EPA-230-02-87-02 4
January 1987
Improving RIAs: Suggestions for the
Analysis of Hazardous Waste Regulations
Josephine A. Mauskopf
Donald Anderson
Pamela Jacobs
Research Triangle institute
Research Triangle Park, PC 27709
Contract Mo.: b80!-7033
Project Officer: Ann Fisher
Economic Analysts Division
Office of Policy, Planning and Evaluation
O.S. Environmental Protection Agency
Washington, DC
The information in this document has been funded wholly or in
part by the United States Environmantal Protection Ayency under
Contrac! Mo, 68-01-7033, work assignments 169 and 198. It has been
subjected to the Agency's peer and administrative review and has been
approved for publication as an PPft document. Mention or trade names
or coiHTiereial products does not constitute endorsement or recommen-
dation for use.

Executive Order 12291, issued by President Reagan on February 17, 1981,
requires that Federal agencies prepare a regulatory impact analysis (RIA) for
their new major regulations. The intent of this order was to ensure that
regulations would be subject to a rigorous benefit-cost analysis before they
could be promulgated and that alternatives to regulation would be considered.
As stated in the Environmental Protection Agency (EPA) Guidelines for Perform-
ing Regulatory Impact Analyses, "...by developing and organizing information,
quantifying and monetizing benefits and costs to the extent possible, and
determining distributional effects and economic impacts, the RIA should pro-
vide decisionmakers with a comprehensive assessment of the implications of
alternative regulatory actions." This study explores how future hazardous
waste RIAs could be performed so as to provide such comprehensive information
for regulatory decisionmakers.
Figure ES-1 illustrates the eight main components described by EPA for its
RIAs of hazardous waste regulations as well as other environmental rulings. A
hazardous waste RIA starts with a brief description of the nature of the prob-
lem the proposed regulations are designed to correct as well as the Agency's
statutory authority to impose such regulations. The current and proposed
regulations and other regulatory alternatives to be analyzed are presented
next. Major sources of data used in the analysis are then described. Supple-
mentary data needed for each specific estimation model used in the analysis
are presented later with the estimation models.
The analysis of impacts on products markets uses an economic model to
determine how the new regulations will affect the prices and quantities of
various goods. Impacts on employment level and plant closures are estimated
as part of this analysis. The analysis of impacts on products markets pro-
vides inputs into two further components of the RIA: estimating the benefits
due to the resulting changes in exposure to hazardous substances, and estimat-
ing the costs of the new regulation due to enforcement and compliance activ-
ES 1

Describe Data
Sources Used
Analyze Impacts
on Exposure
Analyze Impacts
on Products Markets
Present Proposed
Regulation and Alternatives
to be Analyzed
Summarize Nature of Problem
and Statutory Authority
Estimate Net Benefits or
Cost-Effectiveness Ratios
for Proposed Regulation
and Alternatives
Estimate Costs for
Proposed Regulation
and Alternatives
Estimate Benefits for
Proposed Regulation
and Alternatives
Figure ES-1, Flow chart for a hazardous waste RIA.

