United States Solid Waste and EPA530-R-99-028
Environmental Protection Emergency Response NTIS: PB99-156 036
Agency (5305W) April 1998
Regulatory Impact
Analysis: Phase IV
Land Disposal
Restrictions - TC
Metal Wastes; Final
Report
Printed on paper that contains at least 30 percent postconsumer fiber
-------
Regulatory Impact Analysis:
Phase IV Land Disposal
Restrictions - TC Metals Wastes
Final Report
Prepared for
U.S. Environmental Protection Agency
Office of Solid Waste
401 M St., SW (5307W)
Washington, DC 20460
Prepared by
Tayler H. Bingham
James. H. Turner
Edward E. Rickman
Brooks Depro
Elizabeth A. Heath
Research Triangle Institute
3040 Cornwallis Road
Research Triangle Park, North Carolina 27709-2194
Contract Number 68-W6-0053
RTI Project Number 6720-08
May 4, 1998
-------
Table of Contents
Section Paee
1.0 Affected Industries 1
2.0 National Hazardous Waste Constituent Survey Data 1
3.0 Waste Generation and Management Under the BRS 3
4.0 Current Treatment Practices 6
5.0 Management Costs Analysis 10
6.0 Waste Management Decisions 12
6.1 Baseline Management 12
6.2 With-Regulation Management 12
7.0 Aggregate Costs 15
8.0 Economic Impacts 15
9.0 Impacts on Small Entities 17
10.0 Benefits , 17
10.1 The Circular System 20
10.2 The Economic Benefits of Groundwater Protection 21
10.2.1 With Policy Groundwater Quality Changes 21
10.2.2 Groundwater Service Flow Changes 21
10.2.3 Resource Allocation Changes 25
10.2.4 Human Welfare Changes T 25
11.0 Benefit-Cost Comparison 26
References 27
Appendix A: Development of Cost Functions forTC Metals Wastes with Organic UHCs A-l
Appendix B: Cost and Economic Impacts: Phase IV Land Disposal Restrictions Final
Rule—TC Metals B-1
Appendix C: Groundwater Risk Screening Analysis for Non-Ferrous Foundry Sands
Managed in Municipal Landfills - C-l
Appendix D: A Screening Analysis of the Economic Impacts of the LDR on Small Businesses
in the Zinc Sulfate Fertilizer Industry D-l
in
-------
Figures
Page
1. Ba>eline Management ot'TC Metals Wastes with Potentially Organic UHCv
Sludges, 1995 5
2. Baseline Management of TC Metals Wastes with Potentially Organic UHCs:
Solids, 1995 .~ .'. . . ~ 5
3 The Circular System 22
4 Grounds ater Function 23
Tables
Page
1. Industries Potentially Generating TC Metals Wastes with Organic UHCs 2
2. Nationwide Quantities of TC Metal Wastes with Organic Underlying
Hazardous Constituents (UHCs) Found in the National Hazardous Waste
Constituent Survey—Commercial Treaters 3
3. Number of BRS Facilities in Each SIC Code Potentially Generating TC Metals
Wastes with Organic UHCs 7
4. Size Distribution of Facilities Potentially Generating or Managing TC Metals
Wastes with Organic UHCs 8
5. Baseline Management of Potential TC Metals Wastes with Organic UHCs for Generators
by SIC Code .". ." 13
6. \Vith-Regulation Management of Potential TC Metals Wastes with Organic UHCs for
Generators by SIC Code 14
7. Costs of Management of Potential TC Metals Wastes with Organic UHCs for Generators
by SIC Code 16
8. Economic Impact of UTS on Generators of Potential TC Metals Wastes with Organic
UHCs 18
9. Small Business Statistics 19
10. Storage and Service Functions of Water Resources Potentially Impacted by TC
Metals Wastes 24
11 Empirical Estimates of Ground Water Protection Benefits 27
IV
-------
§3004(m) of the Resource Conservation and Recovery Act directs the EPA Administrator to
promulgate treatment standards for hazardous wastes prohibited from land disposal in order to minimize
long term threats to human health and the environment.1 In 1990 as part of the Third Third LDR rule
EPA developed treatment standards for Extraction Procedure (EP) metals wastes that require the wastes
meet characteristic levels before land disposal. In 1994 the Phase n LDR rule established Universal
Treatment Standards (UTS) for 216 organic, metal, and cyanide constituents in hazardous waste. In
1995, EPA proposed to revise treatment standards for eight toxicity characteristic (TC) metal wastes:
arsenic, barium, cadmium, chromium, lead, mercury, selenium and silver. These metals are the subject of
another RIA.
The previous RIA found that, for most TC metals wastes, treatment practices sufficient to meet
current requirements are expected to also be sufficient to meet the LTSs. Because the current treatment
practices (primarily stabilization with cement) may be used to meet UTSs, costs for these practices are
not expected to increase under the proposed regulations.2 Typically, these wastes would be treated by
stabilization and disposed of in a subtitle D landfill. However, for TC metals sources that also generate
TC metal wastes with organic underlying hazardous constituents (UHCs), concerns were raised that
current treatment practices would not meet the UTSs. This screening analysis was performed to
determine whether potentially organic UHCs are prevalent in TC metals wastes and if so, whether the
costs and economic impacts appear significant enough to warrant a more thorough analysis. As shown in
the screening analysis below, data from the National Hazardous Waste Constituent Survey (NHWCS)
show that the UHCs on a either a facility or nationwide basis do not exist in sufficient quantities to
require separate consideration under the proposed RIA. Further, even if worse-case assumptions are
used, the Agency does not expect any incremental costs resulting from the Phase IV rule for any of the
industries discussed below.
1.0 Affected Industries
Industries that may generate TC metals wastes with organic UHCs were identified by a
commercial waste management firm that receives these wastes for treatment. Table 1 provides a list of
the SIC codes for these industries. The table also includes estimates of revenue and profits for each
industry in 1995. Over 24,000 establishments with $729 billion dollars in revenues are classified under
these SIC codes. However, not all facilities are expected to generate these wastes as production
processes vary even within industries. The NHWCS provides useful information on the waste generation
of facilities in this industry.
2.0 National Hazardous Waste Constituent Survey Data
The National Hazardous Waste Constituent Survey (NHWCS), was analyzed for waste streams
with organic UHCs. The 1993 survey was searched for all commercial treaters of hazardous wastes,
including TC metal wastes with organic UHCs, under the D004 to DO 11 waste codes. The data for
181 streams at 35 sites revealed that less than 0.006 weight percent of the constituents contained in the
42 U.S.C. §6924(m). Solid Waste Disposal Act 3004(m).
December 19, 1996 letter to Anita Cummings, USEPA, Office of Solid Waste from Michael G.
Fusco, director of Regulatory Analysis, Rollins Environmental Inc., p. 4 of edited draft EPA trip
report letter to Rollins Highway 36 facility in Colorado.
1
-------
Table 1. Industries Potentially Generating TC Metals Wastes with Organic UHCs
SIC
2821
2822
2823
2824
2833
2834
2835
2836
2841
2842
2843
2844
2851
2861
2865
2869
2879
3471
3711
3713
3714
3715
3716
4922
4923
4924
4925
4952
4953
4959
1 Calculated
Sources:
Industry Description
Plastics materials and resins
Synthetic rubber
Cellulosic man made fibers
Organic fibers, noncellulosic
Medicinals and botanicals
Pharmaceutical preparations
Diagnostic substances
Biological products exc. diagnostic
Soap and other detergents
Polishes and sanitation goods
Surface active agents
Toilet preparations
Paints and aJlied products
Gum and wood chemicals
Cyclic crudes and intermediates
Industrial organic chemicals, n.e.c.
Agricultural chemicals, n.e.c.
Plating and polishing
Motor vehicles and car bodies
Truck and bus bodies
Motor vehicle parts and accessories
Truck trailers
Motor homes
Natural gas transmission
Gas Transmission and distribution
Natural gas distribution
Mixed gas
Sewerage systems
Refuse systems
Sanitary services, n.e.c.
Total
after taxes.
U.S. Department of Commerce, Bureau
Establishments
499
113
13
83
244
707
232
286
685
715
197
768
1,359
79
210
692
253
3,310
482
629
3,248
355
122
616
1,683
1,647
53
496
3,438
1,439
24,653
of Census. 1995 Annual
1995
Revenue
nO"S/vr)
43.528.7
5.942.2
1,222.1
12.813.3
7.037.9
57.943.3
9.676.4
6,226.6
16,131.8
8,700.3
4.886.6
20,438.9
17,942.6
816.9
12,419.0
63,303.1
10,079.3
5.778.4
200.939.4
7,802.7
107.417.3
6,381.5
3,640.3
9.436.2
31.650.1
40,113.5
579.5
380.0
15.225.6
758.4
729,211.9
Survey of Manufc
Estimates
Profit1
(106$/yr)
3,069.2
419.0
86.2
903.5
1.057.9
8,710.0
1,454.5
936.0
1,154.7
622.8
349.8
1,463.1
1,284.4
57.6
875.7
4,463.5
721.5
179.9
9,596.9
372.7
5,130.3
304.8
173.9
651.1
1,835.7
1,925.5
46.4
26.6
807.0
51.6
48.731.3
icturers.
Washington, DC: Government Printing Office.
U.S. Department of Commerce, Bureau of Census. 1992 Census of Transportation, Communications.
and Utilities: Establishment and Firm Size. Washington, DC: Government Printing Office.
U.S. Department of Commerce, Bureau of Census. Quarterly Financial Report for Manufacturing,
Mining, and Trade Corporations. Washington, DC: Government Printing Office. June 1996.
Small Business Administration. 1994 U.S. Firm Size Data at the 4-Digit SIC Level. [Online].
Available: «http://www.sba.gov/advo/stats/int_data.html». Data obtained 11/18/94.
Industry Norms & Key Business Ratios 1995-1996. Murray Hill, NJ. Dun & Bradstreet Information
Services.
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waste streams were UHC organics. For the only four sites that reported organic and inorganic
constituents above the UTS levels, annual quantities of organic constituents ranged from 0.021 tons per
year to 1.5 tons per year, with percentages ranging from 0.006 to 58. The median quantity of organics
was 0.29 tons per year, while the median percentage of organics was 0.041. The reported organic
constituents in the streams consisted of phenols, toluene, xylene, ethyl benzene, and polychlorinated
biphenyls (PCBs) including Arochlor 1242. Table 2 shows the quantities of organic wastes and total
waste found at each of the five sites reporting organics, and compares them with the total quantity of
treated waste found in the database.
Table 2. Nationwide Quantities of TC Metal Wastes with Organic Underlying Hazardous
Constituents (UHCs) Found in the National Hazardous Waste Constituent Survey—
Commercial Treaters
Sites Containing TC
Metal Wastes with
Organic UHCs
UHC Organics in
Wastes
(tons per year)
All Constituents in
Wastes
(tons per year)
UHC Organics in
Wastes
1
2
3
4
Totals for 4 sites
Nationwide totals
0.021
0.34
0.24
1.5
2.1
2.1
358
0.59
337
17.400
18,096
35,001
0.006
58
0.072
0.009
0.012
0.006
Because the reported percentage of TC metal wastes with organic UHCs is a fraction of a percent
of total TC metal wastes found in the facilities searched in the NHWCS, no nationwide problem is
perceived with this class of wastes. Based on this information, TC metals wastes with organic UHCs are
unlikely to require combustion.
3.0 Waste Generation and Management Under the BRS
An alternate source of information regarding waste generation, the Biennial Reporting System
(BRS), was analyzed for comparison with the NHWCS data. The most recent (1995) version of the BRS
was used to identify specific facilities in the SIC codes listed in Table 1 that may be generating or
receiving TC metals wastes with organic UHCs for management. All sites generating more than
1,000 kg/month of RCRA hazardous waste or 1 kg/month of RCRA acute hazardous waste (or
accumulated that amount at any time) or that accumulated more than 100 kg of spill cleanup material
contaminated with RCRA acute hazardous waste are required to report in the BRS. Once a site meets
these requirements for any of its wastes, it is required to report on all its RCRA hazardous wastes, even if
any specific waste is present at much smaller levels. Generator wastes are reported on a GM form, one
form per waste generated. The waste form number, which consists of the generator's EPA facility ID and
a form number, serves as the primary key for the waste. Received wastes are reported on a WR form.
The waste number, which consists of the generator's EPA facility ID, the form number, and the subpage
number serves as the primary key for the waste. Treatment facilities are reported on a PS form one for
-------
each treatment system type, system permit status, and system operational status. The system number,
which consists of the generator's EPA facility ID and form number serves as the primary key for the
waste.
TC metals wastes include wastes in codes D004 through D011. All waste forms that have any of
the waste codes D004 through D011 were identified in the BRS data. This reduced the original BRS list
of more than 242,000 generator waste forms to approximately 28,000. Next, those forms with the SIC
codes in Table 1 were identified. Although facilities are not required to report their SIC code in the BRS,
fewer than 1,700 of the 28,000 forms with applicable wastes had blank SIC code fields. This facility list
was then joined with the list of waste streams having D004 to D011 (described above) to get a list of
waste forms with the desired waste codes from facilities with the applicable SIC codes. This resulted in a
list of approximately 5,500 waste forms. Because the SIC code is reported with the waste form and not
the facility form, it is possible for a facility to report more than one SIC code in BRS. The procedure
described above resulted in a facility being included if any of its waste forms had a SIC in one of the
affected industries. A list was then made of only those waste forms that are non liquid and non gaseous
(i.e., have a waste form code not between Blxx and B2xx or between B7xx and B8xx). The resulting list
had approximately 3,500 wastes. One facility record was developed for each waste form (solid or
sludge) which included SIC code, quantity, and baseline management practice.
Three BRS facilities identified as generators each reported waste quantities over 30,000 metric
tons. Further facility-level analysis of online BRS data revealed that these quantities included liquids
associated with facility operations (i.e., rinse and cleansing). Therefore, the waste quantities for these
facilities were adjusted to reflect amounts managed by RCRA-permitted TSD units. This reduced the
total waste quantities reported for these facilities from 162,000 metric tons to approximately 300 tons.
Two facilities were excluded from the data set because additional analysis suggested they only
transported generated wastes.
Facilities that may be receiving TC metals wastes with organic UHCs for treatment were
identified in a similar manner to generators. The first task was to determine which received wastes
contained one or more of waste codes D004 through D011 without any other waste codes being present.
This reduced the original BRS list of more than 816,000 received wastes to approximately 75,000
received wastes containing only codes D004 to DO II. Only those wastes that are non liquid and non
gaseous (i.e., have a waste form code not between Blxx and B2xx or between B7xx and B8xx) were
considered for further calculations. The resulting list had approximately 44,000 wastes. One facility
record was developed for each waste form (solid or sludge) which included quantities received. The list
was divided into commercial and captive management facilities based upon commercial availability
codes and company names. A list of commercial incineration facilities provided by Industrial
Economics, Incorporated was also used. Governmental and university facilities were excluded. The
result of this process is to identify the upper limit on the number of facilities that may generate or manage
TC metals wastes with organic UHCs. Since there is no specific waste code for these wastes, it is likely
that the list of facilities includes some that do not generate or manage these types of wastes.
Figure 1 summarizes the management of TC sludges, Figure 2 of TC solids as estimated under
the procedures described above. Again we emphasize that these wastes are not known to have potentially
organic UHCs. Based on Table 1, only a very small fraction of these wastes are likely to have some
organic UHCs. However, since we have no way to identify this fraction we carry the entire quantities
along for this screening analysis.
-------
5,139
generated
1.286
self-manasement
3.853
commercial management
1.026
on-site
260
captive sites
285
incinerated
3,568
other treatment
Figure 1. Baseline Management of TC Metals Wastes with Potentially Organic UHCs:
Sludges, 1995.
Note: All values in metric tons.
Source: 1995BRS.
23,808
generated
4,667
self-management
19.141
commercial management
1,090
on-site
3,577
captive sites
452
incinerated
18,689
other treatment
Figure 2. Baseline Management of TC Metals Wastes with Potentially Organic UHCs:
Solids, 1995.
Note: All values in metic tons.
Source: 1995 BRS
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Generators may self-manage these wastes on-site. Some firms also have captive facilities where
wastes from a number of their generator facilities are sent to be treated. Generators may also ship wastes
to commercial facilities for treatment. The data for the captive and commercial managers indicate larger
quantities of wastes passing the waste type screen used with the BRS data than facilities in the SIC codes
of interest report shipping off-site. This is because the off-site managers receive TC metals wastes from
industries in SIC codes other than those that may generate TC metals wastes with organic UHCs. To
adjust for this, each captive and commercial manager's quantity of solids or sludges was scaled by the
proportion of the amount shipped by generators for off-site management to the amount managed to
provide an estimate of the amount of TC metals wastes with organic UHCs managed off-site.
Some of the commercial managers are known to operate incinerators for hazardous waste
treatment. These facilities were identified from the list of facilities pulled from the BRS. We presume
that the potentially TC metals wastes with organic UHCs sent to these managers are being
incinerated—see Figures 1 and 2.
Table 3 identifies the number of BRS facilities potentially generating TC metals wastes with
organic UHCs in each SIC listed in Table 1. It also reports the numbers of commercial and captive
facilities receiving TC metals wastes with organic UHCs. Comparison of the tables reveals that only a
small share (3.4%) of all the existing facilities in these SIC codes are potential generators of TC metals
wastes with organic UHCs. The plating and polishing (SIC 3471), motor vehicle parts and accessories
(SIC 3714) and industrial organic chemicals, n.e.c. (SIC 2869) industries report the largest number of
facilities, accounting for nearly half of these generators.
Table 4 shows the size distribution of the BRS facilities listed in Table 3. This table indicates
that most of the facilities reported small quantities of potential TC metals wastes with organic UHCs. All
generating facilities reported under 2,000 metric tons of waste. Only 3 facilities reported quantities
greater than 300 metric tons while over 700 facilities reported quantities less than 25 metric tons.
