineering fee o Equipment o 15% contingency maintenance labor The analysis assumed that landfills have a remaining operating life of 20 years and that a landfill cell is opened each year starting in year 0 through year 19, and that a cell is closed each year starting in year 1 through year 20. Therefore, cell excavation and closure costs, although they are technically ------- IH-3 capital costs, were treated as annual costs (incurred and expensed in each year). Appendix B provides a complete listing of all unit costs shown in Table III-l by landfill size. 2. Surface Impoundments. Pre-ISS costs estimated for surface impoundments uere less comprehensive than those estimated for landfills, and consist prima- rily of facility construction costs. Surface impoundments are simpler to design and operate than landfills because wastes are piped into instead of physically placed in the facility. Thus, initial capital costs are less than those for landfills and annual O&M costs are negligible. Because all surface impoundments were assumed to be on-site (i.e., they are always associated with other indus- trial or land disposal processes), there was no need to estimate costs for offices or special personnel. Table 111-2 lists the categories for which pre-ISS costs were estimated for surface impoundments. TABLE III-2 Pre-ISS Cost Components for Surface Impoundments Capital Costs o Site clearing and grading o Excavation o Access road o Revegetation o Inlet/outlet valve o 5% inspection fee o 10% engineering fee o 15% contingency Initial Costs o Land acquisition Depreciable Capital Costs Occurring in Year 20 o Fill/compact/slope o Revegetation Intermittent Costs o Dredge and disposal of accumulated wastes ------- III-4 As Table II1-2 shows, surface Impoundment excavation Is a capital cost, and Is therefore depreciable. Unlike landfills, where new cells must be exca- vated each year, surface Impoundments are only excavated once In the zero year, before actual operation begins. However, all surface Impoundments must be dredged periodically to maintain their design capacities. The analysis assumed that dredging frequency Is a function of surface Impoundment size, although In practice, other factors (e.g., production rates, etc.) are likely to affect dredging frequency. Dredging costs reflect both the cost to remove (estimated to be $3 per metric ton) accumulated waste from the Impoundment and the cost to dispose of the waste in a 123,000 metric ton/year off-site landfill. Ship- ping costs were not included because assumptions made regarding hauling dis- tances would be extremely arbitrary. Appendix B provides a complete listing of all pre-ISS unit costs by surface impoundment size. B. ISS-Incremental Costs and Assumptions For All Processes For the most part, ISS administrative, monitoring and testing, and record- keeping and reporting costs were taken from the Arthur D. Little Economic Impact Analysis £f_ RCRA Interim Status Standards. Incremental-design costs resulting from the ISS regulations were estimated by PRA. While certain cost elements were fixed (independent of facility size and type), others varied with both size and type of facility. For example, ADL's estimate of the cost to prepare an annual report was the same for all types and sizes of land disposal units. However, the ADL study used different fenc- ing and runoff control formulae (which were dependent on the amount of waste handled) for each type of process. 1. Cost elements that apply to all processes. Basic cost elements that were generally the same for all land disposal processes are outlined below. Exceptions are noted. ------- III-5 Groundwater Monitoring. Capital costs for 4 ground-water wells (3 upgrad- ient and 1 downgradient) were included in the baseline costs for all land- fills, surface impoundments, and land treatment facilities, consistent with ISS requirements. Ground-water sampling and analysis costs assumed quarterly testing in the initial year (year zero) and annual testing thereafter. Because the ISS regulations do not require waste piles to undertake ground- water monitoring, costs for this activity were not included in the waste pile baselines. Contingency Equipment. Capital costs for contingency equipment for clean- ing up spills, putting out fires, etc. were included in the baseline costs for all land disposal processes. Fencing. Costs for fencing were included for all processes. For land- fills, fencing costs were assumed to be annual (surrounding each cell), while for the other three types of facilities, fencing costs were included as depreciable capital expenses incurred in year zero. Run-off/run-on Control. The ISS regulations require facilities to collect run-off and divert run-on from active portions of the facility. Collected run-off is to be treated as hazardous. Baseline costs for surface impound- ments , land treatment facilities and waste piles included capital costs in year 0 for run-off/run-on control. Run-on/run-off control costs were In- cluded