United States Solid Waste and EPA530-R-99-026
Environmental Protection Emergency Response NTIS: PB99-156 010
Agency (5305W) April 1998
Application of the
Phase IV Land
Disposal Restrictions
to Contaminated
Media: Costs, Cost
Savings, and
Economic Impacts
Printed on paper that contains at least 30 percent postconsumer fiber
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APPLICATION OF THE PHASE IV
LAND DISPOSAL RESTRICTIONS
TO CONTAMINATED MEDIA:
COSTS, COST SAVINGS, AND
ECONOMIC IMPACTS
Aprils, 1998
Prepared for
Office of Solid Waste
U.S. Environmental Protection Agency
Prepared by
ICF Incorporated
Contract Number 68-W4-0040
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TABLE OF CONTENTS
CHAPTER 1. INTRODUCTION 1-1
1.1 New Soil Treatment Standards 1-2
1.2 Standards for Media Contaminated With Mineral Processing
Wastes 1-3
1.3 Standards for TC Metals Media 1-3
1.4 Outline of This Document 1-4
CHAPTER 2. METHODOLOGY 2-1
2.1 Developing the Contaminated Soil and Sediment Database 2-2
2.2 Assigning Treatment Methods and Costs 2-4
2.3 Partitioning the Database 2-22
2.4 Estimating Amount of Soil and Sediment Subject to LDRs Annually . 2-25
2.5 Estimating Baseline Soil and Sediment Treatment Costs 2-31
2.6 New Soil Treatment Standards 2-32
2.7 Media Contaminated With Mineral Processing Wastes 2-39
2.8 Soil and Sediment that Exhibit the TC for Metals Only 2-41
2.9 Contaminated Ground Water and Debris 2-45
2.10 Major Data and Modeling Limitations 2-48
CHAPTER 3. RESULTS 3-1
3.1 Baseline Treatment Methods and Costs 3-1
3.2 Cost Savings Of The New Soil Treatment Standards 3-6
3.3 No Change In Cost: Media Contaminated with Newly Identified
Mineral Processing Wastes . 3-15
3.4 Increased Costs for TC Metals Soil 3-16
3.5 Summary of Costs/Cost Savings for Phase IV LDR Rule 3-18
CHAPTER 4. ECONOMIC IMPACTS 4-1
4.1 Requirements for a Regulatory Flexibility Analysis 4-1
4.2 Number of Entities With Increased Costs 4-2
4.3 Distribution of Affected Entities Across Different Industries 4-4
4.4 Number of Affected Small Firms In Each Industry 4-5
4.5 Estimating Economic Effects On Affected Small Firms 4-9
4.6 Why Phase IV Does Not Impose Significant Economic Impacts On a
Substantial Number of Small Entities- 4-12
4.7 Why Phase IV Does Not Impose Significant Economic Impacts On a
Substantial Number of Large Firms 4-13
APPENDIX A: SOIL AND SEDIMENT DATABASE A-1
APPENDIX B: SUPPLEMENTAL ECONOMIC IMPACT ANALYSIS TABLES B-1
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CHAPTER 1. INTRODUCTION
In the 1984 Hazardous and Solid Waste Amendments (HSWA) to the Resource
Conservation and Recovery Act (RCRA), Congress specified that land disposal of
hazardous waste is prohibited unless the waste first meets treatment standards
established by EPA or is disposed of in units from which there will be no migration or
hazardous constituents for as long as the waste remains hazardous. The HSWA
amendments require that treatment standards must substantially diminish the toxicity or
mobility of hazardous waste, so that short- and long-term threats to human health and
the environment are minimized. Today's final rule addresses a set of LDR proposals,
Notices of Data Availability (NODA), and one final rule, collectively known as "The
Phase IV Land Disposal Restrictions rule ('Phase IV1)." Phase IV is the latest in a
series of Land Disposal Restrictions (LDR) rules that establish treatment standards for
newly listed and identified wastes and that address other hazardous waste matters.
This document analyzes the impact of the Phase IV rulemaking on the treatment
of contaminated media. The analysis covers:
New soil treatment standards for soil contaminated with hazardous
waste;
New LDR treatment standards for media contaminated with newly
identified mineral processing wastes; and
New LDR treatment standards for media that exhibit the toxicity
characteristic (TC) for metal constituents.
The rulemaking's effect on media contaminated with Manufactured Gas Plant (MGP)
wastes is analyzed in the "Application of Phase IV Land Disposal Restrictions to Newly
Identified Mineral Processing Wastes: Regulatory Impact Analysis."1 The rulemaking's
effect on process waste is analyzed in several regulatory impact analyses.
Based on the analysis documented in this paper, EPA expects that the
rulemaking will slightly increase treatment costs for selected volumes of soil that exhibit
the TC for metals, while slightly decreasing treatment costs for other volumes of soil
under the new soil treatment standards. The rulemaking is not expected to significantly
affect the costs of treating contaminated sediment, ground water, debris, or the costs of
treating media contaminated with newly identified mineral processing wastes.
1 U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response, "Regulatory Impact
Analysis: Application of Phase IV Land Disposal Restrictions to Newly Identified Mineral Processing Wastes," Jan
1998.
Chapter 1: Introduction Page 1-1
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The remainder of this introductory chapter has four parts. The first three parts
summarize the new soil treatment standards, the new LDR standards for media
contaminated with mineral processing waste, and the new LDR standards for media
that exhibit the TC for metals. The fourth section provides an overview of the
remainder of this report.
1.1 New Soil Treatment Standards
Currently, hazardous contaminated soil and other hazardous media are subject
to the same treatment standards as the contaminated restricted wastes. Hazardous
contaminated media are subject to the appropriate treatment standards listed in the
Universal Treatment Standards (UTS) Table in 40 CFR 268.48(a). In the Phase IV
rule, the Agency is promulgating new soil standards that will apply specifically to
hazardous soil that is restricted from land disposal, including hazardous soils
contaminated by TC metals and mineral processing wastes. The new soil standards
require the concentration of each hazardous constituent to be reduced by 90 percent or
to 10 times the UTS, whichever less stringent.
As discussed in the preamble to the final rule, EPA is establishing these new soil
standards to address specific treatability issues posed by hazardous soil. The UTS
levels were established with industrial process waste in mind. The composition of
contaminated soils is quite different from process wastes, which often makes
attainment of current UTS levels infeasible or inappropriate. While facilities currently
have the option of obtaining a treatability variance in this situation, obtaining a variance
often causes delays and increases costs. Additionally, EPA has long recognized that
the difficulty and cost of meeting the current LDR standards provide incentives for
facilities to pursue a legal option of capping or treating hazardous contaminated soils
in-situ to avoid the application of LDRs, rather than excavating the soil and treating it
more effectively using the best demonstrated available technology (BOAT).
Thus, the Agency is establishing these alternative LDR standards in order to
provide regulatory flexibility for facilities generating hazardous soil. EPA believes that
the new soil standards will significantly improve the management of hazardous soil by
increasing treatment options and reducing procedural delays. EPA also believes that
these standards will encourage implementation of more aggressive or permanent
remedies, substantially reduce hazardous constituent concentration, and also
"minimize threats" to human health and the environment, as required by RCRA Section
3004(m).
The new soil treatment standards apply to soil that is hazardous because it
exhibits a characteristic of hazardous waste or contains listed waste. Other final rule
provisions also affect soil and other media containing listed waste. Revised 40 CFR
268.3(c) requires media contaminated with listed hazardous waste to be treated for all
hazardous constituents reasonably expected to be found in the waste, instead of only
the primary constituents listed in 40 CFR 268.40, as is currently the case. (If these
Page 1-2 Chapter 1: Introduction
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media also exhibit the toxicity characteristic, they may already be subject to a
requirement to treat all underlying hazardous constituents.)
1.2 Standards for Media Contaminated With Mineral Processing Wastes
In the Phase IV rulemaking, EPA finalizes treatment standards for newly
identified characteristic mineral processing wastes that are not excluded from RCRA
under the Bevill Amendment. Under the current requirements, media contaminated
with these wastes are not subject to the LDRs. Under the final rule, these media must
comply with the LDR standards for characteristic wastes, that is, the UTS levels for all
underlying hazardous constituents (UHCs). Debris, however, may be treated using the
alternative debris treatment standards. Sediment and debris contaminated with newly
identified mineral processing wastes also must be treated to UTS levels for all UHCs.
Soils contaminated with newly identified mineral processing wastes must meet the
newly promulgated soil standards described above.
1.3 Standards for TC Metals Media
Until this rule, all process wastes and contaminated media exhibiting the toxicity
characteristic for metals that also fail the extraction procedure (EP) were subject to
treatment standards equal to the TC levels.2 Because the characteristic levels and
lead and chromium LDR levels are insufficient to minimize human health and
environmental threats, additional treatment of these remediation wastes left on site is
normally required. EPA is now requiring that facilities treat TC metal wastes to existing
UTS standards for all TC metals and UHCs. Sediment and debris exhibiting the TC for
metals will also have to meet the new standards. Debris, however, may be treated
under the alternative treatment standards for hazardous debris. Soils exhibiting the TC
for metals will have to comply with the newly promulgated soil standards described
above.
In addition to establishing new treatment standards for eight TC metal wastes
(arsenic, barium, cadmium, chromium, lead, mercury, and selenium), EPA is revising
the UTS for nonwastewater forms of the following 12 metal constituents (six TC metals
and six non-TC metals):
Antimony; Nickel;
Barium; Selenium;
Beryllium; Silver;
Cadmium; Thallium;
Chromium; Vanadium; and
Lead, Zinc.
See 55 FR 22520, June 1, 1990.
Chapter 1: Introduction Page 1-3
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The Agency also is setting new treatment standards for wastewater forms of barium,
cadmium, chromium, lead, selenium, and silver TC wastes at levels equal to the
previous wastewater UTS levels.
1.4 Outline of This Document
This report estimates the incremental costs and the cost savings associated with
the three parts of the Phase IV rule summarized above. The remainder of this report is
organized as follows:
Section 2 presents the methodology and the major limitations;
Section 3 describes the results; and
Section 4 analyzes the economic impacts of the projected
incremental costs of the rulemaking on small entities.
In addition, Appendix A describes the soil and sediment database used in this analysis
and Appendix B presents detailed (e.g. industry-by-industry) results of the economic
impact analysis.
Page 1-4 Chapter 1: Introduction
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CHAPTER 2. METHODOLOGY
This chapter describes the methodology for estimating the incremental costs and
cost savings of the application of the Phase IV rule to contaminated media.
Section 2.1 describes the development of the contaminated soil
and sediment database, which contains volume, constituent, and
constituent concentration data for a sample of Comprehensive
Environmental Response, Compensation, and Liability Act
(CERCLA) remedial action and RCRA corrective action sites.
Section 2.2 summarizes the formulas used to assign treatment
methods and costs to soil and sediment in the database under both
the baseline and the post-regulatory analyses.
Section 2.3 explains how and why the database was partitioned
into three portions for purposes of this analysis: soils exhibiting the
TC for organics, soils and sediments exhibiting the TC for metals
only, and non-TC soils and sediments, which are assumed to
contain listed waste.
Section 2.4 describes the estimation of the amount of contaminated
soil and sediment treated annually under various remediation
programs.
Section 2.5 explains the approach for estimating baseline soil and
sediment treatment costs.
Section 2.6 outlines the approach for estimating the cost savings
associated with the new soil treatment standards.
Section 2.7 describes the analysis of possible incremental costs of
the new requirements on soil and sediment contaminated with
mineral processing wastes.
Section 2.8 discusses the approach for estimating the incremental
costs of treating all UHCs in soils and sediments exhibiting the TC
for metal wastes.
Chapter 2: Methodology Page 2-1
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Section 2.9 presents the analysis of the impact of the new TC
metal and mineral processing waste treatment standards on the
management of contaminated groundwater and contaminated
debris.
Section 2.10 describes the major data limitations of the analysis.
This methodology is summarized in Exhibit 2-1.
2.1 Developing the Contaminated Soil and Sediment Database
In order to assess the cost impacts from the Phase IV rule on contaminated soil
and sediment, the affected volumes of these media had to be characterized. These
volumes are generated through CERCLA, RCRA corrective action, RCRA closures,
state superfund, and voluntary cleanup programs. Characterizing these volumes is
most reliably done through examining data on volumes of such media generated in past
remedial actions. Therefore, EPA compiled a database containing available soil and
sediment data on existing CERCLA remedial action and RCRA corrective action sites,
as reported in CERCLA Records of Decision (RODs) and several databases compiled
for analyses of RCRA corrective action initiatives. (Detailed data were not available for
other remediation programs.) Because this analysis analyzes the effect of the Phase
IV requirements on cleanups that will occur in the future, EPA does not have data on
the soils and sediments that will be generated at those cleanups. Instead, the Agency
developed this database to predict the nature of soils and sediments that will be
cleaned up in the future. In addition, the database volumes were not used to predict
the number and size of future cleanups; separate data sources were examined tor
those estimates, as described in Section 2.4.
The data for each site include contaminated soil and/or sediment volumes for a
distinct segment of the cleanup and the types and maximum concentrations of
hazardous constituents present. Because detailed data on sediment contamination at
RCRA corrective action sites were not available, the impact of Phase IV on the
management of sediment at RCRA sites was derived from data for CERCLA remedial
action sediment and RCRA corrective action soil. The RODs and corrective data
sources are described more fully in Appendix A.
The complete database contains data on 535 soil and sediment sites (or
particular volumes) with approximately 44 million tons of contaminated media. The 535
sites include 326 CERCLA sites with approximately 9 million tons of contaminated soil,
88 CERCLA sites with just under one million tons of contaminated sediment, and
121 RCRA corrective action sites with 34 million tons of contaminated soil. The
database is further described in Appendix A.
Page 2-2 Chapter 2: Methodology
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Exhibit 2-1
Methodology for Analyzing Impact of Phase IV on Contaminated Media
Step
Key Outputs
1. Develop database for a sample of CERCLA rem<
action and RCRA corrective action sites (Section
2.1)
fflftfe-specific data on volume and maximum constituent
concentrations for:
CERCLA remedial action soil
RCRA corrective action soil
CERCLA remedial action sediment
2. Develop approach to assign baseline treatment
methods and costs for soil and sediment at sampjlbased
sites (Section 2.2)
Formulas for assigning treatment methods and costs
on site constituents, concentrations, and
volumes.
3. Partition database volumes based on whether vo
exhibit the TC for metals, the TC for organics, or
no TC (Section 2.3)
ififtes and volumes that:
Exhibit TC for organics or for organics and metals
(soil)
Exhibit TC for metals only (soil and sediments)
Do not exhibit TC and are assumed to contain liste
waste (soil)
4. Estimate volume of contaminated soil and sedim
treated annually by various remediation program:
(Section 2.4)
Annual volume of soil treated at:
CERCLA remedial actions
RCRA corrective actions
RCRA closures
State superfund cleanups
Voluntary cleanups
Annual volume of sediment treated at:
CERCLA remedial actions
RCRA corrective actions
5. Estimate soil and sediment treatment costs in the) Average
baseline (Section 2.5)
treatment cost per ton for:
CERCLA remedial action, state superfund, and
voluntary cleanup soil
RCRA corrective action and RCRA closure soil
CERCLA remedial action sediment
RCRA corrective action sediment
6 Project Phase IV treatment and costs for soil and
sediment for sample sites for each partitioned volu|rfer:
(Section 2.6 through 2.8)
Average treatment cost per ton for each partial volur
CERCLA remedial action soil
RCRA corrective action soil
CERCLA remedial action sediment
7. Multiply changes in weighted average treatment
costs from Steps 5 and 6 by annual volumes fronji^tBpRCLA
4 to project total annual cost savings (Sections
2.6 through 2.8)
Annual costs or cost savings for:
remedial action, state superfund, and
voluntary cleanup soil
RCRA corrective action and RCRA closure soil
CERCLA remedial action sediment
RCRA corrective action sediment
8. Discuss potential changes in treatment costs for
contaminated ground water and contaminated debris
(Section 2.9)
Qualitative discussion of Phase IV impacts.
Chapter 2: Methodology
Page 2-3
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2.2 Assigning Treatment Methods and Costs
Compliance approaches for both the baseline and the post-regulatory scenarios
are based on a host of site-specific factors, all of which could not be taken into
consideration in this analysis. Given the available information, treatment technologies
were assigned for each site (or particular volume) in the database, for both baseline
and post-regulatory scenarios, based on three factors:
The types of hazardous constituents in the contaminated soil or
sediment;
Their maximum concentration; and
The volume to be remediated.
This approach to projecting soil and sediment treatment methods was originally
developed to support the analysis of the proposed hazardous waste identification rule
for contaminated media (HWIR-Media). See the "Economic Assessment" of the
proposed HWIR-Media rule.3 The approach has been adapted to analyze the impact of
the Phase IV rule on contaminated soil and sediment. Although the approach, as
originally developed, projects both in-situ and ex-situ treatment, the LDRs including the
Phase IV standards apply to soil and sediment treated ex-situ only. Thus, while the
modeling described here covers both in-situ and ex-situ treatment, the projected Phase
IV incremental costs and cost savings reflect only changes in ex-situ treatment.
The Agency, nevertheless, recognizes that changes in the LDRs also create
incentives for shifts between in-situ and ex-situ management. For example, less
stringent soil treatment standards may prompt remediation decision makers at some
sites to use ex-situ instead of in-situ soil treatment technologies. These shifts could
occur, despite the generally higher cost of ex-situ versus in-situ treatment, because the
LDR-compliant ex-situ treatment methods may be less costly under the relaxed LDRs
then under the baseline. In these situations, treatment costs will be higher under the
new soil treatment standards than under the baseline because the remediation decision
maker found the advantages of ex-situ treatment (e.g., greater effectiveness, more
protective management of the residuals, and a permanent remedy that avoids the
potential long-term costs of an inadequate remedy) exceeded the disadvantages of
higher costs. EPA expects that facility managers will use the more expensive ex-situ
option only if they believe that the long-term financial benefits of more protective
treatment will exceed the additional short-term expense. In any case, such shifts may
not occur frequently and EPA has not quantified the additional short-term cost or long-
term benefits associated with the more expensive treatment methods.
3 U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response, "Economic Assessment
the Proposed Hazardous Waste Identification Rule for Contaminated Media," April 1,1996.
Page 2-4 Chapter 2: Methodology
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The approach for assigning treatment methods was reviewed by EPA and
industry remediation experts to ensure that it was reasonable and appropriate for this
analysis. There are many limitations associated with assigning treatment technologies
using just a few parameters and without considering other site-specific parameters that
might influence the selection of treatment technologies (e.g., distance to nearest
residence or drinking water source). Nevertheless, as is discussed further below, the
treatment technologies used in this analysis generally reflect the current and expected
use of the technologies over the next five years and effectively incorporate the use of
technologies approved under RCRA treatability variances.
The predicted treatment technologies for soil and sediment and their estimated
average treatment costs per ton are based on several data sources, including the
following:
Corrective Action RIA Technologies List. Corrective Action
Regulatory Impact Analysis, Office of Solid Waste, U.S. EPA,
March 1994: a comprehensive list of innovative treatments and
treatment costs developed for the corrective action RIA remedy
selection process.
Vendor Information System for Innovative Treatment Technologies
(VISITH. Office of Solid Waste and Emergency Response, U.S.
EPA, EPA 542-R-93-001, April 1996: a database containing
innovative treatments and treatment costs submitted by
developers, manufacturers, and suppliers.
Regulatory Impact Analysis of Phase II Land Disposal Restrictions
Proposed Rule. Office of Solid Waste, U.S. EPA, September 13,
1993.
Five volumes of the eight-volume series of Innovative Site
Remediation Technologies prepared by WASTECH, a multi-
organization cooperative project managed by the American
Academy of Environmental Engineers: Chemical Treatment (Vol. 2,
1994); Soil Washing/Soil Flushing (Vol. 3, 1993);
Stabilization/Solidification (Vol. 4, 1994); Thermal Desorption
(Vol. 6, 1993); and Thermal Destruction (Vol. 7, 1994).
Cleaning Up the Nation's Waste Sites. Market and Technology
Trends. Office of Solid Waste and Emergency Response, U.S.
EPA, EPA 542-R-96-005, April 1997.
Engineering Bulletin: In-Situ Soil Vapor Extraction Treatment.
Office of Emergency and Remedial Response and Office of
Chapter 2: Methodology Page 2-5
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Research and Development, U.S. EPA, EPA 540-2-91-006, May
1991.
Innovative Treatment Technologies Overview and Guide to
Information Sources. Office of Solid Waste and Emergency
Response, U.S. EPA, EPA 540-9-91-002, October 1991.
BCD: An EPA-Patented Process for Detoxifying Chlorinated
Wastes. Office of Research and Development, U.S. EPA, 1991.
r
Handbook on In-Situ Treatment of Hazardous Waste-
Contaminated Soils. Risk Reduction Engineering Laboratory, U.S.
EPA, EPA 540-2-90-002, January 1990.
EPA's Contaminated Sediment Management Strategy, Office of
Water, U.S. EPA, EPA823-R-94-001, August 1994.
Selecting Remediation Technologies for Contaminated Sediment.
Office of Water and Office of Research and Development, U.S.
EPA, EPA 823-B93-001, June 1993.
Classification Methods Compendium, Office of Water, U.S. EPA,
EPA 823-R-92-006, September 1992.
Innovative Treatment Technologies: Annual Status Report.
Application of New Technologies at Hazardous Waste Sites, Office
of Solid Waste and Emergency Response, EPA 542-R-95-008,
September 1995.
As shown in the Exhibit 2-2, EPA assigned hazardous constituents to one of four
constituent treatability groups based upon their amenability to different remediation
technologies:
Volatile organic compounds (VOCs);
Semi-volatile organic compounds (SVOCs);
Aromatic halogenated organic compounds and halogenated
pesticides and herbicides (all labeled AHCs in this document for
simplicity); and
Metals.
Page 2-6 Chapter 2: Methodology
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Exhibit 2-2
List of Hazardous Constituents by Treatability Group
Volatile Organic Compound (VOCs)
1,1,1-Trichloroethane
1,1,2-Trichloro-1,2,2-trifluoroethane
1,1,2-Trichloroethane
1,1,2,2-Tetrachloroethane
1,1,1,2-Tetrachloroethane
1,1-Dichloroethane
1,1-Dichloroethylene
1,2-Dichloroethane
1,2-Dichloropropane
1,3-Dichloropropene
2-Butanone (MEK)
3-Chloropropene
Acetone
Benzene
Bromodichloromethane
Bromomethane
Carbon Disulfide
Carbon Tetrachloride
Chloroform
Chloromethane
Cis-1,2-Dichloroethylene
Cis-1,3-Dichloropropene
Cumene
Cyanide (amenable)
Dibromomethane
Dichlorodifluoromethane
Dichloromethane
Ethyl Benzene
Ethyl Ether
Methyl Isobutyl Ketone
Styrene
Tetrachloroethylene
Toluene
Trans-1,2-dichloroethene
Trans-1,3-dichloropropene
Trichloroethylene
Trichlorofluoromethane
Vinyl Chloride
Xylenes
Semi-Volatile Organic Compounds (SVOCs)
1,2,3-Trichloropropane
1,2-Dibromo-3-chloropropane
1,2-Diphenylhydrazine
1,3-Dinitrobenzene
1,4-Dioxane
2,4-Dimethylphenol
2,4-Dinitrophenol
2,4-Dinitrotoluene
2,4-Toluenediamine
2,6-Dinitrotoluene
2,6-Toluenediamine
2-Chloro-1,3-butadiene
2-Ethoxyethanol
2-Napthylamine
2-Nitropropane
2-sec-Butyl-4,6-dinitrophenol (Dinoseb)
3,3'-Dimethoxybenzidine
3,3'-Dimethylbenzidine
3-Methylcholanthrene
7,12-Dimethylbenz(a)anthracene
Acenaphthene
Acetonitrile
Acetophenone
Acrolein
Acrylamide
Acrylonitrile
Aniline
Benzidine
Benzo(a)pyrene
Benzyl Alcohol
Benzo(a)anthracene
Bis(2-chloroethyl)ether
Bis(2-chloroisopropyl)ether
Bis(2-ethlyhexyl)phthalate
Butanol
Butyl Benzyl Phthalate
Chlorodibromomethane
Chrysene
Cresols
Dibenzo(a,h)anthracene
Diethyl Phthalate
Diethylstilbestrol
Chapter 2: Methodology
Page 2-7
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Exhibit 2-2 (continued)
List of Hazardous Constituents by Trestability Group
Semi-Volatile Organic Compounds (SVOCs) (continued)
Dimethoate Methyl Parathion
Dimethyl Phthalate m-Cresol
Diphenylamine Naphthalene
Disulfoton Nitrobenzene
Di-n-butyl Phthalate N-Nitrosodimethylamine
Di-n-octyl Phthalate N-Nitrosodiphenylamine
Epichlorohydrin N-Nitroso-di-n-propylamine
Ethyl Acetate N-Nitrosomethylethylamine
Ethyl Methacrylate N-Nitrosopiperidine
Ethyl Methanesulfonate N-Nitrosopyrrolidine
Ethylene Dibromide N-Nitroso-diethylamine
Ethylene Thiourea N-Nitroso-di-n-butylamine
Famphur Octamethyl Pyrophosphoramide
Fluoranthene o-Cresol
Fluorene o-Toluidine
Formaldehyde Parathion
Formic Acid Phenol
Furan Phenylenediamine
Hexachlorocyclohexane Phorate
Hexachlorocyclopentadiene Phthalic Anhydride
Hexachloroethane Pyrene
Hexachloro-1,3-butadiene Pyridine
Indeno (1,2,3-cd) pyrene p-Chloroaniline
Isobutyl Alcohol p-Cresol
Isophorone p-Toluidine
Maleic Anhydride Safrole
Methacrylonitrile sym-Trinitrobenzene
Methanol Tetraethyl Dithiopyrophosphate
Methoxychlor Tribromomethane
Methyl Methacrylate Tris (2,3-dibromopropyl) phosphate
Aromatic Halogenated Compounds (AHCs) and Halogenated Pesticides and Herbicides
1,2,4,5-Tetrachlorobenzene 2378 HpCDFurans
1,2,4-Trichlorobenzene 2378 HxCDDioxins
12378PeCDFuran 2378 HxCDFurans
2,3,4,6-Tetrachlorophenol 2378 PeCDDioxins
2,4,5-Trichlorophenol 2378 TCDDioxin
2,4,5-Trichlorophenoxyacetic acid 2378 TCDFuran
2,4,6-Trichlorophenol 2-Chlorophenol
2,4-Dichlorophenol 3,3'-Dichlorobenzidine
2,4-Dichlorophenoxyacetic acid Aldrin
23478 PeCDFuran alpha-HCH
2378 HpCDDioxins Aramite
Page 2-8 Chapter 2: Methodology
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Exhibit 2-2 (continued)
List of Hazardous Constituents by Treatability Group
Aromatic Halogenated Compounds (AHCs) and Halogenated Pesticides and Herbicides
(continued)
Benzotrichloride Heptachlor epoxide (a,b,g isomers)
Benzo(b)fluoranthene Hexachlorobenzene
Benzyl Chloride Hexachlorophene
beta-HCH Kepone
Chlordane Octachlorodibenzodioxin (OCDD)
Chlorobenzene Octachlorodibenzofuran (OCDF)
Chlorobenzilate o-Dichlorobenzene
ODD Pentachlorobenzene
DDE Pentachloronitrobenzene (PCNB)
DDT Pentachlorophenol
Diallate Polychlorinated Biphenyls (PCBs)
Dieldrin Pronamide
Endosulfan p-Dichlorobenzene
Endrin Silvex (2,4,5-TP)
gamma-HCH (Lindane) Strychnine and salts
Heptachlor Toxaphene
Metals
Antimony Mercury
Arsenic Molybdenum
Barium Nickel
Beryllium Selenium
Cadmium Silver
Chromium Thallium
Copper Vanadium
Lead Zinc
Source: Cleaning Up the Nation's Waste Sites: Markets and Technology Trends, U.S. EPA, EPA-542-R-
92-012, April 1993, Exhibit A-2. This EPA document relied on U.S. EPA, Test Methods for
Evaluating Solid Waste, Volume 1A: Laboratory Manual, Physical/Chemical Methods, Third
Edition, November 1987.
Chapter 2: Methodology Page 2-9
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To better identify specific treatment technologies, contaminated soil and
sediment volumes were also classified into four groups by high or low volume (HV or
LV) and high or low concentration (HC or LC). The volume cutoff for both the baseline
and the post-Phase IV analysis is 20,000 tons for each treatability group except the
four treatability groups that contain AHCs and two or three additional contaminant
groups (VOCs, SVOCs, and/or metals). For the three treatability groups with AHCs
and two additional contaminants, the volume cutoff is 50,000 tons. For the treatability
group with AHCs and all three other contaminants, the volume cutoff is 65,000 tons.
Contaminated soil and sediment volumes of less than these 20,000, 50,000, and
65,000 ton thresholds are classified as low volume. Larger volumes are classified as
high volume.
Treatment methods vary with soil and sediment volume because economies of
scale make some technologies (e.g., vacuum extraction) more economical at large
volumes. Conversely, cost of other technologies (e.g., incineration) may become
prohibitively expensive for large volumes. The cutoff volumes of 20,000, 50,000, and
65,000 tons (and the high and low concentration cutoffs) were set both to reflect these
economies and so that the baseline projections would reflect the expected choice of
treatment methods in the absence of Phase IV new soil treatment standards. Because
incineration is used more often to treat soils and sediments contaminated with AHCs
and the other contaminant types than it is used for other treatability groups, the cutoff
volume was increased to reflect these differences in management.
In the baseline analysis, 100 times the UTS was chosen as the dividing point for
high and low concentration of organic constituents. Treatment-driving constituents
present in contaminated soil and sediment at concentrations less than 100 times UTS
were defined as low concentration; while treatment-driving constituents present at
concentrations at or greater than 100 times the UTS were defined as high
concentration. (The treatment-driving constituent is the constituent in each constituent
group with the highest ratio of its concentration to its UTS value.) The 100 times UTS
breakpoint was chosen to reflect the expected choice of management methods in the
absence of Phase IV new soil treatment standards. A technology-based criteria, like
UTS, is an appropriate basis for defining low and high concentrations, because these
definitions determine the treatment technology selected in the model. Later sections of
this methodology discuss how and why these baseline concentration cutoffs were
redefined for the post-regulatory analysis.
The concentration of metal constituents was not taken into account in assigning
treatment technologies because the concentration generally is not a significant
determinant in selecting treatment remedies for metals. For this analysis,
immobilization is the only treatment method for metals, as described below. The
Agency does, however, recognize that soil and sediment contaminated with very high
concentrations of metals may be managed through high-temperature metal recovery.