In addition to any TC metals wastes with organic UHCs generated as part of a continuing process
of production, facilities may also generate such wastes on a more sporadic basis from their removal of
contaminated media. These are one-time events where, typically, soil that is contaminated with TC
metals wastes with organic UHCs is removed and treated. These wastes are not covered in this analysis.
Although the NHWCS analysis reported on in Section 2 indicates that TC metal wastes with
organic UHCs are not likely to be an issue because of their very small quantities, this analysis uses the
BRS data as //these were the correct quantities of the affected wastes for the subsequent analysis of
management methods and costs.
4.0 Current Treatment Practices
The treatment practices used to reduce the mobility of metal concentrations in TC wastes consist
of a series of unit operations beginning with storage of the waste and ending with disposal of the treated
waste. These activities may be completed entirely either on-site at the generator facility or at an off-site
commercial or captive facility. In some cases, there is some pre-processing at the generator facility
followed by off-site treatment and disposal. Specific practices will vary across facilities depending on
the specific conditions of each manager.
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Table 3. Number of BRS Facilities in Each SIC Code Potentially Generating
TC Metals Wastes with Organic UHCs
BRS Number of Facilities
SIC Industry Segment
Generators. Managed Off-Site
2821 Plastics materials and resins
2822 Synthetic rubber
2823 Cellulosic manmade fibers
2824 Organic fibers, noncellulosic
2833 Medicinals and botanicals
2834 Pharmaceutical preparations
2835 Diagnostic substances
2836 Biological products exc. diagnostic
284 1 Soap and other detergents
2842 Polishes and sanitation goods
2843 Surface active agents
2844 Toilet preparations
285 1 Paints and allied products
286 1 Gum and wood chemicals
2865 Cyclic crudes and intermediates
2869 Industrial organic chemicals, n.e.c.
2879 Agricultural chemicals, n.e.c.
3471 Plating and polishing
3711 Motor vehicles and car bodies
37 1 3 Truck and bus bodies
37 14 Motor vehicle parts and accessories
3715 Truck trailers
37 1 6 Motor homes
4922 Natural gas transmission
4923 Gas transmission and distribution
4924 Natural gas distribution
4925 Mixed gas
4952 Sewerage systems
4953 Refuse systems
4959 Sanitary services, n.e.c.
Total
Generators, Managed On-Site
2821 Plastics materials and resins
285 1 Paints and allied products
2865 Cyclic crudes and intermediates
2869 Industrial organic chemicals, n.e.c.
2879 Agricultural chemicals, n.e.c.
347 1 Plating and polishing
3714 Motor vehicle parts and accessories
4953 Refuse systems
Totals
Captive Managers
Commercial Managers
Total
80
9
1
8
21
69
11
7
7
3
5
11
65
2
18
133
21
184
53
16
140
2
2
45
1
9
3
5
0
0
931
1
1
3
9
2
3
5
1
25
136
147
Solids
76
9
1
8
21
69
11
6
7
2
5
11
62
2
18
129
19
155
51
13
133
2
2
44
1
9
3
5
0
0
874
1
1
3
8
1
2
4
1
21
121
141
Sludges
4
0
0
0
0
0
0
1
1
1
0
1
8
0
0
8
2
52
13
3
30
0
1
. 1
0
0
1
1
0
0
128
0
0
0
1
I
2
1
0
5
53
93
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Table 4. Size Distribution of Facilities Potentially Generating or Managing TC Metals Wastes with Organic UHCs
OO
Facility Size Distribution (metric tons)
Solids
SIC
Generators.
2821
2822
2823
2824
2833
2834
2835
2836
2841
2842
2843
2844
2851
2861
2865
2869
2879
3471
3711
3713
3714
3715
3716
Industry Segment
Managed Off-Site
Plastics materials and resins
Synthetic rubber
Cellulosic manmade fibers
Organic fibers, noncellulosic
Medicinals and botanicals
Pharmaceutical preparations
Diagnostic substances
Biological products exc.
diagnostic
Soap and other detergents
Polishes and sanitation goods
Surface active agents
Toilet preparations
Paints and allied products
Gum and wood chemicals
Cyclic crudes and intermediates
Industrial organic chemicals,
n.e.c.
Agricultural chemicals, n.e.c.
Plating and polishing
Motor vehicles and car bodies
Truck and bus bodies
Motor vehicle parts and
accessories
Truck trailers
Motor homes
Mean
7.6
30.3
0.6
11.3
12.4
11.6
13.9
4.3
14.8
8.0
39.3
1.2
27.0
1.1
47.4
31.2
16.6
19.5
83.8
13.3
35.8
10.0
14.5
0-10
68
7
1
6
18
60
8
5
6
1
3
11
47
2
11
82
13
118
17
9
90
1
1
11-25
2
1
-
-
1
4
2
1
0
1
-
-
6
-
2
19
2
14
15
0
19
1
-
26-100
5
-
-
2
1
3
-
-
1
-
1
-
6
-
3
20
4
17
5
4
15
-
1
101-300 >300
1
1
-
-
1
1 1
1
-
-
-
1
-
2 1
-
1 1
4 4
-
4 2
9 5
-
5 4
-
-
Mean
2.5
na
na
na
na
na
na
0.1
20.0
0.3
na
0.0
7.1
na
na
6.2
42.5
13.7
39.0
17.1
86.6
na
20.9
0-10
4
-
-
-
-
-
-
1
-
1
-
1
5
-
-
7
1
44
7
2
19
-
-
Sludges
11-25 26-100 101-300 >300
.
.
.
.
.
.
-
.
1 - - -
-
.
-
3 - - -
.
.
1 - - -
1
34 11
231-
1
4421
.
1 - - -
(continued)
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Table 4. Size Distribution of Facilities Potentially Generating or Managing TC Metals Wastes with Organic UHCs (Continued)
Facility Size Distribution (metric tons)
SIC Industry Segment
Generators. Managed Off-Site (Continued)
4922 Natural gas transmission
4923 Gas transmission and
distribution
4924 Natural gas distribution
4925 Mixed gas
4952 Sewerage systems
4953 Refuse systems
4959 Sanitary services, n.e.c.
Total/Average
Generators, Managed On-Site
2821 Plastics materials and resins
285 1 Paints and allied products
2865 Cyclic crudes and intermediates
2869 Industrial organic chemicals,
n.e.c.
2879 Agricultural chemicals, n.e.c.
347 1 Plating and polishing
37 1 4 Motor vehicle parts and
accessories
4941 Water supply
4953 Refuse systems
Totals/Average
Captive Managers
Commercial Managers
Mean
5.4
0.5
77.0
35.9
3.8
na
na
27.2
0.2
0.1
74.9
87.2
10.4
3.1
37.5
57.8
1.2
52.2
29.6
137.1
0-10
39
1
6
2
4
-
-
637
1
1
1
3
-
2
3
-
1
12
58
73
Solids
11-25 26-100 101-300 >300
311-
.
1-11
1
I ...
-
.
95 89 34 19
.
-
1 1
113-
1 ...
.
1
I
.
23 50
9 19 14 21
29 36 16 22
Mean
' O.I
na
na
0.8
0.0
na
na
32.1
na
na
nu
143.0
432.4
222.0
6.5
na
na
205.2
4.9
55.3
0-10
1
-
-
1
1
-
-
95
-
-
-
-
-
1
1
-
-
2
30
57
Sludges
11-25 26-100 101-300 >300
.
.
-
-
-
-
.
15 13 41
.
-
-
1
1
1
-
-
-
0012
7 10 4 2
12 13 74
-------
Wastes are typically stored in drums, tanks, roll-off containers, or buildings prior to treatment or
shipment off-site. Small quantities of solids are usually stored in drums. Each storage method has its
own requirements for moving the waste into and out of the storage area. Where leaching or leaking can
take place, monitoring must be used to detect such occurrences. As long as the material is defined as
hazardous waste, storage facilities must meet Subtitle C design and operating requirements.
Metal-bearing solids and dewatered sludges that exhibit a characteristic and are, therefore,
hazardous are typically stabilized with cement and/or other materials that form a hard substance with low
leaching characteristics. Stabilization adds significantly to the mass of material that must be landfilled.
After treatment, residues must be given a final disposal place. Either Subtitle C or Subtitle D
landfills are generally used. Subtitle D landfills are generally used to dispose of the treated wastes, but
Subtitle C landfills are sometime used. Stringent monitoring, closure, and post-closure requirements
must be met to ensure that toxic materials do not migrate from the site. Construction must be such that
leaching or migration is kept to a minimum. Highly impermeable underlying soils and landfill liners are
required. In some cases, because of logistics, it may be less costly to dispose of Subtitle D wastes in a
Subtitle C landfill. For characteristic wastes that have been treated to a concentration below the required
treatment level, disposal may be made in a Subtitle D landfill. Some of these landfills do not have the
special requirements for construction, monitoring, and closure that are found at the Subtitle C landfills.
5.0 Management Costs Analysis
To treat TC metals wastes that contain underlying hazardous constituents (UHCs) to the UTSs
prior to disposal, treatment beyond Portland cement stabilization is likely to be necessary. Specifically,
incineration of the solid or sludges followed by stabilization of the ash and landfill of the stabilized ash
in a subtitle D facility is anticipated. The unit ($/ton) costs of managing nonwastewater TC metals
wastes with organic UHCs under the baseline and with the UTS treatment practices are presented here as
a function of the quantity of waste treated. The point of departure for these estimates are the estimates
developed for mineral processing wastes. With the exception of incineration, these functions have been
used directly or in modified form as described in Appendix A, to arrive at treatment costs for each
operation in the treatment train. Appendix B provides a description of the development of the cost
function for stabilization only. Storage functions are used directly. Stabilization functions are revised in
accordance with public comments received on the mineral processing waste RIA. Disposal functions are
modified from the mineral processing waste functions to account for changes in volume of waste due to
preceding treatment steps. Incineration cost functions are developed from data obtained for hazardous
waste incinerator regulations.3 The functions cover only the technical aspects of the treatment train.
Facility-wide costs triggered by the construction of an incinerator are excluded. These costs would
include those for permitting, demonstrating financial responsibility, and for facility-wide corrective
action.
The estimated cost for managing nonwastewaters (solids and sludges) TC metals wastes with
organic UHCs are:
Spreadsheet supplied by Paul Borst, US EPA, November 26, 1997. Data include capital and
annual costs for 50 non-commercial incinerators as pan of a database containing information for
over 100 combustors. Types described also include cement kilns, light-weight aggregate kilns,
commercial incinerators, and government facilities.
10
-------
Sludge
Baseline
Storage: cost = 24.589 Q + 132.23 for Q < 200 mt/yr
= -0.0022 Q1 + 29.272 Q + 4,840.9 for 200 < Q < 7,500 mt/yr
Stabilization: cost = 234.96 Q + 20,836 for 300 < Q < 3,000 mt/yr
= 38.516 Q +298.633 for 3,000
-------
6.0 Waste Management Decisions
Generators of wastes are presumed to select the least-costly method of managing their TC metals
wastes with organic UHCs: on-site (including captive management) or off-site at a commercial facility.
All waste managers, whether on-site or commercial, will, however, incur costs in addition to the
engineering costs estimated directly above. These are the costs associated with permitting,
demonstrating financial responsibility, and corrective action. Since these costs are not very sensitive to
the quantity of wastes managed, they tend to mitigate against on-site management for small generators.
For generators, the cost of on-site treatment would thus be:
treatment costs + administrative costs.
Their costs of off-site management would be
transportation costs + costs of commercial management.
Comparison of the costs of the two alternatives would find the least-cost management choice.
6.1 Baseline Management
Table 5 shows the management for potential TC metals wastes with organic UHCs under the
baseline. For this case we know from the BRS how each generator is currently managing its wastes (i.e.,
on- or off-site). Presumably each have conducted a "make or buy" decision as outlined above and found
the method chosen least-costly among the alternatives. Those facilities managing on-site are assumed to
be using the current treatment practices as described above (i.e., cement stabilization). Wastes sent to
commercial managers may either be managed in the same manner, or, in some cases, apparently are
already being incinerated, as shown in Figures 1 and 2.
6.2 With-Regulation Management
Compliance with the UTSs is modeled in this screen to require incineration of TC metals wastes
with organic UHCs. Generators will reassess their previous waste management decisions to identify their
new, least-cost practices. Two factors mitigate against the continuation of on-site management of TC
metals wastes with organic UHCs. First, incineration is subject to economies of scale; thus small
generators in particular are likely to find off-site treatment the least-cost option. Commercial facilities
can lower unit costs by treating large quantities collected from many generators. Second, the
administrative costs of installing and operating an incinerator to treat these wastes are likely to be cost
prohibitive. Thus, all of the potential TC metals wastes with organic UHCs are assumed to be sent off-
site to commercial managers—see Table 6. We emphasize again that not all these wastes have organic
UHCs and that some of these wastes are already being incinerated. It is possible that wastes with organic
UHCs are already being incinerated. However, for this screen we continue to assume that all wastes
identified would be incinerated under the regulation.
12
-------
Table 5. Baseline Management of Potential TC Metals Wastes with Organic UHCs for Generators
by SIC Code
Quantity (metric tons)
Off-Site
SIC Code
2821
2822
2823
2824
2833
2834
2835
2836
2841
2842
2843
2844
2851
2861
2865
2869
2879
3471
3711
3713
3714
3715
3716
4922
4923
4924
4925
4952
4953
4959
Industry Segment
Plastics materials and resins
Synthetic rubber
Cellulosic manmade fibers
Organic fibers, noncellulosic
Medicinals and botanicals
Pharmaceutical preparations
Diagnostic substances
Biological products exc. diagnostic
Soap and other detergents
Polishes and sanitation goods
Surface active agents
Toilet preparations
Paints and allied products
Gum and wood chemicals
Cyclic crudes and intermediates
Industrial organic chemicals, n.e.c.
Agricultural chemicals, n.e.c.
Plating and polishing
Motor vehicles and car bodies
Truck and bus bodies
Motor vehicle parts and accessories
Truck trailers
Motor homes
Natural gas transmission
Gas transmission and distribution
Natural gas distribution
Mixed gas
Sewerage systems
Refuse systems
Sanitary services, n.e.c.
Total Generated
Less Captive Management
Total Commercial Management
Solids
577.4
272.5
0.6
90.4
260.4
798.3
152.8
25.8
103.4
16.0
196.6
13.2
1,675.9
2.3
853.3
4,030.3
315.9
3,016.9
4,274.6
173.0
4,762.9
20.0
29.0
236.4
0.5
692.8
107.7
19.1
-
-
22,718.1
3,576.8
19,141.3
Sludge
10.1
-
-
-
-
-
-
0.1
20.0
0.3
-
-
56.5
-
-
49.9
84.9
712.5
506.7
51.2
2,598.7
-
20.9
0.1
-
-
0.8
0.0
-
-
4,112.6
260.0
3,852.6
On-Site
Solids Sludge
0.2
-
-
-
-
-
-
-
-
-
-
-
0.1
-
224.6
697.8 143.0
10.4 432.4
6.3 444.0
-
-
149.9 6.5
-
-
-
-
-
-
-
1.2
-
1,090.4 1,026.0
-
13
-------
Table 6. With-Regulation Management of Potential TC Metals Wastes with Organic UHCs for
Generators by SIC Code
Quantity (metric tons)
Off-Site
SIC Code
2821
2822
2823
2824
2833
2834
2835
2836
2841
2842
2843
2844
2851
2861
2865
2869
2879
3471
3711
3713
3714
3715
3716
4922
4923
4924
4925
4952
4953
4959
Industry Segment
Plastics materials and resins
Synthetic rubber
Cellulosic manmade fibers
Organic fibers, noncellulosic
Medicinals and botanicals
Pharmaceutical preparations
Diagnostic substances
Biological products exc. diagnostic
Soap and other detergents
Polishes and sanitation goods
Surface active agents
Toilet preparations
Paints and allied products
Gum and wood chemicals
Cyclic crudes and intermediates
Industrial organic chemicals, n.e.c.
Agricultural chemicals, n.e.c.
Plating and polishing
Motor vehicles and car bodies
Truck and bus bodies
Motor vehicle parts and accessories
Truck trailers
Motor homes
Natural gas transmission
Gas transmission and distribution
Natural gas distribution
Mixed gas
Sewerage systems
Refuse systems
Sanitary services, n.e.c.
Total Generated
Less Captive Management
Total Commercial Management
Solids
577.6
272.5
0.6
90.4
260.4
798.3
152.8
25.8
103.4
16.0
196.6
13.2
1,676.0
2.3
1,077.9
4,728.2
326.3
3,023.2
4,274.6
173.0
4,912.7
20.0
29.0
236.4
0.5
692.8
107.7
19.1
1.2
-
23,808.5
-
23,808.5
Sludge
10.1
-
-
-
-
-
. -
0.1
20.0
0.3
-
-
56.5
-
-
192.9
517.3
1,156.5
506.7
51.2
2,605.3
-
20.9
0.1
-
-
0.8
0.0
-
-
5,138.6
-
5,138.6
On-Site
Solids Sludge
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
14
-------
7.0 Aggregate Costs
Table 7 shows the baseline, with regulation, and the differences in costs of managing TC metals
wastes with organic UHCs for the generators. For the baseline, costs for on-site management are
estimated facility-by-facility for stabilization using the cost equation presented above. For wastes sent
off-site to commercial managers, generator costs are estimated based on the charges for that treatment.
These charges are the price per ton for treatment plus the price per ton for transport.
Individual facility-level decisions on type of commercial treatment (incineration vs. cement
stabilization) could not be determined. Therefore, the baseline costs presented in Table 7 are assumed to
be the sum of transportation costs (S101.73/ton) and the price of stabilization only (S240/ton). This
assumption underestimates total baseline costs to generators to the extent it excludes costs of quantities
already being incinerated.