as annual costs in the landfill baselines. Planning Costs. The Part 265 regulations require all facilities to engage in certain planning activities. The following types of activities were costed for all land disposal processes: o Contingency plan development o Closure/post closure plan development o Waste analysis plan % o Establishment of a reporting system, operating log, etc. (systems design) o Training course development The' analysis assumed that all planning costs are nondepreciable expenses that are incurred in the zero year. Recordkeeping and Reporting Costs. The Part 265 regulations impose a num- ber of reporting costs on land disposal facilities. Costs for the following activities were included in the baselines for all land disposal processes. o Initial Year Costs Only - Initial EPA notification - Part A administration and recordkeeping and reporting - Regulatory review ------- III-6 o Initial Year and Annual Costs - Maintenance of detailed disposal records (This was not Included In the waste pile cost baseline). - Annual report - Ground-water sampling and analysis - Waste testing - Regular inspection - Personnel training o Last Year Costs - Decontamination and certification 2. Cost elements that vary by type of process. The ISS costs that were specific to certain processes are described below. Landfill and Surface Impoundment Cap Costs. The Part 265 regulations re- quire disposal facilities to close so as to minimize the need for further maintenance and to minimize or eliminate the release of contaminants. PRA estimated the cost of an ISS cap for landfill cells and for surface impoundments. (The analysis assumed that surface Impoundments close as landfills.) Post Closure Costs for Landfills and Surface Impoundments. Costs for the following post closure activities were estimated and included in the ISS baselines for landfills and surface impoundments. The post closure period was assumed to be 30 years, consistent with requirements in Part 265. o Capital costs - replanting of the facility in the first year of the post closure period. - replacement of the fence surrounding the facility in year 16 of the post closure period. - correction of damage to final cover expected to occur once (assumed to be year 15 of post closure period). o Annual O&M costs - Inspection of the facility - grass mowing - repair of routine erosion damage - fertilization of the groundcover planted at the facility1 - ground-water monitoring - 30% contingency Special Requirements for Waste Piles. The ISS regulations require facility owner/operators to install sturdy Impermeable bases for waste piles or to protect the pile from precipitation and run-on. PRA developed designs and estimated costs for bases that would last for the remaining operating life of the waste pile (20 years). 1 Actually this cost occurs annually for the first three years and then five times in the next 27 years. These costs were adjusted to derive an equiv- alent annual cost to simplify the calculations. ------- III-7 Although the analysis assumed that waste pile bases last for 20 years, it did not assume that the piles themselves would last for 20 years. Rather, it assumed that piles sized at 2,000, 10,000 and 25,000 cubic feet would be completed, removed and disposed of each year; that a 100,000 cubic ft pile would be completed in two years; that a 500,000 cubic ft pile would be completed in 10 years; and that it would take 20 years to complete a 1,000,000 cubic ft pile. The baseline analysis also assumed that all disposal of piles, bases, contaminated soils, etc., took place in a 123,000 MT/yr off-site landfill that was complying with the ISS regulations. There were no post closure costs for waste piles. Special Monitoring Requirements for Land Treatment Facilities. The Part 265 regulations require land treatment facilities to perform soil core and soil pore-liquid monitoring in the unsaturated zone, below the depth to which waste is incorporated. The regulations do not specify the number of test locations or the required frequency of sampling. The analysis assumed an average of 7 samples per year for soil core and soil pore liquid monitor- ing in the zone of aeration using lyslmeters. The analysis also assumed pH analysis of soil samples, and treatment of surface water runon/runoff. Closure for land treatment facilities consists of revegetation. Post closure costs include costs for soil pore liquid and ground-water monitor- Ing, and wind dispersal control. ------- 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 ------- IV-2 guidance document that will support the regulations. The three designs are described below. o Design #1 was a single synthetic liner design. Its top layer was a leachate collection system which consisted of 30 cm of gravel inter- spersed with drainage tiles spaced at 15.25 meter intervals, and 15 cm of sand. A 30 mil synthetic membrane was located Immediately under the leachate collection system. The membrane was on a 15 cm sand buffer, which