This modeling limitation does not significantly affect the analysis. Only relatively small
Page 2-10 Chapter 2: Methodology
-------
volumes of media are treated in this manner. In addition, the changes in the LDRs
under Phase IV are not likely to affect the selection of this technology.
The remainder of this section describes, in general terms, the treatment
technologies assigned for each treatability group. Because these assignments reflect
other factors besides the LDR treatment standards, including site-specific cleanup
goals, the assigned technologies (e.g., incineration) may be more than sufficient to
satisfy solely the LDRs.
2.2.1 Treatment Methods for Metals
Immobilization is currently the only technology that is widely used to treat
metals. The technology can be used to treat all metal constituents except for
selenium.4 Thus, immobilization is used in this analysis as the treatment technology for
all soils and sediments containing metals.
2.2.2 Treatment Methods for VOCs
Vacuum extraction is currently the preferred technology for both halogenated
and nonchlorinated VOCs. Bioremediation and thermal desorption also are used to
treat VOCs at some sites. Bioremediation is lower in unit cost than vacuum extraction
and thermal desorption, but is effective only for biodegradable compounds and can
take longer to achieve reductions than vacuum extraction. Therefore, this analysis
assumes both vacuum extraction and bioremediation will be used to treat VOCs.
2.2.3 Treatment Methods for SVOCs
Bioremediation and thermal desorption are the most frequently selected
innovative technologies for CERCLA remedial action sites with SVOCs. Considering
the increasing use of bioremediation, its ability to destroy contaminants, and its low unit
cost, this technology is expected to be the preferred technology for low-concentration
SVOC wastes. For high-concentration SVOCs, other technologies such as incineration
and thermal desorption are more effective at reducing constituent concentrations.
These technologies are expected to be the choices for high-concentration, low-volume
SVOCs. Although these technologies are not necessary to meet the LDRs for soil
under Phase IV (e.g., to meet the 90 percent reduction standard), their use was
projected because of the importance of site specific risk factors (e.g., need for
reductions greater than 90 percent). Because of higher unit costs for thermal
desorption and incineration, bioremediation is expected to remain the preferred
technology for high-concentration, high-volume SVOC wastes.
' Because there is no method currently available for treating selenium-bearing wastes effectively,
facilities typically obtain a treatability variance for such wastes.
Chapter 2: Methodology Page 2-11
-------
EPA's analysis of treatment technology trends indicates that the use of
incineration is declining and generally limited low-volume wastes. Thermal desorption,
effective at achieving reductions of SVOCs at high concentrations, is gaining in use at
sites treating a range of SVOCs at the same time that incineration is declining. To
reflect recent treatment trends for high concentration, low-volume SVOC wastes, the
predicted technologies for this treatment group were assumed to be 75 percent
incineration and 25 percent thermal desorption.
2.2.4 Treatment Methods for AHCs
Bioremediation is predicted to be the preferred technology for low-concentration
AHC wastes because of its ability to destroy organic contaminants at a low cost.
Bioremediation, however, may be inhibited by high concentration AHCs. For high
concentration AHCs, incineration or thermal desorption is more effective at achieving
reductions. Yet, as discussed above, the use of incineration for large waste volumes is
cost-prohibitive. Soil washing followed by dechlorination has been used effectively to
treat AHCs at a number of sites with a lower unit cost than thermal desorption. Thus,
these methods were assigned as the preferred technology for high-volume, high-
concentration AHCs. Based on available CERCLA data, high-concentration, low-
volume AHCs were assigned treatment technologies in the same manner as SVOCs.
Although use of incineration and thermal desorption may not be necessary to meet the
Phase IV soil treatment standards (e.g., 90 percent reduction), use of these
technologies is projected because of the importance of site-specific risk factors.
2.2.5 Treatment Methods for Mixed Constituent Treatability Groups
Treatment assignments for soil and sediments with multiple types of constituents
were developed by assuming that the treatment-driving organic constituent within a
treatment group would determine the technologies used to treat the contaminated
media. In addition, all media contaminated with metals as well as organics were
assigned to include immobilization. Whether immobilization is in-situ or ex-situ
depends on whether the organics treatment technology is in- or ex-situ. Thus, the
treatment trains described in exhibits on the following pages were developed to
address multiple treatment-driving constituent waste streams.
2.2.6 Estimating Treatment Costs
EPA estimated per ton costs for the soil and sediment treatment methods by
consulting numerous data sources. Where appropriate, costs for excavation,
treatment, and disposal of residuals were included in the estimates.5 Exhibit 2-3
presents these unit costs, the specific source for the estimate, and any specific
assumptions used in developing the cost.
Excavation and residual disposal costs were factored only into ex-situ treatments.
Page 2-12 Chapter 2: Methodology
-------
Exhibit 2-3
Soil and Sediment Treatment Costs Per Ton
Treatment Method
Bioremediation
(in-situ)
Bioremediation
(ex-situ)
Dechlorination
Immobilization
(in-situ)
Immobilization
(ex-situ)
Incineration
Cost/Ton
(1997$)
$67
$76
$193
$54
$164
$1,375
Sources
Vendor Information System for Innovati
Treatment Technoloaies (VISim. Offk
of Solid Waste and Emergency Respor
U.S. EPA, EPA 542-R-93-001 , 1996: a
database containing innovative
treatments and treatment costs submitJ
by developers, manufacturers, and
suppliers.
VISITT.
Economic Assessment of the Procosec
Hazardous Waste Identification Rule fo
Contaminated Media. Reaulatorv Anal\
Branch, Communications, Analysis anc
Budget Division, Office of Solid Waste
and Emergency Response, U.S. EPA, >
1996.
Reaulatorv Impact Analysis: Applicatioi
of Phase IV Land Disposal Restrictions
to Newly Identified Mineral Processina
Wastes. Office of Solid Waste, U.S. EP
January 1998.
Reaulatorv Impact Analysis: ADDlicatior
of Phase IV Land Disposal Restrictions
to Newly Identified Mineral Processina
Wastes. Office of Solid Waste, U.S. EP
January 1998.
Economic Assessment of the Proposes
Hazardous Waste Identification Rule fo
Contaminated Media.
Comments
/Average cost of 31 sites in
database.
se,
ed
Average cost of 39 sites in
database.
Assumes 90% of the waste
are treated and disposed o
snn site and 10% of the was
are treated and disposed o
off site.
\pril
_
V,
\,
Assumes 90% of the waste
are treated and disposed o
on site and 10% of the was
treated are disposed of off
site.
!S
;s
Chapter 2: Methodology
Page 2-13
-------
Exhibit 2-3 (continued)
Soil and Sediment Treatment Costs per Ton
Treatment Method
Incineration and
Immobilization of the
Ash
Soil Washing
Thermal Desorption
Vacuum Extraction
Cost/Ton
(1997$)
$1,382
$119
$110
$150
Sources
Economic Assessment of the Proposet
Hazardous Waste Identification Rule fo
Contaminated Media.
VISITT.
VISITT.
Contaminated Soil Treatment
Technoloaies- Analysis of Treatabilitv
Data. Prepared by ICF Inc. under EPA
Contract 68-W2-008, Work Assignmen
Task 4 for Office of Solid Waste, U.S.
EPA, April 1997.
Innovative Treatment Technoloaies:
Annual Status Report (Seventh Ed.)
Applications of New Technoloaies at
Hazardous Waste Sites. U.S. EPA. EP/
542-R-95-008, Sept 1995.
Field Demonstration of Thermal
Desorption of Manufactured Gas Plant
Soils. Prepared bv Barr Enaineerina Cc
for EPRI, EPRI TR-1 05927, Sept 1996
Economic Assessment of the Prooosec
Hazardous Waste Identification Rule fo
Contaminated Media.
Comments
Assumes 90% of the waste
[are treated and disposed o1
on site and 10% of the was
are treated and disposed 01
off site.
Average cost of 19 sites in
database.
Assumes 90% of the waste
are treated and disposed o'
on site and 10% of the was
are treated and disposed o
off site.
Average cost for 52 sites in
database.
Assumes 90% of the waste
are treated and disposed o
S82jte and 10% of the was
are treated and disposed o
off site.
;s
;s
5S
Page 2-14
Chapter 2: Methodology
-------
Exhibits 2-4 and 2-5 show how baseline and post-regulatory soil and sediment
volumes were assigned to treatment methods for soil and sediment, respectively.
Volumes were assigned a treatment method based on the hazardous constituents
present, constituent concentrations, and contaminated soil and sediment volumes.
(The difference between baseline and post-regulatory treatment methods depends, in
part, on difference in the cutoffs between high and low concentrations.) These exhibits
also present the estimated cost per ton in 1997 dollars of each combination of
treatment methods.
Sediments were assumed to be managed in the same manner as soil with two
exceptions. The cost estimates were increased by $15 per ton to reflect the additional
cost of dredging before other management costs are incurred; and in-situ treatment
methods were not considered.
The selection of treatment methods identified in Exhibits 2-4 and 2-5 were
reviewed by EPA and industry remediation experts to ensure that they were reasonable
and appropriate for this analysis. There are many limitations associated with assigning
treatment technologies using just a few parameters and without considering site-
specific parameters that might influence the selection of treatment technologies (e.g.,
distance to nearest residence or drinking water source). Nevertheless, the treatment
technologies used in this analysis generally reflect the current and expected use of the
technologies over the next few years and effectively incorporate the use of
technologies approved under RCRA treatability variances. The assignment of
technologies was verified in part by using the frequencies of treatment selection used
by the Superfund remedial action program,6 the frequency of treatment selection used
in the draft March 1993 Corrective Action Regulatory Impact Analysis methodology,
available published data on the volume of remedial waste managed by selected
technologies in 1994,7 articles on use of incineration to treat remediation waste,8 and
knowledge of trends towards increasing use of innovative technologies.9
6 See, e.g., Innovative Treatment Technologies: Annual Report. Application of New Treatment Technologies at
Hazardous Waste Sites. Office of Solid Waste and Emergency Response, EPA 540-R-95-008, September 1995.
7 E.g., John Hanke, "Hazardous Waste Incineration 1995," El Digest, May 1995, and Christine L. Seidel,
"Mobile Thermal Treatment 1994," El Digest. December 1994.
8 E.g., John Hanke, "Hazardous Waste Incineration 1996," El Digest. May 1996.
9 Cleaning Up the Nation's Waste Sites: Markets and Technology Trends. Office of Solid Waste and Emergency
Response, EPA 542-R-96-005, April 1997.
Chapter 2: Methodology Page 2-15
-------
Exhibit 2-4
Soil Treatment Technologies and Costs
Constituent
Type
VOCs
SVOCs
AHCs
Metals
VOCs and SVOC
VOCs and AHCs
VOCs and Metals
Concentration/
Volume
LC/LV
LC/HV, HC/LV, HC/HV
LC/LV, LC/HV, HC/HV
HC/LV
LC/LV, LC/HV
HC/HV
HC/LV
LC/LV
LC/HV, HC/LV, HC/HV
sLC/LV, LC/HV, HC/HV
HC/LV
LC/LV
LC/HV, HC/HV
HC/LV
LC/LV
LC/HV, HC/LV, HC/HV
Treatment"
50% In-Situ Bioremediation & 50% Vac
Extraction
Vacuum Extraction
50% In-Situ Bioremediation and 50% E
Situ Bioremediation
75% Incineration & 25% Thermal
Desorption
50% In-Situ Bioremediation & 50% Ex-
Situ Bioremediation
Soil Wash & Dechlorination
75% Incineration & 25% Thermal
Desorption
In-Situ Immobilization
Ex-Situ Immobilization
50% In-Situ Bioremediation & 50% Va(
Extraction
75% Incineration & 25% Thermal
Desorption
50% In-Situ Bioremediation & 50% Ex-
Situ Bioremediation
Vacuum Extraction
75% Incineration & 25% Thermal
Desorption
50% In-Situ Bioremediation & In-Situ
Immobilization, 50% Ex-Situ
Bioremediation & Ex-Situ Immobilizatk
Vacuum Extraction & In-Situ
Immobilization
Cost/Ton
(1997$)
uum $111
$150
x- $72
$1,058
$72
$312
$1,058
$54
$164
uum $111
$1,058
$72
$150
$1,058
$181
n
$204
Page 2-16
Chapter 2: Methodology
-------
Exhibit 2-4 (continued)
Soil Treatment Technologies and Costs
Constituent
Type
VOCs, SVOCs, a
Metals
VOCs, SVOCs ai
AHC's
VOCs, AHCs, an
Metals
VOCs, SVOCs,
AHCs, and Metal
SVOCs and AHC
Concentration/
Volume
tC/LV
LC/HV, HC/HV
HC/LV
dLC/LV
LC/HV, HC/HV
HC/LV
ILC/LV
LC/HV
HC/HV
HC/LV
LC/LV
>
LC/HV
HC/HV
HC/LV
LC/LV
LC/HV
HC/HV
HC/LV
Treatment"
50% In-Situ Bioremediation & In-Situ
Immobilization, 50% Ex-Situ
Bioremediation & Ex-Situ Immobilizatic
Vacuum Extraction & In-Situ
Immobilization
75% Incineration & Immobilization of
Ash & 25% Thermal Desorption
50% In-Situ Bioremediation & 50% Ex-
Situ Bioremediation
Vacuum Extraction
75% Incineration & 25% Thermal
Desorption
50% In-Situ Bioremediation & In-Situ
Immobilization, 50% Ex-Situ
Bioremediation & Ex-Situ Immobilizatic
Vacuum Extraction & In-Situ
Immobilization
Soil Wash, Dechlorination, and Ex-Situ
Immobilization
75% Incineration & Immobilization of
the Ash & 25% Thermal Desorption
50% In-Situ Bioremediation & In-Situ
Immobilization, 50% Ex-Situ
Bioremediation & Ex-Situ Immobilizatic
Vacuum Extraction & In-Situ
Immobilization
Soil Wash, Dechlorination, & Ex-Situ
Immobilization
75% Incineration & Immobilization of
Ash & 25% Thermal Desorption
50% In-Situ Bioremediation, 50% Ex-S
Bioremediation
Soil Wash & Ex-Situ Bioremediation
Soil Wash & Dechlorination
75% Incineration & 25% Thermal
Cost/Ton
(1997$)
$181
n
$204
$1 ,064
$150
$150
$1,058
$181
n
$204
$476
$1 ,064
$181
n
$204
$476
$1,064
tu $72
$195
$312
$1,058
Chapter 2: Methodology
Page 2-17
-------
Exhibit 2-4 (continued)
Soil Treatment Technologies and Costs
Constituent
Type
SVOCs and Mete
SVOCs, AHCs, a
Metals
AHCs and Metak
Concentration/
Volume
IkC/LV, LC/HV
HC/LV, HC/HV
ibC/LV
LC/HV
HC/HV
HC/LV
LC/LV
HC/LV
LC/HV, HC/HV
Treatment"
50% In-Situ Bioremediation & In-Situ
Immobilization, 50% Ex-Situ
Bioremediation & Ex-Situ Immobilizatic
Soil Wash, Ex-Situ Bioremediation, &
Ex-Situ Immobilization
50% In-Situ Bioremediation & In-Situ
Immobilization, 50% Ex-Situ
Bioremediation & Ex-Situ Immobilizatic
Soil Wash, Ex-Situ Bioremediation, &
Ex-Situ Immobilization
Soil Wash, Dechlorination, & Ex-Situ
Immobilization
75% Incineration & Immobilization of
Ash & 25% Thermal Desorption
50% In-Situ Bioremediation & In-Situ
Immobilization, 50% Ex-Situ
Bioremediation & Ex-Situ Immobilizatic
75% Incineration & Immobilization of
Ash & 25% Thermal Desorption
Soil Wash, Dechlorination, & In-Situ
Immobilization
Cost/Ton
(1997$)
$181
n
$359
$181
n
$359
$476
$1,064
$181
n
$1,064
$421
* The assignment of treatment technologies reflects the LDR standards and other factors,
including potential site-specific risk-based cleanup goals.
Page 2-18
Chapter 2: Methodology
-------
Exhibit 2-5
Sediment Treatment Technologies and Costs
Constituent
Type
VOCs
SVOCs
AHCs
Metals
VOCs and SVO
VOCs and AHC:
VOCs and Meta
VOCs, SVOCs,
and Metals
Concentration/
Volume
LC/LV, LC/HV, HC/LV, HC/h
LC/LV, LC/HV, HC/HV
HC/LV
LC/LV, LC/HV
HC/HV
HC/LV
LC/LV, LC/HV, HC/LV, HC/H
3sC/LV, LC/HV, HC/HV
HC/LV
i LC/LV, LC/HV, HC/HV
HC/LV
sLC/LV, LC/HV, HC/LV, HC/h
LC/LV
LC/HV, HC/HV
HC/LV
Treatment"
^x-Situ Bioremediation
Ex-Situ Bioremediation
75% Incineration & 25% Thermal
Desorption
Ex-Srtu Bioremediation
Soil Wash & Dechlorination
75% Incineration & 25% Thermal
Desorption
jEx-Situ Immobilization
Ex-Situ Bioremediation
75% Incineration & 25% Thermal
Desorption
Ex-Situ Bioremediation
75% Incineration & 25% Thermal
Desorption
^Cx-Situ Bioremediation and Ex-Situ
Immobilization
Ex-Situ Bioremediation and Ex-Situ
Immobilization
Soil Wash, Ex-Situ Bioremediation,
and Ex-Situ Immobilization
75% Incineration & Immobilization o
Ash & 25% Thermal Desorption
Cost/Ton
(1997$)
$91
$91
$1 ,074
$91
$327
$1,074
$181
$91
$1 ,074
$91
$1,074
$255
$255
$374
$1,079
Chapter 2: Methodology
Page 2-19
-------
Exhibit 2-5 (continued)
Sediment Treatment Technologies and Costs
Constituent
Type
VOCs, SVOCs
and AHCs
VOCs, AHCs,
and Metals
VOCs, SVOCs,
AHCs, and Mets
SVOCs and AH<
Concentration/
Volume
LC/LV, LC/HV
HC/HV
HC/LV
LC/LV, LC/HV
HC/HV
HC/LV
LC/LV, LC/HV
Is
HC/HV
HC/LV
feC/LV
LC/HV
HC/HV
HC/LV
Treatment"
Ex-Situ Bioremediation
Soil Wash and Ex-Situ Bioremediatic
75% Incineration & 25% Thermal
Desorption
Ex-Situ Bioremediation and Ex-Situ
Immobilization
Soil Wash, Dechlorination, and Ex-
Situ Immobilization
75% Incineration & Immobilization ol
the Ash & 25% Thermal Desorption
Ex-Situ Bioremediation and Ex-Situ
Immobilization
Soil Wash, Dechlorination, & Ex-Situ
Immobilization
75% Incineration & Immobilization o
the Ash & 25% Thermal Desorption
Ex-Situ Bioremediation
Soil Wash & Ex-Situ Bioremediation
Soil Wash & Dechlorination
75% Incineration & 25% Thermal
Desorption
Cost/Ton
(1997$)
$91
n $210
$1 ,074
$255
$491
$1,079
$255
$491
$1,079
$91
$210
$327
$1,074
Page 2-20
Chapter 2: Methodology
-------
Exhibit 2-5 (continued)
Sediment Treatment Technologies and Costs
Constituent
Type
SVOCs and
Metals
SVOCs, AHCs,
and Metals
AHCs and Meta
Concentration/
Volume
LC/LV, LC/HV
HC/LV, HC/HV
LC/LV
LC/HV
HC/HV
HC/LV
sLC/LV
HC/LV
LC/HV, HC/HV
Treatment"
Ex-S'rtu Bioremediation and Ex-Situ
Immobilization
Soil Wash, Ex-Situ Bioremediation, &
Ex-Situ Immobilization
Ex-Situ Bioremediation and Ex-Situ
Immobilization
Soil Wash, Ex-Situ Bioremediation, &
Ex-Situ Immobilization
Soil Wash, Dechlorination, & Ex-Situ
Immobilization
75% Incineration & Immobilization ol
the Ash & 25% Thermal Desorption
Ex-Situ Bioremediation and Ex-Situ
Immobilization
75% Incineration & Immobilization 01
the Ash & 25% Thermal Desorption
Soil Wash, Dechlorination, & Ex-Situ
Immobilization
Cost/Ton
(1997$)
$255
$376
$255
$376
$491
$1,079
$255
$1 ,079
$491
* The assignment of treatment technologies reflects the LDR standards and other factors,
including potential site-specific risk-based cleanup goals.
Chapter 2: Methodology
Page 2-21
-------
2.3 Partitioning the Database
As previously stated, the soil and sediment database represents an extensive
compilation of available data on contaminated soil and sediment volumes, constituents,
and constituent concentrations for CERCLA remedial actions and RCRA corrective
actions. From this extensive characterization of soil and sediment generation, the
impacts of the Phase IV rule on soils contaminated with TC metals, mineral processing
waste, and previously regulated wastes can be determined. As the different
components of the Phase IV rulemaking will affect soil and sediments contaminated
with different wastes, EPA partitioned the database into three groups. (The Agency did
not address media exhibiting the characteristic of ignitability, corrosivity, or reactivity
because these media volumes are small and are assumed to be not significantly
affected by Phase IV.)
Soils and sediments exhibiting the TC fororganics. As required by the Phase II
LDR rulemaking, all wastes exhibiting the TC for organics currently must treat all UHCs
to UTS levels. The new soil standards will relax the soil treatment standards to 10
times UTS or 90 percent reduction. Thus, facilities generating TC organic soils
(including those soils that are TC for both organics and metals) may recognize a cost
savings because they can use less expensive innovative technologies to treat soils to
the less stringent LDR levels. Thus, all soils exhibiting the TC for organics or the TC
for both organics and metals are analyzed for potential cost savings under the new soil
standards.
Soils and sediments exhibiting the TC for metals only. Prior to this rule, LDR
treatment standards for soils exhibiting the TC for metals were set at TC levels; all
UHCs were not required to be treated. The Phase IV rule revises the UTS levels for
12 metal constituents and requires that TC metal soils be treated for all UHCs to the
new soil standards. Soils exhibiting the TC for metals only, can, and often do, contain
organic UHCs at less than TC levels. Facilities generating soils exhibiting the TC for
metals only that contain organic UHC's may see additional costs from any treatment
required for these organic UHCs.
So/7s and sediments contaminated with listed waste. Database volumes that do .
not exhibit the TC for organics or metals may be contaminated with listed wastes and
therefore hazardous or may be determined not to contain hazardous waste. If
considered hazardous and subject to RCRA Subtitle C standards if excavated, these
volumes may be subject to either increased or decreased treatment costs. Treatment
costs for some volumes of soil and sediment may increase because Phase IV requires
treatment of all hazardous constituents reasonably expected to be present, rather than
just the hazardous constituents identified in 40 CFR 268.40 for the listed wastes
contained in the soil. Treatment costs may decline for other volumes of soil because
the new soil treatment standards relax required treatment levels from UTS to 10 times
UTS or 90 percent reduction.
Page 2-22 Chapter 2: Methodology
-------
Available data did not indicate whether soil and sediment in the database were
hazardous because they exhibited the TC or were contaminated with listed waste.
Thus, EPA identified soil and sediment in the database exhibiting the TC by calculating
soil and sediment concentrations equivalent to the TC regulatory levels found in Table
1 of 40 CFR 261.24. To calculate the equivalent soil concentrations from the TC
levels, EPA estimated constituent leaching behavior using the Organic Leaching Mode!
(OLM) for organics and constituent-specific CSOIL:CTCLP ratio for metal.
If all of the constituents with TC levels have calculated maximum concentrations
below those levels, then the entire site is assumed to be contaminated with listed
waste. For sites that have at least one constituent calculated above TC levels, only a
portion of the soil may be considered to exhibit the TC. The proportion of the
contaminated soil above TC levels was estimated by the following functional
relationship, which was derived from a regression analysis of detailed data available for
a limited number of CERCLA remedial action sites:10
Y = X3; where:
Y = Proportion of site above the TC level; and
X = (MC - TC)/MC; where:
MC = Maximum constituent concentration detected in the site, and
TC = TC level.
Analysis of SURFER11 data yielded the Y = X3 relationship based on an
evaluation of both the theoretical fit and the statistical fit of different functional
relationships. The theoretical relationship between X and Y should produce an
intercept value of zero and a dependent variable coefficient of 1. The intercept should
be zero to ensure that Y equals zero when X equals zero (i.e., there is no area above
the TC level when the maximum contaminant level equals the TC level). The
dependent variable coefficient should equal 1 to ensure that Y approaches 1 as X
approaches 1.
To test for the appropriate statistical relationship, EPA ran the regression
analyses of Y as a function of X2 and X3. The X3 relationship was the strongest
statistical fit, yielding an R2 of 80 percent for 42 observations generated by SURFER
analysis of a limited number of sites with detailed ROD data. EPA also generated
10 See "Revised Approach to Estimating Proportions of CERCLA and RCRA Corrective Action Remediation Wast
Above and Below Bright Line Levels," memorandum to Lyn Luben, Office of Solid Waste, U.S. Environmental Protection
Agency by ICF Incorporated, July 29, 1994.
11 The SURFER software is a modeling tool that uses a statistical modeling process called the "minimum curve
method" to draw constituent concentration contour lines for remediation sites.
Chapter 2: Methodology Page 2-23
-------
1,248 observations by using the Monte Carlo simulation of site data based on empirical
site characteristic data from DOE's Superfund Reauthorization (SURE) model. The
statistical fit (R2) demonstrated by the SURE model was 85 percent. These data
indicate that the functional relationship derived from limited SURFER data is consistent
with the field data used in the SURE model preprocessor.
By definition, the value of X is greater than zero and less than one for any
maximum constituent concentration above the TC level, and the value of X approaches
1 when the maximum concentration is very high relative to the TC level for that
constituent. Therefore, the functional relationship used to estimate the value of Y (Y =
X3) ensures that Y is also a fraction that approaches 1 when the maximum constituent
concentration is very high relative to the TC level for that constituent. This relationship
is consistent with the expectation that a substantial proportion of contaminated soil will
be above TC levels at those sites where maximum concentrations are substantially
higher than TC levels. Conversely, the values of X and Y approach zero when the
maximum constituent concentration is just slightly higher than the TC level for that
constituent. This relationship is consistent with the expectation that a relatively small
proportion of contaminated soils will be above TC levels at sites where maximum
concentrations just barely exceed TC levels.
If there are multiple constituents in a treatability group, the constituent with the
highest X value is used to determine the volume managed in that treatability group. In
addition, the X and Y values defined above must be calculated for each treatability
group associated with each volume. For example, if the constituents in a certain
volume include both metals and VOCs, then X and Y values must be calculated for the
maximum constituent concentrations in each of these treatability groups. If these
calculations indicate that 70 percent of the soil volume is above the TC level for VOCs
and 20 percent is above the TC level for metals, then this analysis assumes that 20
percent of the site soil volume incurs treatment costs for soil contaminated with both
metals and VOCs, and 50 percent of the site soil volume incurs treatment costs for soils
contaminated with VOCs only. In effect, this methodology recognizes that different
treatment technologies may be used for different portions of a site that have different
combinations of contaminants above TC levels.
The methodology for allocating volumes to be above or below TC levels was
performed separately for CERCLA remedial action soil, RCRA corrective action soil,
and CERCLA remedial action sediment. The results are presented below in Exhibit 2-
6. They show that CERCLA soil tend to have higher levels of TC metals and lower
levels of TC organics than RCRA soils.
Page 2-24 Chapter 2: Methodology
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Exhibit 2-6
Partitioned Database Volumes
(Includes Volumes Managed In-Situ and Ex-Situ)
Type of Media
CERCLA Soil
RCRA Soil
CERCLA
Sediment
Portion of Database Volumes
TC Metals Only
20%
7%
22%
TC Organics
12%
18%
N/A
Non-TC (Listed)
68%
75%
N/A
2.4 Estimating Amount of Soil and Sediment Subject to LDRs Annually
Hazardous soil and sediment are subject to the LDRs and may be affected by
the Phase IV rulemaking if these media are managed ex-situ and are not in a corrective
action management unit (CAMU) or an area of contamination (AOC). To estimate the
impacts of the final rule on the treatment of such media, EPA estimated the annual
generation of contaminated soil subject to the LDRs from the following remediation
programs:
Remedial actions under CERCLA;
Corrective actions under RCRA;
Closure of hazardous waste management units at RCRA treatment,
storage, and disposal facilities (TSDFs);
State superfund cleanup programs; and
Voluntary cleanup programs.
In addition, the Agency estimated the generation of contaminated sediment from
CERCLA remedial actions and RCRA corrective actions. The other cleanup programs
are not expected to generate large volumes of contaminated sediments.12
12 In addition, the HWIR-Media proposed rule would exclude hazardous sediment dredged from navigable water
and managed under the Clean Water Act or Marine Protection, Research, and Sanctuaries Act from application of RCR
Subtitle C standards.
Chapter 2: Methodology
Page 2-25
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To estimate the incremental costs and cost savings of the rule, the Agency
projected the volumes of soil and sediment to be treated annually over the five-year
period following implementation of the final rulemaking, that is, the first five-year period
when the remediation decisions reflect the new rules. The Agency used this medium-
term estimate because of the uncertainties associated with longer-term projections and
the pace with which the rule will be fully implemented and reflected in the use of
different treatment methods. Longer-term projections are subject to substantial
uncertainties, such as government remediation and enforcement budgets, potential
changes in the CERCLA statute and budget, and the demand for restoring
economically valuable contaminated properties (e.g., Brownfields).
The pace of implementation is subject to two major types of uncertainty. First,
the pace at which states adopt and implement the less stringent alternative soil
standards is uncertain. States are not required to adopt less stringent RCRA rules,
such as the new soil treatment standards. Second, the pace at which remedy selection
decisions reflect the new rules and are implemented is also uncertain. Because of the
time period between remedy selection and remedy constructions, treatment
technologies selected after the Phase IV rules are finalized may not result in soil
treatment for substantially more than a year. Remedies selected but not implemented
before the rules become effective may not be revised to take advantage of any less
stringent standards. Some remedies, however, may need to be revised where the
Phase IV rules are more stringent.
The Agency used a wide variety of data sources to develop the annual
generation estimates. Exhibit 2-7 presents the estimated annual volumes of
contaminated soil and sediment treated at CERCLA remedial actions, RCRA Subtitle C
corrective actions, RCRA Subtitle C closures at disposal facilities, RCRA Subtitle C
closures at treatment and storage facilities, state Superfund cleanups, and voluntary
cleanups. These data sources are described below.
Considerably more data were available to characterize the CERCLA remedial
action and RCRA corrective action programs than were available to characterize the
other remediation programs. For CERCLA, the Agency used the following data sources
for the data elements identified in Exhibit 2-7.