Transportation cost estimates are based upon dollar-per-ton-mile figures provided by DPRA
(1992). These estimates were adjusted to 1995 dollars using the Consumer Price Index for
transportation. Assuming an average shipping distance of 400 miles, the average transportation costs
would be S101.73 per ton.4
With the regulation, all wastes are assumed to be commercially incinerated. The cost is the sum
of transportation costs (5101.73/ton) and the cost of incineration (Sl,127/ton). The price of commercial
incineration is based on 1995 data reported in El Digest (May, 1995). Incineration price for bulk and
drummed solids/sludges ranged from S990/mt to S1.265/mt. The midpoint of this estimate range
(51,127) is used in this analysis.
The total costs estimated under this economic screen reported in Table 7 are the difference in the
baseline and with-regulation costs. As discussed in Section 2.0, based on the NHWCS, the BRS
quantities used to develop the cost estimates are, in fact, not accurate estimates of TC metals wastes with
organic UHCs. This screen assumes a scenario where all TC metals wastes require combustion to treat
organic UHCs. EPA does not believe this is likely under today's final rule.
8.0 Economic Impacts
Compliance with the revised standards will raise the costs of production for any generator of TC
metals wastes with organic UHCs not currently sending wastes to commercial incinerators. Depending
on market conditions for the generators of TC metals wastes with organic UHCs, some or all of this
amount may be passed downstream to consumers in the form of higher prices for their products or
upstream to input suppliers to in the form of lower input prices. In the long run these costs are likely to
be passed on entirely to consumers of their products as new facilities will not be constructed unless
investors can expect to cover all their costs. However, in the short run when there is specificity in the
fixed capital (e.g., the plant and equipment used in making each generator's products may have no value
except that of scrap metal outside the industry), the costs will be shared across owners, consumers of
their products, and suppliers of inputs to these generators. In the extreme case, facilities may be closed.
Letter from Carol Sarnat. DPRA. to Paul Borst, March 4, 1993.
15
-------
Table 7. Costs of Management of Potential TC Metals Wastes with Organic UHCs for Generators
by SIC Code
Total Costs (S/yr)
SIC Code
2821
2822
2823
2824
2833
2834
2835
2836
2841
2842
2843
2844
2851
2861
2865
2869
2879
3471
3711
3713
3714
3715
3716
4922
4923
4924
4925
4952
4953
Industry Segment
Plastics materials and resins
Synthetic rubber
Cellulosic manmade fibers
Organic fibers, noncellulosic
Medicinals and botanicals
Pharmaceutical preparations
Diagnostic substances
Biological products exc. diagnostic
Soap and other detergents
Polishes and sanitation goods
Surface active agents
Toilet preparations
Paints and allied products
Gum and wood chemicals
Cyclic crudes and intermediates
Industrial organic chemicals, n.e.c.
Agricultural chemicals, n.e.c.
Plating and polishing
Motor vehicles and car bodies
Truck and bus bodies
Motor vehicle parts and accessories
Truck trailers
Motor homes
Natural gas transmission
Gas transmission and distribution
Natural gas distribution
Mixed gas
Sewerage systems
Refuse systems
Total
Baseline
200,798
93,105
206
30,907
88,985
272,813
52,205
8,836
42,146
5,602
67,200
4,498
592,028
782
339,960
1,575,422
232,338
1,371,394
1,633,909
76,589
2.549,357
6,843
17,059
80,828
177
236,762
37.089
6,534
248
9,624,621
With
Regulation
722,076
334,771
740
111.129
319,955
980,932
187,711
31,772
151,543
20,142
241,626
16,174
2.128.738
2.811
1.324,435
6,046,727
1.036,612
5,135,619
5.874.915
275,385
9.237,578
24.606
61,338
290,626
635
851,307
133,358
23,493
1,416
35,568,170
Incremental Costs
of the Regulation
521,278
241,665
534
80,222
230,970
708,119
135,505
22,936
109,396
14,540
174,426
11,675
1.536.710
2.029
984,475
4,471,306
804,274
3,764,225
4,241.005
198,796
6,688,221
17,762
44.279
209,798
459
614,545
96,269
16,959
1,168
25,943,550
Note: Off-site services price = S1,127/ton.
Transportation costs = S101.73/ton.
16
-------
The standard view of the facility closure decision is that profit-maximizing managers will elect to
exit a market when the value of the productive assets in their best alternative use exceeds the expected
present value of remaining in the market. This view requires that generators and commercial managers
of TC metals wastes with organic UHCs evaluate the revenue and costs implications of keeping the
facility open and remaining in the market.
However, this analysis has not formally examined the impact of the costs of the UTSs on
generators' product pricing or facility closure decisions as hazardous waste management costs are likely
to represent an insignificant share of total product revenues. Indeed, as shown in Table 8, the costs of the
regulation, even assuming the worst-case scenario where all TC metals wastes require combustion, are
less than one percent of revenues for most SIC codes. Because only a small share of most industries
were identified from the BRS, it was necessary1 to account for this in the revenue and profit estimates in
Table 8. Revenues and profits per establishment were calculated from Table 1 and then multiplied by the
number of facilities in Table 3 to get the revenue and profit estimates of Table 8.
9.0 Impacts on Small Entities
The Small Business Regulatory Enforcement Fairness Act of 1996 (SBRJEFA) requires that
agencies consider the impact of new regulations potential impacts on small businesses, amending and
strengthening the requirements of the Regulatory Flexibility Act (RRA). Agencies must either certify
that a rule will not have "significant impacts on a substantial number of small entities" (with a factual
justification) or must comply with additional requirements.
According to current EPA draft guidance on completing small business initial assessment, there
is a rebuttable presumption that significant economic impacts result to a substantial number of small
entities (firms) when the estimated compliance cost of the rulemaking equals or exceeds 3 percent of firm
sales/revenues. When firm-specific data is unavailable, industry sales/revenues may be used as a proxy
for estimating impacts.
The Agency does not believe organics are a significant component of TC metals wastes. Thus,
the cost estimates are extreme values. However, we continue to conduct this screen as //these were the
costs.
As shown in Table 9, many of the affected industries have a large number of small businesses.
However, in terms of the ratio of regulatory costs to revenues for the affected facilities, using Agency
guidance, there is not a significant impact to a substantial number of small entities resulting from the
revision of UTS for TC metals wastes with organic UHCs using the regulatory cost to sales criterion.
However, as a share of profits, the regulatory costs, were they the actual costs of the rule, are significant
in one industry in Table 8: plating and polishing.
10.0 Benefits
The revised standards for TC metals are designed to reduce the release of hazardous materials
into the environment thereby increasing the quality of environmental services and, indirectly, human
welfare. Although no changes in TC metals wastes with UHCs are anticipated with this rule, the types of
environmental benefits generally expected with improved waste management methods are very briefly
outlined below. This provides a context within which any benefits may be considered.
17
-------
Table 8. Economic Impact of UTS on Generators of Potential TC Metals Wastes with Organic UHCs
00
SIC Code
2821
2822
2823
2824
2833
2834
2835
2836
2841
2842
2843
2844
2851
2861
2865
2869
2879
3471
3711
3713
3714
3715
3716
4922
4923
4924
4925
4952
4953
Estimated Revenue Compliance Cost As
(million $) Share of Revenues (%)
Plastics materials and resins
Synthetic rubber
Cellulosic manmade fibers
Organic fibers, noncellulosic
Medicinals and botanicals
Pharmaceutical preparations
Diagnostic substances
Biological products exc. diagnostic
Soap and other detergents
Polishes and sanitation goods
Surface active agents
Toilet preparations
Paints and allied products
Gum and wood chemicals
Cyclic crudes and intermediates
Industrial organic chemicals, n.e.c.
Agricultural chemicals, n.e.c.
Plating and polishing
Motor vehicles and car bodies
Truck and bus bodies
Motor vehicle parts and accessories
Truck trailers
Motor homes
Natural gas transmission
Gas transmission and distribution
Natural gas distribution
Mixed gas
Sewerage systems
Refuse systems
Totals
7,065.8
473.3
94.0
1,235.0
605.7
5,655.0
458.8
152.4
164.9
36.5
124.0
292.7
871.4
20.7
1,123.6
1 2,624.0
8366
323.0
22,095.0
198.5
4,696.2
36.0
59.7
689.3
18.8
219.2
32.8
3.8
4.4
60,211.1
0.01%
0.05%
0.00%
0.01%
0.04%
0.01%
0.03%
0.02%
0.07%
0.04%
0.14%
0.00%
0.18%
0.01%
0.09%
0.04%
0.10%
1.17%
0.02%
0.10%
0.14%
0.05%
0.07%
0.03%
0.00%
0.28%
0.29%
0.44%
0.03%
0.04%
Ustimated Profits
(million S)
498.2
33.4
66
87.1
91.1
850 1
69.0
22.9
11.8
2.6
8.9
21.0
62.4
1.5
79.2
890. 1
59.9
10.1
1,055.3
9.5
224.3
1.7
2.9
-47.6
II
10.5
2.6
0.3
0.2
4,161 .5
Compliance Cost As
Share of Profits (%)
0.10%
0.72%
0.01%
0.09%
0.25%
0.08%
0.20%
0.10%
0.93%
0.56%
1 .96%
0.06%
2.46%
0.14%
1.24%
0.50%
1.34%
37.45%
0.40%
2.10%
2.98%
1 .03%
1.55%
0.44%
0.04%
584%
3.67%
6.32%
050%
062%
-------
Table 9. Small Business Statistics
SIC Code
2821
2822
2823
2824
2833
2834
2835
2836
2841
2842
2843
2844
2851
2861
2865
2869
2879
3471
3711
3713
3714
3715
3716
4922
4923
4924
4925
4952
4953
•
Industry Segment
Plastics materials and resins
Synthetic rubber
Cellulosic manmade fibers
Organic fibers, noncellulosic
Medicinals and botanicals
Pharmaceutical preparations
Diagnostic substances
Biological products exc. diagnostic
Soap and other detergents
Polishes and sanitation goods
Surface active agents
Toilet preparations
Paints and allied products
Gum and wood chemicals
Cyclic crudes and intermediates
Industrial organic chemicals, n.e.c.
Agricultural chemicals, n.e.c.
Plating and polishing
Motor vehicles and car bodies
Truck and bus bodies
Motor vehicle parts and accessories
Truck trailers
Motor homes
Natural gas transmission
Gas transmission and distribution
Natural gas distribution
Mixed gas
Sewerage systems
Refuse systems
Totals
Number of
Firms with less
than 500
Employees
208
73
6
25
200
512
171
174
574
641
133
664
1.026
41
112
360
180
3,146
388
534
2,488
300
93
84
58
350
33
415
2,174
15,163
Share of Small
Business
Facilities
(%)
45.9%
69.0%
46.2%
30. 1 %
84.0%
74.3%
76.3%
63.3%
85.8%
93.7%
69.5%
87.9%
8 1 .0%
72.2%
57.6%
54.9%
73.9%
98.0%
81.3%
87.9%
78.7%
86.5%
76.2%
14.6%
5.6%
29.0%
69.8%
86.3%
69.8%
Share of
Industry
Receipts
(%)
9.7%
11.6%
1.4%
3.1%
21.7%
13.6%
17.1%
17.9%
19.8%
56.7%
33.9%
23.2%
40.5%
32.4%
18.4%
11.3%
19.8%
86.7%
1.3%
52.5%
12.1%
28.9%
28.2%
5.1%
3.0%
13.2%
54.7%
69.6%
30.8%
Source: Small Business Administration. 1994 U.S. Firm Size Data at the 4-Digit SIC Level. [Online]. Available.
.
19
-------
Human welfare changes form the basis for valuing environmental quality changes expected with
environmental regulations. To relate human welfare to changes in the quality of environmental and
natural resources it is necessary, among other things, to identify the ways in which individuals interact
with economic and environmental systems and the ways these two systems interact. Economic systems,
including market and household systems, operate in conjunction with environmental systems to
contribute to human \velfare.
A conceptual framework is developed immediately below to outline how benefits may be
generated by the improved management of hazardous wastes. The focus here is on groundwater
resources as they are most typically threatened by improper hazardous waste management. This
framework: (1) identifies the ways environmental quality affects human welfare. (2) distinguishes
between economic and environmental system responses to changes in environmental quality, and
(3) illustrates how benefits from the regulation can be inferred. This is followed by a tracing of the
linkage between the regulation and its benefits.
10.1 The Circular System
Pearce and Turner (1990) identify three key economic functions of the environment that can be
used to guide this analysis:
• resource supply-the extraction or in-situ use of environmental and natural resources in the
production of goods and services ("commodities") by governments, firms, and households
(e.g., use of ground water for drinking water supply or for process water).5
• waste assimilation-the provision of a sink for disposal of waste products produced by
economic and natural systems (e.g., use of land for disposal of wastes).6
• aesthetic services-trie direct, incidental exposure to the environment (e.g., enjoyment
provided when people observe the environment).
Integrating these three functions we arrive at Boulding's (1966) metaphor of the earth as a
spaceship with a closed economic and environmental system except for solar energy. This system
recognizes the limits that exist at any point in time in our resource base, environmental quality, capital
and labor stock, technical methods, and institutions for creating utility flows (Figure 2). Utility is the
term used to describe individual's subjective sense of economic well-being. It is conditioned by people's
values and preferences. Economic systems are designed to promote improvements in utility.
Labor services, capital services (e.g., plant and equipment, infrastructure created from past
production), intermediate production (e.g., materials, energy), and environmental and natural
resource services are combined in the economic system where public, market, and household
systems use the appropriate techniques or receipts to convert these inputs into more desired public
and household commodities.
Economic systems generate unwanted byproducts or residuals in the form of heat, scrap,
combustion byproducts, etc. As Kneese, Ayres, and d'Arge (1970) point out, the First Law of
Thermodynamics requires that "...the amount (i.e., mass) of residuals inserted into the
environment must be approximately equal to the weight of basic fuels, food, and raw materials
entering the processing and production system, plus oxygen taken from the atmosphere."
20
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When the assimilative capacity of the groundwater is exceeded by the release of pollutants to the
environment the resource supply function of the environment is threatened. Faced with the threats posed
by contaminated groundwater decisionmakers in government, industry, and in households may take
averting or preventative actions to avoid or reduce these risks. They may also undertake mitigating or
repair actions once the event has been registered.
Both averting and mitigating behaviors require the diversion of resources away from their
alternative uses reducing the utility provided by those uses. Also, mitigating actions may only
incompletely restore the services provided by the affected natural, physical or human capital. The
benefits of environmental regulation are the avoided losses in utility to the US population from the
release of pollutants to the environment.
In addition to these "use" benefits people may also enjoy "nonuse" benefits from the protection
of the three functions of the environment. Nonuse benefits may derive from altruistic preferences.
Nonuse services may also contribute to an individual's welfare through a sense of stewardship for the
environment. That is, individuals not directly impacted by the controls may experience a utility gain
when they learn that the quality of the environment has been protected.
10.2 The Economic Benefits of Groundwater Protection
A key threat to the environment from improper hazardous waste management is their potential to
leach into groundwater resources. Bergstrom et al. (1996) have developed a framework to assess the
economic benefits of groundwater that, with some modifications, forms the basis of this review of the
benefits of protecting groundwater resources from pollutants. The framework consists of (1) assessing
the changes in the quality of the resource stock with a regulation, (2) identifying groundwater service
flows that may be effected by the quality changes, (3) evaluating how market and household production
may be impacted by the change in service flows, and (4) valuing the effect on human welfare of the
production impacts and of the passive linkages between human welfare and environmental quality.
Developing quantitative estimates of the economic benefits of protecting groundwater entails two
challenging requirements. First, formal linkages between groundwater protection policies and changes
in the biophysical condition of groundwater must be established. Second, these linkages must be
developed in a manner that allows for the estimation of policy-relevant economic values. The framework
in Figure 3 is used to identify and characterize the potential benefits of improved hazardous waste
management practices.
10.2.1 With Policy Groundwater Quality Changes
The first step in developing estimates of the impact of the regulation on groundwater is to
measure or estimate current groundwater conditions in quantity and quality terms. Step two is to assess
how baseline quality will change with and without the proposed regulation. This step provides estimates
of the reference (without-policy) quality and the subsequent (with-policy) quality.
10.2.2 Groundwater Service Flow Changes
Groundwater has two broad functions that may be positively impacted by environmental
regulations. The first function is storage of a water resource. Groundwater stored in an aquifer provides
a reserve of water with given quantity and quality dimensions. The second function is discharge to
21
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solar energy
Environmental
Systems
natural
resources
aesthetic ana
spiritual
services
environmental and
natural resource
services
waste
Economic Systems
labor services
p
Sy
ubllc
stems
publicly-
managed
resources
market
commodities
i
public commodities
\
Sy
Firm
stems
firm-
managed
resources
market
commodities
Hoi
Sy
i i
jsehold
stems
household-
managed
resources
public i
commodities
household commodities
human health
leisure time
J I
Human Value &
Preference Systems
: utility
t
Figure 3. The Circular System.
22
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surface waters. Again, this discharge supply has quantity and quality dimensions. Through this function,
groundwater indirectly contributes to services generated by surface waters. As Figure 4 indicates,
surface waters may also recharge groundwaters. Table 10 is adapted from the Bergstrom et al. (1996)
framework and presents the groundwater service flows associated with each of the two broad
groundwater functions that could be threatened by TC metals wastes. Of these services, provision of
drinking water and nonuse services appear to be most threatened by the release of TC metals into
groundwater.
withdrawals
withdrawals
residuals
Human
Activity
in-site uses
residuals I
Ground
Water
discharge/recharge _
Surface
Water
1 recharge
Hydrocycle
(i.e., precipitation,
runoff)
recharge
Figure 4. Groundwater Function.