completed the design. The design cost included sump pumps, wet wells, and a leachate treatment system. This was the lowest cost design used in the analysis. It was believed to be capable of satisfying the performance requirements provided in §264.301(a). Owner/operators using this design would still need to undertake ground-water monitoring. Design costs were the same for both off-site and on-site landfills. o Design //2 was a double liner system. A second drainage layer of 30 cm of gravel was included below the primary synthetic liner and sand buffer of Design //I. A secondary liner consisting of 60 cm of compacted clay was then situated under the drainage layer. The clay liner resulted in higher design costs for on-site landfills than for off-site landfills. This was because the analysis assumed that clay would not be readily available to on-site facilities and would need to be brought in. However, off-site landfills were assumed to locate close to sources of clay, so their clay costs were considerably lower, reflect- ing the lower shipping expense. The analysis assumed that landfills using this design would still be required to undertake ground-water monitoring. o Design #3 was a double synthetic liner system intended to satisfy the conditions specified in the Guidance Document for avoiding ground-water monitoring. It consisted of all the items outlined above, except that the clay liner under Design //2 was replaced with a second 30 mil synthe- tic liner sitting on a 15 cm sand buffer. The gravel drainage layer located between the two liners served as a leak detection system. De- sign costs were the same for off-site and on-site landfills. The analysis assumed that landfills using this design would not need to do ground-water monitoring. Appendix C lists the detailed engineering costs for each of these designs. The regulations provide that owner/operators that can demonstrate the ability of alternative design and operating practices and/or location charac- teristics to prevent the migration of any hazardous constituents into the ground water or surface water at any future time can be exempted from some ------- 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 ------- IV-4 systems, the presence of liquids In the leak detection systems, or malfunction of wind dispersal control measures. The analysis did not cost any of these incremental monitoring and inspection requirements. It assumed that these costs would be about the same under FSS as they were under ISS (i.e., no change from baseline). These costs are expected to be very small compared to other compliance costs. 5. Surveying and recordkeeping. Section 264.309 requires owner/operators to maintain a map showing the exact location and dimensions of each cell with respect to permanently surveyed benchmarks, and records showing the contents of each cell and the general location of each waste type within each cell. Again, costs for these items were not estimated, but are expected to be small. 6. Closure. The regulations require owner/operators to place a cap or final cover on each cell at closure. This cap is to be designed and constructed to minimize the migration of liquids into the landfill. It is also to have a permeability less than or equal to the permeability of any bottom liner system or natural subsoils present. PRA developed liner costs based on the following design. o The cap design included 61 cm of vegetated top soil as a top cover; a 30.5 cm drainage layer of sand with perimeter collection tiles for run- off /runon control; and 61 cm of compacted clay to provide the impermeable layer. Costs assumed that the cell would be filled and graded to a 3 percent slope before final cover is applied. The analysis assumed that cap costs are incurred in each year of operation (yrs 1 through 20), because of the assumption that one cell is opened and closed each year. Cap costs were higher for on-site landfills than for offsite land- fills because of the assumption that on-site facilities do not have clay avail- able on site but must ship it in, while off-site facilities are better situated with respect to clay supplies. Engineering costs for caps for different land- fill sizes are listed in Appendix C. ------- 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). ------- IV-6 While existing portions of surface Impoundments do not technically need to comply with the liner requirements specified In §264.221 and §264.222 (only new surface Impoundments or lateral expansions of existing impoundments are required to comply), owner/operators of existing surface impoundments may wish to upgrade their facilities to reduce the likelihood that they will leak and contaminate ground water. However, surface impoundments are not like landfills, where Part 264 liners can simply be applied to new cells. The owner/operator of an existing surface impoundment that wants to install a Part 264 liner system, must either close the impoundment as a landfill according to the Part 264 closure requirements under §264.228 and construct a new impoundment, or he can close the facility temporarily and retrofit. Both of these options were costed in the analysis for each of the 3 liner systems described below, in addition to the case where the owner/operator does nothing except ground-water monitoring and closure. As previously discussed, surface impoundment liner and cap costs are treated as capital expenses instead of annual expenses, because it is assumed that surface impoundments have 20-year operating lives, while In- dividual landfill cells only have 1-year lives. The requirements are described below. 