Page 2-26 Chapter 2: Methodology
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Exhibit 2-7
Contaminated Soil and Sediment Treated Annually
Remediation Category
Site
Equivalents/
Year
Remediated
Site Equivalents/
Year with
Soil/Sediment
Treatment
Average
Tons
Treated/
Site
Annual Tons
Treated
Annual Tons
Treated Outside of
CAMUs and AOCsb
Soil
CERCLA Remedial Action Soil
RCRA Corrective Action Soil
RCRA Closures Soil (Landfills)
RCRA Closures Soil
(Storage & Treatment Facilities)
State Superfund Soil
Voluntary Cleanup Soil
Soil TOTALS
Sediment
CERCLA Sediment
RCRA Corrective Action
Sediment TOTALS
70
115
40
240
510
830
1,805
70
130
200
30
111
40
199
464
614
1,458
15
8
13
28,000
7,400
3,900
1,100
280
830
NA
9,700
9,700
NA
840,000"
820,000a
160,000
220,000
130,000
510,000
2,680,000
;
150,000
80,000
230,000
240,000a
230,000a
40,000
60,000
130,000
510,000
1,210,000
60,000
30,000
90,000
3 Includes volumes treated in-situ, which are not subject to LDRs and therefore are not projected to be affected by Phase IV.
b CAMU and AOC adjustment: 72 percent of the volume of CERCLA remedial action, RCRA corrective action, and RCRA closure soil is assumed to be
treated in CAMUs or AOCs.
-------
Site Equivalents Remediated per Year. The estimated number of
CERCLA remedial actions equivalents13 per year was based on two
data sources. First, EPA Superfund Remedial Program Managers,
who oversee CERCLA remedial actions, projected that an average
of 109 remedial actions will have completed construction per year
over the period from 1996 to 2000.14 Second, the EPA report
entitled "Clean Up the Nation's Waste Sites: Market and
Technology Trends" (hereinafter cited "Market and Technology
Trends") noted that in recent years, the Agency has added an
average of 30 new remedial action sites to the National Priority List
(NPL).15 If this rate continues and remedial action occurs at all
these NPL sites, then an average of 30 sites per year will be
remediated. For this analysis, the two numbers were averaged
((109+30)72 = 70).
Site Equivalents with Soil or Sediment Treatment. This figure was
estimated by multiplying the number of site equivalents cleaned up
per year by (1) the percentage of these sites with soil or sediment
contamination (72 and 22 percent, respectively) and (2) the
percent of such sites with treatment remedies, instead of source
control remedies such as capping, institutional controls,
monitoring, or relocation (60 and 100 percent, respectively). All
these percentages were taken from "Market and Technology
Trends" data.16 While these two sets of figures were for non-
federal remedial action sites between 1982 and 1995 and 1992 to
1995, respectively, EPA believes that these data are reasonable to
use for federal and non-federal sites remediated in the five years
after the Phase IV rule is implemented.
13 The term site "equivalent" recognizes that media may be treated at a site over a period of several years.
For example, if six sites of equal size were cleaned up over a two-year period, the pace of cleanup would be three
site equivalents per year.
14 See Letter from Elliot P. Laws to Congressman John D. Dingell, January 28,1994 (OSWER Directive 9200.2-
21).
151996 Edition, U.S. EPA, Office of Solid Waste and Emergency Response, #EPA 542-R-96-005. April 1997.
15 The estimate that all Superfund sites with contaminated sediment are treated ex-situ reflects an
assumption that such sediment is seldom managed in-situ, but rather is excavated and treated.
Page 2-28 Chapter 2: Methodology
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Average Volume Treated per Site. The estimates of 28,000 tons of
soil and 9,700 tons of sediment per site were taken from the
remedial action sites in the soil and sediment database described
earlier. Although the volume of soil includes soil managed both in-
situ and ex-situ, the LDRs do not apply to soil managed in-situ and
such volumes are not attributed any costs or cost savings in this
analysis (see the methodology for a further discussion of this
issue).
Portion of Annual Volume Managed Outside of CAMUs and
/AOCs.17 Based on the preceding estimates, 840,000 tons of
contaminated soil will be treated annually at CERCLA remedial
action sites. Using previous analysis of the CAMU rulemaking,
EPA estimates that 72 percent of this soil will be managed in
CAMUs or AOCs and therefore will not be subject to the LDRs or
affected by Phase IV.18 Thus, about 240,000 tons per year of
CERCLA remedial action soil are potentially affected by the Phase
IV rule. The entire volume of contaminated sediment, 60,000
tons/year, is assumed to be treated outside of CAMUs and AOCs.
The RCRA corrective action estimates are based primarily on several analyses
of corrective action rules by the Office of Solid Waste, as described below.
Sites Remediated per Year. The estimated number of RCRA
corrective actions per year was based on EPA analysis of the
RCRA corrective action program.19 Specifically, the Agency
projected that 2,289 facilities would be subject to corrective action
over a 20-year period or 115 facilities per year.
Portion of Sites with Soil or Sediment Treatment. Based on the
RCRA corrective analysis, 97 percent or 2,227 of the 2,289 RCRA
corrective action facilities (or 111 facilities per year over 20 years)
17 This methodology assumes full implementation of the CAMU rule as projected by the CAMU RIA. While availabl
data indicate more limited adoption of CAMUs, EPA expects the use of CAMUs to increase, particularly if a lawsuit
regarding the rule is decided in favor of the rulemaking.
18 RCRA Subtitle C regulations are generally considered as applicable or relevant and appropriate
requirements (ARARs) at CERCLA remedial actions. As a result, CERCLA remedial actions are generally conducted in
compliance with RCRA Subtitle C standards and may take advantage of the flexibility offered by the CAMU rule.
EPA's analysis of the CAMU rule estimated that 72 percent of RCRA corrective action soil would be managed in CAMUs
See, Regulatory Impact Analysis for the Final Rulemaking on Corrective Action Units and Temporary Units, U.S. EPA,
Office of Solid Waste, January 11,1993. This analysis uses the same percentage for CERCLA remedial actions since
media in both programs also can be managed in CAMUs or AOCs.
19 "Draft Regulatory Impact Analysis for the Final Rulemaking on Corrective Action for Solid Waste Management
Units: Proposed Methodology for Analysis," U.S. EPA, Office of Solid Waste, March 1993.
Chapter 2: Methodology Page 2-29
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would be subject to source control or soil treatment. Data on
sediments were not directly available from the corrective action
analysis. Instead, EPA used data from the "Market and
Technology Trends" indicating that historically, only 6 percent of
corrective actions have sediment contamination.
/Average Volume Treated per Site. The estimate of 7,400 tons of
soil treated per site was taken from EPA's RCRA corrective action
analysis. For sediments, EPA used the estimate for CERCLA
remedial action, 9,700 tons per site, in the absence of RCRA
sediment data.
Portion of Annual Volume Managed Outside ofCAMUs. This step
used the same estimates that were applied to CERCLA remedial
action sites. Seventy-two percent of contaminated soil is estimated
to be treated outside of CAMUs and AOCs, which are assumed not
to be used for contaminated sediment.
Fewer data were available for RCRA closures, state superfund cleanups, and
voluntary cleanups than for CERCLA remedial actions and RCRA corrective actions.
For these programs, EPA used the decision science technique of expert judgment
elicitation to estimate key quantities when reliable data were not otherwise available.
This structured process included the following steps:
Select the parameters to be estimated by the experts;
Identify experts for possible interviews;
Prepare background information and supply to the selected experts;
Conduct the elicitation interviews; and
Compile the results and apply statistical analysis.
Rather than asking experts to directly estimate the total volume of soil and
sediment managed annually, EPA elicited estimates for more fundamental parameters
that affect total volumes, such as the remedial time frame, the projected number of sites
with remediations over the time frame, the percent of sites with contaminated soil or
sediment, and the average volume of soil or sediment managed at individual sites.
Attempting to directly estimate total annual soil and sediment volumes can be less
accurate because it requires simultaneous consideration all factors that might affect
total volumes. Through direct experience or knowledge, experts are more likely to
provide accurate estimates of more basic variables. EPA therefore used these
fundamental parameters to generate total volume estimates.
EPA identified persons from government, industry, and academia who
possessed expertise in CERCLA, RCRA, state, and voluntary cleanup activities. EPA
also developed a set of initial estimates of the parameters identified above for each
type of remediation program, including RCRA landfill closures, RCRA treatment and
9-30
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storage facility closures, state superfund cleanups, and voluntary cleanups.
Preliminary estimates of the parameters affecting annual soil and sediment volumes
were sent to experts with an accompanying letter that provided background information.
The initial estimates were generated using a variety of remediation data sources.
Annual volumes of contaminated soil and sediment were calculated using the
experts' estimates of the remedial time frame, the projected number of sites with
remediations over the time frame, the percent of sites with contaminated soil or
sediment, and the volumes of media generated at individual sites over the remedial
time frame. Because their estimates of these parameters were subject to considerable
uncertainty, EPA used DEMOS modeling software to calculate the annual volume of
soil and sediment as a function of the parameters estimated by the experts. DEMOS is
a decision modeling application that creates an estimate of a desired quantity, such as
the total annual volume of soil for state superfund cleanups, that depends on uncertain
factors. For each remediation program, DEMOS calculated a probability distribution
using the individual expert responses for each of the uncertain input parameters. The
software was then used to generate the probability distribution of the annual volume of
soil and sediment for each remediation category.
In a few cases, EPA subsequently found data sources that were used instead of
the expert judgments. For example, the estimated number of state superfund cleanups
per year (510) is based on data from "An Analysis of State Superfund Programs: 50-
state Study, 1995 Update," Environmental Law Institute, December 1995. In addition,
EPA assumed that soil and sediment at state and voluntary cleanups would be treated
off-site to avoid the need for RCRA treatment permits and the associated requirements
for facility-wide corrective action. As a result, none of these volumes are assumed to
be managed in AOCs or CAMUs.
2.5 Estimating Baseline Soil and Sediment Treatment Costs
In order to model the incremental costs and cost savings of the Phase IV rule,
EPA estimated the cost of treating soils and sediments under current requirements. To
estimate these baseline costs, the Agency first applied the treatment methods and
costs explained in Sections 2.2 to the CERCLA remedial action and RCRA corrective
action sites in the soil and sediment database. This step calculated a per ton cost of
treating soil and sediment under each program.
Second, the Agency used these per ton costs to estimate the annual treatment
cost for soil and sediment potentially affected by Phase IV under the various
remediation programs. In this extrapolation from the database sample to the national
universe:
The average CERCLA remedial action ex-situ treatment cost per
ton was multiplied by the estimated annual amount of soil ex-situ
treated in CERCLA remedial actions, state superfund cleanups,
Chapter 2: Methodology Page 2-31
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and voluntary cleanups. In other words, soil contamination at state
Superfund and voluntary cleanup sites are assumed to have similar
types and concentrations of contaminants as CERCLA remediation
action sites. State Superfund and voluntary sites, however, have
considerably smaller average volumes per site.
The average RCRA corrective action ex-situ treatment cost per ton
was multiplied by the estimated annual amount of soil treated ex-
situ in RCRA corrective actions and RCRA closures. Thus, the
nature of the contamination at RCRA closures and corrective
actions is assumed to be similar.
The average RCRA corrective action treatment cost per ton also
was multiplied by the annual amount of sediment treated in RCRA
corrective actions.
Sediment contaminant data for RCRA corrective actions were
unavailable. Thus, EPA assumed that such contamination was
more similar to soil contamination for RCRA corrective action sites
than sediment contamination for CERCLA remedial action sites.
2.6 New Soil Treatment Standards
As explained earlier, the Phase IV new soil treatment standards will make the
treatment standards for contaminated soils less stringent. EPA expects that ex-situ
treatment of soil outside of CAMUs or AOCs will shift in three ways:
To less effective and less expensive treatment;
To no treatment; and
To more effective and more expensive treatment.
Each of these impacts on the cost of treating affected contaminated soils is explained
below.
Less Effective and Expensive Treatment
The new soil standards will be less stringent than the current standards for soils
with hazardous constituents, which require treatment to UTS levels. Under Phase IV,
constituents must be treated only to 10 times UTS or to achieve 90 percent reduction in
their concentrations, which ever concentration is less stringent. As a result, some
remediation decision makers will select cheaper, but somewhat less effective,
innovative ex-situ technologies instead of established and more~expensive, but also
more effective, ex-situ technologies (particularly incineration). This substitution, and
the resulting cost savings, will occur only if the less expensive technology can meet any
site-specific risk-based cleanup standards as well as the new soil treatment standards.
Paqe 2-32 Chapter 2: Methodology
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No Treatment
Soils containing only hazardous constituents with concentrations below 10 times
UTS that also meet risk based standards will not be required to be treated under the
new soil standards. Where such soils are currently required to be treated to UTS
levels, treatment costs may be completely avoided under Phase IV, if the soils meet the
conditions explained above. Soils with constituent concentrations above risk-based
levels will still require treatment to meet site-specific cleanup goals.
More Effective and Expensive Treatment
For soils that do not exhibit a characteristic but are hazardous because they
contain listed waste, the new soil treatment standards may be more stringent than the
current requirements.20 Under Phase IV, non-TC hazardous soils must be treated for
all UHCs, not just for the constituents for which the wastes were listed (i.e., the primary
constituents), as specified in 40 CFR 268.40. However, EPA does not believe that the
additional costs for treating these soils will be significant because:
Non-listed constituents will typically not be present in non-TC soils
containing listed waste at levels exceeding 10 times UTS; or
Non-listed constituents may already be treated to new soil
standard levels because of their site-specific risks or incidentally
as a result of intentional treatment for the listed constituents.
20 Soil containing listed waste and exhibiting the TC for organics is not subject to more stringent standards
because it currently must be treated for all UHCs by virtue of being TC for organics.
Chapter 2: Methodology Page 2-33
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2.6.1 Methodology for Estimating Cost Savings or Cost
This section describes the methodology for estimating the three types of impacts
of the new soil treatment standards on two categories of hazardous soil: soil that
exhibits the TC for organics and soil that does not exhibit the TC, but is assumed to be
hazardous because it contains listed waste. The impact of the new standards on soils
that are TC only for metals is addressed in Section 2.8.
Less Effective and Expensive Treatment
Soil that is hazardous because it exhibits the TC for organic constituents is most
likely to be affected by the new soil standards. Currently, all UHCs in these soils must
treated to UTS levels. Under the new soil standards, the TC organic constituents and
all UHCs will be subject to less stringent standards of 10 times UTS or 90 percent
reduction of the original constituent concentration.
EPA believes that the primary result of the less stringent treatment standards will
be that some soils currently incinerated will be treated by less expensive ex-situ
treatment methods (e.g., soil washing, dechlorination, and bioremediation). The
Agency believes that this will occur because innovative treatment technologies will
provide a more appropriate and less costly way to meet the new soil standards.
To estimate the cost savings for TC organic soils under the new soil treatment
standards, EPA performed the following four steps:
First, EPA estimated the volume of TC organic soil that will switch from higher-
cost ex-situ treatment technologies, such as incineration or thermal desorption, under
the baseline to less expensive ex-situ treatment technologies, such as ex-situ
bioremediation, under the new soil standards. The Agency estimated this volume by
changing two of the baseline assumptions. First, EPA assumed that hazardous
constituents with concentrations below the lesser of 10 times UTS or the TC level will
not be treated under Phase IV, except incidentally as the result of treating other
constituents above such levels. As described below, all TC organic soil volumes will
still be treated, but they may be treated for fewer types of constituents. The Agency
used the lesser of 10 times UTS or the TC level because 10 times UTS is above TC
levels only for a few constituents (primarily metals) and, in such cases, facilities are
likely to treat soils that are above the TC level but meet LDR standards to TC levels so
that the treated soil can be disposed of outside the Subtitle C system.
The second assumption the Agency changed was the dividing point for high and
low concentration, which was increased from 100 to 200 times UTS for organic
constituents. By increasing the cutoff, additional volumes of soil are considered as low
concentration and projected to be treated with less effective, but also less expensive,
innovative technologies that can meet the new 10 times UTS or 90 percent reduction
standard. EPA expects that the affected volumes will tend to have the lowest levels of
Paqe 2-34 Chapter 2: Methodology
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contamination of all soils that are treated by the more effective technologies (that is, the
lowest concentration segment of the soil in the high concentration category). The shift
from 100 to 200 times UTS captures these volumes.
Changing these two assumptions shifts some CERCLA soil from incineration or
thermal desorption to less expensive ex-situ treatment technologies. Specifically,
about half of CERCLA TC soils (but only 10 percent of all CERCLA soils) managed ex-
situ are projected to be treated with incineration or thermal desorption in the baseline.
Fourteen percent of these soils, or about seven percent of all CERCLA soils managed
ex-situ, are projected to shift to less expensive treatment under Phase IV. Negligible
quantities of CERCLA soil shifted from other higher cost to lower cost ex-situ treatment
methods.
For RCRA, negligible amounts of soil shifted treatment categories. Only 18
percent of RCRA soil exhibits the TC for organics and less than one percent of that soil
was projected to be incinerated or thermally desorpted. As a result, the remaining
steps in the methodology were not applied to RCRA soil. In addition, the following
steps focus on changes from incineration/thermal desorption to less expensive
treatments because the results of step one did not identify any other significant shifts
among treatment methods, even though such shifts are feasible.
Second, the Agency calculated the per ton cost savings for the volumes that
shifted from incineration or thermal desorption in the baseline to less expensive ex-situ
treatments under Phase IV. The average baseline treatment cost for such soils was
$1,064/ton and the average post-regulatory treatment cost was $464/ton, for an
average incremental per-ton savings of $600 ($1,064-$464).
Third, EPA applied this per-ton cost savings to TC organic soils treated at
CERCLA, state superfund, and voluntary cleanup volumes that are anticipated to
switch from incineration/thermal desorption to other ex-situ treatment methods as a
result of this rule. Specifically, the $600/ton savings was applied to TC organic soils
that are expected to be managed ex-situ and outside a CAMU or AOC, times the
portion of these volumes that are incinerated or thermally desorpted in the baseline (52
percent), times the portion of the incinerated or thermally desorpted volumes that shift
to other treatment methods (14 percent).
Soil that is hazardous solely because it contains listed waste (or non-TC
hazardous soil) may also incur a similar cost savings due to soils switching to less
expensive treatment methods. Currently, the listed constituents in such soils must be
treated to UTS levels. Under Phase IV, these soils will be subject to the relaxed new
soil treatment standards. Any other hazardous constituents in the soil (i.e., UHCs),
however, will be subject to the LDRs for the first time under Phase IV. Because the
available constituent data for CERCLA remedial actions and RCRA corrective actions
do not distinguish between listed and non-listed constituents, it is impossible to
determine which constituents are listed constituents. For this reason, this analysis
Chapter 2: Methodology Page 2-35
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estimates the savings by assuming that the portion of soil incinerated or thermally
desorpted in the baseline that shifts to less expensive treatment under Phase IV (14
percent), and the average cost savings per ton ($600/ton) are the same for soil
exhibiting the TC for organics and soil contaminated with listed wastes.
No Treatment
As described earlier, some contaminated soil that is treated in the baseline may
not require treatment under the new soil treatment standards. This result will not
typically occur for TC organic soil, because, as noted above, facilities are expected to
treat their TC soils so that they will be non-hazardous and will not have to be disposed
of in a Subtitle C facility. A shift to no treatment, however, may occur for soil that is
hazardous only because it contains listed waste.
In order to dispose of soils containing listed waste that meets risk-based levels,
facilities will have to obtain a contained out determination. EPA believes that obtaining
this determination will be a fairly straightforward exercise, since much of the work
associated with obtaining the determination will already have been performed during
site characterization. To the extent that obtaining the contained out determination will
reduce the cost savings of non-TC soils, this analysis overestimates the savings.
EPA believes that the following methodology likely underestimates the savings
associated with soils requiring no treatment because soil contaminated at low levels
that are treated in-situ in the baseline could be excavated and disposed of off-site in a
Subtitle D facility if they meet 10 times UTS levels and Subtitle D disposal is less
expensive than in-situ treatment (which it generally is). However, many state superfund
or voluntary cleanup programs have a preference for treatment that may minimize such
shifts. In any case, this analysis does not estimate the savings associated with shifts
from in-situ to ex-situ treatment.
To quantify the cost savings for these soils, EPA performed a number of steps.
First, the Agency estimated the volume of non-TC CERCLA and RCRA soil in the
database by isolating sites that have non-TC volumes and subtracting the volume of
TC soil from the total site volume. The resulting total CERCLA non-TC volume in the
database was estimated to be 5,938,000 tons, or 68 percent of the total CERCLA
volume, and the total RCRA non-TC volume in the database was estimated to be
23,417,000 tons, or 75 percent of the total RCRA volume.
Second, the Agency estimated the volume of non-TC CERCLA and RCRA soil
in the database contaminated with constituents present at below concentrations of 10
times UTS. To accomplish this, the Agency:
Determined, for each site with non-TC soil, which constituent had
the highest constituent concentration, relative to UTS levels.
Page 2-36 Chapter 2: Methodology
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Estimated, for each site with non-TC soil, the volume of soil
contaminated with the most highly concentrated constituent
(determined in the previous step) at higher than 10 times UTS
levels, using the methodology described in Section 2.3 and
substituting 10 times UTS for UTS levels.
Estimated the volume of soil at each site below 10 times UTS
levels by subtracting the volume of soil calculated in the previous
step from the total site volume. This step assumes that soils
contaminated with the most highly concentrated constituent at the
site at levels above 10 times UTS will include all soils
contaminated with other constituents above 10 times UTS.21 The
total volumes of non-TC CERCLA and RCRA soil in the database
with constituent concentrations below 10 times UTS were 780,000
and 1,749,000 tons, respectively.
Third, EPA estimated the volume of database soils below 10 times UTS that are
expected to be treated ex-situ by assigning treatment methods using the methodology
described in Section 2.2. Ex-situ volumes with concentrations below 10 times UTS
were estimated to be 408,000 tons for CERCLA and 1,004,000 tons for RCRA.
Fourth, EPA estimated the percentage of all non-TC CERCLA and RCRA soils
treated ex-situ that fell out of RCRA Subtitle C regulation by dividing the database
volume of non-TC soils treated ex-situ with constituent concentrations below 10 times
UTS (calculated in the previous step) by the total volume of non-TC soil treated ex-situ.
The total volume of non-TC soil treated ex-situ was estimated by applying the overall
baseline percentage of CERCLA and RCRA soils treated ex-situ (58 and 48 percent for
CERCLA and RCRA soils, respectively) to non-TC soils.22 The resulting ex-situ, non-
TC volumes were 3,444,000 tons for CERCLA (5,938,000 X.58) and 11,240,000 tons
for RCRA (23,417,000 X.48).
The formula used for estimating the percentage of non-TC RCRA and CERCLA
soils treated ex-situ that fall out of Subtitle C regulation was as follows:
21 See Section 2.3 for more details regarding how soil volumes were estimated.
22 The percentages of CERCLA and RCRA soils treated ex-situ in the baseline (58 percent for CERCLA and 48
percent for RCRA) were used here because the model was unable to directly project how non-TC soils will be treated.
Chapter 2: Methodology Page 2-37
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Non-TC soil volume treated ex-situ < 10 times UTS
Non-TC soil volume treated ex-situ
For CERCLA, the percentage was estimated to be 12 percent (408,000 / 3,444,000).
For RCRA, the percentage was estimated to be 9 percent (1,004,000 /11,240,000).
Fifth, EPA estimated the per ton cost savings for the soils expected to fall out of
RCRA Subtitle C regulation. To accomplish this, the Agency subtracted the estimated
cost of Subtitle D disposal ($55) from the estimated per ton cost of treating soils with
concentrations below 10 times UTS under the baseline ($285 for CERCLA and $169 for
RCRA23). The cost of Subtotal D disposal was estimated to be approximately $55 per
ton. This estimate includes costs of excavation, waste transport, and landfill tipping
fees. Soil excavation costs were assumed to be approximately $16 per ton. Waste
transport costs were estimated to average $5 per ton, based on analysis indicating that
Subtitle D transport costs are approximately four to seven dollars per ton for every 100
miles of truck or rail hauling.24 A $34 per ton landfill tipping fee estimate reflects a
recent nationwide survey estimate.25 The resulting per ton cost savings for CERCLA
and RCRA were $230 and $114 per ton, respectively.
Sixth, EPA applied the percentages calculated in step four and the per-ton cost
savings calculated in step five to non-TC soils generated by various remediation
programs. Specifically, the 12 percent and $230 figures were applied to non-TC soils
generated at CERCLA, state superfund, and voluntary cleanup sites and the nine
percent and the $114 figures were applied to RCRA corrective action and closure sites.
More Effective and Expensive Treatment
The third type of impact of the new soil treatment standards, more effective and
expensive treatment, applies only to soil that is hazardous because it contains listed
waste. This impact will arise only if the following conditions are met:
The soil contains hazardous constituents that are not listed
constituents at levels exceeding 10 times UTS;
Any current treatment methods do not meet the new soil standards
for such constituents; and
23 The costs of treating soils with concentrations less than 10 times UTS under the baseline was calculated
using the soil and sediment model. Because all volumes expected to fall out of regulation are expected to only have
low-concentrations of constituents present, all volumes were assigned the treatment cost appropriate for low-
concentration soils.
24 Konheim and Ketchum, "Exporting Waste: A Report on Locations, Quantities, and Costs of Out-of-State
Disposal of New York City Commercial Waste," April 1991.
25 "The State of Garbage," Biocycle, April 1995, page 2-38.
Page 2-38 Chapter 2: Methodology
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After being treated using current methods, the soil is considered
hazardous under the contained-in policy.
The Agency believes that these conditions will seldom arise for the following
reasons:
Contaminated soil, particularly at the older, more expensive to
remediate CERCLA remedial action and RCRA corrective action
sites, will seldom be found to contain listed wastes. This soil will
often be classified as hazardous because it exhibits a
characteristic, rather than because it contains listed waste. Soil at
these sites may seldom be classified as listed because of the
difficulty of identifying specific listed wastes disposed of many
years ago.
The hazardous constituents most likely to be present in such soil
and to present a risk to human health and the environment are the
listed constituents, which already must be treated to UTS levels.
Where soil contains non-listed UHCs, the required treatment of the
listed UHCs or other constituents posing site-specific risks may
bring the non-listed constituent concentrations to levels that are
below 10 times UTS or contained-in levels.
EPA did not estimate the increased costs resulting from applying the LDRs to
non-listed UHCs in soil that does not exhibit a characteristic. For the reasons
described above, these incremental costs are likely to be small. In addition, estimating
such costs would be difficult because the available constituent data for CERCLA
remedial action and RCRA corrective action sites does not distinguish between listed
and non-listed constituents. As a result, it is impossible to determine which
constituents are listed constituents.
2.7 Media Contaminated With Mineral Processing Wastes
Media contaminated with newly regulated mineral processing wastes, which
include wastes from the processing of ores and minerals, must be treated on-site to TQ
levels before disposal into a Subtitle D unit.26 These media are not required to comply
with LDR requirements. The Phase IV rule, however, will require media contaminated
with newly regulated mineral processing wastes to comply with existing LDR standards
for characteristic wastes. Thus, soils containing these wastes must meet the new soil
standards and other media must meet the UTS for all UHCs.
26 54 FR 36592 and 55 FR 2322 required that facilities dispose of such materials in a Subtitle C unit or treat
it to TC levels before disposal into a Subtitle D unit.
Chapter 2: Methodology Page 2-39
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As explained in Section 3.1.1 of "Application of Phase IV Land Disposal
Restrictions to Newly Identified Mineral Processing Wastes: Regulatory Impact
Analysis,"27 EPA assumes that mineral processing facilities are in full compliance with
RCRA Subtitle C requirements (outside of the LDRs) for managing waste materials.
Thus, this analysis assumes that all media contaminated with mineral processing
wastes that are excavated under RCRA or CERCLA are currently being treated to
remove the characteristic, stabilized, and disposed of in a Subtitle D unit.
In order to project the effects of the Phase IV rulemaking on the cost of
remediating hazardous media contaminated with mineral processing wastes, EPA:
Reviewed documentation on the composition of newly identified
mineral processing wastes to determine what constituents are
found in the wastes;
Based on the constituents in the media, determined the treatment
methods most likely to be used to meet the new standards; and
Estimated potential cost changes resulting from new treatment
methods or additional activities required to meet the new
standards.
2.7.1 Composition of Media Contaminated With Newly Identified Mineral
Processing Wastes
The vast majority of media contaminated with mineral processing wastes are
exempted from Subtitle C and the LDR requirements by the Bevill Amendment of the
Solid Waste Disposal Act Amendments (PL 96-4S2).28 Of the media that are
contaminated with newly identified mineral processing wastes which were brought into
the Subtitle C universe in 1990, EPA expects only a small portion to be excavated and
thus fall under the LDR requirements. Thus, the only media contaminated with newly
identified mineral processing wastes that are potentially affected by the Phase IV rule
are those that are excavated and managed outside of a CAMU or AOC. EPA expects
that these media contain primarily metal constituents, including cadmium, mercury,
arsenic, selenium, chromium, lead, silver, and barium.29
2.7.2 Treatment of Media Contaminated with Mineral Processing Wastes
27 See footnote 1.
28 The Bevill Amendment exempts soils generated from the extraction and beneficiation of mineral ores.
29 See Section 3.1.1, Waste Management Assumptions of Office of Solid Waste, U.S. Environmental Protection
Agency
Page 2-40 Chaoter 2: Methodoloav
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As explained above, EPA assumes that facilities currently treat affected soil and
sediment media to TC levels using solidification/stabilization, the most widely used
method for treating wastes with metal constituents. EPA anticipates that
solidification/stabilization will continue to be the primary method used to treat soil and
sediment contaminated with newly identified mineral processing wastes over the period
covered by this analysis because it has been found to be effective in treating all metals
to UTS levels, except for selenium. Because of the difficulties of treating high
concentrations of selenium, media containing this constituent are recognized as likely
candidates for a treatment variance under Section 268.44.
The solidification/stabilization process involves mixing the media with reagents
that reduce the mobility of its contaminants and/or physically bind or enclose them
within a stabilized mass (such as cement). Depending on the chemical and physical
properties of the waste, either or both of these methods may be used to prevent
leaching. The amount of reagent used depends on the concentration of the waste and
the target treatment level.
The results of the final methodology step, examining the potential cost changes
resulting from new treatment methods, are discussed in Section 3.3.