23
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Table 10. Storage and Service Functions of Water Resources Potentially Impacted by TC Metals
Wastes
Services
Effects
I Provision of Drinking Water
2 Provision of Water for Crop Irrigation
3 Provision of Water for Livestock
4 Provision of Water for Food Processing
5 Provision of Water for Other Manufacturing
Processes
6 Pro\ ision ot' Clean Water Through Support of
Living Organisms
7 Support of Recreational Swimming, Boating,
Fishing, Hunting, Trapping, and Plant
Gathering
8 Support of Commercial Fishing, Hunting,
Trapping, and Plant Gathering
9 Support of On-Site Observation or Study of
Fish, Wildlife, and Plants for Leisure,
Educational, or Scientific Purposes
10 Provision of Passive or Non-Use Services (e.g..
Existence or Bequest Motivations
11 Provision of Non-Use Services (e.g., Existence
Services) Associated with Surface Water Body
or Wetlands Environments or Ecosystems by
Ground Water
Change in Quality of Drinking Water
Change in Human Health or Health Risks
Change in Value of Crops or Production Costs
Change in Human Health or Health Risks
Change in Value of Livestock Products or Production
Costs
Change in Human Health or Health Risks
Change in Value of Food Products or Production Costs
Change in Human Health or Health Risks
Change in Value of Manufactured Goods or Production
Costs
Change in Human Health or Health Risks
Change in Animal Health or Health Risks
Change in Value of Economic Output or Production
Costs
Change in Value or Costs of Recreational Activities
Change in Human Health or Health Risks
Change in Value or Costs of Commercial Harvest or
Costs
Change in Value or Costs of On-Site Observation or
Study Activities
Change in Personal Utility
Change in Personal Utility
Source: Bergstrom. J.C.. K.J. Boyle, C.A. Job. and M.J. Kealy, "Assessing the Economic Benefits of Ground Water for
Environmental Policy Decisions." Paper No. 95041 of the Waier Resources Bulletin wtih some modifications.
24
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10.2.3 Resource Allocation Changes
Changes in the quality of services provided by groundwater may directly change some marker and
household activities. In Figure 3. this phenomenon is depicted by the arrows flowing from environmental
systems to the economic stocks and production processes (market and household). Two types of
productive behaviors are particularly important-averting and mitigating.
Averting behaviors are those taken to avoid or to reduce the impact of service quality reductions.
For example, polluted irrigation water may induce farmers to change cropping patterns or practices.
Households may purchase bottled water in lieu of consuming well water. Governments may install
alternative municipal water supply systems to avoid contaminated water supplies. The result of health-
related averting activities is a lower level of realized (or ex post) exposure to environmental
contaminants. This will effect one's actual health state. The relationship between realized exposures
and the ex ante health state is determined through the human biological system.
Brain, kidney, and nervous system functions may all be impaired by exposures to water pollutants
leading to excess illness and even premature death. Knowledge of these effects and of the potential for
exposure is likely to lead to averting activities by households.
Conditional upon contracting an environmentally-related illness, the individual's realized health
state may differs from the ex ante health state because of mitigating behaviors. The key resources needed
to treat the ill individuals are the labor, materials, and capital from the medical services sector.
Since averting behaviors are taken to avoid some or all of the anticipated effects of a reduction in
service quality, the role of information is critical to those choices. Further, averting and mitigating
behaviors are substitutes. Indeed, costless irreversibility is a perfect substitute for averting behaviors.
Health related pathways groundwater quality could affect human welfare. In this framework,
household time is an endowment and must be allocated among multiple uses. In Figure 3, time is divided
between labor and leisure (leisure makes up part of the flow from household production to utility). In the
health model, this is expanded to include averting activities, mitigating activities, and sick time.
The issue of information and uncertainty is particularly applicable to the health model. While the
health model in Figure 3 implicitly treats the relationship between exposures, averting, and mitigating
behaviors, and health state as certain, the reality is individuals face considerable uncertainty and must
make decisions based on expected health outcomes.
10.2.4 Human Welfare Changes
In Figure 3, a regulation may positively impact human welfare by
• reducing the amount of resources allocated to averting and mitigating activities by producers
and households thereby leaving more resources for consumption goods and services,
• increasing health, and
• increasing the passive or nonuse services of the environment.
25
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The conceptual measure of the change in human welfare in economic analysis is the change in an
individual's utility due to the above-listed changes. However, utility is unobservable, thus the need for a
surrogate. The surrogate used in most analyses is money. Two monetary measures of individual welfare
change are employed—willingness to pay (WTP) and willingness to accept (WTA). WTP is the
maximum amount an individual is willing to pay for utility-augmenting changes and is taken as the
indis idual's value (benefits) of the change. WTA is the minimum compensation the individual would be
willing to accept to forgo the welfare improvement. It is also accepted as the individual's the value
(benefits) of the improvement.
Prices formed in competitive markets provide a basis for developing WTP/WTA values for averting
and mitigating activities. WTP/WTA is simply the avoided expenditures (i.e.. price times quantity). For
household time spent on avening or mitigating activities or sick, the price of labor services (i.e.. the wage
rate) may be used to develop estimates of foregone income.
In addition to these direct costs any utility loss associated with the inability of averting activities to
completely protect or mitigating activities to completely restore the individual's utility stream must also
be valued. For example, individuals who purchase bottled water to avoid exposures to lead in drinking
water may still be exposed through purchased meals prepared with contaminated water. Or, individuals
who do experience an environmentally-related illness my not have immediate or complete recovery.
Nonuse or passive use represents final benefit category to consider. Nonuse values are said to arise
from a variety of motives, including knowledge of existence, a desire to bequeath natural resources to
future generations, a sense of stewardship or responsibility for preserving features of ecosystems and/or
natural resources, and a desire to preserve options for futures use (Freeman, 1993). One cannot rely on
observable behavior such as expenditures or price differences for evidence of nonuse values because they
arise without an individual taking any action. They enter the utility function directly and are not related
to other processes within the household production framework. For example, individuals may gain utility
from the knowledge that a healthy ecosystem exists, or simply that a stock of groundwater is protected by
regulation of waste streams. The only way to determine these values is to ask people to directly provide
them in response to a contingent outcome question. Table 11, reproduced from Crutchfield et al. (1995)
shows that households value groundwater protection in the range of several hundred dollars annually.
11.0 Benefit-Cost Comparison
The potential benefits of an environmental regulation may accrue to direct users of the affected
water resources and to nonusers who would benefit to the extent that they hold altruistic values for the
affected individuals or a sense of environmental stewardship for the impacted resources. The potential
key gains to users are the reduced averting and mitigating expenditures, increased incomes, and improved
health states. Individuals proximate to the several thousand sites where these wastes are managed would
benefit through direct use of the environment. The rest of the U.S. population would benefit through
nonuse linkages.
Juxtaposed against these potential benefits are the annual costs of the regulation. The benefit-cost
comparison requires subtracting costs from benefits to determine if the regulation is expected to provide
a welfare gain. However, because many benefits, and even some costs, may not be readily monetized, or
even quantified, qualitative assessment should accompany formal benefit-cost comparison.
26
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I
Table 11. Empirical Estimates of Ground Water Protection Benefits
Study
"Good" being valued
Estimated willingness to pay
(WTP)
Caudill. 1992. and Protection of ground water subject to
Caudill and Hoehn. 1992 pesticides and nitrates.
Powell, 1991
McClelland and others,
1992
Shultz, 1989, and Shultz
and Lindsay, 1990
Jordan and Elnagheeb,
1992
Poe. 1993. and Poe and
BUhop. 1992
Edwards, 1988
Sun, 1990, and Sun,
Bergstrom, and Dorfman.
1992
Ground water subject to contamination by
toxic chemicals and diesel fuel.
Ground water, type of contaminant not
specified
Ground water, type of contaminant not
specified
Drinking water subject by contamination by
nitrates.
Drinking water subject to contamination by
nitrates.
Ground water subject to contamination by
nitrates and pesticides.
Ground water subject to contamination by
agricultural fertilizers, nitrates and
pesticides.
Rural: S43-S46/household
(hh)/\ear.
Urban: S34-S69/hh/yr.
All data: $61.55/hr/year.
Respondents with a history of
contamination: 581.66/hh/year
Respondents with no
contamination: S55.79/hh/year.
Complete sample: $84/hh/year.
Mean WTP: $129/hh/year.
Public water system: $146/hh/year.
Private wells: S169/hh/year.
S168-S708/hh/year.
$286-Sl.I30/hh/year.
Mean WTP: 5641/hn/year, ranges
fromS165-$l.452/hh/vear.
Source:
Crutchfield. S.R.. P.M. Feather. D.R. Hellerstein. "The Benefits of Protecting Rural Water Quality: an
Empirical Analysis." Report No. 701 Economic Research Service. U.S. Department of Agriculture.
References
Bergstrom, J.C., K.J. Boyle, C.A. Job, and M.J. Kealy, "Assessing the Economic Benefits of Ground
Water for Environmental Policy Decisions." Paper No. 95041 of the Water Resources Bulletin.
Boulding, K. "The economics of the coming spaceship Earth," in H. Jarrett (ed.) Environmental Quality
in a Growing Economy. Johns Hopkins University Press, Baltimore, 1966.
ChemExpo. August 4, 1997. "Zinc Sulfate." Industry News: Chemical Profile.
-------
Instruction Manual for the Biennial Reporting System (BRS) Flat Files, U.S. Environmental Protection
Agency. Office of Solid Waste, Washington, DC, April 1997.
1995 Hazardous Waste Report—Instructions and Forms, U.S. Environmental Protection Agency,
Washington DC, EPA Form 8700-13A/B (5-80) (8-95), August 1995.
Industry Norms & Key Business Ratios 1995-1996. Murray Hill, NJ. Dun & Bradstreet Information
Services.
Kneese, A.V., R.U. Ayres, R.C. D'Arge. Economics and the Environment: A Materials Balance
Approach. The Johns Hopkins Press, Baltimore and London. ISBN 0-8018-1215-1. 1972.
Pearce, D.W., and R.K. Turner. Economics of Natural Resources and the Environment. The Johns
Hopkins University Press, Baltimore, 1990.
Queneau, Paul B.. Barry J. Hansen, and D. Erik Spiller. 1993. "Recycling Zinc in the United States."
Chapter 22 of the proceedings of the Milton E. Wadsworth 4th International Symposium on
Hydrometallurgy, AIME SME/TMS, Salt Lake City, UT, August 1-5.
Small Business Administration. 1994 U.S. Firm Size Data at the 4-Digit SIC Level. [Online].
Available: <
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Appendix A
Development of Cost Functions for TC Metals Wastes with Organic UHCs
This appendix briefly describes the origins of the cost functions used for estimating storage,
treatment, and disposal of TC metals wastes with organic UHCs. With the exception of incineration, the
costs are taken directly from functions developed for mineral processing wastes or are adapted from
them. Descriptions of these equations are included in Regulatory Impact Analyses: Phase IV Land
Disposal Restrictions—TC Metals (TC Metals R1A), April 14, 1997. Four sets of equations are used
here: cost functions for baseline sludges, baseline solids, post-rule sludges, and post-rule solids.
However, because several of the equations are used for more than one case, the equations are presented
by facility operation.
All storage operations use the same set of equations. They are described in the TC Metals RIA,
p. A-6. For quantities less than 200 mt/yr, drums are assumed. For larger quantities, rolloffs are
assumed.
Storage: cost = 24.589 Q + 132.23 Q< 200 mt/yr
= -0.0022 Q2 + 29.272 Q + 4,840.9 200 < Q < 7,500 mt.yr
Incineration
Costs for non-commercial hazardous waste incineration were supplied in spreadsheet form as
used for maximum achievable control technology (MACT) standards.1 All annual costs were summed
and compared to annual quantities of waste incinerated, from which a power equation was derived. The
annual costs include a credit for fuel value of the waste burned. For the present work, this cost was
omitted because the TC metals waste is assumed not to have any significant fuel value. The equation
below was used for baseline and post-rule cases.
cost = 158,860 Q*6984 300 < Q < 185,000 mt/yr
Stabilization
Stabilization costs are developed from revised mineral processing waste cost functions,2 but
extended to include a lower end case of 300 mt/yr of waste treated. The cases were also revised to use 25
percent cement stabilization in place of 36 percent stabilization.
Spreadsheet supplied by Paul Borst, US EPA, November 26, 1997. Data include capital and
annual costs for 50 non-commercial incinerators as pan of a database containing information for
over 100 incinerators. Types described also include cement kilns, light-weight aggregate kilns,
commercial incinerators, and government facilities.
Memorandum to Paul Borst, US EPA, from Jen Mayer and John Collier, ICF, September 15,
1997.
A-l
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Baseline sludge and solids:
cost = 234.96 Q + 20,836 300 < Q < 3,000 mt/yr
= 38.516 Q + 298,633 3,000 < Q < 300,000 mt/yr
Post-rule sludge:
cost = 220.5 Qx 0.35 + 21,263 300 < Q < 3,000 mt/yr
= 17.058 Qx 0.35+ 403,721 3,000 < Q < 300,000 mt/yr
Post-rule solids:
cost = 220.5 Qx 0.85 + 21,263 300 < Q < 3,000 mt/yr
= 17.058 Q x 0.85 + 403,721 3,000 < Q < 300,000 mt/yr
Disposal
The disposal equation is described in the TC Metals RIA, p. A-5. Its form is such that one factor
is changed to accommodate changes in waste quantity to be treated. The change in quantity results from
prior treatment that increases or decreases the quantity of material to be disposed of. For example, 100
mt of waste mixed with 35 mt of cement and water would result in an overall quantity of 135 mt to be
disposed of. The factor in the equation would change to 1.35. For waste containing 65 percent water,
incineration residues (after mixing with cement and water) are 56.8 percent of the original mass of waste
submitted for treatment. For solids with 15 percent water, the stabilized residues for disposal are 138
percent of the original mass of waste.
Baseline sludge and solids:
cost = (35 + 5.68) Q x 1.35x0.9072 x (381.1/358.2)
Post-rule sludge:
cost = (35 + 5.68) Qx 0.568 x 0.9072 x (381.1/358.2)
Post-rule solids:
cost = (35 + 5.68) Q x 1.38x0.9072 x (381.1/358.2)
A-2
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Appendix B
Cost and Economic Impacts: Phase IV Land Disposal Restrictions Final Rule—TC Metals
Notice to Reviewers
This report was originally written based on using 36 percent cement stabilization forTC metals wastes.
Since completion of the original analysis, information from a commercial treatment company indicates
that cement in the range of 20 to 25 percent is sufficient to meet the proposed UTSs. This revised
version is based on 25 percent cement stabilization for TC metals wastes.
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§3004(m) of the Resource Conservation and Recovery Act directs the EPA Administrator to
promulgate treatment standards for hazardous wastes prohibited from land disposal in order to minimize
long term threats to human health and the environment.' In 1990 as part of the Third Third LDR rule
EPA developed treatment standards for Extraction Procedure (EP) metals wastes that require the wastes
meet characteristic levels before land disposal. In 1994 the Phase n LDR rule established Universal
Treatment Standards (UTS) for 216 organic, metal, and cyanide constituents in hazardous waste. In
1995, EPA proposed to revise treatment standards for eight toxicity characteristic (TC) metal wastes:
arsenic, barium, cadmium, chromium, lead, mercury, selenium and silver.2 In the RIA for the proposed
rule, EPA stated that the achievement of the proposed universal treatment standards (UTS) for TC metal
wastewaters and nonwastewaters could be achieved through existing technology at a minimal cost.5
Public commenters have raised concern over their technical ability to meet the standards and the
costs associated with the previously proposed treatment standards. EPA has carefully considered this
information giving particular attention to nonferrous foundries as these sources have been specifically
singled out by commenters. Based on this review, EPA believes that there will not be significant costs to
the majority of the TC metals universe affected by the standards, including nonferrous foundries as
compliance with current requirements appears sufficient to meet the UTS requirements. However, as
part of this review, EPA has found that the concern of nonferrous foundries may be based on the need to
switch from iron filings as a reagent to cement or trisodium phosphate to meet the UTS requirements.
However, iron filings do not appear to be sufficiently protective of the environment to meet the current
requirements. This report provides a discussion of the Agency's basis for concluding that the costs of the
rule are likely to be negligible for sources of TC metals and an analysis of the costs and economic
impacts for nonferrous foundries to move from a noncompliance to compliance baseline.
1.0 Nonferrous Foundries
The United States nonferrous foundry industry (SIC codes 3366, 3369, also some nonferrous
foundries in the fabricated metal SIC codes, principally 3491, 3492, and 3494, valves and fittings)
includes some 2,000 nonferrous foundries (3,000 total) producing fabricated metal products. All
foundries produce spent sand from molds used to form metal castings. Approximately, 791 nonferrous
foundries (either brass & bronze or brass, bronze & aluminum) would be directly impacted by the rule.4
It is generally believed that all nonferrous foundries are small businesses according to the Small
Business Administration definition of small business as firms with fewer than 500 employees. A 1989
survey by the American Foundrymen's Society (AFS) indicated that the average foundry size was
69 employees. The survey was biased towards larger foundries because foundries with 10 or fewer
42 U.S.C. §6924(m), Solid Waste Disposal Act 3004(m).
Developed from a telecon between Gary Mosher, American Foundrymen's Society, and James H.
Turner, RTI. September 24, 1996.
Regulatory Impact Analysis of the Phase IV Land Disposal Restriction Rule, August 18, 1995, pp.
1-11,1-14.
Data provided in a letter from Collier, Shannon, Rill, and Scott, November 27, 1995 to EPA
RCRA Information Center.
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employees were not included. A 1995 AFS survey indicates that 345 of 614 surveyed copper-based
foundries had fewer than 50 employees. An extrapolation from data from the 1992 Census of
Manufactures indicates that 1992 annual revenues for this group of nonferrous foundries were
approximately $2.094 billion.5
2.0 Waste Generation and Management
Sand is used in the production of nonferrous castings to provide physical support of the mold and
to serve as a heat sink. While much of this sand is recycled, some is degraded and must be discarded. Of
the estimated seven million tons of foundry sand disposed of annually about 300,000 tons exhibit the
toxicity characteristic for lead and cadmium. This estimate is based on the assumption that each of the
650 brass and bronze foundries and each of the 386 brass, bronze and aluminum foundries generate
375 tons of waste sand annually. Further, it is estimated that 98 percent of the former group and
40 percent of the latter generate sand wastes that exhibit the TC for lead and cadmium.6 Thus,
375[(650 * 0.98) + (386 * 0.40)] = 300,000
Assuming all facilities that generate TC wastes requiring treatment require treatment for all their
waste sand, about 791 facilities would be directly impacted by the requirement to meet UTS
requirements. About 89 percent of these facilities (704) treat on site. Of that treated on site about
75 percent is treated with iron filings. The remainder is stabilized with other chemicals typically
trisodium phosphate. (TSP)7—see Table 1. Of particular interest are the foundries that treat with iron
filings as they are believed not capable of achieving UTS requirements.