1. Liners. The Part 264 regulations require that all surface Impoundments (except for existing portions) must have liners that are designed, constructed, installed and maintained to prevent any migration of wastes out of the Impound- ment to the adjacent subsurface soil or ground water or surface water at anytime during the active life (including the closure period) of the impoundment. The regulations require that liners for disposal surface impoundments (those that close as landfills) be constructed of materials that can prevent wastes from migrating into the liner during the active life of the facility.1 Storage 1 This uas Interpreted to mean that disposal Impoundments must be con- structed with synthetic liners. Because the analysis assumed that all surface impoundments are disposal, all the surface impoundment designs included at least one synthetic liner. ------- 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. ------- 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 ------- 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). ------- 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 ------- IV-11 liners must be designed, constructed, installed and maintained to prevent any migration of wastes out of the pile to the adjacent subsurface soil or ground' water or surface water at anytime during the active life (including the closure period) of the waste pile. The leachate collection and removal system is to be designed, constructed, maintained and operated to collect and remove leachate from the pile. The regulations provide that owner/operators of certain types of double-lined waste piles can obtain exemptions from ground-water monitoring requirements under Subpart F of the regulations, provided that a leak detection system is installed between the liners. The draft guidance for waste piles stated that a base of admixed materials such as concrete or asphalt and run-off controls could be used instead of the liner/leachate collection system for above grade piles. In addition, §264.253 of the regulations allows owner/operators to avoid ground-water monitoring under certain conditions if they remove wastes in the pile periodically and inspect the liner or impermeable base for deterioration, cracks, or other conditions that may result In leaks. PRA developed costs for each of these three compliance options. o Liner/Leachate Collection System: Costs for a double synthetic liner system were estimated for waste piles. The system consisted of a primary 30 mil synthetic liner overlaying a leachate collection system that consisted of a 30 cm sand layer with drainage tiles and a wet well and sump pump. Underneath the leachate collection system there was a se- condary 30 mil synthetic liner with a 15 cm sand buffer below it. Because of the double synthetic liner, ground-water monitoring was not required. o Sturdy Impermeable Base with Ground-Water Monitoring: Liner costs used here were the same" as those used for the ISS baseline. Capital costs for ground-water monitoring wells and initial year and annual costs for ground-water sampling and analysis were included, consistent with the addition of these requirements in Part 264. o Sturdy Impermeable Base with Periodic Inspection: Liner costs assumed here were the same as those used to develop the ISS baseline. Annual inspection costs to move the pile and check the base were added. Ground- water monitoring was not required. ------- IV-12 Costs to install liners or bases were treated as depreciable capital expenses, because the life of the base/liner system was assumed to be 20 years ' for all waste pile sizes. The regulations provide that owner/operators that can demonstrate the ability of alternative design and operating practices and/or location charac- teristics to prevent the migration of any hazardous constituents into the ground water or surface water at any future time can be exempted from the requirements. However, EPA did not estimate the cost of making such a demon- stration, or the potential cost savings from successful demonstrations, or make assumptions about the number of waste piles that would attempt to obtain this exemption or succeed in obtaining the exemption. 