2.8 Soil and Sediment that Exhibit the TC for Metals Only
Excavated soils and sediments that are hazardous only because they exhibit the
TC for metals are currently treated to site-specific risk-based levels or to the TC level to
avoid the requirement to manage treated media in a Subtitle C facility. Under Phase
IV, all hazardous constituents or UHCs in TC metals soil must be treated to reduce
concentrations either to 10 times UTS or UHCs or by 90 percent, and hazardous
constituents in sediments must be treated to UTS. Where existing treatments do not
meet these new standards, treatment costs may increase.30 To estimate these
incremental costs, EPA performed four analytical steps. The first step explains why
any increased treatment costs for the metal constituents in the volumes that are TC for
metals only are likely to be low and therefore are not modeled. The other three steps
model the increased costs for organic constituents in these volumes.
First, EPA considered the effect of the requirements on metal constituents in
soils and sediments that are TC only for metals. Currently, TC metal constituents are .
treated to below the TC levels or risk-based levels, whichever is lower, while non-TC
metal constituents are treated to risk-based levels. Under the Phase IV rule, all metal
constituents must be treated to the LDR levels. In many instances, however, these
constituents will be treated to applicable site-specific risk-based levels or their
characteristic levels, if more stringent.
30 With more stringent and potentially expensive treatment standards, some media may be managed in-situ,
rather than ex-situ, to avoid the LDRs. This shift in management was not captured as an impact of the Phase IV
rule.
Chapter 2: Methodology Page 2-41
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For all metal constituents with TC levels except silver, EPA expects the rule to
have no effect on soil treatment. As shown in Exhibit 2-8, the new soil treatment
standards are less stringent than TC levels for all constituents, except silver. EPA
assumes that soils with these constituents will continue to be treated to the lower of
site-specific risk levels or TC levels and therefore treatment methods and costs will not
change.31
Exhibit 2-8
Comparison of TC and LDR Levels for TC Metal Constituents
(mg/l)
Constituent
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
TC Level
5.0
100
1.0
5.0
5.0
0.2
1.0
5.0
Soil Treatment
Standard:
10 x UTS
14
210
1.1
6.0
7.5
0.25
57
1.4
Sediment
Treatment
Standard: UTS
1.4
21
0.11
0.60
0.75
0.025
5.7
0.14
Under Phase IV, silver and non-TC constituents in soil must be treated to 10
times UTS (which is just below the TC level for silver) or to achieve 90 percent
reduction. Also, metal constituents in sediment must be treated to UTS levels; the new
soil standards do not apply to sediment. EPA believes that the incremental costs for
meeting these new standards should be negligible for the following reasons:
Virtually all soils and sediments that are hazardous because they
exhibit the TC only for metals are currently stabilized or solidified.
Current stabilization/solidification methods, designed to meet TC
levels, often will meet the new standards for all metal constituents.
31 The Agency recognizes that, in situations where excavated untreated contaminated soils meet the new soil
standards but not TC levels, it may be less expensive to dispose of the soils directly in a Subtitle C landfill
without treatment (as LDR standards are met). EPA believes that these situations are unlikely to occur frequently
and thus did not estimate these potential savings.
Page 2-42
Chapter 2: Methodology
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Where current practices do not satisfy the new standards, the
treatment can be adjusted at a limited cost to meet the standards,
such as by increasing the ratio of reagent to soil.
Second, EPA modeled the application of the new treatment requirements for
organic constituents in the database volumes of soils and sediments that exhibit the TC
for metals only. Currently, EPA believes that these volumes are frequently treated for
their organic constituents, particularly where the organics exceed site-specific risk
levels and the treated soil is disposed of on-site. In addition, high concentrations of
organics may be treated to avoid their interference with the effectiveness of
immobilization. EPA considered two possible changes in treating organics under
Phase IV:
A shift to more extensive and expensive treatment of organics; and
A shift from no treatment to treatment.
To model the shift to a more extensive and expensive treatment, EPA revised
the high-low concentration cutoff for organic constituents from 100 times UTS in the
baseline to 25 times UTS for soil and 15 times UTS for sediment under Phase IV. The
cutoff for sediment is lower because the new soil standards do not apply to sediment.
This high-low concentration cutoff determines when volumes are treated with more
effective and expensive treatment methods, such as incineration. Having a lower "high-
low" concentration cutoff for organics effectively models a shift to more effective
treatment technologies consistent with the more stringent Phase IV requirements. By
reducing the cutoff concentration, additional volumes of soil may be treated with these
technologies and consequently treatment costs will rise.
This type of treatment impact seems realistic. The 10 times UTS or 90 percent
reduction standard for organic UHCs may require more extensive treatment for volumes
of contaminated soil and sediment where:
The site-specific risk-based cleanup level for organics is less
stringent than the Phase IV alternative soil standard; and
The organics treatment technology selected based on any site-
specific risk-based cleanup level does not meet the new alternative
soil standards.
The Agency expects the affected volumes to be those with the highest levels of organic
constituent concentrations that are treated with the less effective technologies (i.e., the
highest concentration segment of the media in the low concentration category). The
shift in the high-low concentration cutoff from 100 times UTS to 25 or 15 times UTS
captures these volumes.
Chapter 2: Methodology Page 2-43
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Changing the concentration cutoff shifted approximately eight percent of the TC
for metals only of CERCLA soil in the database into categories treated with highly
effective treatment methods (e.g., incineration/thermal desorption). A negligible
amount of CERCLA sediment and RCRA soil changed categories.
EPA did not model the potential shift from no treatment to treatment of organics
in soil and sediment that are for TC metals only. In some cases, TC metals media may
not be specifically treated for their organic constituents, if any. This situation may arise
where the concentration of organics is below any site-specific risk-based cleanup
levels. Phase IV will require treatment of such constituents if their concentrations are
greater than 10 times UTS for soil or UTS for sediments. EPA did not model this type
of change for two reasons:
This situation seems unlikely to arise. Where constituent
concentrations are below risk-based levels prior to treatment, the
media are likely to be determined not to contain hazardous waste
even if the concentrations are greater than 10 times UTS.
Moreover, the soil may be eligible for a site-specific variance from
the technology-based new soil treatment standards for soils below
levels that minimize threats to human health and the environment.
Our modeling approach projected treatment for organics if any
organic constituent concentrations were reported in CERCLA
RODs or RCRA corrective action RIA documentation This
approach reflects an assumption that constituent concentrations
generally would not be reported if they did not affect remedy
selection.
Third, using the revised organics concentration cutoff, EPA reassigned
treatment technologies and calculated the changes in the per ton ex-situ treatment
costs.
Performing these first three steps yielded nine CERCLA sites in the database
with increased costs (of the 97 CERCLA database sites generating soils that are TC for'
metals only). The estimated cost increase for CERCLA TC metals only soils managed
ex-situ at these sites was $19 per ton. This figure was calculated by subtracting the
average per ton treatment cost for these CERCLA soils under the baseline from their
average per ton treatment cost under Phase IV.
In contrast, no RCRA soil sites had increased costs because no RCRA soil
exhibiting the TC only for metals had organics with concentrations greater than 25
times UTS. In fact, over 95 percent of the RCRA TC for metals only volume did not
contain any organics. For CERCLA sediments, the average cost per ton increased by
a negligible $0.05 per ton. This effect was caused by the shift to incineration and
-------
thermal desorption of only 13 out of 221,000 tons. Thus, the remaining steps described
were not performed for RCRA soils or CERCLA and RCRA sediments.
Fourth, EPA extrapolated the per ton cost savings from the database sites to the
universe of sites remediated annually. The increased cost per ton for CERCLA
remedial action TC metals only soil, treated ex-situ, outside of a CAMU or AOC was
applied to the annual volumes of such soil generated by CERCLA remedial actions,
state superfund cleanups, and voluntary cleanups. No cost savings were attributed to
RCRA soils and sediments and CERCLA sediments because the model predicted no
increased costs for these media.32
2.9 Contaminated Ground Water and Debris
The following section presents the methodology used to analyze the impacts of
the new LDR standards on the management of contaminated ground water and
contaminated debris. In neither case does the Agency believe that the Phase IV
rulemaking will significantly increase treatment costs.
2.9.1 Contaminated Ground Water
Contaminated ground water is potentially subject to the LDRs. If water pumped
from the ground exhibits a characteristic of hazardous waste or contains listed waste, it
cannot be placed on the land unless it:
Is determined not to contain hazardous waste under the contained-
in policy;
32 Because the database contains no data on RCRA sediments, CERCLA results were extrapolated to the RCRA
universe.
Chapter 2: Methodology Page 2-45
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Has been treated in compliance with the LDRs; or
Is exempt from the LDRs.
The most common method of addressing ground water contamination is
treatment. Alternative remedies include containment of the contamination through
subsurface barriers, such as slurry walls, or controlling or limiting direct exposures,
such as providing alternate water supplies or closing wells. These non-treatment
methods leave the ground water in place and therefore are not affected by the LDRs.
Almost all sites with ground water treatment use pump and treat systems. For
example, 99 percent of non-federal NPL sites with ground water treatment have used
pump and treat systems.33 Ninety-three percent of these sites used such systems only,
while the other six percent also used in-situ treatment methods, such as air sparging,
bioremediation, passive treatment walls, and dual-surface extraction. Only one percent
of the sites used in-situ treatment only.
Following pumping, ground water may be managed in several ways, including:
Treated and discharged in a system subject to a National Pollutant
Discharge Elimination System (NPDES) permit under Section 402
of the Clean Water Act;
Treated in accordance with the pretreatment requirements under
Section 307 of the Clean Water Act prior to discharge into publicly
owned treatment works (POTWs); and
Returned to the aquifer through a variety of infiltration or injection
methods.
Ground water that is hazardous only because it exhibits a characteristic is exempt from
the LDRs if it is managed in either of the first two manners under 40 CFR 268.1(c)(4).
Ground water that is returned to the aquifer also is exempt from the LDRs if it is
reinjected through a Class IV underground injection control (UIC) well. A Class IV UIC
well, by definition, injects hazardous waste into or above a formation that contains
within one-quarter mile an underground source of drinking water. Under RCRA Section
3020, such reinjected ground water is not subject to the LDRs. Specifically, under
Section 3020, contaminated ground water from Superfund remedial actions and RCRA
corrective actions can be disposed of in a Class IV well if it is treated "to substantially
reduce hazardous constituents prior to such injection" and the cleanup "will, upon
33 "Market and Technology Trends," 1996 edition.
-------
completion, be sufficient to protect human health and the environment." EPA has
interpreted this statutory provision to apply instead of the LDR provisions.34
Following pumping and treatment, ground water may be returned to the aquifer
through methods other than reinjection by a Class IV well, such as infiltration in ditches
or pipes laid across a field. Such placement of ground water is potentially subject to
the LDRs. Nevertheless, the Agency believes that these situations are likely to be rare.
Treated ground water is unlikely to be placed on the ground if it
contains hazardous constituents at concentrations exceeding any
site-specific risk levels (e.g., through volatilization of organics or
soil contamination). In situations where the treated water is above
risk-based levels but is returned to the aquifer, an injection well is
likely to be used because it may avoid these risks.
If the treated water does not pose any risks, it may be determined
to not "contain" hazardous waste.
In addition, where the LDRs apply to treated ground water placed on the ground,
current treatment methods may already meet the higher standards imposed by
Phase IV.
While the Agency acknowledges that increased ground water treatment costs
under Phase IV are conceivable, significant cost increases are unlikely and could not
be estimated with readily available data.
2.9.2 Contaminated Debris
Debris contaminated with hazardous waste is subject to RCRA Subtitle C and
the LDRs. Hazardous debris can be treated to comply with the LDRs under one of two
primary standards:
34 OSWER Directive 9234.1-06, December 27, 1989 contains the following guidance: "Although RCRA Section 30
and the LDR provisions at RCRA Section 3004(0, (g), and (m) arguably can address the same activity, RCRA Section
3020 specifically applies to all CERCLA and RCRA ground-water treatment reinjections into Class IV injection
wells. Consistent with traditional principles of statutory construction, RCRA Section 3020which is directly
focused on injections of treated contaminated ground water into Class IV wells during cleanupsshould control for
such injections; a contrary reading would render Section 3020(b) meaningless. Where Congress has provided two
potentially applicable statutory provisions, a choice between them is both necessary and appropriate, and within
the discretion of the expert agency. Accordingly, EPA construes the provisions of RCRA Section 3020 to be
applicable, instead of LDR provisions at RCRA Section 3004(f), (g), and (m), to reinjection of contaminated ground
water into an underground source of drinking water, which are part of CERCLA response action or RCRA corrective
action."
Chapter 2: Methodology Page 2-47
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Treated to meet the standards for the hazardous waste or wastes
contaminating the debris (assuming the debris is not ignitable,
corrosive, or reactive); or
Treated to meet alternative debris treatment standards that allow
particular extraction, destruction, or immobilization technologies
under specified performance and/or design and operating
standards.
35
Debris are generally treated using the second approach
The Phase IV rule does not amend these alternative technology-based treatment
standards. It would affect the application of the new soil standards only for hazardous
debris that contains UHCs that, by virtue of Phase IV:
Become restricted contaminants subject to treatment standards;
and,
Are in constituent classes that would make the current debris
treatment method inadequate to satisfy the new soil standards.
These situations will seldom, if ever, arise for debris contaminated with TC
metals. The only acceptable technologies for metals are immobilization or extraction,
excluding thermal desorption (unless it is used to treat mercury contamination). These
technologies are also acceptable for any organic constituents, with one exception:
dioxin-listed waste cannot be treated using high-temperature metals recovery. If TC
metal debris is contaminated with dioxin-listed waste, it cannot be treated using high-
temperature metals recovery prior to Phase IV or afterwards. Thus, the requirement to
treat organic UHCs in TC metal debris will not change treatment methods or costs.
While the promulgation of LDRs for newly identified mineral processing wastes
may change the management of contaminated debris, the Agency lacks the data to
project the affected volumes or the increased costs. EPA reviewed CERCLA Records .
of Decisions (RODs) and other documentation of mineral processing site cleanups and
could not find adequate data to project this impact of Phase IV. EPA, nevertheless,
expects any such increased costs to be relatively small.
The Phase IV rule, also may affect the management of debris residuals. These
residuals are subject to the waste-specific treatment standards for the waste
contaminating the debris. Thus, these residuals may be subject to additional or
different treatment under Phase IV The Agency also lacks the data to estimate the
35 See, "Cost and Impact Analysis of Land Disposal Restrictions for Newly Listed Wastes and Contaminated
Debris (Phase I LDRs) Final Rule," U.S. EPA, Office of Solid Waste, June 30,1992.
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magnitude of these impacts. EPA, however, expects the increased costs to be
relatively small.
2.10 Major Data and Modeling Limitations
Modeling the impact of the changes in the RCRA land disposal restrictions on
the treatment of contaminated soil and sediment is inherently difficult because
remediation decisions reflect a range of critical factors in addition to the federal RCRA
regulations.
Unlike hazardous process waste, hazardous soil and sediment that
were contaminated prior to the LDRs are not required to be treated
unless the media are excavated. Thus, remediation decision
makers may decide, based on site-specific factors, to cap
contaminated soil or sediment in place without treatment or to treat
it in-situ, avoiding application of the LDRs.
Likewise, based on site-specific factors, soil and sediment may be
managed in AOCs or CAMUs, avoiding the LDRs.
Treatability variances have been issued frequently for hazardous
soil and sediment because of the stringency of the LDRs, which
increases the difficulty of modeling the baseline and complicates
the identification of regulatory effects.
When contaminated soil and sediment are subject to the LDRs,
treatment goals may be more stringent than the LDRs because of
site-specific risk factors (e.g., residential setting, presence of a
drinking water source karst terrain). Thus, the changes in the
LDRs may not change treatment goals and technologies at many
sites.
Furthermore, remediation decisions may vary from state-to-state
based on factors including state risk-based cleanup standards and
remediation resources, particularly for state superfund programs.
In addition to these general concerns, the analysis of the potential soil treatment
cost savings and incremental costs resulting from the Phase IV rule is qualified by
several major data and methodological limitations, which are described below. Many of
these limitations also apply to the limited analysis of the potential incremental sediment
treatment costs.
Chapter 2: Methodology Page 2-49
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Use of Sample of Sites
The contaminated soil and sediment database consists of data from CERCLA
RODs signed in 1989 through 1996 and a stratified representative sample of RCRA
corrective actions.
CERCLA Sites. While remediation decisions at the CERCLA sites in the
database generally will not be affected by the Phase IV rule,36 the nature of the
contamination at these sites should be reasonably representative of the contamination
at CERCLA sites potentially affected by the rule. The severity of risks at newly listed
CERCLA remedial action (or National Priority List) sites may decline over time,
assuming that the highest risk sites are generally listed first. This trend may not
significantly affect the likelihood and magnitude of changes in treatment methods under
Phase IV. All sites must have a minimum Hazard Ranking System score to be listed on
the NPL. In addition, the impact of Phase IV depends largely on the types and
concentrations of hazardous constituents at these sites, which may not change
significantly over time, particularly during the medium term, five-year projection period
of this analysis.
RCRA Corrective Action Sites. Similarly, the sample of RCRA corrective action
sites should be reasonably representative of future corrective action sites. This sample
of sites was initially developed for EPA's analysis of the RCRA corrective action
program in 1990 and 1991 to represent the universe of RCRA corrective actions. It
remains reasonably representative of future RCRA corrective actions because the
universe of corrective action sites that remain to be remediated has not changed
substantially since then. In addition, the original sample, which includes projected
remedies, was recently supplemented with data for additional cleanups from available
RCRA Statements of Basis. These new data reflect actual remediation decisions and
thereby help ensure the representativeness of the expanded sample.
Applying CERCLA and RCRA Corrective Action Data to State Superfund, Voluntary
Cleanup, and RCRA Closure Sites
The methodology applies the average cost per ton savings or incremental costs
for soil treated ex-situ at CERCLA remedial actions to soil generated at state superfund
and voluntary cleanups. State and voluntary cleanup programs generally manage
smaller volumes per site of less contaminated soil than the CERCLA remedial action
program and generally treat soil ex-situ and off-site to avoid the need for RCRA
treatment permits and thereby becoming subject to facility-wide corrective action.
Whether the types and concentrations of hazardous constituents are different at state
and voluntary cleanup sites and CERCLA remedial action sites, however, is unclear
36 Remedies have been selected for all sites in the database, since they all have RODs (Records of Decision).
These remedies are not likely to be changed by Phase IV, unless Phase IV requires more effective treatment than
provided by the selected ex-situ treatment remedy and the remedy has not already been constructed.
^*,^ o en
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because of the absence of detailed site-specific data on the nature of contamination
and management practices at state superfund and voluntary cleanup sites. Thus, it
remains unclear whether the methodology overestimates or underestimates the
increased costs or cost savings at these sites. Similar uncertainty applies to the
extrapolation from RCRA corrective actions to RCRA closures. This concern is
important because most soil treated ex-situ outside of CAMUs or AOCs is generated by
state and voluntary cleanup programs and RCRA closures.
Definitions of High and Low Concentration and High and Low Volume
The baseline and post-regulatory definitions of high and low concentration and
high and low volume determine the projected treatment methods. The cutoffs between
high and low concentration are multiples of UTS levels (e.g., 100 times UTS). These
multiples are somewhat subjective. Constituent-specific concentration cutoffs may be
more appropriate than the cutoffs based on a multiple of the UTS. Constituent-specific
cutoffs could address the varying toxicity, fate, and transport characteristics of
individual constituents and their amenability to the use of different treatment
technologies. In addition, high and low volume cutoffs might be more appropriately
applied on a technology-specific and/or waste-specific basis.
EPA did not develop more sophisticated concentration and volume cutoffs
because of the difficulties involved, the resources required, and the relatively modest
expected gains in accuracy. The cutoffs used in the methodology were developed so
that the baseline results are realistic, based on available data. The changes in the
cutoffs from the baseline analysis to the post-regulatory analysis are designed to
identify the types of sites that are likely to be require more or less effective and
expensive treatment under Phase IV. In addition, even constituent-specific cutoffs
would not reflect the site-to-site differences in meeting either the 90 percent reduction
standard or the 10 times UTS standard.
As EPAs approach was not able to examine the effect of the 90 percent
reduction standard, EPA estimated the volumes of soil which would be able to take
advantage of this standard. The assessment showed that only 3 to 5 percent of the
volume had concentrations above 100xUTS levels, and thus would benefit from the 90
percent reduction standard. Therefore, this limitation in the analysis likely has little
effect on the overall results.
Trends in Treatment Technologies
The analysis does not account for future trends in the remediation of
contaminated soil and sediment, such as the development of new treatment
technologies. Baseline treatment methods reflect the current mix of remediation
treatments and existing trends towards increased use of innovative treatment methods.
Baseline and post-regulatory treatment methods include only technologies that have
been successfully used at remediation sites. It is likely, however, that existing
Chapter 2: Methodology Page 2-51
-------
technologies will be improved and new technologies developed. The impact of
technological innovation on the estimated cost savings is unclear because the changes
would reduce costs under both the baseline and the post-regulatory scenarios.
However, because this analysis covers only the five years following implementation of
the rule, EPA believes that the treatment methods projected in this analysis will not
change dramatically due to technological innovation.
Affected Volumes
Contaminated soil and sediment at each site are segregated into volumes that
are above and below the toxicity characteristic levels and above and below the high
and low concentration threshold. The proportion of contaminated soil or sediment at
sites with contamination in these categories is estimated using a functional relationship
(Y=X3), as described earlier in this chapter. This equation is based on statistical
analysis of a limited sample of sites and therefore its representativeness is uncertain.
To verify the model's validity, EPA compared these results with over 1,200
observations using a Monte Carlo simulation that was based on empirical site
characterization data from DOE's Superfund Reauthorization (SURE) model. The
results indicate that the functional relationship derived from the limited data is
consistent with field data used in the SURE model.
EPA, nonetheless, recognizes that the distribution of constituent concentrations
does not vary uniformly across sites. Sites often have numerous "hot spots" of highly
contaminated soil. Nevertheless, EPA believes that, consistent with the approach
used, contaminant concentrations often will decline moving from the area of localized
maximum contamination. Thus, for simplicity and because the functional relationship is
representative of the sample of sites analyzed, the Agency used this approach to
determine volumes.
The assumption that volumes in the different categories will be segregated and
managed separately may overestimate or underestimate the costs savings or
incremental costs. At some sites, these volumes are likely to be managed together,
using the same technology or technology train. The direction and magnitude of this
approach's impact on the estimated savings or incremental costs is difficult to gauge
because the approach is used in both the baseline and post-regulatory analysis. In
addition, the impact is difficult to determine because the model, consistent with current
practices, allocates volumes to in-situ and ex-situ treatment methods based, in part, on
the volumes subject to remediation. Only the volumes treated ex-situ, however, are
subject to the LDRs.
Pace of Remediation Nationally
The numbers that EPA used to estimate the number of sites remediated each
year were adapted from a number of different sources. There was considerably more
information for CERCLA and RCRA than for state superfund and voluntary cleanup
-------
programs, so CERCLA and RCRA estimates may be more accurate. EPA recognizes
that these numbers may change due to a variety of factors and that the further out the
analysis extends the less accurate they become. In order to minimize the effect of
changes to the pace of remediation, the Agency limited the analysis to the five years
after the requirements begin affecting remediation decisions.
So/7 Contaminated with Listed Versus Characteristic Waste
The data available for the CERCLA remedial action and RCRA corrective action
sites in the database do not specify whether soil subject to remediation is hazardous
because it exhibits a characteristic or because it contains listed waste. The analysis
determines, based on maximum constituent concentrations, whether the soil is likely to
exhibit the toxicity characteristic for metals, organics, or both. The analysis also makes
the simplifying assumptions that soil exhibiting the TC is not contaminated with listed
waste and that soil not exhibiting the TC is contaminated with listed waste.
This approach may overestimate the increased costs imposed by requiring soils
exhibiting the TC for metals (but not for organics) to be treated for any organic UHCs.
In the baseline, these soils may be treated to UTS levels (rather than risk-based levels)
for the organic UHCs if the organic UHCs are listed constituents from listed wastes.
Thus, the analysis may underestimate baseline costs and overestimate the incremental
post-regulatory costs. EPA, however, does not believe that this overestimate is likely to
be significant, in part because of the relatively small estimated incremental costs from
the more stringent requirements.
This approach may also underestimate the savings associated with the new soil
standards. As the analysis was performed, no cost savings were attributed to soils
exhibiting the TC for metals only because it was assumed that these soils were
considered hazardous because they exhibited a characteristic, not because they
contained listed waste. Soils contaminated with listed wastes are currently required to
be treated for listed constituents to UTS levels, so taking listed waste into account
would increase the total cost savings associated with the new soil standards (as soils
contaminated with listed wastes will now be able to utilize the less stringent new soil
standards).
No Increased Costs on RCRA Soils or CERCLA and RCRA Sediments
EPA's modeling showed that the volume of RCRA soils and CERCLA and RCRA
sediments affected by this rulemaking to be insignificant, and thus the Agency
estimated that the Phase IV rule would not have any significant impacts on these
media. As explained, EPA believes that RCRA soils and CERCLA and RCRA
sediments are infrequently incinerated under current requirements and that this will
continue under Phase IV. However, the Agency recognizes'that some volumes of
these media may switch treatment categories (i.e., from a less expensive ex-situ
treatment method to incineration) and will thus be affected by the Phase IV rule.
Chapter 2: Methodology Page 2-53
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CHAPTERS. RESULTS
This chapter presents the results of the analysis of the incremental costs and
cost savings resulting from the application of the Phase IV LDR rule to contaminated
media. It is organized as follows:
Section 3.1 summarizes the baseline soil and sediment treatment
methods and costs;
Section 3.2 describes the estimated cost savings under the new
soil treatment standards;
Section 3.3 discusses the lack of changes in treatment costs for
media contaminated with newly identified mineral processing
wastes; and
Section 3.4 presents the estimated incremental costs for soil that
exhibits the TC for metals only.
Exhibit 3-1 summarizes these results.
3.1 Baseline Treatment Methods and Costs
As described in Chapter 2, EPA used data from a sample of CERCLA remedial
action soil and sediment contamination sites and RCRA corrective action soil
contamination sites to analyze the baseline costs and the incremental costs or cost
savings of the Phase IV final rule. Exhibit 3-2 presents the constituent types,
concentration, volumes, and corresponding treatment technologies for the largest
volume treatability groups across the three remediation categories represented in the
soil and sediment database. The exhibit demonstrates that a large fraction of CERCLA
soil is contaminated with multiple constituents types and therefore is relatively
expensive to treat. Seven percent of CERCLA soil, for example, is contaminated with a
high concentration and low volume of constituents in all four constituent groups and is
therefore projected to be managed using incineration or thermal desorption combined
with immobilization of the resulting residuals at an average cost of $1,064 per ton.
Another two percent of the volume is also contaminated with all four types of
constituents having high concentration and high volume. Because incineration may be
economically infeasible for such high volume sites (greater than 65,000 tons/site for
this treatability group), the baseline treatment method is soil washing, dechlorination,
and ex-situ immobilization at $476 per ton. The average treatment cost for CERCLA
soil managed in-situ or ex-situ is $307/ton. The average ex-situ treatment cost for
CERCLA soil is $354/ton.
Chapters: Results' Page 3-1
-------
Exhibit 3-1
Summary of Phase IV Costs/Savings for Contaminated Media
Phase IV
Provisions
New Soil
Treatment
Standards
Media
Analyzed
Soil exhibiting
TC for organics
or TC for both
organics and
metals
Soil containing
listed waste
Management Standards
Baseline
Treat all TC
constituents and
allUHCstoUTS
Treat listed
constituents to
UTS
Post-Regulatory
Treat all TC
constituents and all
UHCstolOxUTS
or 90 percent
reduction
Treat all listed
constituents and
UHCstolOxUTS
or 90 percent
reduction
Subtotal For the New Soil Standards
Media
Contaminated
with Mineral
Processing
Waste
Media
Exhibiting TC
for Metals
Soil, sediment,
ground water,
debris
Soil exhibiting
TC for metals
only
Sediment
exhibiting TC for
metals only
Groundwater/
debris exhibiting
TC for metals
only
Treat to TC levels
Treat to the lower
of TC or site risk-
based levels
Treat to the lower
of TC or site risk-
based levels
Treat to the lower
of TC or site risk-
based levels
Treat to new soil
standards (soils) or
to UTS (other
media)
Treat all
constituents
(including UHCs) to
the lower of TC,
site risk-based, or
alternative standard
levels
Treat all
constituents
(including UHCs) to
the lower of TC,
site risk-based, or
UTS levels
Treat all
constituents
(including UHCs) to
the lower of TC,
site risk-based, or
UTS levels
Affected Volumes
(tons/year)
CERCLA= 1000
RCRA = 0
State Superfund = 1 ,000
Voluntary = 5,000
Total = 7,000
CERCLA = 13,000
RCRA = 1 1,000
State Superfund = 1 2,000
Voluntary = 47,000
Total = 83,000
CERCLA = 14,000
RCRA = 11,000
State Superfund = 13,000
Voluntary = 52,000
Total = 90,000
No affected volumes
predicted
CERCLA = 35,000
RCRA = 0
State Superfund = 26,000
Voluntary = 102,000
Total = 163, 000
No affected volumes
predicted
Not quantifiable
Incremental
Cost/Savings (million
$/year)
CERCLA = (0.6)
RCRA = 0
State Superfund =(0.7)
Voluntary = (2.7)
Total = (4)
CERCLA = (3.5)
RCRA = (1.2)
State Superfund =(3.2)
Voluntary = (12.8)
Total = (21)
CERCLA = (4.1)
RCRA = (1.2)
State Superfund =(3.9)
Voluntary = (15.5)
Total = (25)
No cost changes
CERCLA = 0.7
RCRA=0
State Superfund = 0.5
Voluntary = 2.0
Total = 3
No cost changes
Not quantifiable
Comments
Savings primarily reflects shift from
incineration/thermal desorption to
less expensive ex-situ treatments.
Savings primarily reflect shift from
incineration/thermal desorption to
less expensive ex-situ treatments and
no treatment for soils less than 10
times UTS. Does not account for
increased costs from treating non-
listed UHCs. Non-TC soil is
assumed to contain listed wastes.
Volumes were not determined
because incremental treatment soil
cost expected to be negligible.
Increased cost primarily reflects shift
from less expensive ex-situ
treatments to incineration/thermal
desorption to treat organic UHCs.
Analysis predicted that sediment
treatment costs would. not be
significantly affected.
Analysis predicted that groundwater
and debris treatment costs would not
be significantly affected.