Table 1. Estimated Number of Foundries Employing Each Stabilization Reagent
for On-Site Treatment in the Baseline
Stabilization Reagent Number of Facilities
Iron fillings 528
Trisodium phosphate 176
Total 704
Data from the 1992 Census of Manufactures indicates that 437 nonferrous foundries (including
copper, brass, bronze foundries) each generated receipts of $2.647 million. This would
extrapolate to an aggregate value of $2.094 billion (791 x 2.647 = 2.094 billion) for
791 nonferrous foundries that AFS believes are affected by today's rule.
Data provided in a letter from Collier, Shannon, Rill, and Scon, November 27, 1995 to EPA
RCRA Information Center.
Letter from the American Foundrymen's Society, Inc. to Michael Petruska, USEPA, Office of
Solid Waste, August 2, 1996.
B-2
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3.0 Current Treatment Practices
The treatment practices used to reduce the mobility of metal concentrations in TC wastes consist
of a series of unit operations that can be combined in different ways depending on the waste to be treated
and its form. These operations are described below for treatment of nonwastewaters. These operations
are current practices and can be used to meet the proposed standards. Practices will vary across facilities
depending on the specific conditions of each manager.
While similar to mineral processing waste treatment, quantities and specific treatment practices
may be different. For example, cement is a typical stabilizing agent used in the treatment of metal
wastes. However, as noted above, information suggests that foundry wastes are typically treated with iron
filings or TSP.
The current LDR treatment standard for hazardous lead nonwastewaters is 5.0 mg/L TCLP.
After the concentration of lead is reduced below its characteristic level, the waste is no longer hazardous
and may be disposed of in a Subtitle D landfill. A typical waste treatment train used to reduce
concentrations of solid toxic metals includes storage, stabilization of solids with cementitious materials,
and disposal of stabilized wastes in Subtitle D (nonhazardous) landfills. The treatment methods and
subsidiary operations are summarized below.
Storage
Wastes are typically stored in drums, tanks, roll-off containers, or buildings. Small quantities of
solids are usually stored in drums. Each storage method has its own requirements for moving the waste
into and out of the storage area. Where leaching or leaking can take place, monitoring must be used to
detect such occurrences. As long as the material is defined as hazardous waste, storage facilities must
meet Subtitle C design and operating requirements.
Stabilization
Metal-bearing solids and dewatered sludges that exhibit a characteristic and are, therefore,
hazardous can be treated with cement and/or other materials that form a hard substance with low leaching
characteristics. Stabilization adds significantly to the mass of material that must be landfilled.
Disposal
After treatment, residues must be given a final disposal place. Either Subtitle C or Subtitle D
landfills are generally used.
Subtitle C Landfill Disposal Subtitle C landfills are required for disposal of hazardous wastes.
Stringent monitoring, closure, and post-closure requirements must be met to ensure that toxic materials
do not migrate from the site. Construction must be such that leaching or migration is kept to a minimum.
Highly impermeable underlying soils and landfill liners are required. In some cases, because of logistics,
it may be less costly to dispose of Subtitle D wastes in a Subtitle C landfill.
Subtitle D Landfill Disposal of Treated Wastes For characteristic wastes that have been
treated to a concentration below the required treatment level, disposal may be made in a Subtitle D
landfill. Some of these landfills do not have the special requirements for construction, monitoring, and
closure that are found at the Subtitle C landfills.
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4.0 Revised UTS Levels for TC Nonwastewaters
Public commenters including a commercial hazardous waste treatment firm and trade
associations representing generators of lead-bearing hazardous waste D008 (primarily secondary lead
slags from lead-acid batter smelters and foundry sands from nonferrous foundries) stated in their
response that either the proposed treatment standards for certain constituents could not be met or
alternatively that they could only be met at an additional cost.8 These comments focused mostly on the
proposed treatment standards for lead, chromium and selenium. For lead and chromium nonwastewaters,
one commercial hazardous waste treatment firm. Chemical Waste Management, suggested that additional
costs could result from additional treatment reagent when the total lead and chromium content of these
wastes exceeded one percent.9 Another commercial hazardous waste treatment firm, Rollins
Environmental, has suggested that it would have been able to meet treatment standards for lead and
chromium nonwastewaters at the 0.37 and 0.86 ppm level without modifying its treatment process.10
Only the foundry industry identified cadmium as a constituent of potential concern in terms of treatability
using treatment reagents, trisodium phosphate and iron filings, currently utilized within the foundry
industry. EPA has carefully considered this information in developing revised treatment standards levels.
For lead, chromium, and selenium TC metal nonwastewaters, EPA had previously proposed UTS
of 0.37, 0.86 and 0.16 ppm respectively. For its reproposal, EPA is proposing UTS standards for lead of
0.75 ppm, chromium of 0.85 ppm, and selenium at 5.7 ppm (its current treatment standard) for TC metal
wastes. Most of the wastes identified by the commercial hazardous wastes treaters as not amenable to
the proposed UTS relate to selenium bearing wastes. Since EPA has reproposed to retain its treatment
standard for selenium at its current level, it does not believe that the rule will incur incremental costs for
any selenium-bearing DO 10 hazardous waste as a result of the reproposed selenium UTS.
Regarding lead, public commenters for the secondary lead smelter industry and nonferrous
foundry industry indicate that the secondary lead slags and nonferrous foundry sands are either not
amenable to the proposed UTS nonwastewater level of 0.37 ppm" or cannot achieve this level without
8 Letter to RCRA Docket from Kevin Igli, Vice-President, Chemical Waste Management,
November 20, 1995; Letter to Anita Cummings, USEPA, Office of Solid Waste from Kevin Igli,
Vice-President, Chemical Waste Management, June 17, 1996 (non-CBI portion); Letter to RCRA
Docket from John L. Wittenborn, William M. Guerry, Jr., Peter G. McHugh, of Collier, Shannon,
Rill & Scott on behalf of the American Foundrymen's Society, November 20, 1995; Letter to
Mike Petruska, USEPA, Office of Solid Waste from Gary Mosher, Director of Environmental
Affairs, American Foundrymen's Society, August 2, 1996; Letter to Paul A. Borst, USEPA,
Office of Solid Waste from Susan Panzik of Swindler & Berlin, on behalf of the Association of
Battery Recyclers, November 12, 1996.
9 Personal communication between Paul A. Borst, USEPA, Office of Solid Waste and Mitch Hahn,
Chemical Waste Management Inc., June 21, 1996.
10 December 19, 1996 letter to Anita Cummings, USEPA, Office of Solid Waste from Michael G.
Fusco, director of Regulatory Analysis, Rollins Environmental Inc., p.4 of edited draft EPA trip
report letter to Rollins Highway 36 facility in Colorado.
1' The secondary lead smelter industry has been the principal commenter that secondary lead slags
could not meet the proposed UTS for lead.
B-4
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incurring additional costs.|: However, it is possible that secondary lead smelters may be able to modify
their processes to generate nonhazardous secondary lead slags. Some secondary lead smelters have been
able to render slags generated as nonhazardous by processing them through an electric arc furnace.13
Other secondary lead-smelters have been able to render slags nonhazardous as generated through
reprocessing them through blast furnaces onsite a second time, though this has proven unsuccessful
commercially.'4 Finally, it is possible for slags containing hazardous constituents such as lead, cadmium
and arsenic to be cooled in such a way either through ambient cooling or quenching to significantly
reduce the leachability of these constituents in the slag matrix.15
Moreover, EPA has data suggesting that secondary lead slags have been successfully treated to
the proposed UTS level for lead by both secondary lead smelters and commercial hazardous waste
treaters.16 In contrast to comments from Chemical Waste Management, the data from Rollins
Environmental (as well as the slag data from BCI/ABR) also seem to suggest that when portland cement
is used as the primary stabilization reagent, it is possible to treat a wide variety of TC metal wastes
including high lead and chromium wastes (i.e., those with greater than one percent total concentrations of
lead and chromium) to the previously proposed UTS levels including 0.37 ppm for lead and 0.86 for
chromium without incurring additional treatment cost or modifying existing treatment processes.
Because these results apply to the more conservative previously proposed treatment standards for TC
metal wastes, EPA believes that for the higher revised UTS standard for lead of 0.75 ppm that it will be
even easier to meet these treatment standards using portland cement-based stabilization without incurring
additional treatment costs.
However, when less expensive, less effective treatment reagents other than portland cement are
used to treat TC metal waste, existing data indicates more of these reagents must be used at a higher cost
(principally for additional treatment reagent) to achieve the reproposed UTS standards in today's rule.
Although most commercial hazardous waste treatment facilities and many industries use portland cement
as the treatment reagent of choice, other industries such as the foundry industry principally use other
treatment reagents such as iron filings or phosphate-based treatment reagents.
12 The American Foundrymen's Society main contention in its public comments has been that
existing management practices of treating lead-bearing foundry sands to the current treatment
standards of 5 ppm leachable lead cannot be maintained without additional cost. However, in
contrast to the Association of Battery Recyclers, AFS has not made the claim that hazardous
foundry sands were not treatable to the proposed UTS for lead.
13 Personal Communication between Paul Borst, USEPA, Office of Solid Waste and Gerald Dumas,
Vice-President for Environmental Services, RSR Corporation. September 23, 1996.
14 R.A. Leiby, Jr. Secondary Lead Smelting at East Penn Manufacturing Co. Inc.. EP Congress
1993 as cited in Paul Queneau, et al.. Recycling Heavy Metals in Solid Waste. Sponsored by
Office of Special Programs and Continuing Education, Colorado School of Mines, June 28-30,
1994.
15 Paul Queneau, Lawrence D. May, and Douglas E. Cregar, application of slag Technology to
Recycling of Solid Wastes, Incineration Conference, Knoxville, TN, May 1991, as cited in
Queneau, supra. Note 9.
16 Supra, Note 11, See also October 9. 1996 letter to Anita Cummings, USEPA, Office of Solid
Waste from Steve Emmons, Battery Council International Environmental Committee chair and
Earl Cornette, Chairman, Association of Battery Recyclers, Inc.
B-5
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Although these reagents are typically claimed to be less expensive than portland cement,'7 recent
estimates by EPA suggest that phosphates are more expensive than cement. Also, the range of TC metal
constituents and long-term effectiveness of some of these reagents is questionable.18 Based on existing
data on iron and phosphate based treatment reagents, EPA believes that phosphate-based treatment
reagents (usually trisodium phosphate or calcium phosphate) with or without ph buffers represent only
one reagent that could be considered effective treatment for a range of TC metal wastes that are not TC
simply for lead. EPA is not commenting on the long term effectiveness of phosphate-based treatment
reagents in this analysis. Rather, because: 1) the American Foundrymen's Society only provided bench
scale data on phosphate-based reagent performance for both lead and cadmium in foundry wastes and did
not provide comparable data on iron filings for TC lead and cadmium wastes and 2) some industry data
indicate that iron filings are ineffective treatment agents for hazardous EP (extraction procedure)
cadmium wastes, EPA does not believe that it is appropriate to estimate compliance costs from today's
rule using iron filings as the baseline management method. Rather, EPA has modeled portland cement as
the least expensive reagent that has been demonstrated in bench scale trials to treat both lead and
cadmium in foundry wastes.
5.0 Cost Analysis
Treatment costs are estimated for lead nonwastewater generated by nonferrous foundries at the
facility and industry level.
5.1 Unit Costs
Functions used for estimating existing and future costs due to regulation of TC metal wastes are
based on the same functions used for mineral processing wastes. The modification of these functions for
TC wastes is described in a previous document"
Equations used for the analysis of lead wastes from foundries are listed below. Storage,
stabilization, and disposal in a Subtitle D (nonhazardous) landfill are the operations required for the solid
waste treatment and disposal. The equations described here apply to the post-rule situation of conversion
from treatment with iron filings at 15 percent to cement at 25 percent.20 This quantity of cement
17 Supra, Note 9, August 2, letter from Gary Mosher. American Foundrymen's Society to Mike
Petruska, USEPA, Office of Solid Waste. AFS data indicate that to treat foundry sands, the
reagent cost of portland cement in foundry sand stabilization averages 555 per ton compared with
$26 to $31 per ton for trisodium phosphate or $11 per ton for iron filings.
18 EPA has previously proposed to prohibit the use of iron filings as treatment reagent as
impermissible dilution because the Agency believes that iron filings do not provide effective long
term stabilization of lead in hazardous wastes such as foundry sands. 60 FR 11702, 11731
(Thursday, March 2, 1995). The Agency also noted that iron filings or iron material may result in
false negatives for the Toxicity Characteristic Leaching Procedure (TCLP).
19 Draft RIA document. Phase IV Land Disposal Restrictions - TC Metals, T. H. Bingham and J. H.
Turner, delivered to Paul Borst, April 14, 1997.
20 Supra, Note 10, range of 20 percent to 25 percent used by Rollins.
B-6
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represents an intermediate value in the range (8 percent21 to 36 percent") found to be used by waste
treatment facilities.
Storage costs for waste to be treated and for treatment reagents are included in the stabilization
equations described below
Stabilization
With exceptions, the stabilization functions for TC metals wastes for treatment with 25 percent
cement are derived from the same data and assumptions used for mineral wastes for treatment with
36 percent cement.23 The exceptions are described below.
Cement at 25 Percent
The mineral waste functions are formed from eight cases ranging from waste generation of
900 metric tons per year (mtpy) to 300,000 mtpy. A ninth case, 300 mtpy, is added to extend the range of
cases below the typical foundry size of 340 mtpy (375 short tpy). Two differences exist in equipment
selection for the 300 mtpy over the 900 mtpy cases: a waste storage silo (storage hopper) of reduced size
is formulated by assuming that a hopper two-thirds the size of the hopper used for the 900 mtpy case will
cost 80 percent as much. A smaller screw conveyor motor is priced based on comparison of costs in the
Means Building Construction Cost Data manuals. For all cases, equipment sizes are adjusted for quantity
sizes between 36 percent cement as used for mineral wastes and 25 percent as used for TC metals wastes.
Table 2 shows the nine cases, in which the upper eight cases are similar to the eight mineral
waste cases, but with unit stabilization costs about 5 percent to 20 percent lower than for 36 percent
cement depending on plant size. When total annual costs for treatment with 36 percent cement are
plotted against annual waste generated for the eight upper cases, the same linear cost equation is obtained
that was found for the mineral waste cases (Equation 4 below). This equation implies that the TC metal
wastes cases are constructed in the same manner as the mineral waste cases.
Addition of the ninth case changes the cost equation slightly (Equation 2 below). This equation
implies that the added case has a minor effect on the cost function (on average, about a five percent
difference from the equation formed from eight points).
Examination of the plot formed from the nine cases (Figure 1) shows that the four points
clustered at the bottom end of the curve have a different slope than is found for all nine cases. Figure 2
shows these four points and the regression line associated with them. The line shows that the 300 mtpy
case is consistent with 900 mtpy, 1,500 mtpy, and 3,000 mtpy mineral waste cases. A cost equation for
the four cases is given below as Equation 3.
21 Memorandum from Jen Mayer and John Collier to Paul Borst, September 15, 1997, Cement and
Trisodium Phosphate Stabilization Cost Functions, and subsequent communication on October 17.
Range of 8 percent to 2Q percent suggested by the Portland Cement Association.
:: Supra, Note 2\, range of 10 percent to 36 percent suggested by McCutcheon Enterprises.
:3 Supra, Note 22, upper end of range suggested by McCutcheon Enterprises.