2. Run-on/run-off control. The Part 264 regulations require waste pile owner/operators to design, construct, operate and maintain run-on and run-off control systems. As for landfills, the run-on control system must be capable of preventing flow onto the active portion of the landfill during the peak discharge from at least a 25-year storm. The run-off control system must be capable of collecting and controlling the water volume resulting from a 24-hour, 25-year storm. These systems are to be managed efficiently, with special attention required after storms to maintain design capacity. Part 264 run-on/run-off control costs were the same as those estimated for the ISS baseline. However, where owner/operators elected to comply by instal- ling a llner/leachate collection system instead of the hard impermeable base, run-on/run-off control costs were slightly reduced, because of the smaller area required for that containment system. As with the liner and base costs, run- on/run-off control costs are capital expenses Incurred in year zero. 3. Wind dispersal control. The regulations require owner/operators of waste piles containing particulate matter which could be subject to wind ------- 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. ------- IV-14 D. Part 264 Land Treatment Requirements Costs estimated for land treatment areas differ from costs estimated for other processes because there are no requirements for a containment system under this process. Rather, the regulations and guidance specify a treatment program Which, if followed, will ensure that hazardous constituents placed on or in the treatment zone are degraded, transformed or Immobilized. The types of compliance activities required under the Part 264 regulations and their treatment in the analysis are described below. 1. Treatment demonstration. For each waste to be applied, §264.272 requires owner/operators to demonstrate that hazardous constituents in the waste can be completely degraded, transformed or immobilized in the treatment zone. Field tests or laboratory analysis can be used to make the demonstration. The demonstration must be based on conditions similar to those present in the treatment zone. The analysis assumed that each land treatment area would undertake one initial waste analysis and demonstration. The cost used repre- sented an average of the cost of field testing and the cost of lab analysis. 2. Design and operating requirements. The regulations require owner/ operators to maintain land treatment facilities to maximize the degradation, transformation and immobilization of hazardous constituents in the treatment zone. To do this the regulations require that they: o control soil pH. The analysis assumed that 10 percent of all land treatment areas would require an initial pH adjustment. The pH adjust- ment was attained by applying lime to the area. o apply wastes at a specified rate. The analysis assumed that wastes are applied at a rate of 206 metric tons per acre per year. o fertilize or take other action to enhance microbial or chemical reac- tions .Annual costs for ground cover planting and fertilization were included for 90 percent of the areas. o control moisture content. The analysis assumed that 90 percent of all land treatment areas that are 20 acres or larger would incur capital costs for an irrigation mobile pump and spray nozzle. Smaller areas were assumed to use garden hoses. Annual costs for irrigation that assumed operation of the system for two hours every three days were applied to 90 of all areas (regardless of size). ------- IV-15 o minimize run-off of hazardous constituents from the treatment zone. No Incremental costs were assumed for run-off control, because it was assumed (based on Part A information) that most areas are already graded to the desired slope for proper run-off control. o design, construct and maintain a run-on control system capable of pre- venting flow onto the treatment zone during peak discharge from at least a 25-year storm. No incremental (over ISS) costs were assumed for run- on control. o control wind dispersal of particulate matter. The analysis assumed that the measures taken to control moisture content of the treatment zone would also satisfy the wind dispersal control requirements. o inspect the facility weekly and after storms to detect any malfunction of the run-on/run-off control system or the wind dispersal control sys- tem. Incremental costs for these inspection activities were not included in the analysis. ISS inspection costs were assumed to satisfy this requirement. 