-------
Exhibit 3-2
Baseline Treatment of Soil and Sediment for Sample Sites*
MediaType
CERCLA
Soil
Constituent Types
Metals
SVOCs, AHCs, and
Metals
\/OOsฃMDOs3tiAHCs
VOCs,SVOCs,AHCs,
and Metals
VOCs,SVOCs,AHCs,
and Metals
SVOCs and Metals
VOCs and Metals
VOCs,SVOCs,AHCs,
and Metals
AHCs and Metals
VOCs, SVOCs, and
Metals
SVOCs and AHCs
VOCs
VOCs and SVOCs
Concentration/
Volume
LC/HV, HC/LV, HC/HV
LC/HV
HC/HV
HC/LV
LC/LV
LC/LV, LC/HV
LC/HV,HC/LV,HC/HV
LC/HV
HC/HV
LC/HV, HC/HV
HC/HV
LC/HV,HC/LV,HC/HV
LC/HV
Other Treatabilitv Groups
Volume
15%
8%
8%
7%
6%
5%
5%
5%
5%
4%
3%
3%
3%
26%
Treatment
Ex-situ immobilization
Soil washing, ex-situ
bioremediation, and ex-situ
immobilization
Vacuum Extraction
Incineration, or thermal
desorption, and immobilization of
the ash
50% in-srtu and 50% ex-sttu
bioremediation and immobilization
50% in-situ and 50% ex-situ
bioremediation and immobilization
Vacuum extraction and in-situ
immobilization
Vacuum extraction and in-situ
immobilization
Soil washing, dechlorination, and
ex-situ immobilization
Vacuum extraction and in-situ
immobilization
Soil washing and dechlorination
Vacuum extraction
ncineration or thermal desorption
Various methods
CostperTon
$164
$359
$150
$1 ,064
$181
$181
$204
$204
$476
$204
$312
$150
$1,058
$412
Chapters: Results
Page 3-3
-------
Exhibit 3-2 (continued)
Baseline Treatment of Soil and Sediment for Sample Sites*
Media TypejConstituent Types
RCRASoil
CERCLA
Sediment
Metals
SVOCs and Metals
VOCs
VOCs and Metals
SVOCs and Metals
VOCs, AHCs, and
Metals
Concentration/
Volume
LC/HV,HC/LV,HC/HV
LC/LV, LC/HV
LC/HV,HC/LV,HC/HV
LC/HV,HC/LV,HC/HV
HC/LV, HC/HV
LC/HV
Other Treatability Groups
Metals
SVOCs, AHCs, and
Metals
VOCs,SVOCs,AHCs,
and Metals
VOCs and Metals
AHCs
SVOCs and Metal
VOCs and SVOCs
AHCs
AHCs
LC/HV,HC/LV,HC/HV
LC/HV
HC/LV
LC/HV,HC/LV,HC/HV
HC/HV
HC/LV, HC/HV
LC/LV, LC/HV, HC/HV
HC/LV
LC/LV, LC/HV
Other Treatment Groups
Volume
41%
25%
,_ 24%
3%
2%
1%
3%
23%
13%
10%
8%
7%
6%
6%
5%
4%
19%
Treatment
Ex-situ immobilization
50% in-situ and 50% ex-situ
bioremediation and immobilization
Vacuum extraction
Vacuum extraction and in-situ
immobilization
Soil washing, ex-situ
bioremediation, and ex-situ
immobilization
Vacuum extraction and in-situ
immobilization
Various methods
Ex-situ immobilization
Soil washing, ex-situ
bioremediation, and ex-situ
immobilization
Incineration, or thermal
desorption, and immobilization o1
the ash
Ex-situ bioremediation and ex-situ
immobilization
Soil washing and dechlorination
Soil washing, ex-situ
bioremediation, and ex-situ
immobilization
Ex-situ bioremediation
Incineration or thermal desorption
Ex-situ bioremediation
Various methods
CostperTon
$164
$181
$150
$204
$359
$204
$365
$181
$376
$1,079
$255
$327
$376
$91
$1 ,074
$91
$440
* Totals may not add due to rounding.
Key: LC = low concentration LV = low volume
HC = high concentration HV = high volume
Paae 3-4
-------
In contrast, RCRA soil is typically contaminated with VOCs and/or metals, which
are relatively inexpensive to treat. Therefore, the average in-situ and ex-situ cost for
treating RCRA soil is only 56 percent of the cost for CERCLA soil, $170/ton versus
$310/ton. Similarly, the average RCRA ex-situ soil treatment cost is $179/ton versus
$354/ton for CERCLA soil. Fifty-seven percent of RCRA corrective action soil is
contaminated with metals only and is projected to be managed using ex-situ
immobilization at $164 per ton. Another 24 percent is contaminated with VOCs only
and is projected to be managed using vacuum extraction at $150 per ton.
CERCLA soil and CERCLA sediment volumes are contaminated with similar
types of contaminants. Thus, the average ex-situ treatment costs for CERCLA soil and
sediment are almost identical, $401 and $403 per ton, respectively. Despite having
slightly less complex contamination than CERCLA soil, CERCLA sediment is slightly
more expensive to manage because of the need for dewatering at $15/ton.
The significant average cost per ton difference between CERCLA soil and
sediment sites and RCRA soil sites also reflects the prevalence of incineration and
thermal desorption. About 10 percent of CERCLA soil is projected to require
incineration or thermal desorption at an average cost of approximately $1,062 per ton.
This volume is responsible for 33 percent of the CERCLA soil management costs.
Similarly, the 18 percent of the CERCLA sediment that is projected to be treated by
incineration or thermal desorption is responsible for 49 percent of the total sediment
management costs. In contrast, less than one percent of RCRA soil is projected to
require incineration or thermal desorption and only three percent requires the next
expensive treatment method, soil washing, which in combination with various
secondary treatments, costs $312 to $476 per ton.
Exhibit 3-3 presents the national baseline of soil and sediment ex-situ treatment
costs. (See also Exhibit A-3 for the percent of media treated by different treatment
methods.) This baseline excludes volumes managed in CAMUs or AOCs, since LDRs
do not apply to these cleanups. As described in Chapter 2, the average treatment cost
per ton figures for RCRA corrective actions are applied to RCRA closures. Similarly,
the average ex-situ treatment cost per ton for CERCLA remedial actions is applied to
state superfund and voluntary cleanups. The CERCLA ex-situ cost is used because
media generated by state superfund and voluntary cleanups are assumed to be treated
primarily off-site and therefore are treated ex-situ. The estimated national ex-situ soil
and sediment treatment costs, excluding volumes managed in CAMUs or AOCs, in the
absence of the Phase IV rulemaking, are $306 million/year and $24 million/year,
respectively. These baseline estimates cover the five-year period following
implementation of the Phase IV standards, but do not include the impact of Phase IV.
Chapter 3: Results Page 3-5
-------
Exhibit 3-3: National Baseline Ex-Situ Treatment Costs
(Excludes Volumes Managed in AOCs or CAMUs)
Remediation Program
Tons Treated Ex-Situ
Per Year
AverageCost/Ton
Annual Cost
($ million)
Soil
CERCLA Remedial Actions
RCRA Corrective Actions
RCRA Closures
State Superfund
Voluntary
Soil Totals
140,000
110,000
50,000
130,000
510,000
940,000
$354
$179
$179
$354
$354
$326
$50 million
$20 million
$9 million
$46 million
$181 million
$306 million
Sediment
CERCLA Remedial Actions
RCRA Corrective Actions
Sediment Totals
40,000
20,000
60,000
$403
$403
$403
$16 million
$ 8 million
$24 million
These baseline figures do not represent the actual baseline costs attributable to the LDR rules applied to media, in as much as these
costs are largely attributable to the given cleanup authority under which remediation takes place.
3.2 Cost Savings Of The New Soil Treatment Standards
EPA expects that facilities generating soils exhibiting the TC for organic
constituents and non-TC soils containing listed wastes will most likely recognize cost
savings as a result of the new soil standards. Some soils that are hazardous because
they exhibit the TC for organic constituents are likely to incur cost savings because
they will be treated with less expensive treatment methods. Some non-TC soils with
constituent concentrations below 10 times UTS could recognize cost savings because
they will fall out of Subtitle C regulation altogether and will be eligible for disposal in a
Subtitle D facility. Based on the methodology described in Chapter 2, EPA estimates
that the Phase IV cost savings for facilities generating these soils will be approximately
$25 million per year ($4 million for TC organic soils + $21 million for non-TC soils).
3.2.1 Estimated Cost Savings for Soil Exhibiting the TC for Organics
In order to estimate national cost savings from the new soil standards on soil
exhibiting the TC for organics, EPA extrapolated the per-ton cost savings calculated
using the database (as outlined in Section 2.6) to the universe of sites remediated
nationally. In order to estimate the CERCLA soil cost savings, EPA calculated that 12
percent of all CERCLA soil in the database was TC for organics (roughly 1.05 out of
Page 3-6
Chanter?-
-------
9.09 million tons of CERCLA soil in the database). In addition, about nine percent of
CERCLA soil projected to be managed ex-situ was TC for organics (473,000 tons out of
5.24 million tons). The Agency estimates that 52 percent of the TC organic soils
treated ex-situ will be incinerated or thermally desorpted in the baseline (246,000
tons/473,000 tons). Finally, of the TC organic soil that is incinerated or thermally
desorpted, the analysis showed that 14 percent would switch from incineration or
thermal desorption under the baseline to other ex-situ treatment methods as a result of
the new soil standards (approximately 35,000 out of 246,000 tons). For these volumes,
the average cost savings is $600 per ton. The average per ton cost savings was
calculated by subtracting the average per ton cost of other ex-situ treatments from the
per ton cost of incineration and thermal desorption.
The model predicted that no TC organic soil at RCRA sites would shift from
incineration or thermal desorption to an alternative treatment method. Thus, there are
no estimated cost savings for RCRA soil. EPA, however, does expect some low level
of savings for these RCRA soils. EPA believes that the cost savings will be
substantially lower for RCRA soil than for CERCLA soil because RCRA soils are
generally less highly contaminated than CERCLA soils. Furthermore, a significantly
smaller share of RCRA soil is incinerated in the baseline. To the extent that TC
organics soil at RCRA cleanups will recognize cost savings, this analysis
underestimates the savings related to the new soil treatment standards.
Thus, the costs savings shown in Exhibit 3-4 were calculated as follows:
CERCLA Remedial Action Soil: $0.6 million/year = 140,000
(tons/year treated ex-situ outside of a CAMU or AOC) x .09 (portion
of soil treated ex-situ exhibiting the TC for organics) x .52 (portion
of TC organic soil treated ex-situ that is incinerated or thermally
desorpted) x .14 (portion of TC organic soil that switches from
incineration or thermal desorption to another ex-situ treatment
method) x $600 (average cost savings per ton for soils shifting from
incineration or thermal desorption to another ex-situ treatment
method).
State Superfund and Voluntary Cleanup Soil: $3.4 million/
year = 640,000 (tons/year treated ex-situ outside of a CAMU or
AOC) x .12 (portion of all CERCLA soil exhibiting TC for organics)37
x .52 (portion of TC organic soil treated ex-situ with incineration or
37 EPA assumed that soil generated at state superfund and voluntary cleanups is similar to all CERCLA soil,
rather than just CERCLA soil treated ex-situ. As a result, EPA assumed that 12% of all state superfund and
voluntary cleanup soil exhibits the TC for organics, rather than 9%, which reflects only CERCLA soil treated ex-
situ.
Chapter 3: Results Page 3-7
-------
Exhibit 3-4
Estimated Cost Savings for TC Organics Soil Under The New Soil Standards
Remediation Category
CERCLA Remedial Action So
RCRA Corrective Action Soil
RCRA Closures Soil
State Superfund Soil
Voluntary Cleanup Soil
Totals
TonsTreatedEx-
Situ
Outside of CAMU
or AOC'
1 140,000
110,000
50,000
130,000
510,000
940,000
Portion
Exhibiting TC
For Organics
9%
18%
18%
12%
12%
N/A
Portion of TC
Organic Soil
Treated Ex-Sftu
With
Incineration/T
hermal
Desorption
52%
-
52%
52%
N/A
Portion
Switching Ex-
SituTreatments
14%
0%
0%
14%
14%
N/A
Cost Savings
Per Ton
$600
$0
$0
$600
$600
N/A
Cost Savings for TC
Organics Soil
$0.6 million/yr.
$0.7 million/yr.
$2.7 million/yr.
$4.0 million/yr.
See Exhibit 2-7 and accompanying text for an explanation of how these volumes were calculated.
-------
thermal desorption) x .14 (the percentage of TC organic soil that
switches from incineration or thermal desorption to another ex-situ
treatment method) x $600 or thermal desorption (average cost
savings per ton for soils shifting from incineration or thermal
desorption to another ex-situ treatment method).
These estimates do not reflect the new site-specific variance from the
technology-based new soil treatment standards for soils with concentrations above the
new soil treatment levels that minimize threats to human health and the environment.
This variance will allow soils that are currently treated below site-specific risk-based
levels due to the LDR requirements to be exempted from the new treatment levels if
they can meet the risk based standards needed for the variance. These soils may
recognize additional savings from the variance, as they may not be required to be
treated at all or could be treated to less stringent levels than under the new soil
standards.
3.2.2 Estimated Cost Savings for Soil Contaminated with Listed Waste
Soils contaminated with listed wastes are likely to recognize savings from less
expensive treatment and from no treatment at all. This section first presents the
estimated savings from less expensive treatment and then the savings from no
treatment. Overall cost savings for soils contaminated with listed waste are estimated
to be approximately $21 million per year.
Savings from Less Expensive Treatment
As noted in Section 2.6, soil that is hazardous because it contains listed wastes
will likely achieve some cost savings under the Phase IV new soil treatment standards
when some constituents already meet the 10 times UTS standard. These savings
could not be estimated directly using the approach applied to TC organic soil because
of modeling limitations and because some of these soils also may face increased costs
(they must now be treated for all UHCs, including hazardous constituents that are not
listed constituents). To estimate an upper bound of these savings, EPA estimated the
effects of the percentage of soil shifting from incineration or thermal desorption in the
baseline to less expensive treatment under Phase IV. The resulting cost savings per
ton were the same for soil contaminated with listed wastes as for TC soil. These
estimates represent an upper bound for two reasons:
Some of these soils may be considered as non-hazardous because
they do not "contain" listed hazardous waste under the contained-
in policy; and
The soil may contain UHCs that are not primary constituents and
therefore may be subject to increased treatment costs under
Phase IV
Chapter 3: Results Page 3-9
-------
Using this methodology, the estimated savings apply to soil generated by
CERCLA remedial action, state superfund, and voluntary cleanups, since no RCRA TC
soil shifted from incineration to another treatment method. Sixty-eight percent of the
database volumes of all CERCLA soil were found not to exhibit the TC and therefore
may be hazardous because they contain listed waste. Seven percent of this soil, or
11 percent of the volume treated ex-situ, is expected to be treated by incineration or
thermal desorption in the baseline. Then, using the results from the analysis of TC
organics soil, 14 percent of the incinerated or thermally desorpted soil is assumed to
utilize less expensive treatment methods under Phase IV, at an average savings of
$600 per ton. The resulting estimated cost savings are $4.9 million per year, as shown
in Exhibit 3-5.
No Treatment
As explained in Section 2.6, some contaminated soil that is treated in the
baseline may not require treatment under Phase IV because it will meet the new soil
treatment standards and risk based standards upon excavation. Instead of treatment,
the soils are expected to be disposed of directly into a Subtitle D landfill, assuming that
site owner/operators obtain a contained out determination for the soil.38 For CERCLA,
state superfund, and voluntary cleanups, EPA estimated that 12 percent of non-TC (or
listed) soils will meet 10 times UTS levels upon excavation; these sites will recognize a
savings of approximately $230 per ton. As shown in Exhibit 3.6, cleanups conducted
under these programs are expected to save approximately $2.6 million, $2.4 million,
and $9.6 million, respectively. For RCRA corrective action and closure cleanups, EPA
estimated that approximately nine percent of non-TC soils will meet 10 times UTS
levels upon excavation; these sites will recognize savings of approximately $114 per
ton. As shown in Exhibit 3.6, cleanups conducted under RCRA corrective action and
closure programs are expected to save approximately $0.8 and $0.4 million,
respectively. Total cost savings from soils requiring no treatment under the new soil
standards are estimated to be $15.8 million.
3.2.3 Potential Additional Cost Savings In Absence of the CAMU Rule
The results described above for CERCLA and RCRA cleanups assume that the
CAMU rule is completely effective in the baseline and under Phase IV and that 36
percent of soils managed ex-situ (180,000 tons/year for CERCLA, 140,000 tons/year
for RCRA corrective action, and 65,000 for RCRA closure) is treated in CAMUs and
therefore not affected by the LDRs, including Phase IV If the CAMU rule was not in
See page 2-36 for more details regarding the contained out determination.
Page 3-10 Chanter 3: Results
-------
Exhibit 3-5
Estimated Cost Savings for Listed Soils Requiring Less Expensive Treatment Under The New Soil Standards
Remediation Category
CERCLA Remedial Action So
RCRA Corrective Action Soil
RCRA Closures Soil
State Superfund Soil
Voluntary Cleanup Soil
Totals
TonsTreatedEx-
Srtu Outside of
CAMU or AOC*
1 140,000
110,000
50,000
130,000
510,000
940,000
Portion Non-TC
68%
75%
75%
68%
68%
N/A
Portion of
Non-TC Soil
Treated Ex-
Situ With
Incineration
or Thermal
Desorption
11%
0%
0%
11%
11%
N/A
Portion of This
Non-TC Soil
Switching Ex-
SituTreatments
14%
0%
0%
14%
14%
N/A
Cost Savings
Per Ton
$600
$0
$0
$600
$600
N/A
Cost Savings for Listed
Soil
$0.9 million/yr.
-
$0.8 million/yr.
$3.2 million/yr.
$4.9 million/yr.
* See Exhibit 2-7 for a complete explanation of how these volumes were calculated.
-------
Exhibit 3-6
Estimated Cost Savings for Listed Soils With Constituent Concentrations Below 10 Times UTS
Remediation Category
CERCLA Remedial Action So
RCRA Corrective Action Soil
RCRA Closures Soil
State Superfund Soil
Voluntary Cleanup Soil
Totals
Tons Treated Ex-
Situ Outside of
CAMUorAOC'
I 140,000
110,000
50,000
130,000
510,000
940,000
Portion Non-TC
68%
75%
75%
68%
68%
N/A
Portion of
Non-TC Soil
BebwIOTmes
UTS
12%
9%
9%
12%
12%
N/A
Cost Savings
Per Ton
$230
$114
$114
$230
$230
N/A
Cost Savings for Listed
Soil
$2.6 million/yr.
$0.8 million/yr.
$0.4 million/yr.
$2.4 million/yr.
$9.6 million/yr.
$15.8 million/yr.
See Exhibit 2-7 for a complete explanation of how these volumes were calculated.
-------
place in the baseline or under Phase IV, the additional ex-situ soil volumes affected by
Phase IV would increase by 180,000 tons per year (from 140,000 to 320,000 tons) for
CERCLA, by 140,000 tons per year (from 110,000 to 250,000 tons) for RCRA
corrective actions, and by 65,000 tons per year (from 50,000 to 115,000 tons) for
RCRA closures. Thus, the annual cost savings would increase as follows:
For TC organic soils, from $4.0 million to $4.7 million;
For listed soils requiring less expensive treatment, from $4.9
million to $6.0 million;
For listed soils requiring no treatment, from $15.8 million to $20.7
million.
Thus, assuming no CAMU, the total cost savings for the new soil standards is
estimated to be $31 million/year ($4.7 million/year + $6.0 million/year + $20.7
million/year).
3.2.4 Major Differences Between HWIR-Media and Phase IV Cost Savings
The $25 million per year projected cost savings for the new soil treatment
standards are substantially lower than the $1.048 billion per year projected cost
savings for soil for the proposed HWIR-Media rule. This section explains the major
reasons for this difference.
No Bright Line
In the HWIR-Media analysis, 84 percent ($881 million/year) of the projected cost
savings for contaminated soil were for volumes below the bright line. Under the Phase
IV soil treatment standards, these volumes are unlikely to experience a shift to lower
cost treatment methods. This soil has relatively low concentrations of hazardous
constituents and therefore is currently being treated with low cost treatment methods.
The same treatment methods are likely to be used under the new soil treatment
standards. In addition, only a small portion of contaminated soil appears to be below
10 times UTS for all hazardous constituents and therefore would not be required to be
treated under the new soil treatment standards.
Availability of CAMUs
The HWIR-Media analysis assumed that CAMUs were not available in the
baseline or under HWIR-Media. It also incorporated the use of AOCs at CERCLA
remedial actions, but not at RCRA corrective actions or closures. For Phase IV,
CAMUs and AOCs are assumed to be used in both the baseline and the post-
regulatory analysis for CERCLA remedial actions and RCRA corrective actions and
closures. These changes from the HWIR-Media analysis reduced the volumes with
Chapter 3: Results Page 3-13
-------
potential cost savings by almost 50 percent at CERCLA corrective actions and by 72
percent at RCRA corrective actions and closures.
These changes did not affect state superfund and voluntary cleanups and
therefore these cleanups are responsible for a higher portion of the total cost savings
under Phase IV than under HWIR-Media. Contaminated soil generated by state
superfund and voluntary cleanups is assumed to be treated off site so that these
facilities avoid the need for a RCRA permit and the associated facility-wide corrective
action requirements. By treating the contaminated media off site, no volumes are
managed in CAMUs or AOCs.
Less Baseline Incineration
The Phase IV analysis projects less incineration in the baseline than the HWIR-
Media analysis. Under HWIR-Media, 17 percent of CERCLA remedial action soil and 1
percent of RCRA corrective action soil, respectively, were projected to be incinerated in
the baseline. In the Phase IV analysis, these figures have declined to 10 percent and
less than 0.1 percent, respectively. In addition, a fourth of these volumes are projected
to be treated using thermal desorption, instead of more costly incineration.
These changes are consistent with trends towards decreasing use of
incineration and increasing use of thermal desorption. In addition, they reflect new soil
contamination data. Since the HWIR-Media analysis was completed, the soil and
sediment database was expanded to include data from the CERCLA RODs for 1994-
1996 and RCRA statements of basis. (See Appendix A.) These new sites have lower
levels of hazardous constituent concentrations, on average, than other database sites.
As a result, treatment costs are lower under both the baseline and post-regulatory
scenarios (low levels of constituents are less expensive to treat than high levels).
Slower Pace of Remediation
Incorporating recent EPA data on the number of remedial action sites added to
the National Priority List,39 EPA reduced the projected future number of CERCLA
remedial action sites remediated per year to 70 from 109 in the HWIR-Media analysis.
Similarly, the projected number of state superfund cleanups declined from 790 to 510
based on new data from an Environmental Law Institute report entitled "An Analysis of
State Superfund Programs: 50-state Study, 1995 Update," December 1995. These
changes reduced the CERCLA remedial action and state superfund soil volumes, and
thus lowered the projected savings for the Phase IV new soil treatment standards.
"Cleaning Up the Nation's Waste Sites: Market and Technology Trends," supra footnote 8.
-------
No Significant Savings for RCRA Sites or Soils Exhibiting the TC for Metals Only
Under the HWIR-Media analysis, 40 percent of the soil cost savings were for
RCRA corrective actions and closures. Most of these savings (37 of 40 percent) were
for volumes below the bright line. The Phase IV analysis, in contrast, projects no
significant savings for RCRA sites, largely because less than one percent of these
volumes is incinerated in the baseline. Similarly, the Phase IV analysis projects no
savings for the 25 percent of CERCLA remedial action soil that is TC for metals only.
Ex-Situ Treatment Only
The HWIR-Media rule would have changed the requirements for in-situ as well
as ex-situ treatment of contaminated media. For example, facilities conducting in-situ
treatment of below-the-bright-line soil could avoid the need to obtain a RCRA treatment
permit. Phase IV will not affect in-situ treatment requirements, because the LDRs
generally do not apply to contaminated soil treated in-situ. The estimated cost savings
for Phase IV do not include any savings for volumes treated in-situ. In addition, to
improve the modeling for Phase IV, EPA disallowed any shifts from baseline ex-situ
treatment to post-regulatory in-situ treatment. Such shifts in the HWIR-Media analysis
may have unrealistically inflated the cost savings for volumes above the bright line.
3.3 No Change In Cost: Media Contaminated with Newly Identified Mineral
Processing Wastes
EPA expects that treatment costs for facilities generating media contaminated
with newly identified mineral processing wastes will not increase significantly under
Phase IV because:
For soils, the new alternative treatment levels for most TC metal
constituents are higher than existing TC levels, as discussed in
Section 2.7; and
For media containing metal constituents with new or lower
treatment levels, the stabilization/solidification treatment process
currently used also treats non-TC metal constituents. The process
can be inexpensively modified in order to account for the new
standards.
Thus, EPA expects that generators of soils with these constituents will continue to treat
their contaminated wastes to TC levels to avoid Subtitle C regulation of the residuals
and will thus have no change in treatment costs.
For silver and non-TC metal constituents in soils or for media that must meet
UTS levels, EPA believes that the additional cost of treating wastes to the lower new
soil standards will not be significant. In order to meet the new standards, EPA expects
Chapters: Results Page 3-15
-------
that facilities will increase the ratio of reagent to media during the treatment process to
decrease the concentration of constituents in the residue. As this change does not
significantly modify the treatment process or require any additional treatment steps, the
Agency does not expect treatment costs for media containing newly identified mineral
processing wastes to increase significantly.
3.4 Increased Costs for TC Metals Soil
EPA expects that facilities managing contaminated soil or sediments exhibiting
the TC for metals at CERCLA, state superfund, and voluntary cleanups only could incur
increased costs because all UHCs present must now be treated to the new soil
treatment standards for soils or to UTS levels for sediments. Based on the analysis
described in Section 2.8, EPA estimates that the incremental costs of the Phase IV rule
to generators of such contaminated soil will be approximately $3 million per year, an
increase of less than one percent of total baseline treatment costs. The analysis
estimated negligible incremental costs for cleanups performed under RCRA and for
contaminated sediment managed under both CERCLA and RCRA.
In order to calculate the incremental national soil treatment costs from the Phase
IV rule, EPA extrapolated the $19 per ton cost increase for soil treatment calculated for
CERCLA remedial action sites in the database (outlined in Section 2.8) to the universe
of CERCLA sites remediated nationally. These calculations and the estimated volume
of soil treated annually are presented in Exhibit 3-7. The increased costs were applied
only to soil that exhibits the TC for metals only and is treated ex-situ outside of CAMUs
or AOCs. About 20 percent of all CERCLA soils exhibit the TC for metals only, and
about 25 percent of CERCLA soil treated ex-situ exhibits the TC for metals only. Thus,
the increased cost for CERCLA remedial action soil cleanup is $0.7 million per year
(140,000/tons per year treated ex-situ x .25 x $19/per ton).
To determine national costs of Phase IV at state superfund and voluntary
cleanups, EPA used the results of the ex-situ analysis of the sample of all CERCLA soil
volume in the database. Thus, 20 percent of soil generated by state superfund and
voluntary cleanups is assumed to exhibit the TC for metals only. The average
incremental cost per ton for treating these soils is assumed to be the same as for
CERCLA soil ($19/ton). Thus, the increased cost is $0.5 million per year for state
superfund cleanups (130,000 tons/year x .20 x $19/ton) and $2 million for voluntary
cleanups (510,000 tons/year x .20 x $19/ton).
-1 C
-------
Exhibit 3-7
Increased Contaminated Soil and Sediment Treatment Costs under Phase IV
For TC Metal-Contaminated Soils and Sediments
Remediation Category
CERCLA Remedial Action Soil
RCRA Corrective Action Soil
RCRA Closures Soil (Landfills)
State Superfund Soil
Voluntary Cleanup Soil
CERCLA Sediment
RCRA Corrective Action Sediment
Totals
Tons Treated
Ex-SituOutside
dKfiMJsafiOCs
140,000
110,000
50,000
130,000
510,000
60,000
30,000
940,000
Percent
Exhibiting TC
For Metals
Only'
25%
7%
7%
20%
20%
22%
7%
N/A
Additional
Treatment
CostPerTon
$19
$0
$0
$19
$19
$0
$0
N/A
Incremental Cost of
Phase IV for TC
Metals Only Media
$0.7 million/yr.
-
-
$0.5 million/yr.
$2 million/yr.
-
-
$3.2 million/yr.
* Reflects only volumes treated ex-situ.
As explained in Section 2.8, the model predicted no incremental costs for
treating RCRA soils and sediments that exhibit the TC for metals, primarily because of
the small volume of RCRA media projected to be incinerated/thermally desorpted in the
baseline. EPA, however, does expect some low level of incremental costs for these
RCRA soils. EPA believes that the incremental costs will be substantially lower for
RCRA soil than for CERCLA soil because RCRA soils are generally less highly
contaminated than CERCLA soils. Furthermore, a significantly smaller share of RCRA
soil is TC for metals only and contains organic UHCs. To the extent that there are
incremental costs at RCRA soil and sediment cleanups, this analysis underestimates
the overall cost of the Phase IV rule.
The relatively low level of incremental treatment costs is consistent with the new
site-specific variance from the technology-based new soil treatment standards for soils
with concentrations above levels that can be shown to minimize threats to human
health and the environment. This variance could potentially exempt from the new soil
standards soils that, in absence of the variance, would have to be treated to below site-
specific risk-based cleanup levels. Thus, the variance may decrease the incremental
costs associated with the new LDR requirements for some TC metal only soils.
However, some TC metal soils will have to be treated to levels lower than the site-
specific risk-based cleanup levels applied in the baseline because the minimal threat
Chapter 3: Results
Page 3-17
-------
levels under the LDR variance will be more stringent. For example, current cleanup
levels, but not the minimal threat levels, may take into account the effectiveness of
engineering and institutional controls in reducing risk.
3.4.1 Potential Incremental Costs In Absence of the CAMU Rule
The results described above for CERCLA remedial actions assume that the
CAMU rule is completely effective and 36 percent of ex-situ CERCLA soil (180,000
tons/year) is treated in CAMUs. The CAMU rule allows for the movement,
consolidation, and treatment of hazardous wastes within designated areas without
triggering the LDRs. Thus, contaminated media managed within CAMUs would be
unaffected by the Phase IV rule. If the CAMU rule was not in place, the additional
CERCLA soil volumes affected by Phase IV would increase by 180,000 tons per year
(or 129 percent) from 140,000 to 320,000 tons per year. Thus, the incremental costs
for CERCLA remedial actions would increase by $0.8 million/year to $1.5 million/year.