B-7
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Table 2. Annual Stabilization Cost at 25 Percent Cement
Case
Waste quantities (mt/yr)
Waste quantities (ml/quarter)
Waste quantities (mt/d)
Operational hours per day
Operational days per quarter
Operational days per year
Waste quantities (ml/hr)
Reagent
Cement (mt/d)
Cement (ftVd)
Horsepower — screw conveyer
Capital Cost
Silo
Screw conveyer
O&M Cost
*? Cement. $
oo
Labor
Electricity
Maintenance
Water usage
Water (ml/d)
Water (gal/d)
Horsepower - pump
Capital Cast
Tank
Freight and installation
Pump
O&M cost
Water ($)
Labor
Electricity
Maintenance
A'
300
75
13
8
6
24
2
3.1
81
7.5
1,200
10,000
6,961
5.510
75
1.120
1.3
331
0.5
450
135
734
66
5,017
5
118
A
900
225
14
8
16
64
2
3.5
91
7.5
1 ,2(K)
K).(KK)
20,883
14,694
200
1,120
1.4
372
0.5
1,681
504
734
198
13,379
13
242
B
1.500
375
14
8
26
104
2
3.6
94
7.5
1.200
10.000
34,805
23.878
326
1.120
1.4
382
0.5
1.681
504
734
331
21,740
22
242
C
3.000
750
15
8
51
204
2
3.7
95
7.5
1.200
10.000
69.610
46.838
639
1.120
1.5
389 '
0.5
1.681
504
734
662
42,644
43
242
D
15.000
3.750
288
8
13
52
36
72.1
1.870
10
29.200
15,000
348.049
1 1 ,939
217
4,420
28.8
7.633
5
16.684
5.005
2007
3.308
10.870
109
1.869
E
30.000
7,5(K)
288
8
26
104
36
72.1
1.870
10
29,2(K)
15.000
696.098
23,878
434
4,420
28.8
7,633
5
16,684
5,(X)5
2007
6,616
21,740
217
1.869
F
75.000
1H.750
298
8
63
252
37
744
1.930
10
30,400
15,000
1 .740,245
57.859
1.052
4.540
29.8
7,876
5
16.684
5.(X)5
2007
16,539
52.678
526
1,869
C
150.000
<7,5.400
40,000
3.4H0.489
37,654
1.883
10,640
91.5
24.203
5
47.025
I-I.IOH
2007
33,078
34,283
342
4,903
H
300,000
75,000
926
8
81
324
116
231.5
6.004
27.5
72.000
40.000
6.960.979
74.390
3,721
11.200
92.6
24,502
5
47,025
I4.IOK
2007
66.156
67,729
676
4,903
(continued)
-------
Table 2. Annual Stabilization Cost at 25 Percent Cement (Continued)
03
Case
Waste handling
Days/qtr
Horsepower - waste hopper
Capital Cost
Waste hopper
O&M cost
Front-end loader rental ($/yr)
Fuel and maintenance
Electricity
Labor
Maintenance
Pugmill system
Mass processed (mt/d)
Horsepower - pugmill
Capital Cost
Pugmill
Freight and installation
O&M cost
Electricity
Labor
Maintenance
Casting equipment
Number of 1 cy forms
O&M costs
Forms ($/yr)
Total Capital Cost ($)
Annual Cap Cost (Vyr)
O&M Cost (Vyr)
Total Annuallzed Cost (Vyr)
Unit Cost (Vmt)
A'
4.60
7.5
9.640
33.600
10,781
75
11,021
964
17
15
20,000
6,000
150
5,510
2,000
76
3.693
48,159
4,546
86,667
91.213
304.04
A
16.07
7.5
9,640
89,600
28.749
200
29.389
964
19
15
20,000
6,000
401
14,694
2,000
226
10,981
49,759
4.697
227,708
232,405
258.23
B
16.30
7.5
9.640
145.600
46.717
326
47,757
964
19
15
20,000
6,000
651
23,878
2,000
376
18,270
49,759
4,697
368.626
373,323
248.88
C
16.30
7.5
9.640
285.600
91.637
639
93.677
964
20
15
2(),0(X)
6,000
1.278
46,838
2,000
752
36.540
49.759
4,697
720,969
725,666
241.89
D
312.50
10
28.693
72.800
23,358
217
23,878
2.869
389
75
45,000
13,500
1.629
11,939
4,500
3.758
182.601
155,089
14,639
704,573
719,212
47.95
E
326.09
10
28,693
145,600
46,717
434
47.757
2.869
389
75
45.(XXJ
13.500
3.257
23.878
4,500
7.516
365.202
155.089
14.639
1.395.488
1,410.127
47.00
F
323.28
10
28.693
352.800
113.198
1.052
115.718
2,869
402
75
45,000
13,500
7,892
57.859
4,500
IK.790
913.006
1 56.289
14.752
3,444,205
3.458.957
46.12
<;
101351
20
57.386
229.6IX)
73.669
1 ,370
75.309
5.739
1 ,235
150
KX).(XX)
30.1XX)
10,273
37.654
10,000
17.579
1.825,964
356,926
33.690
5.872.850
5.906.540
39.38
H
101351
20
57,386
453,600
145,541
2,706
148.781
5,739
1.250
150
100.000
30.000
20.295
74.390
10.000
75.157
3.651,879
362.526
34,219
11,702.685
11.736.904
39 12
-------
12,000,000
= 3a.1fifiit1.?9B.fi33
50,000 100,000 150,000 200,000
Waste treated mt/yr
250,000 300,000
Figure 1. Stabilization cost, 25% cement, 9 points, $/yr
800,000
700,000 • •
600,000 ••
500,000
500 1,000 1.500 2,000
Waste treated, mt/yr
2.500
3,000
Figure 2. Stabilization cost, 25% cement, 4points, $/yr
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The cost equations for waste treatment at 25 percent are, where Y = cost in S/yr and X = waste
treated in mtpy:
For 8 points: Y= 37.955 (X) + 340,470 r = 0.9980 (1)
9 points: Y= 38.156 (X) + 298,633 r = 0.9976 (2)
4 points: Y = 234.96 (X) + 20,836 1^=1 (3)
For mineral waste treatment at 36 percent, Equation 4 is obtained, which is identical to the
equation obtained for TC metals waste treatment at 36 percent cement.
For 8 points: Y= 49.177 (X) + 342,235 1^ = 0.9988 (4)
Treatment Cost for a Typical Foundry
When applied to a typical foundry at 375 tpy (340.2 mtpy), the four-point equation gives the
following estimated annual treatment costs:
Cement at 25 percent: $100,769/yr $296.21/mt
The estimated cost difference for the foundry in changing from iron filings at 15 percent to
cement at 25 percent for waste treatment is $6l.40/mt. Disposal costs, described below, must be added
to the stabilization costs.
Disposal
Two sets of equations are available for estimating disposal costs after stabilization. Both sets are
derived from functions previously described.24 The final term in each equation is a multiplier accounting
for the difference in mass of disposed material compared to the mass for which the original equations
were derived.
cost = ((25.485) Q + 294,701) x 1.25 for 25% cement, Q > 5,000 mt/yr
= (35 +5.68) Qx 0.9072 x (381.1/358.2) x 1.25 for 25<7c cement Q< 5,000 mt/yr
Disposal Cost for a Typical Foundry
When applied to a typical foundry at 375 tpy (340.2 mtpy), disposal cost is:
Cement at 25 percent: $16,697/yr $49.08/mt
The estimated disposal cost differences for the foundry in changing from iron filings at
15 percent to cement at 25 percent is $3.93/mt.
The capital costs and annual incremental cost (which includes the annualized capital cost) per
foundry for the revised UTS level is provided in Table 3. These values are found by solving appropriate
equations above for Q = 340.2 (the metric equivalent of 375 tpy), the average value per foundry.
24 Supra, Note 19.
B-l
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Table 3. Incremental Cost Per Nonferrous Foundry
Activity Capital Cost Annual Cost
cement @ 25% cement @ 25%
a :i
Storage
Stabilization 1,365 20,888
Disposal ' 1,337
Total Incremental Cost $1.365 $22.225
4 Included in stabilization costs
5.2 Aggregate Costs
The aggregate costs for all nonferrous foundries using iron filings as a reagent to meet current
(baseline) requirements are provided in Table 4. They are estimated by multiplying the per facility
incremental costs from Table 3 by the estimated number of nonferrous foundries using iron filings: 528.
Table 4. Total Incremental Cost to Nonferrous Foundries for
Achieving Compliance with Current Requirements
Capital Cost Annual Cost
Reagent (million dollars) (million dollars per year)
Cement® 25% $0.721 $11.735
6.0 Economic Impacts
Based on the foregoing analysis, EPA believes that most generators of TC metal wastes using
Portland cement as the main reagent of stabilization will not incur cost resulting from today's rule.
However, nonferrous foundries not in compliance with the current requirements will collectively incur
estimated costs of $12 million annually to achieve compliance. These foundries account for a maximum
of two-thirds of the entire industry in terms of number of facilities. As there is industry level data only
for revenues and profits, these values are scaled by 528/791 to develop estimates of these variables for
the industry subset using iron filings—see Table 5. These values are used in Table 6 to compute cost to
revenue and cost to profit ratios for achieving compliance with the current requirements.
The standard view of the facility closure decision is that profit-maximizing managers will elect
to exit a market when the value of the productive assets in their best alternative use exceeds the expected
present value of remaining in the market. This view requires that managers of nonferrous foundries
assess the current and future market for the commodity produced at the facility to evaluate the revenue
implications of keeping the facility open and remaining in the market. It also requires that they assess the
current and future markets for the inputs used to make foundry products to evaluate the cost implications
B-12
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Table 5. Revenues and Profits for Nonferrous Foundry Industry
Estimated Annual Estimated Annual
Industry Segment Revenues* Profits*
All 791 nonferrous foundries $2,094 million S316 million
528 nonferrous foundries using iron 51.398 million $21 1 rrullion
filings
'Based on per facility averages for SIC 3366 and 3369 from the 1992 Census of Manufactures scaled by 791.
Table 6. Economic Impact of Compliance with Current Requirements for the Subset of the
Nonferrous Foundry Industry Using Iron Filings as a Reagent
Compliance Cost as Percentage Compliance Costs as a
Compliance Reagent of Revenues Percentage of Profits
Cement @ 25% 0.1 5.6
of keeping the facility open and remaining in the market. Finally, managers must evaluate the market for
the land and the plant and equipment used to produce the foundry products. Presumably, if only
informally, managers of the 528 foundries in this analysis have completed that evaluation and found that
staying in the market is the profit maximizing choice.
Compliance with the revised standards for lead will raise the costs of production at each
noncompliant nonferrous foundry about $22,000 annually. Depending on market conditions some or all
of this amount may be passed downstream to consumers in the form of higher prices for foundry products
or upstream to input suppliers to in the form of lower input prices. In the long run these costs are likely
to be passed on entirely to consumers of foundry products as new facilities will not be constructed unless
investors can expect to cover all their costs. However, in the short run when there is specificity in the
fixed capital (e.g., the plant and equipment used in making castings may have no value except that of
scrap metal outside the foundry industry), the costs will be shared across foundry owners, consumers of
foundry products, and suppliers of inputs to nonferrous foundries.
It seems unlikely that even if these foundry owners are forced to absorb the entire cost of meeting
the baseline requirements that it would alone cause a nonferrous foundry to prematurely close. There is
considerable randomness to all prices rendering both costs and revenues for nonferrous foundries subject
to fluctuation. It seems likely that much of the costs of estimated above would be largely lost in the
normal profit fluctuations.
7.0 Impacts on Small Entities
The Small Business Regulatory Enforcement Fairness Act of 1996 (SBREFA) requires that
agencies consider the impact of new regulations potential impacts on small businesses, amending and
strengthening the requirements of the Regulatory Flexibility Act (RFA). Agencies must either certify
that a rule will not have "significant impacts on a substantial number of small entities" (with a factual
justification) or must comply with additional requirements.
B-13
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Virtually all nonferrous foundries are small businesses by the SBA definition (less than
500 employees). According to current EPA draft guidance on completing small business initial
assessment, there is a rebuttable presumption that significant economic impacts result to a substantial
number of small entities (firms) when the estimated compliance cost of the rulemaking equals or exceeds
3 percent of firm sales/revenues. When firm-specific data is unavailable, industry sales/revenues may be
used as a proxy for estimating impacts.
However, the Agency estimates that facilities in compliance with current standards will be able
to meet the revised UTS for TC metal wastes with nominal or no cost increase. However, perhaps as
many as 528 foundries will have to come in compliance with current requirements. Table 6 indicates that
the estimated compliance costs are less than 2 percent nonferrous foundry revenues. AFS previously
indicated to EPA that it does not have accurate number on profit percentages for nonferrous foundries.25
However, using data from the 1992 Census of Manufactures, Table 5 indicates that estimated compliance
costs associated with achieving compliance with current requirements are about 6 percent of profits.
;5 Personal communication between Gary E. Mosher, Director of Environmental Affairs, American
Foundrymen's Society and Paul A. Borst, USEPA, Office of Solid Waste, September 23, 1996.
B-14
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Appendix C
Summary of
Groundwater Risk Screening Analysis for Non-Ferrous Foundry Sands
Managed in Municipal Landfills
as prepared by HydroGeoLogic, Inc.
September 7, 1997
The purpose of this analysis was to determine if lead and cadmium concentrations in leachate
produced in untreated and treated non-ferrous foundry sands disposed of at municipal solid waste
landfills exceed Federal Drinking Water Standards. This analysis was necessary given that a stage-one
assessment documented that lead and cadmium in discarded foundry sands were likely to yield
concentrations in groundwater that exceed their respective drinking water standards of 0.015 and 0.005
mg/L, respectively.
This analysis incorporated a coupled modeling approach that utilizes EPACMTP to calculate
groundwater flow and transport simulations and MINTEQ to calculate distribution coefficients for lead
and cadmium. This is the accepted methodology generally employed for this type of analysis.
Lead and cadmium. Both lead and cadmium can be modeled using EPACMTP and MINTEQ.
Hence, the approach is reasonable, acceptable, and consistent with similar modeling efforts currently
underway.
Risks associated with lead in untreated non-ferrous foundry sands and those associated with
cadmium in both untreated and treated non-ferrous foundry sands were assessed. This division was
based on the results of the stage-one assessment.
EPACMTP and MINTEQ both require input data to perform the necessary analysis. The input
data should as closely as possible simulate the conditions of concern. If site-specific data are not
available, or not appropriate for use, then approximations become necessary. Data sources for
EPACMTP are discussed in the document.
EPACMTP simulations were performed in a Finite Source Monte Carlo mode. This is
appropriate given the large distribution and variability in input data. Each Monte Carlo simulation
consisted of 10,000 realizations.
Geographic locations and characteristics of landfills in which foundry sands are disposed are not
known. As a consequence, it was necessary to assume that foundry sands are disposed in Industrial
Subtitle D landfills in model simulations. Two maps showing the distribution of non-ferrous foundries in
the United States relative to Industrial Subtitle D landfills in the United States were provided to
demonstrate that there was sufficient overlap to support the use of this assumption.
Waste quantities were not available for use in the simulations. As a consequence, waste quantity
was treated as a Monte Carlo variable and was defined by a distribution rather than a single input value.
Because the waste generation rate per foundry was not available, it was assumed that revenue and waste
generation rate are correlated. The distribution was based on 423 of the 791 total foundries for which
data were found. This methodology is acceptable //the following hold true: (1) revenue is directly
correlated with waste generation, and (2) economic data for the 423 facilities is representative of the
whole.
C-l
-------
Source leachate concentrations are an important input parameter. Two sources of data were used
in model simulations. Leachate concentrations for untreated sands were treated as a Monte Carlo
variable. In this approach, three TCLP measurements representing different waste sands were used to
define an empirical distribution. Based on this empirical distribution, synthetic source leachate
concentrations were generated. This is a reasonable and acceptable approach given the absence of
sufficient data. For treated sands, two levels of Universal Treatment Standards (pre- and post-rule UTS)
were used. This assumes that the sands are indeed treated to the treatment standard.
The final analysis yielded the percentage of sites having groundwater concentrations that exceed
the Federal Drinking Water Standards for lead and cadmium. Based on these analyses, lead exceeded the
Drinking Water Standard in only 933 of 10,000 test runs for untreated sand (9.3 percent). Lead exceeded
the Drinking Water Standard in 478 (out of 10,000 model runs) and 209 (out of 10,000 model runs) in
treated sands at a source concentrations of 5 mg/L and 0.75 mg/L. Cadmium exceeded the Drinking
Water Standard in 1,427 of 10,000 test runs for untreated sand (approximately 14 percent). The Drinking
Water Standard for cadmium was exceeded in 1,185 (out of 10,000 model runs) and 748 (out of 10,000
model runs) in treated sands at a source concentrations of 1 mg/L and 0.2 mg/L.
C-2
-------
Groundwater Risk Screening Analysis for
Non-Ferrous Foundry Sands Managed
in Municipal Landfills
Prepared for:
Research Triangle Institute
3040 Cornwallis is Road
Research Triangle Park, NC 27709-2194
Prepared by:
HydroGeoLogic Inc.,
1155 Herndon Parkway, # 900
Herndon, VA 20170
September 1997
-------
TABLE OF CONTENTS
1.0 BACKGROUND AND OBJECTIVE 1
2.0 METHODOLOGY AND DATA SOURCES 2
2.1 Approach to the Groundwater Risk Screening Analysis 3
2.2 Data Sources 9
3.0 RESULTS AND DISCUSSION 13
4.0 REFERENCES 19
-------
LIST OF FIGURES
Figure 2.1 Distribution non-ferrous foundries in the U.S 4
Figure 2.2 Distribution of Industrial subtitle D landfills in the U.S 5
Figure 3.1 Frequency distribution of lead groundwater concentrations above the drinking water
standard; (a) untreated sand, (b) UTS level 1(5 mg/L) and ( c) UTS level H (0.75 mg/L
17
Figure 3.2 Frequency distribution of cadmium groundwater concentrations above the drinking
water standard; (a) untreated sand, (b) UTS level 1(1 mg/L) and ( c) UTS level 0 (0.2
mg/L) 18
Figure 2.1 Distribution non-ferrous foundries in the U.S 4
Figure 2.2 Distribution of Industrial subtitle D landfills in the U.S 5
Figure 3.1 Frequency distribution of lead groundwater concentrations above the drinking water
standard; (a) untreated sand, (b) UTS level 1(5 mg/L) and ( c) UTS level n (0.75 mg/L
17
Figure 3.2 Frequency distribution of cadmium groundwater concentrations above the drinking
water standard; (a) untreated sand, (b) UTS level 1(1 mg/L) and ( c) UTS level n (0.2
mg/L) 18
-------
LIST OF TABLES
Table 2.1 Modeling options and data sources used in the groundwater risk screening analysis of
non-ferrous foundry sands 7
Table 2.2 Calculation of waste quantity generated by non-ferrous foundries from annual revenue
data 10
Table 2.3 Cumulative distribution of waste quantity used in groundwater analysis of foundry
sands 11
Table 2.4 Cumulative Distribution of TCLP for lead and cadmium in untreated waste sands ..11
Table 2.5 Universal Treatment Levels (UTS) used in the groundwater risk screening analysis.
12
Table 3.1 Results of groundwater risk screening analysis for lead and cadmium in non-ferrous
foundry sands 14
Table 3.2 Histogram of lead groundwater concentrations above drinking water standard of lead
(0.015 mg/L) 15
Table 3.3 Histogram of cadmium groundwater concentrations above drinking water standard of
cadmium (0.005 mg/L) 16
-------
1.0 BACKGROUND AND OBJECTIVE
This report evaluates potential groundwater exposure and risk due to lead and cadmium
in, untreated and treated non-ferrous, foundry sands managed in municipal solid waste landfills.
The specific question addressed was whether concentrations of lead and cadmium in the
groundwater exceed the Federal Drinking Water Standard (DWS) for these metals, 0.015 and
0.005 mg/L, respectively. The groundwater exposure was estimated at a hypothetical drinking
water well downgradient of the waste management unit.