3. Requirements for growing food-chain crops. Section 264.276 lists re- quirements for growing food-chain crops at hazardous waste land treatment areas. The whole area of food chain crops was not addressed in the analysis because of insufficient information regarding current practices, costs of complying, etc. 4. Monitoring the unsaturated zone. Section 264.278 requires owner/oper- ators of land treatment areas to establish and carry out an unsaturated zone monitoring program to determine whether hazardous constituents migrate oat of the treatment zone. The program is to consist of soil and soil-pore liquid monitoring using soil cores and lyslmeters. A sufficient quantity of samples is to be obtained to represent background levels and determine any changes in these levels. Information provided by R.W. Brown indicated that many land treatment facilities already engage in these activities. Therefore, incremental costs for these activities were not applied across all areas. The analysis assumed that 50 percent of all areas would need to add one lysimeter per 8 acres (an initial capital expense) and would incur an annual cost to analyze an additional 5 parameters. The analysis assumed that 25 percent of all areas would need to increase soil sampling by an additional soil core per 4 acres on an annual basis. ------- IV-16 In addition, the analysis assumed that 10 percent of all areas would show a statistically significant increase in hazardous constituent levels and would have to take additional measures (short of corrective action) to respond to the increases. Costs assumed for evaluating and responding to these situations were as follows: 1) additional annual pH adjustment costs were applied to 3 percent of all areas; 2) capital and annual costs of expanding the treatment zone were applied to 5 percent of all areas; and 3) annual costs to dispose of overload wastes in an off-site landfill were applied to 2 percent of all areas. 5. Closure. At closure the area owner/operator is to establish a vegeta- tive cover on the portion being closed. The cover must not impede degradation, transformation or immobilization of constituents and must be able to grow without extensive maintenance. No incremental cost (above the ISS vegetative cover) was assumed. 6. Post closure care. The regulations require owner/operators to continue all activities (including pH control) necessary to enhance degradation and transformation and sustain immobilization of hazardous constituents in the treatment zone. Where the owner/operator can demonstrate that the level of hazardous constituents in the treatment zone does not exceed background levels, the site can avoid post-closure requirements. However, this alternative was not taken into account in the cost analysis. All land treatment areas were assumed to close with hazardous constituents in place. The analysis assumed additional post closure costs (over ISS) for pH control. ------- 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 ------- 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). ------- 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 ------- V-14 examines the cost effectiveness of adding a small capacity fluid removal system inside the wall to manage water levels and prevent outward leakage of plume fluids. More detailed information on the assumptions and unit costs used to develop cost estimates for slurry walls can be found in Appendix D. 1. Comparison of Slurry Wall and Counterpumping Annual Revenue Require- ments . Table 15 in Section IX.F of the Preamble provided an estimate for total corrective action costs of $677 million. This cost estimate assumes that 2,484 facilities will use Strategy 2 counterpumping beginning in year 0 and continuing for 150 years. Effects on total costs of using slurry walls instead of counterpumping were not estimated for the Preamble, although G&M examined this approach in their analysis. Table V-5 compares total corrective action costs assuming the use of slurry walls with total corrective action costs assuming Strategy 2 counterpumping. Surface seals were Included in the slurry wall design to limit fluid buildup inside the wall, thus reducing outward leakage. The surface area sealed equalled the area of the plume (the area of waste management facility) and the slurry wall's dimensions equalled the perimeter of the plume. Slurry wall costs assumed G&M's mid-wall cost of $5 per vertical foot and their high surface seal cost of $.75 per square foot. TABLE V-5 Comparison of Total Corrective Action Costs Using Counterpumping and Slurry Walls ($ 000 000) Low Estimate: High Estimate: Detect in Year 49 Detect in Year 0 Take Action for 20 Years Take Action for 150 Years Slurry Slurry Count erpumping Wall Counterpumping Wall Total Corrective Action Costs for 2,484 Facilities: 51 104 677 473-758r t The low end of the range assumes that slurry walls are not replaced during the 150 year period. The high end of the range assumes that they must be replaced every 30 years. ------- V-15 The low end of the cost range ($473 million) estimated for slurry walls assumes that the mil does not need to be replaced during the 150-year period. The high end of the range ($758 million) assumes that walls must be replaced every 30 years, and is consistent with the assumption used to estimate counter- pumping costs that the fluid removal and treatment system would need to be replaced every 30 years.1 For the high cost scenario, if it is assumed that slurry walls do not need replacement during the 150 year period, they appear to be much cheaper than counterpumping. This is largely due