3.5 Summary of Costs/Cost Savings for Media Impacts of Phase IV LDR Rule
As shown in Exhibit 3-8, the total impacts of the Phase IV LDR Rule as it applies
to contaminated media are estimated to be an overall savings of approximately $22
Exhibit 3-8: Summary of Costs/Cost Savings for Phase IV LDR Rule
Soil/Sediment Impacts
Affected
Volumes
(tons per year)
Baseline Costs
(million $ per year)
Post-Regulatory
Costs
(million $ per year)
Incremental
Cost/Cost Savings
(million $ per year)
New Soil Treatment Standards
TC Organic Soils
Listed (non-TC) Soils
Soils below 10xUTS
Subtotal
7,000
8,000
75,000
90,000
6.9
8.7
19.9
36
3.0
3.8
4.1
11
(3.9)
(4.9)
(15.8)
(25)
TC Metal Contaminated Soil/Sediment
Soil w/ Organic UHCs1
TOTAL
163,000
253,000
57.7
94
60.8
72
3.1
(22)
TC Metal contaminated sediments showed negligible costs, mineral processing waste contaminated media showed no impacts, as did
groundwater and debris which are contaminated with wastes addressed in this rule. Totals are rounded
1 The baseline and post-regulatory costs for TC metal contaminated soils were calculated using the average baseline treatment cost for
CERCLA soils of $354 per ton, and the incremental difference in costs identified in section 2.8 as $19 per ton.
million per year. This overall savings is made up of an estimated savings for the new
soil treatment standards applied to previously regulated wastes contaminating soil of
approximately $25 million per year, and a cost for TC Metal contaminated soils with
, ~4-^r O-
-------
organic underlying hazardous constituents present of $3 million per year. (See also
Exhibit 3-1 for more complete overview of the cost estimates.) These figures are
rounded to the nearest million dollars. While a sensitivity analysis has not been
performed on the many assumptions employed for this assessment, the total cost
savings estimated for the rule is obviously subject to many uncertainties. These
uncertainties are discussed in section 2.10 of this document.
In order to estimate the overall costs for the entire Phase IV LDR Rule, including
process waste impacts and Manufactured Gas Plant (MGP) contaminated media,
please see the preamble for the Phase IV LDR Final Rule.
Chapters: Results Page 3-19
-------
CHAPTER 4. ECONOMIC IMPACTS
This chapter discusses the economic impacts of the Phase IV rule on industry
and analyzes whether a regulatory flexibility analysis (RFA) is required. The chapter
contains the following sections:
Section 4.1 reviews the requirements for an RFA;
Section 4.2 projects the overall number of firms with increased
costs under Phase IV;
Section 4.3 describes the projected distribution of these affected
firms across different industry sectors;
Section 4.4 estimates the number of small affected firms in each
industry;
Section 4.5 estimates the economic impacts of Phase IV on
affected small firms; and
Section 4.6 explains why Phase IV will not impose significant
economic impacts on a substantial number of small entities.
This chapter focuses on the economic effects of soil cleanups performed under
CERCLA, state superfund, and voluntary cleanups because this analysis predicted that
facilities performing cleanups under RCRA would not see significant additional costs as
a result of this rule. While EPA recognizes that treatment costs at some RCRA sites
will increase, it believes that the majority of the increased costs of Phase IV as it relates
to contaminated media will be at CERCLA, state superfund, and voluntary sites and
thus focuses on these cleanups. Additionally, this chapter only examines the
incremental costs of the Phase IV rule and not the cost savings related to the new soil
treatment standards for contaminated soil.
4.1 Requirements for a Regulatory Flexibility Analysis
The Regulatory Flexibility Act of 1980, as amended by the Small Business
Regulatory Enforcement Fairness Act, requires federal agencies to assess whether
proposed regulations will have a significant economic impact on a substantial number
of small entities. According to EPA's Interim Guidance for Implementing the Small
Business Regulatory Enforcement Fairness Act and Related Provisions of the
Regulatory Flexibility Act, an RFA is required for any notice and comment rule unless
the Agency certifies that the rule will not have a significant economic impact on a
-------
substantial number of small entities.40 Because EPA does not expect that the Phase IV
rule will have an effect on a substantial number of small entities, an RFA was not
prepared.
4.2 Number of Entities With Increased Costs
In order to estimate the economic impacts of Phase IV, EPA first estimated the
overall number of firms that will see increased costs. As discussed earlier, the Agency
believes that of the sites in the database, approximately 1,108 could potentially have
increased costs per year as a result of Phase IV: 30 CERCLA remedial actions, 464
state superfund cleanups, and 614 voluntary soil cleanups per year. In order to
estimate the number of firms that could potentially have increased costs from these
cleanups, the number of cleanups in each cleanup program was multiplied by the
average number of responsible parties per site, using the following assumptions:
For CERCLA remedial actions, an average of 10 firms are
responsible for each cleanup. This assumption is based on the
results of EPA's Remedial Project Manager survey, which indicates
that about 60 percent of nonfederal sites have 10 or fewer
potentially responsible parties and about 40 percent of such sites
have more than 10 potentially responsible parties.
For state superfund and voluntary cleanups, one firm is assumed
to be responsible for the cleanup of a whole site. In reality, more
than one firm may be responsible and, consequently, this analysis
may slightly underestimate the number of firms with increased
costs as a result of Phase IV but conversely overestimate the
average costs per firm. Firms may also be responsible for cleaning
up more than one site, which would result in this analysis
overestimating the number of firms with increased costs but
underestimating the average incremental costs.
Additionally, for CERCLA sites, six of the 300 entities affected were assumed to
be local governments responsible for operating municipal solid waste landfills
(MSWLFs) and were thus excluded from the universe of affected small firms. This
figure of six sites was calculated by assuming that 23 percent of all CERCLA remedial
action sites previously operated as MSWLFs, as indicated by EPA's NPL
Characterization Database (which includes all CERCLA cleanups through 1991).
Therefore, the annual number of CERCLA remedial actions that would have previously
operated as MSWLFs is approximately seven (30 x 0.23). Not all these sites, however,
will involve a local government because approximately 80 percent of all MSWLFs
40 U.S. EPA, "Interim Guidance for Implementing the Small Business Regulatory Enforcement Fairness Act and
Related Provisions of the Regulatory Flexibility Act," February, 1997.
Page 4-2 Chapter 4: Economic Impacts
-------
nationwide are owned or operated by local governments.41 Thus, the estimated number
of local governments that may be affected by Phase IV is approximately six (7 x .8).
The effects of the Phase IV rule on these entities are discussed further in Section 4.7.
This number may slightly underestimate the actual number of local governments
affected by this rule because:
This estimate does not incorporate local government responsibility
for sites that are not MSWLFs;
It does not account for small governments that are responsible for
state superfund and voluntary cleanups; and
Some MSWLFs operated by local governments will have several
local governments as owners and operators. For example, all the
cities in a county may be responsible for cleanups at a county
MSWLF.
As shown in Exhibit 4-1, the estimated total number of entities potentially
affected by Phase IV at CERCLA, state superfund, and voluntary cleanups is 1,372.
This number includes cleanups performed by both private and public (i.e., federal)
entities.
Exhibit 4-1
Annual Number of Entities With Increased Costs Under Phase IV
Type of Cleanup
CERCLA Remedial Action
State Superfund
Voluntary
Total
Sites
Potentially
Affected
30
464
614
1,108
Entities
Potentially
Affected
294
464
614
1,372
Entities
Actually
Affected
8
13
17
38
41 Directory and Atlas of Solid Waste Disposal Facilities, 1994, First Edition, Ehartwell Information
Publishers. According to this directory, in 1994 about 72 percent of all MSWLFs were owned by governments. In this
analysis, the number was rounded up to 80 percent because the portion of MSWLFs owned by governments has been
steadily declining from about 80 percent in 1986 and most CERCLA remedial action sites were contaminated prior to
1986.
Pano 4.
-------
Of these 1,372 entities, only a small portion will see increased costs due to
higher treatment costs for TC metal soil. To determine the actual number of affected
entities, EPA applied the percentage of CERCLA sites affected by Phase IV, as
determined by the analysis of the sample sites in the soil and sediment database, to
the 1,372 firms potentially affected by Phase IV. Nine sites out of the 326 CERCLA
sites (2.8 percent) in the database were predicted to see increased costs. As shown in
Exhibit 4-1, applying this percentage to the total number of entities potentially affected
yields an annual total of 38 entities with increased costs due to Phase IV requirements.
To determine the total number of entities with increased costs, EPA used a five-
year planning horizon. As explained in Section 2.4, the Agency used the five-year
planning estimate because of the uncertainties associated with longer-term projections
and the pace with which the rule will be fully implemented and reflected in the use of
different treatment methods. Longer-term projections are subject to substantial
uncertainties, such as government remediation and enforcement budgets, potential
changes in the Superfund statute and budget, and the demand for restoring
economically valuable contaminated properties (e.g., Brownfields). Thus, over the five
years following implementation of this rule, the total number of entities expected to be
adversely affected will be 190 (38 x 5).
4.3 Distribution of Affected Entities Across Different Industries
To estimate the distribution of industries and firms responsible for cleanups at
CERCLA, state superfund, and voluntary cleanup sites, EPA used a database compiled
by Resources For the Future (RFF). The database was developed as part of a study
estimating the distribution of cleanup costs among responsible parties and the
Superfund trust fund under a series of alternative liability scenarios.42 The database
contains data on 1,134 non-federal National Priority List (NPL) sites obtained from the
Remedial Project Manager survey conducted by EPA in August 1993 and other
sources, including EPA's NPL Characterization Database, the Comprehensive
Environmental Response, Compensation, and Liability Information System (CERCLIS),
state books of NPL sites, and the Site Enforcement Tracking System (SETS)
Database43 For each site, the industries most likely to be responsible for cleanup
costs were identified. The estimated number and percent of CERCLA remedial action
sites per industry, as shown by this data, are presented in Exhibit 4-2.^
42 Probst, K.N. et al, Footing the Bill for Superfund Cleanups: Who Pays and How?, The Brookings Institution
and Resources for the Future, Washington, D.C., 1995.
43 The RFF study also identifies 123 federal NPL sites. No data were collected on these sites, however.
44 EPA did not believe that the industries of the firms identified by the database were representative of the
industries expected to be affected by this rule for three reasons. First, remedies at the sites included in the
database have already been approved and, in many cases, have already been completed. Second, because the numb
affected facilities in the database is so small, it is unlikely that these firms are representative of the
(continued...)
Page 4-4 Chapter 4: Economic Impacts
-------
As calculated in Section 4.2, an estimated 190 firms will be adversely affected by
the Phase IV requirements over the period covered by this analysis. These firms were
apportioned to specific industries based on the percentage of CERCLA remedial action
sites in each industry. Because data on the industries responsible for state superfund
cleanups and voluntary cleanups are not readily available, EPA assumed that the
distribution of firms responsible for these cleanups is the same as that of firms
responsible for CERCLA remedial actions. The results of this apportionment are shown
in Exhibit 4-2. Industries most affected by the changes include:
Chemicals and allied products (SIC 28);
Wholesale trade, durable goods (SIC 50); and
Fabricated metal products (SIC 34).
Approximately 30 percent of the CERCLA sites were not attributed to a specific
industry. For this analysis, EPA chose to keep these sites separate because the
industries responsible for these cleanups are unknown. An alternative would be to
apportion the non-attributed sites to the industries in proportion to the percentage of
attributed sites in each industry. Even if EPA took this later approach, the conclusion
that the new rule does not pose a significant economic impact on a substantial number
of small firms would not change because the number of small firms with significant
economic impacts will remain small (see Section 4.6).
4.4 Number of Affected Small Firms In Each Industry
The next step in the analysis was to estimate the number of affected small firms
in each industry. This analysis uses the Small Business Administration (SBA) definition
of a small business. The SBA defines small businesses at the four-digit SIC code level,
generally in terms of number of employees or annual revenues. Because the available
data on the firms responsible for CERCLA remedial actions are at the two-digit SIC
level, this analysis identifies the number of affected firms at the two-digit SIC code
level. The SBA definition that was most prevalent among the four-digit SIC codes
under each two-digit SIC code was used to define small firms in each industry.
44 (...continued)
industries that will be affected in the future. Third, it is difficult to identify all the firms or industries
responsible for each site because of the age of the contamination and the large number of firms involved.
Additionally, Chemical Waste Management submitted data to EPA indicating a number of industries expected to be
affected by the Phase IV rule with respect to process waste. EPA did not use this data for the analysis of
contaminated media because the Agency believes that there are significant differences between the makeup,
management, and treatment of the two types of hazardous waste.
-------
Exhibit 4-2
Distribution of Firms Affected per Year by Industry
SIC
Code
07
10
12
13
14
17
20
22
23
24
25
26
28
29
30
31
32
33
34
35
36
37
38
40
42
45
47
49
50
72
Industry
Agricultural Services
Metal Mining
Coal Mining
Oil and Gas Extraction
Nonmetallic Minerals,
Except Fuels
Special Trade Contractors
Food and Kindred Product
Textile Mill Products
Apparel and Other Textile
Products
Lumber and Wood Produc
=urniture and Fixtures
Paper and Allied Products
Chemicals and Allied
Products
Petroleum and Coal Prodi
Rubber and Miscellaneous
Plastic Products
Leather and Leather
Products
Stone, Clay, and Glass
3roducts
Primary Metal Industries
Fabricated Metal Products
ndustrial Machinery and
Equipment
Electronic and Other
Electric Equipment
Transportation Equipment
nstruments and Related
3roducts
Railroad Transportation
Trucking and Warehousing
Transportation by Air
Transportation Services
Electric, Gas, and Sanitary
Services
Wholesale Trade, Durable
Goods
Personal Services
Percent of
CERCLA
Remedial
Action Sites
0.2%
0.7%
0.7%
0.7%
0.7%
0.3%
> 0.5%
0.5%
0.5%
:s 3.8%
0.5%
0.5%
13.6%
cts 2.0%
0.5%
0.5%
0.5%
2.9%
6.0%
0.2%
4.6%
0.5%
0.5%
0.3%
0.3%
0.3%
0.3%
0.3%
8.7%
0.2%
CERCLA, State
Superfund, and
foluntaryCleanup
Sites
2
9
9
9
9
4
6
6
6
52
6
6
187
27
6
6
6
40
82
2
64
6
6
4
4
4
4
4
119
3
Entities
Affected by
Phase IV
0
1
1
1
1
1
1
1
1
7
1
1
26
4
1
1
1
6
11
0
9
1
1
1
1
1
1
1
16
0
SmallFirmsAffecte<
Upper
Bound
NA
1
1
1
1
1
1
1
1
7
1
1
24
3
1
1
1
5
11
0
8
1
1
0
0
0
1
0
16
0
Lower
Bound
NA
0
0
0
1
0
0
0
0
4
0
0
5
0
0
0
0
1
6
0
2
0
0
0
0
0
0
0
9
0
Page 4-6
Chapter 4: Economic Impacts
-------
Exhibit 4-2 (continued)
Distribution of Firms Affected per Year by Industry
SIC
Code
75
80
82
87
92
95
97
99
Industry
Automotive Repair,
Services, and Parking
Health Services
Educational Services
Engineering and Managerr
Services
Public Administration
Justice, Public Order, and
Safety
Public Administration
Environmental Quality and
Housing
Public Administration
National Security and
International Affairs
Nonclassifiable
Establishments
Not Attributed
Orphan
Federal
Total2
Percent of
CERCLA
Remedial
Action Sites
0.2%
0.2%
0.2%
ent 0.2%
0.3%
0.3%
0.3%
1 .3%
29.4%
6.6%
9.7%
100.0%
CERCLA, State
Superfund, and
t/bluntaryCfeanup
Sites
3
3
3
3
5
5
5
17
404
91
133
1,372
Entities
Affected by
Phase IV
0
0
0
0
1
1
1
2
56
13
18
190
SmallFirmsAffectec
Upper
Bound
0
0
0
0
NA
NA
NA
NA
NA
NA
NA
93
Lower
Bound
0
0
0
0
NA
NA
NA
NA
NA
NA
NA
34
1 Estimates taken from Probst, K.N. et al., Footing the Bill for Superfund Cleanups: Who Pays and How?,
The Brookings Institution and Resources for the Future, Washington, D.C., 1995. In some cases, estimates
were provided for a group of 2 digit SIC codes. The facilities in these groups have been equally
apportioned among the relevant SIC codes.
2 Totals may not match due to rounding.
na /1_~7
-------
Because EPA cannot predict specific entities that will be affected by Phase IV;
the number of small affected firms could not be determined directly. Instead, the
Agency first collected Census data on the distribution of facilities by employee or
revenue size categories (e.g., 1 to 4 employees or $100,000 to $249,999 in annual
revenues). Appendix B presents the following data by size category for all of the
potentially affected industries:
Number of firms;
Total annual revenues;
Total employment; and
Market share.
Tables B-1 through B-4 show these data for the industries where small entities
are defined by the number of employees. Tables B-5 though B-8 show these data for
the industries where small entities are defined by their annual revenues. Tables B-9 to
B-14 presents the same data on a per-firm level: average revenues, average
employment, and average market share by industry and size category. In these
appendices, the size categories that correspond with small entities are not shaded and
the size categories that correspond with non-small entities are shaded.
EPA apportioned the affected entities in each industry into the various size
categories under two scenarios, thus developing a range for the number of affected
small firms in each industry. To project the upper bound of this range, the Agency
assumed that the affected firms were distributed among the various size categories in
proportion to the distribution of all firms within the industry in each size category.
Under this assumption, the total number of affected firms in a specific industry in a
specific size category is equal to the percentage of firms in the industry that are in this
size category multiplied by the total number of affected firms in the industry. Under this
assumption, Appendix B, Tables B-15 and B-16 show the distribution of affected firms
by industry and size category under this assumption.
EPA considers this assumption to be an upper bound for the number of affected
small firms because the size of a firm is not taken into account in the apportionment.
Instead, all firms in a particular industry are assumed to have an equal probability of
being responsible for cleanup costs. However, many of the waste management
practices that may result in the responsibility for cleanup costs take place only at
relatively large firms. For example, a significant portion of the firms that are
responsible for cleanups have or had on-site waste management units. In general,
only larger firms have such units. To the extent that the waste management practices
at larger firms are more likely to result in the responsibility for cleanup than the waste
management practices at smaller firms, the assumption that affected firms are
distributed among size categories in proportion to the distribution of firms within the
industry in each size category will overestimate the number of affected firms in the
smaller size categories.
Page 4-8 . ' Chapter 4: Economic Impacts
-------
To estimate the lower bound of the range, EPA assumed that the affected firms
were distributed among the various size categories in proportion to the distribution of
revenues within the industry in each size category (i.e., proportional to the market
share for each size category). Under this assumption, the total number of affected
firms in a specific industry in a specific size category is equal to the market share for
that size category multiplied by the total number of affected firms in the industry. This
assumes that smaller firms (in terms of revenue) have a lower probability of being
responsible for cleanup costs. There are many reasons to believe that revenues are
directly related to the probability that a firm will be responsible for cleanup costs. In
general, EPA believes the lower bound to be a more accurate representation of the
number of affected small businesses because:
Revenues and production are directly correlated;
Production and waste generation are positively correlated; and
To the extent that firms that generate larger quantities of waste are
more likely to be responsible for cleanup costs, then revenue and
the probability that a firm will perform a cleanup are directly
correlated.
This estimate is a lower bound, however, because many other factors that may
influence whether a firm will be responsible for cleanup costs do not depend on size.
Appendix B, Tables B-17 and B-18 show the distribution of affected firms by industry
and size category under the lower bound assumption.
Exhibit 4-2 presents the total number of affected small businesses in each
industry under both the upper bound and lower bound assumptions. The Agency
expects this number to range from 34 to 93. As shown, this estimate is sensitive to the
assumption regarding how the affected firms are distributed throughout an industry.
The total upper bound estimate is almost three times the lower bound estimate. The
difference between the upper and lower bound assumptions varies by industry. In
some industries (e.g., metal mining, transportation equipment), the upper bound
estimate may be five or ten times larger than the lower bound estimate but in other
industries, particularly in many service industries, the two estimates are much closer.
4.5 Estimating Economic Effects On Affected Small Firms
The final step of the analysis was to estimate the incremental costs for affected
small firms as a percentage of revenue. To estimate incremental costs for each small
firm, EPA divided the total annual expected incremental cost of Phase IV on cleanup
sites ($3.2 million) by the expected annual number of affected entities (38). The
resulting total incremental cost per firm is approximately $84,000. EPA then amortized
this cost over 20 years because the costs of cleanup corrective will be incurred over
many years in the future.
Chapter 4: Economic Impacts Page 4-9
-------
The rationale for discounting is presented in further detail in EPA's RIA
guidance.45 The 20-year time period was chosen in order to be consistent with other
EPA and Office of Solid Waste RIAs. Furthermore, EPA used a seven percent discount
rate. Although there is no single, correct discount rate, the seven percent real discount
rate was selected because it approximates the marginal pre-tax rate of return on an
average investment in the private sector in recent years. The seven percent rate is
appropriate for cost analyses of public investments and regulatory programs that
imposes costs on the general public. Public investment and regulations displace both
private investment and consumption; the seven percent discount rate accounts for this
displacement.46
When annualized over 20 years using a discount rate of seven percent, the
annual cost to each firm is approximately $8,000. EPA believes that this estimate
represents an upper bound because it assumes that all firms, regardless of size, will
have the same incremental cleanup cost. In reality, small firms are likely to have lower
costs because they are less likely to be responsible for the larger, more expensive,
cleanups than large firms.
In order to determine if this rule will significantly impact small firms, EPA
calculated the annual compliance costs as a percentage of sales revenue for each
industry. Appendix B, Tables B-9 and B-12 present the average annual revenues by
industry and firm size category. Exhibit 4-3 shows, for each industry category with at
least one firm projected to be affected, the average annual compliance costs as a
percentage of revenue for small firms. The exhibit shows that under the upper bound,
all affected small firms except for two are projected to have annual cleanup costs that
are less than one percent of total annual revenue. Thus, EPA projects that very few
firms will have significant economic effects due to the Phase IV rule. Under the lower
bound projection, zero small firms will have cleanup costs that are more than one
percent of total annual revenue.
45 U.S. EPA, Office of Policy Analysis. Guidelines for Performing Regulatory Impact Analysis: Appendix C -
Analysis of the Choice of Discount Rates. 1989.
46 Office of Management and Budget. Guidelines and Discount Rates for Benefit-Cost Analysis of Federal
Programs - Circular A-94, October 29, 1992, page 9.
Page 4-10 Chapter 4: Economic Impacts
-------
Exhibit 4-3
Annual Revenue and Cost of Phase IV as Percentage of Revenue*
SIC Code
07
10
12
13
14
17
20
22
23
24
25
26
28
29
30
31
32
33
34
36
37
38
47
50
Total
Upper Bound
EsthHteof Number
of Small Firms
Affected
NA
1
1
1
1
1
1
1
1
7
1
1
24
3
1
1
1
5
11
8
1
1
1
16
93
Lower Bound
Estimate of
NumberofSmal
FirmsAffected
NA
0
0
0
1
0
0
0
0
4
0
0
5
0
0
0
0
1
6
2
0
0
0
9
34
AnnuaJSates
Revenue
NA
2,453
4,883
2,017
2,017
417
7,071
4,485
1,717
1,520
2,064
7,357
7,759
11,906
4,133
2,313
2,337
6,448
2,783
3,837
3,362
3,239
352
3,741
NA
AnnualCostas
aPercentage
of Sales
Revenue
NA
0.3%
0.2%
0.4%
0.4%
1.5%
0.1%
0.2%
0.5%
0.5%
0.4%
0.1%
0.1%
0.1%
0.2%
0.3%
0.3%
0.1%
0.3%
0.2%
0.2%
0.2%
2.3%
0.2%
NA
Only industry categories that EPA projects will have at least one firm affected
are shown.
Chapter 4: Economic Impacts
Page 4-11
-------
4.6 Why Phase IV Does Not Impose Significant Economic Impacts On a
Substantial Number of Small Entities
To determine if the economic impacts of Phase IV on small entities are
significant on a substantial number of small entities, EPA used criteria specified in its
"Interim Guidance for Implementing the Small Business Regulatory Enforcement
Fairness Act and Related Provisions of the Regulatory Flexibility Act."47 Based on this
guidance, EPA does not expect that the Phase IV rule will impose significant economic
impacts on a substantial number of small firms or governments. As shown in
Exhibit 4-3, the predicted total number of affected small firms over the next five years
ranges from 34 to 93. Even if the high end of the range is used and all affected firms
are assumed to have significant economic impacts, the total number of small entities
experiencing any type of economic impact will not be substantial (e.g., more than
100).48 Additionally, as shown in Exhibit 4-2, EPA expects that a wide variety of
industries will be affected and that no particular industry will bear the brunt of the costs.
Finally, the Agency demonstrated in Section 4.5 that it is unlikely that any small firms
affected by the rule will experience annual economic impacts greater than one percent
of their annual revenues.
With respect to small governments, the Agency estimated in Section 4.3 that
each year, six local governments could potentially be affected by these requirements.
Thus, over the five years covered by this analysis, 30 local governments could be
affected by Phase IV However, the Agency believes that a substantial number of small
governments will not be adversely affected by these requirements because:
Most of the potentially affected governments will not see increased
costs because only 2.8 percent of all cleanup sites are expected to
be affected by Phase IV; and
Only a portion of all governments responsible for MSWLFs will
meet the RFAs of small governments.
Because a substantial number of small firms or governments are not expected to
experience significant economic impacts, the Agency did not perform a regulatory
flexibility analysis for this rule.
4.7 Why Phase IV Does Not Impose Significant Economic Impacts On a
Substantial Number of Large Firms
47 See Table 2, p. 1-18, "Interim Guidance for Implementing the Small Business Regulatory Enforcement
Fairness Act and Related Provisions of the Regulatory Flexibility Act," February 1997.
"8 Additionally, for many of the firms with increased costs, the economic impact will not be substantial.
Because the total number of affected firms is expected to be less than 100, economic impacts on these firms were not
analyzed.
Page 4-12 Chapter 4: Economic Impacts
-------
The previous section explained why EPA does not expect that the Phase IV rule
will impose significant economic impacts on small firms. The Agency does not expect
that the rule will significantly impact large firms either. Depending on the how small
and large firms are defined, the number of large firms affected could range from five to
64. This range was estimated by subtracting from the total number of entities affected
(190) non-firm entities (federal, orphan, non-attributed entities, total number 92) and
small firms (34 to 93).
EPA does not believe that these large firms will be significantly affected by the
rule because:
The analysis predicted the same incremental cleanup costs for
large firms as for small firms (annualized cost of approximately
$8,000), as explained in Section 4.5; and
These costs will be spread over a higher annual revenue than for
small firms, resulting in smaller costs as a percentage of revenue.
As the previous section showed that very few firms will likely be significantly impacted,
the Agency believes that no large firms will see significant economic impacts as a result
of this rule.
Chapter 4: Economic Impacts Page 4-13
-------
APPENDIX A: SOIL AND SEDIMENT DATABASE
EPA compiled a database containing available soil and sediment data on
existing CERCLA remedial action and RCRA corrective action sites, as reported in
CERCLA Records of Decision (RODs) and several databases compiled for analyses of
RCRA corrective action initiatives. (Detailed data were not available for other
remediation programs.) The data for each site include contaminated soil and/or
sediment volumes for a distinct segment of the cleanup and the types and maximum
concentrations of hazardous constituents present. Because detailed data on sediment
contamination at RCRA corrective action sites were not available, the impact of Phase
IV on the management of sediment at RCRA sites was derived from data for CERCLA
remedial action sediment and RCRA corrective action soil. This appendix describes
the development and content of the database.
CERCLA Records of Decision
CERCLA RODs summarize sampling data collected for CERCLA remedial
investigations and feasibility studies, define goals for remediation, analyze remediation
options, and document the remedy selection. EPA reviewed all RODs signed in federal
fiscal years 1989 through 1996 and contained in the Agency's Headquarter's collection
of RODs. Each ROD was examined for data on contaminated soil and sediment.
Because the circumstances differ from site to site, the number of RODs pertinent to
each category of data differed. In addition, a single ROD may pertain to several
distinct volumes of remedial waste with different contamination levels, or a single site
can have more than one ROD. The database is organized around particular volumes
of remedial action waste with their own constituent and constituent concentration data,
which are called "sites" for the purposes of the database.
The types of RODs data used to develop components of the soil and sediment
database and particular issues or limitations associated with these data are discussed
below.
Soil and Sediment Type. RODs generally identify contaminated soil,
contaminated sediment, mixtures of contaminated soil and sediment, and mixtures of
contaminated soil and/or sediment with old wastes and/or debris. EPA partitioned
mixed soil and sediment volumes. Volumes described as soil or sediment mixed with
debris accounted for only negligible volumes in the RODs, and were not partitioned, but
were counted as soil or sediment.49
49 EPA's National Sediment Management Strategy (U.S. EPA Office of Water, August 1994) reports that the most
frequently reported contaminants in sediments are heavy metals and metalloids, PCBs, and AHCs (page 4). These
same contaminant types also predominate in CERCLA RODs sediment data.
iy A- .9n/7 pnrY .9prY/Vrj<=nf Dptehp.ซ?p Paae A-1
-------
[This page intentionally left blank]
-------
Amount of Soil and Sediment Managed. The volumes reported in the RODs and
contained in the database are those volumes that are planned to be managed. There
may be some difference between the volumes planned to be managed and the volumes
actually managed. A brief analysis of predicted management volumes versus actual
management volumes at 12 sites indicated that the RODs may underestimate volumes
by approximately 20 percent.50 These differences, however, should not bias the
analysis overall, and would be difficult to correct without the scope of this analysis.
The RODs volume data were not used to estimate the amount of soil and
sediment treated annually and potentially affected by Phase IV. Instead, a variety of
other data sources were used to estimate the amount of contaminated soil and
sediment treated annually under various remediation programs (see Section 2.4). ROD
volume data, however, were used as a representative sample of the contamination at
CERCLA, state superfund, and voluntary cleanup sites and therefore were critical
inputs in calculating the portion of soil and sediment treated using various treatment
methods and the resulting average treatment wastes under changes in baseline and
Phase IV treatment costs.
Maximum Constituent Concentrations. Most RODs contained maximum
constituent concentration data. These actual maximum concentrations and the
modeled variation in concentration across the site were used to assign treatment
technologies. CAS numbers were added to the constituents to eliminate problems,
such as synonyms and typographical errors associated with constituent names.
Concentration data for constituent groups (e.g., total volatile organic compounds) were
not used in analyses because RCRA treatment standards apply to specific constituents.
In summary, while the RODs data do have some limitations (e.g., data errors in
the RODs, incomplete records, and other inconsistencies), EPA believes that these
limitations do not bias data obtained from the RODs. Moreover, the estimates used in
the Phase IV media analysis are also based on other data sources.