Two documents (Collier, Shannon, Rill &Scott, 1995 and American Foundrymens
Society AFS. 1996) were reviewed to obtain data on waste characteristics such as waste
quantities produced by foundries and Toxicity Characteristics Leaching Procedure (TCLP)
concentrations for lead and cadmium in the waste. The groundwater risk screening analysis for
the untreated sands was performed using lead and cadmium leachate concentrations reported in
these documents. For the treated waste sands, the risk screening analysis was performed
considering two concentration levels of treatment for lead and cadmium. The first level was a
baseline treatment in which lead and cadmium are treated to the characteristic levels of 5 and 1
mg/L respectively, while the second level was based on Universal Treatment Standard (UTS)
levels of 0.75 and 0.20 mg/L respectively for the two metals.
A two stage approach has been adopted for the analysis. The objective of the first stage
(RTI 1997) which was completed in July 1997, was to determine whether or not lead and
cadmium in discarded foundry sands are likely to produce groundwater concentrations that
exceed their Drinking Water Standards. To answer this question, lead and cadmium groundwater
concentrations reported in two groundwater modeling studies, conducted for the Hazardous
Waste Identification Rule (HWIR; EPA 1995) and Mineral Processing Wastes (EPA, 1996 a),
were reviewed. Using results from these studies as benchmarks and considering the available
data (waste quantity and TCLP) for foundry sands, potential risks associated with the two metals
were evaluated relative to the results reported in two benchmark studies. The outcome of the
first stage of the analysis was designed to help in deciding whether or not to proceed to stage two
in which actual fate and transport modeling for lead and cadmium in foundry sands is performed.
Results from the first stage of the analysis indicated that it was necessary to perform a
groundwater modeling analysis to evaluate risks associated with lead in untreated sands and
cadmium in both untreated and treated sands.
This report presents results obtained in the second stage of the analysis as well as the
methodology and data sources used. Section 2.0 discusses the methodologies and data sources
used in the risk screening analysis, and Section 3.0 presents results of the fate and transport
analysis.
-------
2.0 METHODOLOGY AND DATA SOURCES
EPA's Composite Model for Leachate Migration with Transformation Products
(EPACMTP; EPA 1997 a, 1996 b, c, d) was used for performing groundwater flow and transport
simulations of lead and cadmium in foundry waste sands. EPACMTP is designed to simulate
subsurface fate and transport of contaminants released as leachate from land based waste
management units (e.g. landfills, waste piles, surface impoundments etc.) The model uses a 1-
D flow and transport module for simulating movement of contaminants in the unsaturated zone,
and a 3-D module for the saturated zone. It accounts for fate processes such as sorption in the
soil and transformation due to hydrolysis, and has capability to simulate one parent chemical
and up to 6 daughter products simultaneously.
The fate and transport of metals such as lead and cadmium in the subsurface is controlled
by complex geochemical reactions that determine the mobility of metals. To account for these
reactions, EPACMTP uses metal specific non-linear sorption isotherms generated by
MINTEQA2 (EPA 1991), an equilibrium metal speciation model. Each set of isotherm data was
generated considering representative ranges of the major geochemical parameters such pH,
amorphous iron absorbent concentration, natural organic matter and leachate organic matter in
the soil.
The resulting isotherms are, in general, highly non-linear. In most cases, the MINTEQA2
model simulates strong sorption at low concentration values. At high concentration values, the
degree of metals sorption is proportionally much smaller. This simulates the physical situation
where the number of sites available for sorption is finite, but in relative abundance at low
concentration values. As the concentration increases, the available sorption sites become
occupied, with the result that the fraction of contaminant that is sorbed at high concentration is
smaller than at low concentrations. The range of the apparent partition coefficients can span
several orders of magnitude. Conversely, this can be stated in terms of the predicted mobility of
the metal; at low leachate concentration values, the MINTEQA2 model will predict strong
sorption and low mobility, resulting in low concentration in the groundwater. At high leachate
concentrations, the model will predict proportionally higher groundwater concentration as the
fraction of sorbed contaminant decreases. The MENTEQA2 model similarly accounts for
variations in geochemical conditions, such as pH in metal transport. While the methodology
incorporated into EPACMTP for simulating metals transport is a simplification of complex
geochemical interactions that may occur in real world conditions , it also represents a more
realistic approach to metal transport than the linear equilibrium partitioning assumption that is
typically used in groundwater models.
The input data required by EPACMTP include; source data (waste unit area and depth,
waste and leachate concentrations); climatic data (infiltration and recharge rates) ;
hydrogeologic data ( depth to water table, hydraulic conductivity and hydraulic gradient, aquifer
thickness etc.) and receptor well location ( distance form the waste source and depth below water
table). The output of the model is contaminant concentration at a hypothetical receptor well
located downgradient of the source. EPACMTP simulations can be performed either in a
Monte Carlo (stochastic) mode, used for probabilistic analysis in which input parameters are
defined by (j°mt) frequency distributions, or in a deterministic mode.
-------
2.1 Approach to the Groundwater Risk Screening Analysis
The Monte Carlo approach was used in this analysis and the rationale for this decision is
described below. The distribution of foundry facilities, as shown in Figure 2.1, is spread out over
most parts of the country. This indicates that the distribution of waste disposal locations, which
are the areas where potential groundwater risk actually exits, is most likely the same or close to
that of foundries. Because each facility will ship its waste to the nearest or most economical
landfill. From Figure 2.1, it is obvious that key source related parameters in EPACMTP vary
from one site to another. These parameters are geographical locations of landfills (which
determines climatic and hydrogeologic properties of the modeled site), landfill characteristics
(area and depth), the amount of waste and waste concentration (TCLP) disposed in each
landfill. The EPACMTP site-based Monte Carlo approach is appropriate for circumstances ,like
the one above because, unlike deterministic runs, variability in key input parameters are
accounted for in the risk assessment.
The site-based Monte Carlo approach requires that the geographical locations of landfills
and their characteristics be known. This information was not available for foundry sands,
therefore, it was assumed that foundry sands are disposed in Industrial Subtitle D landfills
shown in Figure 2.2 The distribution these landfills is reasonably close to that of foundry
facilities in Figure 2.1. Both Figures show a relatively high density distribution in the eastern
parts of the country and a lower density distribution in the west. The above assumption is
reasonable considering that point of waste generation may not necessarily be the point of
disposal because most foundries cannot avoid to operate their own waste disposal facility. The
geographical locations and characteristics of Industrial Subtitle D landfills were compiled by
EPA's Office of Solid waste (EPA 1996 e) and used to conduct risk assessment for groundwater
pathway analysis for the Hazardous Waste Identification Rule (EPA 1995).
The general procedure for the site-based Monte Carlo simulation in EPACMTP is
provided in Figure 2.3. Table 2.1 lists the modeling options and data sources used to
characterize input parameters used in EPACMTP simulations performed for this analysis. The
steps involved in a Monte Carlo simulation are the following:
1. Generate a waste quantity value randomly from the waste distribution.
2. Randomly select a landfill (area and depth) from the 790 industrial landfills in the
country.
3. Identify the location (city) of selected landfill and then read the specific climatic and
hydrogeologic characteristics of the selected location.
4. Generate a random TCLP value from empirical distribution available for each chemical.
5. Select a receptor well location from EPA database of drinking water wells within 1 mile
radius of industrial Subtitle D landfills.
6. Run EPACMTP for the above combination of parameters and calculate the associated
risk.
7. Repeat steps 1 through 6 for 10,000 times to ensure adequate sampling of all data
distributions.
8. From 10,000 individual risk values obtained above .calculate the number of times where
the Drinking Water Standards for lead and cadmium is exceeded.
-------
Reproduced after RMT Inc. as presented in Exhibit 2 of (Collier, Shannon, Rrill & Scott, 1995)
Figure 2.1 Distribution non-ferrous foundries in the U.S.
-------
Landfill
Figure 2.2 Distribution of Industrial subtitle D landfills in the U.S.
-------
Read Input data
and desired
modeling options
Any Bounds
Exceeded
9
Yes
Post Processing
Perform Deterministic
Simulation
Print Results
(^ STOP J)
Figure 2.3 General Procedure for EPACMTP Monte Carlo Simulation
-------
Table 2.1 Modeling options and data sources used in the groundwater risk screening analysis of non-
ferrous foundry sands.
Management
Scenarios:
Modeling Scenario:
Exposure evaluation:
Risk evaluation format
Municipal Landfills (Subtitle D Industrial landfills)
Finite Source Monte Carlo; constant concentration pulse source
Down gradient groundwater receptor well, peak well
concentration within 10,000 year exposure time limit
Percentage of sites with groundwater concentration above the
Drinking Water Standard (DWS). Prepare frequency distribution
of concentrations above DWS.
Source Parameters:
Waste Unit Area and Volume
Waste Quantity
Infiltration Rate
Leaching Duration
Due to lack data such as area, depth and geographical locations,
HWIR site-based data for Industrial Subtitle D landfills (EPA,
1996 e) were used.
Empirical distribution derived from revenue data generated by
foundry facilities assuming that revenue and waste generation
rate are correlated.
Calculated by HELP model (Schroeder, et. Al. 1994) using
regional climatic data at landfill locations.
Derived, constant source concentration pulse during the entire
simulation period of 10,000 years.
Chemical Specific Parameters:
Decay Rate
Sorption
Metals (no decay).
MINTEQA2 sorption isotherms (Pb, Cd)
-------
Unsatu rated Zone Parameters:
Depth to groundwater:
Soil Hydraulic
Parameters:
Fraction Organic
Carbon:
Bulk Density:
Saturated Zone Parameters:
Recharge Rate:
Saturated Thickness:
Hydraulic Conductivity:
Porosity:
Bulk Density:
Dispersivity:
Groundwater Temperature:
Fraction Organic Carbon:
pH
Site-based, from API/USGS hydrogeologic database
ORD data based on national distribution of three soil types
(sandy loam, silt loam, silty clay loam)
ORD data based on national distribution of three soil types
(sandy loam, silt loam, silty clay loam)
ORD data based on national distribution of three soil types
(sandy loam, silt loam, silty clay loam)
"
Site-based, derived from regional precipitation/evaporation and
soil type
Site-based, from API/USGS hydrogeologic database
Site-based, from API/USGS hydrogeologic database
Effective porosity derived from national distribution of aquifer
particle diameter
Derived from porosity
Derived from distance to receptor well
Site-based, from USGS regional temperature map
National distribution, from EPA STORET database
National distribution, from EPA STORET database
Receptor Wdl Location:
Radial Distance:
Angle Off-Center
Depth of Intake Point:
Nationwide distribution, from EPA's Office of Solid Waste
(OSW) database.
Uniform within ± 90° from plume centerline (no restriction to be
within plume).
Uniform throughout saturated thickness of aquifer
-------
2.2 Data Sources
The data sources for the groundwater pathway analysis of foundry sands were obtained from
two documents (Collier, Shannon, Rill &Scott, 1995 and American Foundrymens Society AFS,
1996). The information in these documents included total waste generation rate and TCLP data
for various metals in the waste. According to these documents, 791 non-ferrous foundries in the
U.S.(see Figure 2.1) produce a total of 300,000 metric tons of waste sands that exhibit
hazardous characteristics for toxicity each year. Given the distribution of foundry facilities
across the country, the amount of waste generated by a foundry and disposed at a given landfill
varies with geographical location and capacity of the facility. For this reason, the waste quantity
was treated as Monte Carlo variable ( i.e. it is defined by a distribution rather than a single
value) in the analysis. However, waste generation rate per foundry was not available. As a
result, an empirical distribution for waste quantity was calculated using economic data ( annual
revenue and number of employees per facility) available for 423 of the 791 total foundries.
The use of economic data to estimate distribution of waste quantity was based on two
assumptions. First, revenue is directly correlated with waste generation , and secondly, economic
data for the 423 facilities is a representative sample of the characteristics of the whole population
of non-ferrous foundries. The calculation of the waste quantity distribution is shown in Table 2.2
and described here. Table 2.2 categorizes foundry facilities based on the number of employees
and provides annual revenue generated by each category. The amount of waste produced by each
category was calculated as the product of total waste quantity (300, 000 mt) produced and the
fraction of revenue (category revenue /total revenue) generated by the category. Table 2.3 shows
empirical distribution of the 20-yr waste quantity used in lead and cadmium model runs. The use
of empirical distribution was appropriate in this case since neither the exact (city level)
geographical locations of the facilities nor the amount of waste generated per facility were
known. The probability values assigned to waste quantities in the cumulative distribution were
calculated as the ratio of the number of facilities in each category to the total number of facilities.
This ensures that sampling of the distribution during Monte Carlo simulation is performed
according to the weight of facilities (i.e the number of facilities per category).
The source leachate concentration (TCLP) distributions for lead and cadmium in untreated
sands are in Table 2.4. The TCLP was a Monte variable in the analysis of untreated sands
because different values of TCLP were measured in samples collected from different waste
sands. Therefore, TCLP was defined as an empirical distribution representing all samples
reported for untreated sands. For treated sands, groundwater exposure risks were estimated for
two levels of Universal Treatment Standards (UTS) as shown in Table 2.5. The first level was
based on a baseline treatment of lead and cadmium to the characteristic levels of 5 mg/L and 1
mg/L respectively. The second treatment level was based on post-rule UTS of 0.75 mg/1 for lead
and 0.2 mg/1 for cadmium.
-------
Table 2.2 Calculation of waste quantity generated by non-ferrous foundries from annual revenue data
No. of
# workers
0
1-4
5-9
10-19
20-99
100-499
>500
TOTALS
Number of Foundries
Non-Ferrous
14
26
24
19
13
4
7
107
Copper
9
55
51
68
107
18
8
316
Total
23
81
75
87
120
22
15
423
Annual Revenue ( X1000)
Non-Ferrous
$2,452
$4.495
$13,590
$19,993
$36,802
$52,622
$234,394
$364.348
Copper
$4,990
$9.722
$22,777
$65,889
$350.648
$199,860
$88,180
$742.066
Total
$7.442
$14.217
$36,367
$85,882
$387.450
$252.482
$322,574
$1.106.414
Percentage
of Total
Revenue
0.007
0.013
0.033
0.078
0.350
0.228
0.292
1.000
Annual
Waste
(mt)
2.02E+03
3.85E+03
9.86E+03
2.33E+04
1.05E+05
6.85E+04
8.75E+04
3.00E+05
20-Year
Waste
(mt)
4.04E-I-04
7.71E-I-04
1.97E+05
4.66E+05
2.10E+06
1.37E+06
1.75E+06
6.00E+06
!0
-------
Table 2.3 Cumulative distribution of waste quantity used in groundwater analysis of foundry sands
No. of
# workers
0
1-4
5-9
10-19
100-499
>500
20-99
TOTALS
Number of
Facilities
23
81
75
87
22
15
120
423
20-Year
Waste
(mt)
4.04E+04
7.71E+04
1.97E+05
4.66E+05
1.37E+06
1.75E+06
2.10E+06
6.00E+06
Individual
Probability
0.054
0.191
0.177
0.206
0.052
0.035
0.284
1.000
20-yr
Cumulative
Weight
4.04E+04
1.17E+05
3.15E+05
7.80E+05
2.15E+06
3.90E+06
6.WE+Q6
NA
Cumulative
Probability
0.054
0.246
0.423
0.629
0.68 1
0.716
1.000
NA
Table 2.4 Cumulative Distribution of TCLP for lead and cadmium in untreated waste sands
Lead TCLP
(mg/L)
14.0
34.0
450
Cadmium TCLP
(mg/L)
3.60
4.40
5.20
Cumulative
Distribution
0.33
0.66
1.00
Source: American Foundrymens Society (1996)
11
-------
Table 2.5 Universal Treatment Levels (UTS) used in the groundwater risk screening analysis.
Name of Chemical
Lead
Cadmium
Universal Treatment Standard
Level I (mg/L)
5
1
Universal Treatment Standard
Level D (mg/L)
0.75
0.20
12
-------
3.0 RESULTS AND DISCUSSION
The results of the groundwater risk screening analysis performed for lead and cadmium in
non-ferrous foundry sands managed in landfills are summarized in Table 3.1. The data show
the probabilities that the leachate released from foundry sands managed in existing Subtitle D
landfills would produce lead and cadmium groundwater concentrations that would exceed their
respective Drinking Water Standards (DWS). Each probability value in Table 3.1 was calculated
as the ratio of receptor well concentrations that exceed the DWS to the total concentration values
in the Monte Carlo simulation. Each Monte Carlo simulation consisted of 10,0000 realizations as
discussed in Section 2.0.
For lead in untreated sands, the probability of DWS exceedence was 0.0933. In other words, the
leachate released from untreated waste sands in 90% of the landfills in the country would
produce groundwater concentrations below the DWS of lead, 0.015 mg/L. Similarly, the
probabilities of DWS exceedence for lead in treated sands are 0.0478 and 0.0209 for Universal
Treatment Standard (L'TSj levels 1 i.5 mg/Lj anJ II (0.75 mg/L) respec:;-. CA. These probabilities
correspond to protection levels of 95% and 97% respectively. In the case cadmium, the
probabilities of DWS exceedence were 0.1428, 0.1185 and 0.0748 for untreated sands and the
two UTS levels (1 and 0.75 (mg/L)) for treated sands. The corresponding protection levels were
of 85.73% for untreated sands and 88.15% and 92.52% for the two UTS treatment levels I and n
respectively.
As an example to illustrate the practical meaning of the above probabilities of DWS
exceedence, assume that an acceptable groundwater risk is when 10% of the landfills produce
groundwater concentrations above the DWS. Based on the data in Table 3.1, this would mean
that there is no need to treat waste sands for lead. On the other hand, a level n UTS treatment is
required in order to achieve 90-th percentile protection level for cadmium.
The frequency distributions of groundwater concentrations that exceeded the drinking
water standards of lead and cadmium are in Tables 3.2 , 3.3 and Figures 3.1 and 3.2. These
Tables and Figures demonstrate the impact of different levels UTS on the receptor well
concentration. For example, for lead in untreated sands, Table 3.1 and Figure 3.1, there are 933
cases in which the DWS was exceeded. Of these 41% exceeded by a factor greater than 150
times. After the waste was treated , the percentage of the population in this category was
reduced to slightly above 10% at treatment level I and zero at level n. A similar trend exists for
the other ranges of DWS exceedence in Tables 3.1 and 3.2.