to: 1) the lower annual O&M costs esti- mated for slurry walls ($10,000 per year no matter how big the wall is to check for major leaks or significant plume migration beyond the wall) compared with $50,000 to $150,000 per year for counterpumping, depending on plume size; and 2) the fact that these costs (and the cost differences) occur every year for 150 years. For the low cost scenario, slurry walls appear to be more than twice as expensive as counterpumping. This is because the costs for both strategies occur so far out in the future (50-70 years) that discounting prac- tically eliminates the disparity in the O&M costs between the two. However, the discounting can not fully eliminate the difference between the two sets of capital costs. Slurry wall capital costs are 2 to 7 times more expensive than the capital costs for a counterpumping system, depending on plume size. Table V-6 indicates how slurry wall and counterpumping costs compare for specific plume sizes. The low ends of the ranges indicate the low cost correc- tive action scenario (beginning in year 49 and continuing for 20 years) while the high estimates assume action for 150 years beginning in year 0. 1 Although slurry wall capital costs are incurred five times in the high cost case and only once in the low cost case, the annual revenue requirement for the high estimate is less than twice that for the low estimate because of discounting far into the future and because of additional depreciation tax shields. ------- V-16 TABLE V-6 Comparison of Slurry Wall and Counterpumping Annual Revenue Requirements For Small and Large Plumes ($ 000) Small Plume Large Plume (100 ft.x 200 ft.) (1,000 ft. x 2,000 ft) Slurry Wall - Wall is not Replaced 7-44 69 - 305 - Wall Replaced Every 30 Years 7-58 69 - 497 Counterpumping - Strategy 1 11-102 21 - 187 - Strategy 2 16 - 141 36 - 314 The table shows that walls tend to be cheaper for smaller plumes but are much more expensive for larger plumes. For a small plume under the 0/150 year scenario, Strategy 2 counterpumping is about 2.5 times more expensive than a slurry wall (even assuming wall replacement every 30 years). However, for a large plume, the slurry wall is more than 1.5 times more expensive than counter- pumping (where it is assumed that both must be replaced every 30 years). This is because slurry wall costs are more dependent on plume size than are counter- pumping costs. As plume sizes increase the ratio of slurry wall costs to counterpumping costs will also increase. 2. Combining a Small Capacity Fluid Removal System With a Slurry Wall Under certain conditions, it may be attractive for facilities to install a small capacity fluid removal system inside the wall to prevent outward leakage of plume fluids. Owner/operators may find this approach financially attractive where the alternative is to pump at a high rate (due to high aquifer discharge rates) for a long period of time. It is also likely to be more attractive for small plumes than for large plumes. Permit writers may find the approach attractive because it provides containment while minimizing impacts on sur- rounding ground-water systems. Table V-7 compares the cost of the slurry wall and small fluid removal system to the cost of a full-scale fluid removal (counterpumping) system. ------- V-17 TABLE V-7 Cost of Counterpumping Compared to Slurry Wall Cost Where Low Pumping Rate is used to Limit Fluid Migration Through the Wall ($ 000) Small Plume (100x200) Strategy 2 Slurry Wall + Counterpumping Pumping at Low Rate 1. Amount of Contaminated Ground Water Requiring Treatment (MT/Year)* 189 <.5 2. Annualized Corrective Action Costt 140 83 3. Annualized Funds Available For Shipping/Treatment - 57 4. Annual Funds Available For Shipping/Treatments - 26 S. Distance Pumped Water Could Be Shipped with Available Funds** - 517 * These quantities reflect pumping rates of 22 million gallons per year (coun- ter pumping only) and 50,000 gallons per year (slurry wall + pumping). t Annualized costs based on corrective action beginning in Year Zero and con- tinuing 150 years. § Assumes 150 years of annual shipping and treatment costs at 3 percent real discount rate. ** Assumes $.15 per ton-mile shipping cost and $60 per MT treatment feost. The table assumes that for a small plume (100 ft x 200 ft) with a slurry wall in place, pumping rates of about 50,000 gallons per year* «.5 metric tons per year) would be sufficient to control any leakage of plume fluids through the wall. This pumping rate compares to an annual rate of 22 million gallons (189 metric tons) per year, which would be required where Counterpumping is the only corrective action measure used. Line 2 of the table compares the costs of the two options and line 3 indicates the cost savings to the owner/ operator of selecting the "slurry wall plus pumping" option. Because the 1 Based on information provided by Geraghty & Miller. ------- V-18 quantity of liquid requiring treatment would be so small under the slurry wall plus