RCRA Corrective Action RIA Databases
To estimate the annual volume of contaminated soil and sediment remediated at
RCRA corrective action facilities and to characterize the contamination at these
facilities, EPA primarily used data from three databases compiled for analyses of the
RCRA corrective action initiatives:
The remedial database;
The RCRA Facility Investigation (RFI) database; and
50 Memorandum to Lyn Luben, U.S. Environmental Protection Agency, from ICF Incorporated entitled "Updates on
Contaminated Media and Debris Data," November 5, 1993, pages 4-8.
Page A-2 Appendix A: Soil and Sediment Database
-------
The Solid Waste Management Unit (SWMU) database.51
These databases do not overlap with the CERCLA RODs data since they address
RCRA corrective action facilities only, excluding CERCLA, state superfund, and
voluntary cleanup sites. All three databases contain data on individual SWMUs at a
stratified random sample of 79 RCRA corrective action facilities. The corrective action
RIA methodology used weighting factors or facility weights for each stratum of the
sample to extrapolate data and results from sample facilities to national-level totals so
that the corrective action data can be presented at the SWMU, facility, or national level.
Subsequently, EPA supplemented the corrective action data, compiled from the
remedial, RFI, and SWMU databases, with data collected from RCRA corrective action
Statements of Basis (SBs).
The remedial database contains information on the corrective action
management methods for each SWMU at facilities in the corrective action RIA sample.
These data, compiled in order to estimate the costs of corrective action, were
generated using expert panels assembled by EPA to decide the most appropriate
remedy for each SWMU. In addition to specifying remedial activities, the expert panels
identified, for each SWMU, the timing and duration of cleanup, the media addressed,
and the cost of the cleanup. When contaminated media or other remedial waste were
projected to be excavated as part of the remediation, the expert panels estimated the
media or other remediation waste volumes. Subsequently, volumes also were
estimated for wastes managed in-situ. Although the database identifies the type of
media or other remedial waste addressed by most of the remedial activities, media are
not specifically identified for non-treatment (containment) remedies. Important
limitations of these volume estimates are described below.
The RFI database contains information on contaminated media for SWMUs with
a release of at least one hazardous constituent at a concentration above Subpart S
action levels. EPA collected the data from mock RCRA Facility Investigation (RFI)
packets that were used by expert panels to select appropriate remedies. In turn, data
in the mock RFI packets were collected from available source documents (e.g., RFIs,
RCRA Feasibility Assessments, or other site studies), or modeling results. Relevant
data elements include the volume and type of media exceeding action levels and the
maximum concentrations of constituents in the media. Because these data were
collected from a wide variety of sources, full data sets are not available for all SWMUs.
The SWMU database contains data characterizing the physical characteristics of
each SWMU and the waste it contains. The sources of these data are the same
sources used to compile the RFI packet database (i.e., available facility studies and
other documents). These data were collected in order to model contaminant releases
at each facility and to prepare mock RFI packets for the expert panels. Data fields in
51 See "Draft Regulatory Impact Analysis for the Final Rulemaking on Corrective Action for Solid Waste
Management Units: Proposed Methodology for Analysis," U.S. EPA, Office of Solid Waste, March 1993.
Aooendix A: Soil and Sediment Database Paae A-3
-------
the SWMU database used in Phase IV contaminated media analyses include the
constituents present in the unit and the central tendency value of constituent
concentrations in the waste, as originally generated. The estimates of original waste
concentrations, however, are highly uncertain. Moreover, the concentration data do not
represent current waste concentrations because they do not reflect the effect of
leaching, volatilization, hydrolysis, and other fate processes that would deplete
constituent mass from the wastes. The Phase IV analysis did not use these constituent
concentration data, but instead used the RFI database concentration data.
The balance of this section describes the types of Corrective Action RIA data
used to project the treatment of contaminated soil and sediment remediated at RCRA
corrective action facilities and how EPA used SBs to supplement these data. It also
discusses particular issues or limitations associated with the data.
Facility Weights. The corrective action RIA analyzes a sample of facilities,
consisting of two separately selected samples: a federal facility sample and a non-
federal facility sample. The two samples were constructed separately using different
sampling designs. Both samples were stratified and sampled in order to reflect the
composition of the potentially affected universe of RCRA Subtitle C facilities and to
over-sample facilities likely to require corrective action. When facility-specific data
(e.g., volume of remediated soil) for all 79 sample facilities are multiplied by facility
weights and the products are summed across facilities, the result is a nation-wide
estimate for all facilities subject to RCRA corrective action authorities.
So/7 and Sediment Type. SWMUs with soil contamination were identified based
on remedy codes in the remedial database. Soil, soil mixed with sediment, unspecified
waste (which may include soil as well as old process waste), and soil mixed with waste
were included. EPA has assumed that soil mixed with sediment or old waste is likely to
be managed in a similar manner to soil. Thus, mixed volumes of soil and sediment or
old waste were not partitioned into individual soil and sediment volumes.
Volume of Soil and Sediment Managed. Data on the volume of contaminated
media were gathered from the remedial database. Because data on volumes of
remediated media, based on monitoring data or engineering estimates indicating the
actual volume of contaminated material at a facility, were rarely available, all volumes
are estimated. Volumes of media managed ex-situ were estimated by expert panels.
In-situ volumes were estimated based on information available from the expert panel
and from SWMU dimensions. Because volumes are not based on actual remediation
records, but estimated using assumptions about the area and depth of contamination at
a sample of SWMUs, sampling error and errors in the assumed extent of contamination
may cause the volume of media to be over- or under-estimated.
Hazardous Constituents. The RFI database and the SWMU database contain
constituent names and CAS numbers. Because modeling for EPA's corrective action
Page A-4 Appendix A: Soil and Sediment Database
-------
analyses was limited to five or fewer constituents per SWMU, some SWMUs contain
additional constituents that do not appear in the databases.
Constituent Concentrations. The RFI database identifies maximum
concentrations detected in soil or sediment, but only for the constituents detected
above RCRA Subpart S action levels. No concentration data are available for 66
percent of the total volume addressed by corrective action. EPA considered
supplementing RFI concentration data with concentration data from the SWMU
database by assuming that soil concentrations equaled the central tendency (i.e.,
typical) constituent concentrations in the waste, as originally generated. However,
because these concentrations do not reflect dilution that occurs as spilled wastes mix
with soil, nor do they reflect the effect of leaching, volatilization, hydrolysis, and other
fate processes that would reduce concentration in the soil, they are likely to
overestimate the maximum concentrations in soil. EPA therefore used only RFI data
for which actual concentrations were present.
Subsequently, EPA reviewed data contained in the current universe of SBs to
identify additional data on remediation waste volumes and corresponding constituent
concentrations to supplement the corrective action sites that were dropped from the two
original samples due to insufficient data. Since the two original corrective action
samples, compiled from the remedial, RFI, and SWMU databases, were stratified
random samples extrapolated to national levels, EPA incorporated data from the SBs
into the analysis in a way that preserves these conventions.
First, EPA determined the appropriate sample (federal or non-federal) and strata
(based on the original sample design) to which each SB belongs. Next, EPA
supplemented the new sites into the appropriate sample and strata. Finally, EPA
calculated and applied new facility weights for extrapolating to national levels based on
the new distribution of sites by strata. In all, EPA supplemented the corrective action
samples with data from 16 SBs that provided data on both remediation waste volumes
and corresponding constituent concentrations.
Complete Soil and Sediment Database
The complete database contains data on 535 soil and sediment sites (or
particular volumes) with approximately 44 million tons of contaminated media. The 535
sites include 326 CERCLA sites with approximately 9 million tons of contaminated soil,
88 CERCLA sites with just under one million tons of contaminated sediment, and
121 RCRA corrective action sites with 34 million tons of contaminated soil.
Appendix A: Soil and Sediment Database PageA-5
-------
Exhibits A-1 and A-2 describe the types of contamination found at all CERCLA
soil and sediment and RCRA soil database sites, including volumes treated in and ex-
situ and within or outside of CAMUs and AOCs. Exhibit A-1 shows that about 75
percent of each category of site is contaminated with metals, the most common
contaminant. Organics are much more prevalent at CERCLA sites than RCRA sites.
For example, while 62, 61, and 48 percent of CERCLA soil sites contain AHCs, SVOCs,
and VOCs, respectively, only 3, 29, and 30 percent of RCRA soil sites have soil
contaminants, respectively. Thus, as shown in Exhibit A-2, only 3 percent of RCRA soil
sites have 3 or 4 types of contaminants. In contrast, 49 percent of CERCLA soil sites
have 3 or 4 types of contaminants. These differences result in much higher average
treatment costs at CERCLA soil sites ($307/ton) than at RCRA soil sites ($170/ton).
Exhibit A-1
Constituents Found at Database Sites
(Percent of Overall Database Volume)
Constituents
Metals
VOCs
SVOCs
AHCs
CERCLA Soil
73%
48%
61%
62%
RCRA Soil
75%
30%
29%
3%
CERCLA
Sediment
74%
22%
40%
51%
Totals exceed 100 percent because volumes are often contaminated with several types of
constituents (e.g., both metals and VOCs).
Exhibit A-2
Multiple Types of Constituents at Database Sites
(Percent of Overall Database Volume)
Number of
Constituent
Types*
One
Two
Three
Four
Totals**
CERCLA Soil
24%
28%
29%
20%
100%
RCRA Soil
67%
30%
3%
0%
100%
CERCLA
Sediment
42%
29%
17%
12%
100%
The constituent types are metals, VOCs, SVOCs, and AHCs.
Totals may not add to 100% due to rounding.
Page A-6
Appendix A: Soil and Sediment Database
-------
Exhibit A-3 identifies the prevalence of different baseline treatment methods at
all database sites, including volumes treated in- and ex-situ. The allocation of volumes
to ex-situ treatment methods, however, is designed to reflect volumes treated outside of
CAMUs or AOCs, since volumes treated in CAMUs or AOCs are not directly affected by
Phase IV. (See also Exhibit 3-1, which presents more detail on the baseline treatment
methods.) Consistent with Exhibits A-1 and A-2, immobilization is the most common
treatment method, and organics treatment technologies are used considerably more
often at CERCLA sites than RCRA sites. In addition, incineration seldom occurs at
RCRA soil sites for several reasons. A minority of RCRA sites are contaminated with
organics. Most of these volumes have relatively low concentrations of organics and
therefore treated by other technologies. In addition, most of this contamination is at
high volumes, which are treated in-situ.
Exhibit A-3
Baseline Treatment Methods at Database Sites
(Percent of Overall Database Volume)
Treatment Technology
CERCLA
Soil
RCRA
Soil
CERCLA
Sediment
Ex-Situ Treatment
Immobilization
Soil Wash
Dechlorination
Bioremediation
Incineration/Thermal Desorption
44%
27%
17%
15%
10%
57%
3%
<1%
15%
<1%
74%
29%
10%
38%
18%
In-Situ Treatment
Immobilization
Vacuum Extraction
Bioremediation
29%
28%
11%
18%
30%
13%
Totals exceed 100 percent because volumes are often treated by
multiple technologies (e.g., incineration or thermal desorption ion).
Appendix A: Soil and Sediment Database
Page A-7
-------
Exhibits A-4 and A-5 show the prevalence of different treatment methods for TC
organics and TC metals only soils in both the baseline and post-rule scenarios. The
use of in-situ treatment methods is not presented because it is not directly affected by
this rule. Consistent with Sections 3.2 and 3.4, Exhibit A-4 shows a slight shift away
from incineration toward other ex-situ treatment methods and Exhibit A-5 shows a slight
shift toward incineration. Additionally, as the analysis predicts that treatment of
sediments and RCRA soils will not be significantly affected by Phase IV, the volumes of
these media being treated by the different technologies are not expected to change
significantly.
Exhibit A-4
Ex-Situ Treatment Methods For TC Organic Soils At
CERCLA and RCRA Database Sites
(Percent of TC Organic Soil Volume)
Ex-Situ Treatment
Technology
Immobilization
Soil Wash
Bioremediation
Dechlorination
Incineration/Thermal
Desorption
CERCLA Soil
Baseline
21%
21%
1%
21%
23%
Post Reg
28%
24%
1%
24%
20%
RCRA Soil
Baseline
35%
15%
35%
0%
0%
Post Reg
35%
15%
35%
0%
0%
* Totals may exceed 100 percent because some volumes are treated by multiple
technologies (e.g., incineration followed by stabilization) and may be less than 100
percent because ex-situ volumes are being compared to total volume.
Page A-8
Appendix A: Soil and Sediment Database
-------
Exhibit A-5
Ex-Situ Treatment Methods at CERCLA and RCRA Database Sites
For TC Metal-Only Soils
(Percent of TC Metal Only Soil Volume)
Ex-Situ
Treatment
Technology
Immobilization
Soil Wash
Bioremediation
Dechlorination
Incineration/Thermal
Desorption
CERCLA Soil
Baseline
40%
4%
10%
4%
11%
Post Reg
39%
4%
9%
4%
12%
RCRA Soil
Baseline
96%
0%
1%
0%
0%
Post Reg
96%
0%
1%
0%
0%
* Totals may exceed 100 percent because some volumes are treated by multiple
technologies (e.g., incineration followed by stabilization) and may be less than
100 percent because ex-situ volumes are being compared to total volume.
EPA did not prepare a table showing treatment methods for non-TC soils
because the agency was unable to determine the specific technologies used due to
data limitations. The primary data limitation was that CERCLA RODs and RCRA
corrective actions data only provided the maximum concentration at the entire site (i.e.
no concentration data was provided for soil subsets at each site).
Appendix A: Soil and Sediment Database
Page A-9
-------
APPENDIX B:
SUPPLEMENTAL ECONOMIC IMPACT ANALYSIS TABLES
Page B-1
-------
[This page intentionally left blank]
-------
Table B-1
Total Number of Firms by Industry and Size Category
(for those industries where small entities are defined by number of employees)
SIC Code
10
12
13
14
20
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
44
45
50
51
0
Employees
119
226
1,686
317
1,551
535
3,333
4,377
961
201
5,160
625
65
930
148
957
323
2,205
3,577
- 1,329
920
692
1,778
1,341
809
24,153
15,947
1-4 Employees
237
394
8,691
1,093
3,853
1,023
5,595
12,903
3,189
546
24,208
2,218
249
2,389
564
3,464
940
7,604
15,646
3,420
2,896
2,852
6,213
2,959
2,207
104,893
61 ,597
5-9 Employees
67
278
2,582
760
2,688
665
3,393
7,059
1,840
520
13,005
1,458
174
1,876
275
2,226
713
5,902
10,476
2,251
1,613
1,738
3,077
1,236
867
51,217
27,431
10-19
Employees
39
350
1,531
634
2,525
697
3,401
5,222
1,663
696
8,231
1,298
142
2,188
246
2,187
838
6,090
9,246
2,109
1,440
1,543
2,345
Not Available
797
663
35,440
19,559
20-99
Employees
52
528
1,329
622
3,755
1,301
5,231
4,589
2,290
1,496
7,818
1,802
265
3,901
397
2,605
1,537
8,417
9,569
3,685
1,994
2,078
2,567
668
633
28,015
18,442
100-499
Employees
32
98
233
202
1,369
583
1,449
873
614
587
1,546
681
155
1,345
142
569
688
2,084
2,024
1,421
731
799
589
215
212
' *:^Sfฃ:..,
.... :....9&fo*:
500+
Employees
^.^^Ll^iL
* s Wvt V>
v, ?jซ\.V:..\l..
, <-&4,Uy
ซ. v>"-""'V'f B3p^\0'^ ^ '
" % ttJJKt^ ^ "v'\
,- ;r$0งPY
$-->?isl^r ;
\^;.3^|iS* ;
J pf-YY$:
.5Y&&^:
lff!SN~l:
-il^^l*.^;
; ^ I^F'!;,*
..^ ...9$h..^.'
..!.ซ, .?il!.\^...^.'
;rl .33|f*o.
^ซ; &ii|lVฃ
^j^j&^^l;
t i^^tlf*
^fM?|Nte^;
T ]5 ^wf1
r;i:;;^1^;8:
; "l^ss^^^r
ฃ ,:,:;-J|ซff|v
':'ฅ|;$$f.:i::;:'
^..:ji ^^Jlll
^:K..iyi!P.^^
Small Entities
546
1,874
16,052
3,628
15,741
4,804
22,402
35,023
10,557
4,046
59,968
8,082
1,050
12,629
1,772
12.008
5,039
32,302
50,538
14,215
9,594
9,702
16,569
7,216
5,391
243,718
142,976
Non-Small
Entities
63
80
214
153
648
305
371
302
233
286
562
578
143
690
73
333
463
828
1,014
733
467
511
220
150
216
6,544
5,360
Total
609
1,954
16,266
3,781
16,389
5,109
22,773
35,325
10,790
4,332
60,530
8,660
1,193
13,319
1,845
12,341
5,502
33,130
51,552
14,948
10,061
10,213
16,789
7,366
5,607
250,262
148,336
Percent
Small
Entities
90%
96%
99%
96%
96%
94%
98%
99%
98%
93%
99%
93%
88%
95%
96%
97%
92%
98%
98%
95%
95%
95%
99%
98%
96%
97%
96%
-------
Table B-2
Total Annual Revenues by Industry and Size Category
(for those industries where small entities are defined by number of employees)
SIC
Code
10
12
13
14
20
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
44
45
50
51
0
Employees
31,830
173,549
496,081
98,544
912,141
266,692
875,123
944,011
260,172
239,606
911,123
565,953
109,596
330,157
26,774
220,218
227,105
731,714
790,786
597,041
673,716
321,195
273,252
1-4
Employees
45,039
232,975
4,359,628
363,966
1,690,030
277,952
1,211,433
3,270,049
526,855
181,436
4,432,933
1,423,730
356,360
767,752
127,313
919,903
328,498
1,751,153
2,786,230
909,957
671,120
706,795
1,139,191
5-9
Employees
34,500
299,674
4,342,625
580,704
3,265,633
503,210
1 ,568,433
4,763,588
903,740
459,950
6,131,977
2,472,556
591,630
1,345,317
145,290
1,567,693
611,418
3,552,353
5,494,984
1 ,649,233
1,109,044
1,319,275
1,630,004
10-19
Employees
51,657
963,918
3,992,345
984,611
5,880,978
1,007,201
3,222,009
6,814,884
1,686,660
1,249,892
8,717,980
4,746,396
871,176
3,259,600
254,017
3,516,154
1 ,445,255
7,778,455
10,932,103
3,009,811
2,175,656
2,333,792
2,841,250
20-99
Employees
301,315
4,388,286
10,343,423
2,588,421
35,665,784
6,230,946
14,232,475
20,091,068
8,367,832
9,905,604
29,294,288
20,275,810
3,792,784
19,389,796
1,615,314
12,002,673
9,591,195
37,488,219
39,656,749
17,434,410
9,681,439
10,047,360
9,481,805
100-499
Employees
875,080
3,091,963
8,849,069
2,699,692
63,884,099
13,262,181
17,362,357
17,366,593
10,043,136
17,729,508
31,414,600
33,220,608
6,779,758
27,102,654
1,929,170
9,836,090
20,287,470
38,581,626
41,475,612
30,940,157
17,946,569
16,698,917
10,139,340
500+
Employees
'"WW$
w$mw
?a,$s$,?s2
.W&jjto
*0*#&m
$2ฃ22#24
mmm..
W#KM$*
.^M$il36
:*&#&#&
mm$&*
2*$4*M&
i4%#$ฃ&
**ฃ0M*2
. ฃ$3งi6$
ป*&&&*&
{mm$&
*iฃ*!$d*>
w.301,642
iซM$M9b
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iwsm&6
i&8&&ป.
Not Available
329,843
354,127
14,746,705
13,662,126
1,088,704
714,743
122,860,032
104,823,507
1,140,395
652,855
132,422,997
116,281,214
1 ,290,672
960,401
175,084,096
148,305,664
3,579,228
3,106,322
466,685,917
403,990,587
5,424,054
5,164,782
244,0?$,$$?
\astjmjm
1ftฃl*#&
mm$?i
mmw
626,46$30S
Small
Entities
1,339,421
9,150,365
32,383,171
7,315,938
111,298,665
21,548,182
38,471,830
53,250,193
21,788,395
29,765,996
80,902,901
62,705,053
12,501,304
52,195,276
4,097,878
28,062,731
32,490,941
89,883,520
101,136,464
54,540,609
32,257,544
31 ,427,334
25,504,842
Non-Small
Entities
9,077,375
15,725,190
73,558,752
7,605,263
306,269,534
52,622,924
32,100,457
34,260,036
24,131,138
106,955,030
90,082,597
275,463,450
142,255,322
68,386,162
5,930,363
37,395,232
114,763,783
84,637,868
166,361,642
169,137,480
402,041 ,287
102,251,936
15,533,528
Total
10,416,796
24,875,555
105,941,923
14,921,201
417,568,199
74,171,106
70,572,287
87,510,229
45,919,533
136,721,026
170,985,498
338,168,503
154,756,626
120,581,438
10,028,241
65,457,963
147,254,724
174,521,388
267,498,106
223,678,089
434,298,831
133,679,270
41,038,370
12,852,896
10,953,230
911,799,747
787,063,098
18,516,820
126,854,871
770,340,856
934,541,965
31,369,716
137,808,101
1,682,140,603
1,721,605,063
Percent of
Revenues at
Small
Entities
13%
37%
31%
49%
27%
29%
55%
61%
47%
22%
47%
19%
8%
43%
41%
43%
22%
52%
38%
24%
7%
24%
62%
41%
8%
54%
46%
-------
Table B-3
Total Employment by Industry and Size Category
(for those industries where small entities are defined by number of employees)
SIC Code
10
12
13
14
20
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
44
45
50
51
0
Employees
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1-4 Employees
445
894
17,498
2,484
9,099
2,371
12,837
28,872
7,245
1,302
55,398
5,107
561
5,655
1,205
7,813
2,188
17,840
35,962
7,659
6,509
6,536
13,683
6,269
4,659
231 ,662
131,774
5-9 Employees
431
1,890
16,834
5,118
18,074
4,510
22,843
46,970
12,421
3,596
85,520
9,812
1,156
12,827
1,834
15,044
4,878
40,074
70,443
15,339
10,879
1 1 ,660
20,546
8,101
5,676
338,884
181,133
10-19
Employees
529
4,889
20,567
8,577
34,310
9,729
47,108
70,413
22,905
9,879
110,306
17,634
1,835
30,398
3,340
29,745
1 1 ,541
83,464
125,699
28,838
19,367
21,063
31,732
Not Available
10,477
8,811
471 ,884
258,675
20-99
Employees
2,136
20,342
50,869
20,170
155,512
59,847
226,482
177,938
96,873
66,881
307,577
71,200
8,551
167,757
17,581
99,445
65,354
340,077
367,539
160,228
83,220
84,065
102,594
24,779
24,289
993,631
656,108
100-499
Employees
5,037
16,366
35,735
18,168
241 ,005
113,839
263,878
136,180
103,566
99,426
263,457
104,872
13,039
228,271
23,514
79,788
119,519
315,270
297,671
244,840
123,492
128,246
94,528
29,422
33,745
: ifcil^? *;'
_jซSy>55_ฃ
500+
Employees
. ^&*"-:L
^II^M-.
"IgT^.x.;;:
- **ป$& >
<.f$8ftM.
- ' 451,737. '*
:: r^f^"
.!..'.:J?35^|*fr.K^.
ซ* $&$$:&>
,^n$^fe^
!".lSto'.''
.rWj&XJ-'5'
/ .124J&A::'
I::.': SOB^f
J-- ;..8J(?1*,j:f!
.. .- awjwor-**:
-:,,ซp$*r;;t
x..fiijp$$xf!
Y^^P^
.:*1$M$Mฃ
v.m8b$:*
.;?.$$%$$
s*4$7j&il:
;-9&1*M
* ?ซ*$&$;
.:.; t^^fty
^ijf^yi^t
Small Entities
8,578
44,381
141,503
54,517
458,000
190,296
573,148
460,373
243,010
181,084
822,258
208,625
25,142
444,908
47,474
231 ,835
203,480
796,725
897,314
456,904
243,467
251,570
263,083
79,048
77,180
2,036,061
1 ,227,690
Non-Small
Entities
44,221
77,828
187,489
49,792
1,163,565
451,777
432,558
230,337
243,416
493,869
758,338
897,006
124,355
506,658
61,711
265,740
476,513
613,790
985,307
1,113,413
1 ,482,553
699,743
127,265
90,147
699,144
1,587,164
1,407,569
Total
52,799
122,209
328,992
104,309
1,621,565
642,073
1 ,005,706
690,710
486,426
674,953
1,580,596
1,105,631
149,497
951 ,566
109,185
497,575
679,993
1,410,515
1 ,882,621
1,570,317
1 ,726,020
951,313
390,348
169,195
776,324
3,623,225
2,635,259
Percent of
Employment
at Small
Entities
16%
36%
43%
52%
28%
30%
57%
67%
50%
27%
52%
19%
17%
47%
43%
47%
30%
56%
48%
29%
14%
26%
67%
47%
10%
56%
47%
-------
Table B-4
Market Share by Industry and Size Category
(for those industries where small entities are defined by number of employees)
SIC
Code
10
12
13
14
20
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
44
45
50
51
0
Employees
0.31%
0.70%
0.47%
0.66%
0.22%
0.36%
1 .24%
1 .08%
0.57%
0.18%
0.53%
0.17%
0.07%
0.27%
0.27%
0.34%
0.15%
0.42%
0.30%
0.27%
0.16%
0.24%
0.67%
1-4
Employees
0.43%
0.94%
4.12%
2.44%
0.40%
0.37%
1.72%
3.74%
1.15%
0.13%
2.59%
0.42%
0.23%
0.64%
1 .27%
1.41%
0.22%
1 .00%
1.04%
0.41%
0.15%
0.53%
2.78%
5-9
Employees
0.33%
1 .20%
4.10%
3.89%
0.78%
0.68%
2.22%
5.44%
1 .97%
0.34%
3.59%
0.73%
0.38%
1.12%
1 .45%
2.39%
0.42%
2.04%
2.05%
0.74%
0.26%
0.99%
3.97%
10-19
Employees
0.50%
3.87%
3.77%
6.60%
1.41%
1 .36%
4.57%
7.79%
3.67%
0.91%
5.10%
1 .40%
0.56%
2.70%
2.53%
5.37%
0.98%
4.46%
4.09%
1 .35%
0.50%
1 .75%
6.92%
20-99
Employees
2.89%
17.64%
9.76%
17.35%
8.54%
8.40%
20.17%
22.96%
18.22%
7.25%
17.13%
6.00%
2.45%
16.08%
16.11%
18.34%
6.51%
21.48%
14.83%
7.79%
2.23%
7.52%
23.10%
100-499
Employees
8.40%
12.43%
8.35%
18.09%
15.30%
17.88%
24.60%
19.85%
21 .87%
12.97%
18.37%
9.82%
4.38%
22.48%
19.24%
15.03%
13.78%
22.11%
15.51%
13.83%
4.13%
12.49%
24.71%
500+
Employees
*m$w\.
^msm
* 6&43%'r
, mm^r
.ฃ3<35%-:
w$m"":
:^4Mm
mt$% - :
Mx5S% '
*&$?&::'
'5ฃJB8%
ซ1^%:
"31*3%
'5&T1%
&$&:
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mm%--
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Not Available
1 .05%
0.26%
0.88%
0.79%
3.47%
0.52%
7.30%
6.09%
3.64%
0.47%
7.87%
6.75%
4.11%
0.70%
10.41%
8.61%
11.41%
2.25%
27.74%
23.47%
17.29%
3.75%
: 414,58%
rm&m
:^mm%^
. yqfflpgx
.:&$$&<'
......^^,.....
Small
Entities
12.86%
36.78%
30.57%
49.03%
26.65%
29.05%
54.51%
60.85%
47.45%
21 .77%
47.32%
18.54%
8.08%
43.29%
40.86%
42.87%
22.06%
51 .50%
37.81%
24.38%
7.43%
23.51%
62.15%
Non-Small
Entities
87.14%
63.22%
69.43%
50.97%
73.35%
70.95%
45.49%
39.15%
52.55%
78.23%
52.68%
81.46%
91 .92%
56.71%
59.14%
57.13%
77.94%
48.50%
62.19%
75.62%
92.57%
76.49%
37.85%
Total
100.00%
100.00%
100.00%
100.00%
100.00%
100.00%
100.00%
100.00%
100.00%
100.00%
100.00%
100.00%
100.00%
100.00%
100.00%
100.00%
100.00%
100.00%
100.00%
100.00%
100.00%
100.00%
100.00%
40.97%
7.95%
54.20%
45.72%
59.03%
92.05%
45.80%
54.28%
100.00%
100.00%
100.00%
100.00%
-------
Table B-5
Total Number of Firms by Industry and Size Category
(for those industries where small entities are defined by annual revenues)
SIC Code
07
15
16
17
41
42
47
49
55
65
67
70 ex 704
72
73
75
76
80
823, 824, 829
87 ex 8733
89
90 to 99
Less than
$250,000
$250,000 -
$499,999
$500,000 -
$999,999
$1,000,000-
$2,499,999
$2,500,000 -
$4,999,999
$5,000,000+
Not Available
82,120
13,369
217,495
7,424
37,017
21,106
3,810
21,055
98,171
7,237
17,890
112,601
119,721
72,193
36,463
150,440
10,016
107,041
6,135
30,360
6,299
63,788
2,050
15,118
4,987
1,121
22,349
38,203
2,146
6,518
17,562
37,001
31,637
10,576
115,694
2,471
31,986
1,873
22,977
5,134
41,362
1,530
1 1 ,220
2,884
799
24,693
25,768
1,984
4,792
7,681
25,812
15,270
5,832
63,069
1,466
21,186
1,292
18,746
5,651
28,889
1,263
9,231
1,879
763
27,818
16,357
2,018
3,637
3,252
18,936
5,902
3,228
32,910
967
14,992
804
7,066
2,920
9,531
485
3,799
610
503
10,391
4,360
953
1,452
773
6,755
1,096
802
10,621
365
4,939
241
Mite
^$fi&fc .
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.<:m-'v--
ฎ*9$& rst
..^#86$:.:,
:fel $&$??'**
-:!.jj
*3M*v*:
;.. -'m^
;: Wr:-:
^.$8&s -;i"
..:"" i$n!?