13
-------
Table 3.1 Results of groundwater risk screening analysis for lead and cadmium in non-ferrous foundry sands.
Name of
Chemical
Lead
Cadmium
Drinking
Water
Standard
(DWS)
(mg/L)
0.015
0.005
No. of
Monte Carlo
Realizations
10000
10000
Untreated Sands
No. Of
DWS
Violations
933
1427
Probability
of DWS
Exceedenc
0.0933
0.1427
Universal Treatment Standards
Level(Pb= 5, Cd= 1 mg/L
No. Of
DWS
Violations
478
1185
Probability of
DWS Exceedence
0.0478
0.1185
Level II (pb = 0.75, Cd = 0.2 mg/L
No. of DWS
Violations
209
748
Protection
Level
0.0209
0.0748
'.4
-------
Table 3.2 Histogram of lead groundwater concentrations above drinking water standard of lead (0.015 ing/L)
Receptor
Well
Cone. Range
(mg/L)
0.015-0.03
0.03 - 0.06
0.06 - 0.09
0.09-0.12
0.12-0.15
0.15-0.30
0.30 - 0.75
0.75 - 1 .50
1 .50 - 2.25
>2.25
Drinking
VViJter
Standard
Exceedence
1 -2
2-4
4-6
6-8
8- 10
10-20
20-50
50- 100
100-150
> 150
Total
Untreated Sands
Frequency
68
74
34
28
26
80
101
82
54
386
933
Cumulative %
7.29%
15.22%
18.86%
21.86%
24.65%
33.23%
44.05%
52.84%
58.63%
100.00%
Universal Treatment Standards
Level 1 = 5 mg/L
Frequency
44
51
33
23
21
57
81
78
39
51
478
Cumulative %
9.21%
19.87%
26.78%
31 .59%
35.98%
47.91%
64.85%
81.17%
89.33%
100.00%
Level ll=0.75m^L
Frequency
24
34
31
17
12
56
35
0
0
0
209
Cumulative %
1 1 .48%
27.75%
42.58%
50.72%
56.46% •
83.25%
100.00%
100.00%
100.00%
100.00%
-------
Table 3.3 Histogram of cadmium groundwater concentrations above drinking water standard of cadmium (0.005 mg/L)
Receptor Well
Cone. Range
(mg/L)
0.005 - 0.01
0.01 - 0.02
0.02 - 0.03
0.03 - 0.04
0.04 - 0.05
0.050.10
0.10-0.25
0.25 - 0.50
0.50 - 0.75
>0.75
Total
Multiples of
Drinking
Water
Standard
1 -2
2-4
4-6
6-8
8- 10
10-20
20-50
50-100
100- 150
> 150
Untreated Sands
Frequency
128
123
69
66
59
145
184
150
91
412
1427
Cumulative %
8.97%
17.59%
22.42%
27.05%
31.18%
41.35%
54.24%
64.75%
71.13%
100.00%
Universal Treatment Standards
Level 1 = 1 (mg/L)
Frequency
138
153
81
62
47
150
248
193
70
43
1185
Cumulative %
11.65%
24.56%
31.39%
36.62%
40.59%
53.25%
74.18%
90.46%
96.37%
100.00%
Level II = 0.20 (mg/L)
Frequency
122
147
100
73
43
167
96
0
0
0
748
Cumulative %
16.31%
35.96%
49.33%
59.09%
64.84%
87. 1 7%
100.00%
100.00%
100.00%
100.00%
-------
(a)
Multiples of Drinking Water Standard
(b)
Multiples of Drinking Water Standard
(C)
o
Multiple of Drinking Water Standard
100.00%
90.00%
80.00%
70.00%
60.00%
50.00%
40.00%
30.00%
20.00%
10.00%
.00%
Frequency !
Cumulative %;
100.00%
90.00%
• 80.00%
70.00%
4-60.00%
50.00%
I 40.00%
30.00%
20.00%
-I- 10.00%
.00%
Frequency
Cumulative % !
100.00%
90.00%
80.00%
70.00%
60.00%
50.00%
40.00%
30.00%
20.00%
10.00%
.00%
Figure 3.1 Frequency distribution of lead groundwater concentrations above the drinking water
standard; (a) untreated sand, (b) UTS level 1(5 mg/L) and ( c) UTS level n (0.75 mg/L)
17
-------
(a)
100.0%
Frequency |
Cumulative % •'
Multiple of Drinking Water Standard
(b)
100.00%
. 90.00%
• 80.00%
- 70.00%
60.00%
• 50.00%
40.00%
30.00%
20.00%
10.00%
.00%
Multiples of Drinking Water Standard
©
100.00%
80.00%
Multiples of Drinking Water Standard
Figure 3.2 Frequency distribution of cadmium groundwater concentrations above the drinking
water standard; (a) untreated sand, (b) UTS level I( 1 mg/L) and ( c) UTS level n (0.2 mg/L)
18
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4.0 REFERENCES
Allison, J D. D. S. Brown, and K. J. Novo-Gradac, 1991. MENTEQA2/PRODEFA2
geochemical Assessment model for environmental systems. Version 3.00 Users Manual. U.S.
Environmental Protection Agency, Athens, GA.
American Foundrymens Society (APS), August 2, 1996. Letter to Mr. Michael Petruska , head
of the Water Treatment Branch, Office of Solid Waste, U.S. EPA , Washington .
Collier, Shannon, Rill & Scott. Attorneys-at-Law, Nov. 27, 1995. Letter to EPA RCRA
Information Center. 3050 K Street # 400, NW, Washington DC 20007.
Kollig P. Heinz, J. J. Ellington. S. W. Karickhoff, B. E. Kitchens, J. M. Long,
E. J. Weber, N. L. Wolfe. Environmental Fate Constants for Organic Chemicals Under
Consideration for EPA's Hazardous Waste Identification Projects. Office Research and
Development, Athens, GA 30605-2720, U.S. EPA.
Research Triangle Institute (RTF), 1997. Groundwater Risk Screening Analysis of Untreated and
Treated Foundry Sands Managed in Municipal Landfills. Research Triangle Institute (RTI), 2040
rornwallis Road, Research Triangle Park, NC 27709-2194.
Schroeder, P.R., 1994. The HydroGeoLogic Evaluation of Landfill Performance Model (HELP):
Vol. I, Users Guide for Version I and Vol. H - Documentation for Version I. EPA/530-SW-84-
009, U.S. EPA Washington, D.C.
USEPA, 1995. Hazardous Waste Identification Rule (HWIR). Background Document for
Groundwater Pathway Results. Office of Solid Waste, Washington, D.C., 20460.
USEPA, 1997a. EPA's Composite Model for Leachate Migration with Transformation Products
(EPACMTP). User's Manual, Office of Solid Waste, Washington, D.C., 20460.
USEPA, 1996-a. Groundwater Pathway Analysis for Mineral Processing Wastes (DRAFT).
Office of Solid Waste, Washington, D.C., 20460.
USEPA, 1996-b. EPA's Composite Model for Leachate Migration with Transformation Products
(EPACMTP). Background Document, Office of Solid Waste, Washington, D.C., 20460.
USEPA, 1996-c. EPA's Composite Model for Leachate Migration with Transformation Products
(EPACMTP). Background Document for Finite Source Methodology. U.S. EPA, Office of
Solid Waste, Washington, D.C., 20460.
USEPA, 1996-d. EPA's Composite Model for Leachate Migration with Transformation
Products (EPACMTP). Background document for Metals: Methodology. U.S. EPA, Office of
Solid Waste, Washington, D.C., 20460.
19
-------
USEPA, 1996-e. Industrial Subtitle D Waste Management Units Database used for Groundwater
Pathway Modeling. U.S. EPA, Office of Solid Waste, Washington, D.C., 20460.
20
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Appendix D
A Screening Analysis of the Economic Impacts of the LDR on Small Businesses in the Zinc Sulfate
Fertilizer Industry
Zinc is among the micronutrients required for normal plant growth and development. Because of
its role in plant nutrition, zinc is incorporated in some fertilizers, especially those targeted at crops
sensitive to lower soil Zn levels (e.g., corn, sorghum, flax, grapes). Producers of zinc sulfate fertilizers
commonly use industrial by-products as a source of zinc (Queneau, Hansen, and Spiller, 1993).
Important sources of the by-products include electric arc furnace dust, steel mill smokestack ash, brass
and bronze scrap, and zinc scrap. Commercial fertilizers that contain recycled hazardous materials must
meet the Universal Treatment Standards (UTS) for the materials unless the waste is emissions control
dust/sludge from the primary production of steel in electric furnaces (KO61) which is exempt. It is not
clear at this time that zinc micronutrient fertilizers will be unable to meet the new Phase IV standards. It
is possible, however, that increases in the stringency of the UTS for zinc could require fertilizer
producers that use the regulated hazardous raw materials to treat them to the UTS levels or substitute
away from these materials. Either action may be expected to raise the cost of fertilizer production for
these producers impacting the economics of their production. Of special concern to the Agency is the
potential impact of the regulation on small businesses. This memorandum provides a screening analysis
of the implications of the costs of switching to nonhazardous raw materials in zinc fertilizers for the three
fertilizer producers who use hazardous zinc as a raw material. One of these producers, Bay Zinc, is a
small business. The second company that uses hazardous zinc is American MicroTrace Corporation
(AMT) which is not a small business. Big River, the third company, is foreign-owned. Complete data is
not available for it for small business classification purposes.
About 15 companies operating about 17 plants produce zinc sulfate fertilizers. Nationwide,
about 56,500 tons of the fertilizer are produced annually (ChemExpo Chemical Profile). Table 1
summarizes the production, zinc content, raw material type and the price of the raw material for zinc
micronutrient fertilizer producers. Three facilities are reported to exclusively use hazardous zinc in
production; 12 use nonhazardous zinc. The remaining facilities use a mixture of the two or the type of
secondary zinc is unknown.
One of the options available to producers of zinc sulfate fertilizers using hazardous zinc is to
switch to the nonhazardous variant. This would bring them into compliance with the Phase IV Land
Disposal Restrictions. The price of the raw material averages $0.55 per pound for hazardous zinc, $0.74
per pound for nonhazardous zinc based on the data for the facilities for which the secondary zinc type is
known and where they exclusively use either the hazardous or nonhazardous type. This unit cost
differential is used to compute the possible annual costs of the rule for one small business, Bay Zinc, that
would be effected by the rule. It's Moxee, WA facility uses tire ash as a source of zinc. Table 2 shows
the results of this analysis.
Replacing 1,000 tons of hazardous zinc with nonhazardous zinc would raise Bay Zinc's annual
costs of production about $320,000. Expressed on a per unit of product basis this would be $60 per ton
of fertilizer; as a proportion of company sales it would be about 5.1 percent
The AMT facility pays $0.87 per pound for nonhazardous and hazardous zinc. This value is
assumed to represent a weighted average of the different prices paid for each type. Table 2 provides a
D-l
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Table 1. Raw Materials for Zinc Micronutrient Fertilizer Producers
Company
Producers only using
Bay Zinc
Frit
Scon G. Williams
Totals
Average
Producers only using
Agrim
CoZinCo
Chem & Pigment
Frit
Sims
WyZinCo
Totals
Average
Producers using both
AMT
Bay Zinc
Big River
Totals
Average
Fertilizer
Production
Facility Location (tons/yr)
hazardous secondary zinc as
Moxee, WA
Norfolk. NB
Co. Conyers, GA
Zinc
(%)
Secondary
Content Zinc Price
(tons) ($/lb)
Expenditures
on Secondary
Zinc (Vyr)
a raw material
5,000
12.000
11,000
28,000
20.0
20.0
21.0
20.4
1.000
2,400
2,310
5.710
0.59
0.59
0.48
0.55
1,180,000
2.832.000
2,217,600
6,229,600
nonhazardous secondary zinc as a raw material
Reise, MI
Reise, MI
Salida, CO
Salida, CO
Pittsburg, CA
Pittsburg, CA
Walnut Ridge/AK
Mt. Gilead, OH
Mt. Gilead, OH
Mt. Gilead, OH
Cheyenne, WY
Cheyenne, WY
hazardous and nonhazardous
Fairbury, NB
Moxee, WA
Sauget, IL
Producers using unknown secondary zinc as a raw
AMT
Bay Zinc
Mineral King
Old Bridge
Totals
Average
Fairbury, NB
Moxee, WA
Hanford, CA
Old Bridge, NJ
Old Bridge, NJ
1.500
1,500
8,000
1,200
2,000
2,500
9.000
500
2,000
4.000
4,000
1.150
37,350
secondary
7,000
14,000
6.500
27,500
material
3,000
3,000
7,000
2,000
8,000
23,000
40.0
27.0
35.5
12.0
35.5
12.0
36.0
20.0
31.0
36.0
35.5
12.0
32.0
zinc as a raw
35.5
18.0
31.0
25.5
12.0
10.5
12.0
35.0
12.0
13.9
600
405
2,840
144
710
300
3.240
100
620
1.440
1,420
138
11.957
material
2.485
2,520
2,015
7,020
380
315
840
700
960
3,195
0.58
0.69
0.87
0.75
0.87
0.75
0.63
0.75
0.71
0.69
0.83
0.75
0.74
0.87
0.50
0.77
0.71
0.75
0.74
0.69
0.89
0.75
0.76
696,000
558,900
4,941,600
216,000
1,235,400
450,000
4,082,400
150,000
880,400
1,987.200
2,357,200
207,000
17.762,100
4,323,900
2,520,000
3.103,100
9,947,000
570,000
466,200
1,159,200
1,246,000
1,440,000
4,881,400
D-2
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Table 2. Small Business Impact Screening Analysis
Fertilizer
Facility Production
Company Location (tons/yr.)
Bay Zinc Moxee, WA
5,000
5,000
AMT Fairbury, NB
7,000
7,000
Big River Sauget, IL
6,500
6,500
Secondary
Zinc Content Zinc Price
(%) (tons) (Mb)
20.0 1,000 0.59
20.0 1.000 0.74
Difference
$/ton
Corporate sales (mill $/yr)
$/$ corporate sales
35.5 2,485 0.55
35.5 2,485 0.74
Difference
$/ton
Corporate sales (mill $/yr)
$/$ corporate sales
31.0 2,015 0.55
31.0 2,015 0.74
Difference
$/ton
Corporate sales (mill $/yr)
$/$ corporate sales
Expenditures
on Secondary
Zinc
($/yr.)
1,180,000
1,480,000
300,000
60.00
5.9
5.1%
2,733,500
3,677,800
944,300
134.90
160.8
0.6%
2,216,500
2,982,200
765,700
117.80
110
0.7%
D-3
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worst case calculation of the impact of the rule for this producer. We assume that all of the reported zinc
consumption is hazardous and is purchased at $0.55 cents per pound—the average price paid by firms
purchasing only hazardous secondary zinc. Then we assume that the firm shifts completely to the
nonhazardous type at $0.74 cents per pound. Replacing 2,485 tons of hazardous zinc with nonhazardous
zinc would raise AMT's annual cost of production about $944,000. Expressed on a per unit of product
basis this would be S135 per ton of fertilizer; as a proportion of company sales it would be about
0.6 percent.
Big River's Sauget, IL facility also both zinc types and pays more per pond for the composite
raw material than our average. Following the same logic as above, replacing 2,015 tons of hazardous
zinc with nonhazardous zinc would raise Big River's annual cost of production about $766,000.
Expressed on a per unit of product basis this would be $ 118 per ton of fertilizer; as a proportion of
facility sales it would be about 0.7 percent. Company sales data are not available for this firm.
Because there is only one impacted producer that is a small business and because of the relatively
small impact on this producer the Agency believes that there are no significant small business
implications for the rule for this industry.
D-4
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50272-101
REPORT DOCUMENTATION | 1. Report No.
PAGE |
| EPA530-R-9&-028
I
| 2.
|
|
1
| 3. Recipient's Accession No.
| PB99-156036
1
4. Title and Subtitle
Regulatory Impact Analysis: Phase IV Land Disposal Restrictions - TC Metal Wastes; Final Report
| 5. Report Date
1 April 1998
1 6.
7. Authors)
| 8. Performing Organization RepL No.
I
9. Performing Organization Name and Address
U.S. EPA
OFFICE OF SOLID WASTE
401 M STREET, SW
WASHINGTON, DC 20460
| 10. Projcct/Task/Work Unit No.
| 1 1 . Contract © or Grant (G) No.
|©
1
I(G)
1
12. Sponsoring Organization Name and Address
| 1 3. Type of Report & Period Covered
1
1 Regulatory Impact Analysis
15. Supplementary Notes
16. Abstract (Limit: 200 words)
Estimates the costs, economic impacts, and benefits of the Phase IV LDR rulemaking for toxicity characteristic metal sources, including those
generated with organic underlying hazardous constituents. Examines affected industries, National Hazardous Waste Constituent Survey data,
waste generation and management under BRS, and current treatment practices. Provides management costs analysis. Addresses waste
management decisions, aggregate costs, economic impacts, and impacts on small entities. Discusses benefits and benefit-cost comparison.
Includes references. Appendices contain development of cost functions for toxicity characteristic metals wastes with organic underlying
hazardous constituents, cost and economic impacts, groundwater risk screening analysis for non-ferrous foundry sands managed in municipal
landfills, and a screening analysis of the economic impacts of the LDR on small businesses in the zinc sulfate fertilizer industry.
17. Document Analysis a. Descriptors
b. Identifiers/Opcn-Ended Terms
c. COSATI Field Group
18. Availability Statement
RELEASE UNLIMITED
| 19. Security Class (This Report) | 21. No. of Pages
| IfNCLASSIFlED |
I I
| 20. Security Class (This Page) |
| UNCLASSIFIED |
(SccANSI-Z39.18)
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
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|