pumping option, on-site treatment would probably not be cost-effective. Therefore, it was assumed that the site owner/operator would ship the water off-site for treatment. Line 4 shows the annual funds that would be available (savings) each year over the 150-year corrective action period that could be used to offset costs to ship the contaminated ground water off-site for treat- ment. Line 5 indicates that the owner/operator could afford to ship the ground water 517 miles (assuming a shipping cost of $.15 per mile and treatment cost of $60 per metric ton) with the money saved by selecting the slurry wall option in lieu of counterpumping. Reducing the pumping rates even more would enable contaminated liquids to be shipped even further. For example, if pumping rates could be reduced to 10,000 gallons per day, an owner/operator could afford to ship contaminated ground water up to 4,126 miles before the wall/pumping combination would become less attractive than counterpumping alone. The costs of the slurry wall/pump- ing option would be even more attractive under more pessimistic assumptions regarding gradient and transmissivity because these changes would not affect the costs of the combination approach. However, the slurry wall/pumping com- bination would be much less attractive with deeper plumes, and infeasible at depths greater than 150 feet. ------- 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. ------- VII-10 B. Total Cost Estimates 1. Landfill Total Costs. Table VII-13 lists the total ISS and incremental Part 264 costs for all landfills units. Total landfill costs were calculated by multiplying the number of landfills in each size category by the unit costs that were provided in the previous section, and summing across all landfill sizes. Table VII-13 lists total costs for basic D&O as well as for D&O plus corrective action. Total costs are provided for all three sets of counterpump- ing timing assumptions for both Strategy 1 and Strategy 2 conditions, as well as for the three landfill liner systems. TABLE VII-13 Total ISS and Incremental Part 264 Annual Revenue Requirements for Landfills* (in Millions of Dollars) Incremental Costs of Part 264 Designs ISS Costs 300.6 - - - Single Synthetic Liner 81.4 93.5 99.6 129.2 155.3 181.4 234.7 Double Liner 157.2 169.2 175.3 204.9 231.1 257.2 310.5 Double Synthetic Liner 159.4 171.5 177.6 210.0 236.2 264.4 317.6 Basic D&O D&O plus CP-1 49-69 CP-2 49-69 D&O plus CP-1 0-20 CP-2 0-20 D&O plus CP-1 0-150 CP-2 0-150 * These cost estimates do not account for transfer payments resulting from either dredged material from surface impoundments or waste pile disposal, and are therefore overstated. The Table shows, for example, that if all landfills complied with the Part 264 regulations by installing double liner designs, the total incremental annual revenue required would be $157 million. If all landfills needed to take correc- tive action immediately and had to counterpump for 20 years, total Incremental costs would be $205 to $231 million, depending on the counterpumplng strategy employed. ------- VII-11 Table VII-14 shows the total ISS and Part 264 incremental first year cash requirements for landfills. Corrective action timing and liner design assump- tions are the same as in Table VI1-13. For the example used above, Incremental first year cash requirements for D&O alone would be $147.5 million. Costs for D&O plus corrective action starting in year 0 would be $313 to $405 million, depending on the pumping strategy used. TABLE VII-14 Total ISS and Incremental Part 264 First Year Cash Requirements for Landfills (in Millions of Dollars) Part 264 Incremental Costs Basic D&O D&O plus CP-1 CP-2 D&O plus CP-1 CP-2 D&O plus CP-1 CP-2 49-69 49-69 0-20 0-20 0-150 0-150 ISS Cost 260.9 - - - 2. Surface Impoundment Total Single Synthetic Liner 75.4 75.4 75.4 240.5 332.9 240.5 332.9 Costs. Table Double Liner 147.5 147.5 147.5 312.6 405.0 312.6 405.0 VII-15 shows Double Synthetic Liner 147.5 147.5 147.5 312.6 405.0 312.6 405.0 the total IS! incremental Part 264 costs for surface impoundments, based on the unit costs by size contained in Section A.2 of this chapter and on the distribution of surface impoundments by size described in Chapter 2. The table includes Part 264 D&O costs for three compliance options: perform detection monitoring only, retrofit the existing impoundment, and replace the current impoundment. The three different liner designs are costed for both the retrofit and replace cases. In addition, costs for both Strategy 1 and Strategy 2 counterpumplng for the three different time periods studied are included in the table. Thus, if all facili- ties chose to retrofit with double liners, and all needed to perform corrective ------- 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. ------- 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. ------- 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. ------- 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 ------- |