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Not Available
Small
Entities
Non-Small
Entities
Total
161,269
33,373
361,065
12,752
76,385
31 ,466
6,996
106,306
182,859
14,338
34,289
141,869
208,225
126,098
56,901
372,734
15,285
180,144
10,345
7,138
3,807
6,198
377
3,303
496
1,601
18,492
3,224
1,563
1,446
490
6,069
698
503
10,079
242
4,271
200
168,407
37,180
367,263
13,129
79,688
31,962
8,597
124,798
186,083
15,901
35,735
142,359
214,294
126,796
57,404
382,813
15,527
184,415
10,545
Percent Small
Entities
96%
90%
98%
97%
96%
98%
81%
85%
98%
90%
96%
100%
97%
99%
99%
97%
98%
98%
98%
-------
Table B-6
Total Annual Revenues by Industry and Size Category
(for those industries where small entities are defined by annual revenues)
SIC Code
07
15
16
17
41
42
47
49
55
65
67
70 ex 704
72
73
75
76
80
23, 824, 82
87 ex 8733
89
90 to 99
Less than
$250,000
$250,000 -
$499,999
$500,000 -
$999,999
$1,000,000-
$2,499,999
$2,500,000 -
$4,999,999
$5,000,000+
Not Available
8,936,162
1,501,197
22,823,944
705,582
4,558,384
2,347,927
379,320
3,023,297
11,052,518
611,946
2,140,573
10,592,008
12,722,507
9,577,698
4,200,715
22,003,542
968,201
1 1 ,463,570
640,851
10,600,313
2,259,805
22,408,166
727,662
5,343,330
1,722,070
390,864
8,175,642
13,484,418
764,027
2,305,686
6,049,579
13,032,720
11,027,478
3,685,003
40,932,245
871,158
11,241,736
658,431
16,084,235
3,637,836
28,741,511
1,054,267
7,880,728
1,995,506
559,132
17,698,291
17,964,663
1 ,405,907
3,344,564
5,228,054
18,014,282
10,351,271
4,017,121
43,104,472
1,014,984
14,767,233
902,875
28,686,776
8,834,980
43,744,777
1,928,248
14,363,741
2,858,796
1,175,172
43,608,072
24,456,853
3,184,398
5,595,322
4,741,407
28,935,640
8,458,945
4,805,497
49,866,711
1,485,690
22,894,717
1,221,718
24,257,294
10,356,805
32,790,304
1,664,233
13,155,791
2,139,558
1,822,953
36,199,405
14,856,414
3,318,583
5,015,128
2,641,495
23,279,361
3,700,059
2,713,716
36,507,348
1 ,270,875
17,056,973
833,257
1$im43$
nw,$i9
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Not Available
Small Entities
Non-Small
Entities
Total
88,564,780
26,590,623
150,508,702
6,079,992
45,301,974
11,063,857
4,327,441
108,704,707
81,814,866
9,284,861
18,401,273
29,252,543
95,984,510
43,115,451
19,422,052
192,414,318
5,610,908
77,424,229
4,257,132
131,666,435
71,937,559
69,816,558
6,286,129
95,316,195
12,358,546
306,189,087
408,291,760
55,879,608
54,946,219
49,143,862
12,375,823
171,373,042
24,519,645
10,391,042
424,082,612
4,245,637
125,104,753
3,245,853
220,231,215
98,528,182
220,325,260
12,366,121
140,618,169
23,422,403
310,516,528
516,996,467
137,694,474
64,231,080
67.545,135
41 ,628,366
267,357,552
67,635,096
29,813,094
616,496,930
9,856,545
202,528,982
7,502,985
Percent
Revenues
at Small
Entities
40%
27%
68%
49%
32%
47%
1%
21%
59%
14%
27%
70%
36%
64%
65%
31%
57%
38%
57%
-------
Table B-7
Total Employment by Industry and Size Category
(for those industries where small entities are defined by annual revenues)
SIC Code
07
15
16
17
41
42
47
49
55
65
67
70 ex 704
72
73
75
76
80
823, 824, 829
87 ex 8733
89
90 to 99
Less than
$250,000
$250,000 -
$499,999
$500,000 -
$999,999
$1,000,000-
$2,499,999
$2,500,000 -
$4,999,999
$5,000,000+
Not Available
151,617
29,001
469,653
31,057
82,201
65,170
9,777
40,333
184,529
22,133
56,441
378,217
383,454
168,131
81,260
385,276
36,227
240,388
11,927
117,006
33,726
356,137
25,981
81,339
34,686
5,420
71,838
142,377
5,877
60,304
169,574
313,784
170,015
56,484
576,448
21,873
177,208
8,386
132,650
47,566
408,152
35,358
109,975
32,287
6,323
127,440
172,908
8,716
87,362
126,585
416,607
149,076
55,038
560,729
21 ,806
205,441
9,832
168,848
94,814
546,694
55,938
174,000
41,041
10,087
235,282
218,239
17,112
146,764
107,755
690,982
107,920
57,942
751 ,370
27,964
294,176
10,930
116,722
92,646
353,599
41,981
137,308
26,644
11,613
158,373
124,582
14,480
133,652
60,809
528,702
41 ,547
28,880
658,297
22,948
208,740
7,471
410,0.16 .
- $&&& '
: 037.784 .
J5&&V.::
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moos .
O$tQ$0:
3S1426--::
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Not Available
Small
Entities
Non-Small
Entities
Total
686,843
297,753
2,134,235
190,315
584,823
199,828
43,220
633,266
842,635
68,318
484,523
842,940
2,333,529
636,689
279,604
2,932,120
130,818
1,125,953
48,546
410,016
501 ,669
637,764
155,315
958,955
120,132
869,002
1,257,050
357,426
98,938
969,018
325,335
3,035,773
191,841
134,100
6,991,416
56,674
1 ,234,999
28,964
1,096,859
799,422
2,771,999
345,630
1 ,543,778
319,960
912,222
1,890,316
1,200,061
167,256
1,453,541
1,168,275
5,369,302
828,530
413,704
9,923,536
187,492
2,360,952
77,510
Percent
Employment at
Small Entities
63%
37%
77%
55%
38%
62%
5%
34%
70%
41%
33%
72%
43%
77%
68%
30%
70%
48%
63%
-------
Table B-8
Market Share by Industry and Size Category
(for those industries where small entities are defined by annual revenues)
SIC Code
07
15
16
17
41
42
47
49
55
65
67
70 ex 704
72
73
75
76
80
823, 824, 829
87 ex 8733
89
90 to 99
Less than
$250,000
$250,000 -
$499,999
$500,000 -
$999,999
$1,000,000-
$2,499,999
$2,500,000 -
$4,999,999
$5,000,000+
Not Available
4.06%
1 .52%
10.36%
5.71%
3.24%
10.02%
0.12%
0.58%
8.03%
0.95%
3.17%
25.44%
4.76%
14.16%
14.09%
3.57%
9.82%
5.66%
8.54%
4.81%
2.29%
10.17%
5.88%
3.80%
7.35%
0.13%
1 .58%
9.79%
1.19%
3.41%
14.53%
4.87%
16.30%
12.36%
6.64%
8.84%
5.55%
8.78%
7.30%
3.69%
13.05%
8.53%
5.60%
8.52%
0.18%
3.42%
13.05%
2.19%
4.95%
12.56%
6.74%
15.30%
13.47%
6.99%
10.30%
7.29%
12.03%
13.03%
8.97%
19.85%
15.59%
10.21%
12.21%
0.38%
8.43%
17.76%
4.96%
8.28%
1 1 .39%
10.82%
12.51%
16.12%
8.09%
15.07%
1 1 .30%
16.28%
11.01%
10.51%
14.88%
13.46%
9.36%
9.13%
0.59%
7.00%
10.79%
5.17%
7.42%
6.35%
8.71%
5.47%
9.10%
5.92%
12.89%
8.42%
11.11%
4:;;$&?$%^
.73MM%!8
* ^4ปK!*
$wtm;:i.
ซ*%'
;: 88,79%
i-"$6;$f&
-...n#t%-:
^m$$%.::
,.e$j4%-::
^7&7$%.'
2$.73%v.
:::::$4ฃiO%.
>$**$% #
-H*8%Vi
\$$.7$%j*
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Not Available
Small
Entities
Non-Small
Entities
Total
40.21%
26.99%
68.31%
49.17%
32.22%
47.24%
1 .39%
21 .03%
59.42%
14.46%
27.24%
70.27%
35.90%
63.75%
65.15%
31.21%
56.93%
38.23%
56.74%
59.79%
73.01%
31.69%
50.83%
67.78%
52.76%
98.61%
78.97%
40.58%
85.54%
72.76%
29.73%
64.10%
36.25%
34.85%
68.79%
43.07%
61.77%
43.26%
100.00%
100.00%
100.00%
100.00%
100.00%
100.00%
100.00%
100.00%
100.00%
100.00%
100.00%
100.00%
100.00%
100.00%
100.00%
100.00%
100.00%
100.00%
100.00%
-------
Table B-9
Average Annual Revenues by Industry and Size Category
(for those industries where small entities are defined by number of employees)
I
SIC Code
10
12
13
14
20
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
44
45
50
51
0
Employees
267
768
294
311
588
498
263
216
271
1,192
177
906
1,686
355
181
230
703
332
221
449
732
464
154
1-4
Employees
190
591
502
333
439
272
217
253
165
332
183
642
1,431
321
226
266
349
230
178
266
232
248
183
5-9
Employees
515
1,078
1,682
764
1,215
757
462
675
491
885
472
1,696
3,400
717
528
704
858
602
525
733
688
759
530
10-19
Employees
1,325
2,754
2,608
1,553
2,329
1,445
947
1,305
1,014
1,796
1,059
3,657
6,135
1,490
1,033
1,608
1,725
1,277
1,182
1,427
1,511
1,513
1,212
20-99
Employees
5,795
8,311
7,783
4,161
9,498
4,789
2,721
4,378
3,654
6,621
3,747
11,252
14,312
4,970
4,069
4,608
6,240
4,454
4,144
4,731
4,855
4,835
3,694
100-499
Employees
27,346
31,551
37,979
13,365
46,665
22,748
1 1 ,982
19,893
16,357
30,204
20,320
48,782
43,740
20,151
13,586
17,287
29,488
18,513
20,492
21,774
24,551
20,900
17,214
500+
Employees
:,mw5
'""tlB^'t
: mzm
:-v*$rt$C
;-*w$py=
y*ti$$s#":
''::i':d8*S2'4: i
*$&'$&*
;,:*esite;
xgJiwS ,i7M$< I : '
Vp&^pN.
'^ISr^^io- .
it;ซiป
'i$8fc$3!$;:,'-:
"1?8IJSSSi&r.
"$^$$8*'"
i?mt3m$:
abiMปid
^mimz
':t38,74P.:
x-m&iijr;.:
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t^mmm
Not Available
246
438
611
857 __,
368
324
1,171
1,702
923
753
2,586
4,239
1,619
1,449
4,940
7,582 _,
5,358
4,907
16,658
21,906
25,228
24,362
":r $*#*!
!!$fflL..>
; *mm$M:
;:;i$tefrH
%ฎ&ฎm*-
'imwm& <
Small
Entities
2,453
4,883
2,017
2,017
7,071
4,485
1,717
1,520
2,064
7,357
1,349
7,759
1 1 ,906
4,133
2,313
2,337
6,448
2,783
2,001
3,837
3,362
3,239
1,539
Non-Small
Entities
144,085
196,565
343,732
49,708
472,638
172,534
86,524
113,444
103,567
373,969
160,289
476,580
994,792
99,110
81,238
112,298
247,870
102,220
164,065
230,747
860,902
200,102
70,607
Total
17,105
12,731
6,513
3,946
25,479
14,518
3,099
2,477
4,256
31,561
2,825
39,049
129,721
9,053
5,435
5,304
26,764
5,268
5,189
14,964
43,167
13,089
2,444
1,781
2,032
3,741
5,505
123,445
587,291
117,717
174,355
4,259
24,578
6,722
11,606
-------
Table B-10
Average Employment by Industry and Size Category
(for those industries where small entities are defined by number of employees)
SIC Code
10
12
13
14
20
22
23
24
25
26
27
28
29
30
0-1
32
33
34
35
36
37
38
39
40
44
45
50
51
0
Employees
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1-4
Employees
2
2
2
2
2
2
2
2
2
2
2
2
2
2
o
2
2
2
2
2
2
2
2
2
2
2
2
5-9
Employees
6
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
10-19
Employees
14
14
13
14
14
14
14
13
14
14
13
14
13
14
14
14
14
14
14
13
14
14
Not Available
13
13
13
13
20-99
Employees
41
39
38
32
41
46
43
39
42
45
39
40
32
43
44
38
43
40
38
43
42
40
40
37
38
35
36
100-499
Employees
157
167
153
90
176
195
182
156
169
169
170
154
84
170
188
140
174
151
147
172
169
161
160
137
159
:.. -;118 i
:.1i8 !
500+
Employees
702
97$:
"876'' "
': 32$:'
1 :1,7$&
"'J^l
:.: -:'i;1$& =:
?-liง> :'.'
.".,,"1,$i& .
'^;?t3%f:'-x-;
?|ii$i34$
3PI-!i$2
:?j?i^$$M- 1
'x::1 i-:i;f$4 -: :
:%::' ^^f^^1"'
.: :. :::**:"*
: \.J.798:.:x>..-
:!!' *:1:$2$ '
r->r 5^741
" - "$72 .
\.1JsW
= 3$f& ' .
1$S$ , '
JKHh
' ฅ-$0^ ' '/:
v-::-.$2?7 '
m
; ^ $??
Small
Entities
16
24
9
15
29
40
26
13
23
45
14
26
24
35
77
19
40
25
18
32
25
26
16
11
14
8
9
Non-Small
Entities
702
973
876
325
1,796
1,481
1,166
763
1,045
1,727
1,349
1,552
870
734
845
798
1,029
741
972
1,519
3,175
1,369
578
601
3,237
243
263
Total
87
63
20
28
99
126
44
20
45
156
26
128
125
71
59
40
124
43
37
105
172
93
23
23
138
14
18
-------
Table B-11
Average Market Share by Industry and Size Category
(for those industries where small entities are defined by number of employees)
SIC
Code
10
12
13
14
20
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
44
45
50
51
0
Employees
0.003%
0.003%
0.000%
0.002%
0.000%
0.001%
0.000%
0.000%
0.001%
0.001%
0.000%
0.000%
0.001%
0.000%
0.002%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
1-4
Employees
0.002%
0.002%
0.000%
0.002%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.001%
0.000%
0.002%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
5-9
Employees
0.005%
0.004%
0.002%
0.005%
0.000%
0.001%
0.001%
0.001%
0.001%
0.001%
0.000%
0.001%
0.002%
0.001%
0.005%
0.001%
0.001%
0.000%
0.000%
0.000%
0.000%
0.001%
0.001%
10-19
Employees
0.013%
0.011%
0.002%
0.010%
0.001%
0.002%
0.001%
0.001%
0.002%
0.001%
0.001%
0.001%
0.004%
0.001%
0.010%
0.002%
0.001%
0.001%
0.000%
0.001%
0.000%
0.001%
0.003%
20-99
Employees
0.056%
0.033%
0.007%
0.028%
0.002%
0.006%
0.004%
0.005%
0.008%
0.005%
0.002%
0.003%
0.009%
0.004%
0.041%
0.007%
0.004%
0.003%
0.002%
0.002%
0.001%
0.004%
0.009%
100-499
Employees
0.26%
0.13%
0.04%
0.09%
0.01%
0.03%
0.02%
0.02%
0.04%
0.02%
0.01%
0.01%
0.03%
0.02%
0.14%
0.03%
0.02%
0.01%
0.01%
0.01%
0.01%
0.02%
0.04%
500+
Employees
J.P&,.',-
OHTT
: :::.ซ&;::,
i#ปWl-::.:
:! ..:-.&tliฃ-
;vmWf*
&$2%--/
v:&ป->
:i;h:&ปV
v:'--$;wr
$$m
~$34% *
: fc$i%:v",:
1 &88ป.;?
.:-::.:^33t:'';i
X&ld^:!!':-
"' -1- WJP ::'
1 ; :'Qm% ,;:
saifcifSj:
^,iป-:;;;
,:<::ซ5ป^
**wimป.
...^Mfcli
Not Available
0.001%
0.000%
0.000%
0.000%
0.001%
0.000%
0.000%
0.000%
0.003%
0.001%
0.000%
0.000%
0.005%
0.001%
0.000%
0.000%
0.017%
0.004%
0.001%
0.001%
0.08%
0.02%
I tMJ0%:::
&&% :
:i;!i,&39% .:
'&&W&J
8$3* :'
:&ป;
Small
Entities
0.02%
0.02%
0.00%
0.01%
0.00%
0.01%
0.00%
0.00%
0.00%
0.01%
0.00%
0.00%
0.01%
0.00%
0.02%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
Non-Small
Entities
1.38%
0.79%
0.32%
0.33%
0.11%
0.23%
0.12%
0.13%
0.23%
0.27%
0.09%
0.14%
0.64%
0.08%
0.81%
0.17%
0.17%
0.06%
0.06%
0.10%
0.20%
0.15%
0.17%
Total
0.16%
0.05%
0.01%
0.03%
0.01%
0.02%
0.00%
0.00%
0.01%
0.02%
0.00%
0.01%
0.08%
0.01%
0.05%
0.01%
0.02%
0.00%
0.00%
0.01%
0.01%
0.01%
0.01%
0.01%
0.00%
0.00%
0.00%
0.39%
0.43%
0.01%
0.01%
0.01%
0.02%
0.00%
0.00%
-------
Table B-12
Average Annual Revenues by Industry and Size Category
(for those industries where small entities are defined by annual revenues)
SIC Code
07
15
16
17
41
42
47
49
55
65
67
70
72
73
75
76
80
823, 824, 829
87 ex 8733
89
90 to 99
Less than
$250,000
$250,000 -
$499,999
$500,000 -
$999,999
$1,000,000-
$2,499,999
$2,500,000 -
$4,999,999
$5,000,000+
Not Available
109
112
105
95
123
111
100
144
113
85
120
94
106
133
115
146
97
107
104
349
359
351
355
353
345
349
366
353
356
354
344
352
349
348
354
353
351
352
700
709
695
689
702
692
700
717
697
709
698
681
698
678
689
683
692
697
699
1,530
1,563
1,514
1,527
1,556
1,521
1,540
1,568
1,495
1,578
1,538
1,458
1,528
1,433
1,489
1,515
1,536
1,527
1,520
3,433
3,547
3,440
3,431
3,463
3,507
3,624
3,484
3,407
3,482
3,454
3,417
3,446
3,376
3,384
3,437
3,482
3,454
3,457
'I- 18.446
1&r&98 -
ttSffl*":;
*i*$tfr:-:
28.867,:-:
r :' 24f$iซ
. 191,249 .
22r079 -
I7J832"--.
35r1S4
. :33.986" V
25,257 :
28,237
35,128
23.868
42r07l
H7v$44-'
2l;2$2j :
I&228* ':
Not Available
Small
Entities
Non-Small
Entities
Total
549
797
417
477
593
352
619
1,023
447
648
537
206
461
342
341
516
367
430
412
18,446
18,896
1 1 ,264
16,674
28,857
24,916
191,249
22,079
17,332
35,154
33,986
25,257
28,237
35,128
20,658
42,076
17,544
29,292
16,229
1,308
2,650
600
942
1,765
733
36,119
4,143
740
4,039
1,890
292
1,248
533
519
1,610
635
1,098
712
-------
Table B-13
Average Employment by Industry
(for those industries where small entities are defined by annual revenues)
SIC Code
07
15
16
17
41
42
47
49
55
65
67
70
72
73
75
76
80
823, 824, 829
87 ex 8733
89
90 to 99
Less than
$250,000
$250,000 -
$499,999
$500,000 -
$999,999
$1,000,000-
$2,499,999
$2,500,000 -
$4,999,999
[Small
Entities
Not Available
2
2
2
4
2
3
3
2
2
3
3
3
3
2
2
3
4
2
2
4
5
6
13
5
7
5
3
4
3
9
10
8
5
5
5
9
6
4
6
9
10
23
10
11
8
5
7
4
18
16
16
10
9
9
15
10
8
9
17
19
44
19
22
13
8
13
8
40
33
36
18
18
23
29
20
14
17
32
37
87
36
44
23
15
29
15
92
79
78
38
36
62
63
42
31
'67: '='" =>J
mr.:|||J$2iT|;t ::.
":. 103 -..
-M:..^..
^j;;!^;^;
t3;ftif$2 ,;!:;;
. ; , ซi* :;:.:
.]f..'?Tf '* ฃ.
:v,C, ^Ik-fS,"'-'1
'!,f .y||t|:^
"^ """" '"Affc^"*^
:::.: ,ftf^ f'tffif
i'iin :^tf^lln, -::::"
!' ' :;>-$$/&- :.-;'*"
r;;;;.mii|00..;4in
...C.^Jlfi^.ni,,,,5;
"..:---2S7. ..s'S-
'L,-:...JMl.... ฃ
mmJi;m,^^,^ii^n
Mir.im.|J5|j|^iM..
':f"14B" x. ::X"
Not Available
Non-Small
Entities
Total
4
9
6
15
8
6
6
6
5
5
14
6
11
5
5
8
9.
6
5
57
132
103
412
290
242
543
68
111
63
670
664
500
275
267
694
234
289
145
7
22
8
26
19
10
106
15
6
11
41
8
25
7
7
26
12
13
7
-------
Table B-14
Average Market Share by Industry and Size Category
(for those industries where small entities are defined by annual revenues)
SIC Code
07
15
16
17
41
42
47
49
55
65
67
70 ex 704
72
73
75
76
80
823, 824, 829
87 ex 8733
89
90 to 99
Less than
$250,000
$250,000 -
$499,999
$500,000 -
$999,999
$1,000,000-
$2,499,999
$2,500,000 -
$4,999,999
$5,000,000+
Not Available
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.01%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.01%
0.00%
0.01%
0.00%
0.00%
0.00%
0.01%
0.00%
0.01%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.02%
0.00%
0.02%
0.00%
0.00%
0.00%
0.03%
0.00%
0.01%
0.00%
0.00%
0.00%
0.01%
0.01%
0.01%
0.00%
0.00%
0.01%
0.00%
0.04%
0.00%
0.05%
0,01%
9,02% ,:
&om:
9;13% ;
~mm ''
U11% '
:":OT%>
v.w% .
'-BJSflS ซ;
'Vffi#>&>'
OT% ;
:yy:v(M3$& $
' WM% II
VM% ^
$m% :
&Q1%-:-
Mm ; :
$01% v
-&22%:':'>
Not Available
Small
Entities
Non-Small
Entities
Total
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.01%
0.01%
0.02%
0.01%
0.13%
0.02%
0.11%
0.06%
0.00%
0.01%
0.05%
0.05%
0.06%
0.01%
0.05%
0.07%
0.01%
0.18%
0.01%
0.22%
0.00%
0.00%
0.00%
0.01%
0.00%
0.00%
0.01%
0.00%
0.00%
0.01%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.01%
0.00%
0.01%
-------
Table B-15
Upper Bound Estimate of Affected Firms by Industry and Size Category
(for those industries where small entities are defined by number of employees)
SIC
Code
10
12
13
14
on
zU
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
44
45
50
51
0
Employees
0
0
0
0
0
0
1
0
0
0
2
0
0
0
0
0
1
0
1
0
0
0
0
2
0
1-4
Employees
0
0
1
0
0
0
3
0
0
0
7
1
0
0
0
1
3
0
2
0
0
0
0
7
0
5-9
Employees
0
0
0
0
0
0
1
0
0
0
4
1
0
0
0
1
2
0
1
0
0
0
0
3
0
10-19
Employees
0
0
0
0
0
0
1
0
0
0
4
0
0
0
0
1
2
0
1
0
0
0
Not Available
0
2
0
20-99
Employees
0
0
0
0
0
0
1
0
0
0
5
1
0
0
0
2
3
0
2
0
0
0
0
2
0
100-499
Employees
0
0
0
0
0
0
0
0
0
0
2
0
0
0
0
1
1
0
1
0
0
0
0
0
#! $-:4:f-^
500+
Employees
V-V;. ::
":if;?$ <
. :<.-$";-: -
v ' ^rr-'j
==. :- : ' &< "
- >&$,<*:&
m- q^!j:K-
:.. .. ซ ::: ^
::.::.::: ' \f< "
1 V . $ if j
..r7"8.ff'i
Small
Entities
1
1
1
1
1
1
7
1
1
0
24
3
1
1
1
5
11
0
8
1
1
0
0
16
0
Non-
Small
Entities
0
0
0
0
0
0
0
0
0
0
2
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Total
1
1
1
1
1
1
7
1
1
0
26
4
1
1
1
6
11
0
9
1
1
0
0
16
0
Percent
Small
Entities
90%
96%
99%
96%
e\&o/
ao%
94%
98%
99%
98%
93%
NA
93%
88%
95%
96%
97%
92%
98%
98%
95%
95%
95%
NA
NA
96%
97%
NA
-------
TableB-16
Upper Bound Estimate of Affected Firms by Industry and Size Category
(for those industries where small entities are defined by annual revenues)
SIC Code
07
15
16
17
41
42
47
49
55
65
67
70
72
73
75
76
80
823, 824, 829
87 ex 8733
89
90 to 99
Less than
$250,000
$250,000 -
$499,999
$500,000 -
$999,999
$1,000,000-
$2,499,999
$2,500,000 -
$4,999,999
$5,000,000+
Not Available
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
:6 .
0
0 : '
.O.v ';
"tf :
. .:$ ? -
a -
0 ^
. a
...!.. .l*t.ฃ >'
:- ::-. 6 ." .'
' r^ .
>;&' * .
$ .
a
: 0
:' , A: .
0
a
Not Available
Small
Entities
Non-Small
Entities
Total
0
0
1
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
0
1
1
1
0
0
0
0
0
0
0
0
0
0
0
0
Percent
Small
Entities
NA
NA
98%
NA
96%
98%
81%
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
-------
Table B-17
Lower Bound Estimate of Affected Firms by Industry and Size Category
(for those industries where small entities are defined by number of employees)
SIC
Code
10
12
13
14
20
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
44
45
50
51
0
Employees
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
n
0
0
0
1-4
Employees
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
n
0
1
0
5-9
Employees
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
n
0
1
0
10-19
Employees
0
0
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
1
0
0
0
0
0
Not Available
n
0
2
0
20-99
Employees
0
0
0
0
0
0
0
2
0
0
0
2
0
0
0
0
0
2
0
1
0
0
0
n
0
5
0
100-499
Employees
0
0
0
0
0
0
0
1
0
0
0
3
0
0
0
0
1
3
0
1
0
0
0
n
0
' z ' -
...7v& '"
-."'-','t:': >:'.
\" l-:'\ '
,x-':;-i:-.;...;:-
i?"?::C $ j.-ซ.; ;
':^s'::fe.5>-?^:
ijj?%;;l':::i1:i
f !::iฃ:|p?i-;,! \
:!!:" 5^7 ;l:f:
T*V;j^%U-^
|i:j: "liLliJv
::;t-s-?ii^N^
H ^Iv&fi;
^i:&fXง:'
''11 ^"j':
'.v'5i"15 X?'.
^:;f $ l|P
S"",t3^"^--
>.* ^jf^\;|p:-
;!lli:;$;:-iflง:
:4^-;i^^^
:*: Ov -fi'"::::^^^-
'''".w-". ^:V:'W^\\\--
*': :' x'x ^^ :** . :: x '
:";Vฃ f*-:-':
irdvA-lHii
Small
Entities
0
0
0
1
0
0
0
4
0
0
0
5
0
0
0
0
1
6
0
2
0
0
0
n
0
9
0
Non-
Small
Entities
1
1
1
1
1
1
0
3
0
1
0
21
3
1
1
1
4
6
0
7
1
1
0
n
0
8
0
Total
1
1
1
1
1
1
1
7
1
1
0
26
4
1
1
1
6
11
0
9
1
1
0
n
1
16
0
I Percent
Small
[ Entities
13%
37%
31%
49%
27%
29%
55%
61%
47%
22%
NA
19%
8%
43%
41%
43%
22%
52%
38%
24%
7%
24%
NA
NA
8%
54%
NA
-------
Table B-18
Lower Bound Estimate of Affected Firms by Industry and Size Category
(for those industries where small entities are defined by annual revenues)
SIC Code
07
15
16
17
41
42
47
49
55
65
67
70
72
73
75
76
80
823, 824, 829
87 ex 8733
89
90 to 99
Less than
$250,000
$250,000 -
$499,999
$500,000 -
$999,999
$1,000,000-
$2,499,999
$2,500,000 -
$4,999,999
$5,000,000+
Not Available
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
.*"$
o .
:" - : a
0
6 -
0
^ :^:: "4
.iiML.iJ:
hi. .;.:'ฅซ .:iv i
S^ilL,::
::!: a--.'.-.:;.
.;.ฑ'LM.:'&
. >'. &r Ji!
:--0-:? '?'
ฃ"
0
. ฃ
-f 0- :
; a'v
Not Available
Small
Entities
Non-Small
Entities
Total
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
o
0
0
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
0
1
1
1
0
0
0
0
0
0
0
0
0
0
0
0
Percent
Small
Entities
NA
NA
68%
NA
32%
47%
1%
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
-------
50272-101
REPORT DOCUMENTATION | I. Report No.
PAGE |
| EPA530-R-99-026
I
12.
| 3. Recipient's Accession No.
PB99-156010
4. Title and Subtitle
Application of the Phase IV Land Disposal Restrictions to Contaminated Media: Costs, Cost Savings, and
Economic Impacts
5. Report Date
ApriM998
6.
7. Authors)
8. Performing Organization Kept. No.
9. Performing Organization Name and Address
U.S. EPA
OFFICE OF SOLID WASTE
401 M STREET, SW
WASHINGTON, DC 20460
10. Project/Task/Work Unit No.
11. Contract ฉ or Grant (G) No.
(G)
12. Sponsoring Organization Name and Address
13. Type of Report & Period Covered
Economic Impact Analysis
14.
15. Supplementary Notes
16. Abstract (Limit: 200 words)
Analyzes the impact of the Phase IV rulemaking on the treatment of contaminated media. Covers new soil treatment standards of soil
contaminated with hazardous waste, new LDR treatment standards for media contaminated with newly identified mineral processing wastes,
and new LDR treatment standards for media that exhibit the toxicity characteristic for metal constituents. Presents the methodology and the
major limitations. Describes the results. Analyzes the economic impacts of the projected incremental costs of the rulemaking on small entities.
Appendices describe the soil and sediment database used in this analysis and present detailed (e.g., industry-by-industry) results of the
economic impact analysis.
17. Document Analysis a. Descriptors
b. Identifiers/Open-Endcd Terms
c. COSAT1 Field Group
18. Availability Statement
RELEASE UNLIMITED
| 19. Security Class (This Report) | 21. No. of Pages
| UNCLASSIFIED |
I I
120. Security Class (This Page) |
| UNCLASSIFIED |
(SeeANSl-Z39.18)
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-3 5)
------- |