New regulations for managing hazardous wastes may reduce releases of the
toxic substances into the environment in two ways: through the use of dif-
ferent disposal technologies or cleanup methods, and through reductions in the
generation of hazardous wastes. The exposure analysis estimates the accom-
panying changes in environmental contamination and human exposure attributable
to the new regulations. The results of the exposure analysis are used to
estimate the benefits from regulatory action. Generally, the major benefit
expected as a result of hazardous waste regulations is an improvement in
health for persons at risk of exposure. Other benefits also may occur, such
as fewer communities having to find alternative water supplies or engage in
costly cleanup activities when aquifers become contaminated.
The promulgation of a regulation results in costs that include: increased
production costs incurred by industry, increased product costs to consumers,
consumer and producer surplus losses, dislocation costs from unemployment of
Tabor and capital, and government costs from regulation. These costs are
estimated using the results of the analysis of impacts on products markets.
In some cases, a new regulation may result in reduced costs to producers and
consumers in at least some market sectors.
The final component of the RIA compares the estimates of costs and bene-
fits. This comparison should provide decisionmakers with a comprehensive
assessment of the implications of alternative regulatory actions.
Table ES-1 lists eight recent hazardous waste RIAs. Table ES-2 sum-
marizes our comparative analysis of how well they satisfy the EPA guidelines
for performiny R[As.
All of the RIAs include some quantitative analysis of the proposed regu-
lation and all, except one, include some quantitative analysis of other regu-
latory alternatives under consideration. No RIA addresses alternatives to
Federal regulation, and most do not discuss market-oriented regulatory alter-
natives and alternatives beyond current legislative scope.
All the RIAs use a variety of data sources, including some estimates
based on informed judgment. Five of the eight perform sensitivity analysis on
some or all of the variable values based on informed judgment. Half of the
RIAs rely heavily on survey data to characterize the wastes, waste facilities,

Abbreviated title
Full reference
1, Contingency Plan:
Regulatory Impact Analysis °^_^p Revisions to the Notional Oil and Hazardous Substances
Po l I ution Contingoncy Plan. f dp, Inc" Por U.S. EPAj Office of Emergency and Remedial
Response. F903.
2, Um4 Oil;
Regulatory Impact Ana 1ya i a of Proposod Standard* far the Manaaetnant of IJayl Oil, Tewple.
Barker, and Sloaoa. For U.S. EPA, Economic Analysis Branch, Office of Solid Waate.
November 1906.
3, Sma I I-Quanti ty Generators; Regulatory Analysis for Proposed Regulation Under RCRA for Smalt Quantity Generators of
Hazardous Wastes. Industrial Economics, For U.5~ EPA, Offica of Solid Waste, June 1986.
Regulatory Impact Analysis of Reportable Quantity Adjustments Under Sections 102 and 183 of
the Comprehensive Environmental Response, Compensation, and Liability Act. ICF. inc. For
U.S. ElFA) Emergency Response t)ivision, March 1906.
4, Reportable Quantities:
5.	Incineration:
0,	Land ban:
7 ,	0 i o * S n s :
B .	So I vents:
Supporting Documentation for the RCRA Incinerator Regulations. PEER Consultants, for U.S.
EPA, Office of Sol'nr'Waat* and En»rg»ncy"B#apon««l October 1.984,
Regulatory Aria lysis of Proposed Restrictions on Land Disposal of Hazardous Wastes.
Tnduatr ia I Economi cs, Inc . and ICP i Inc. For" U.S. EPA, W# i Co of So n d Waste. December
' Pinal
Reflulatory Analysis of Proposed Restrictions on Land DjaposaI of Cartain Dioxln-
Wastes, Industr i a I Economic*, Inc. For U.S. EPA, Office of Solid Waste. Draft
Report. January 19Bfl.
Regulatory Analysis of Proposed Restrictions on Land Disposal of Certain Solvent Wastes.
Industr i a I Economi cs. For U.S. EPA, Office of Solid Waste, Draft Report, January 1986,

Top i c
Contingency plan
Used o iI
SmaiI-quantt ty
Reportable quantities
Nature of
Re I eases of oil and hai-
irdeus subst#nc#s to
water and protect i on of
ertv t ronment when dis-
charges do occur
Management of used oil
Disposal of hazardous
waste from am*11-quantity
Releases of hazardous
wastes to all environ-
mental media from spills/
author ity
Regu f atory
a Iternatives
Some quantitative anal-
ysis for two alternative
reguI ati ons
Quantitative analysis for
four alternative regula-
Some quant i tati ve analysts
for six alternative regu-
Some quantitative anal-
ysis for two alternative
reguIati ons
Data sources
Reporting data, industry
data, estimates from EPA
end other publications,
and informed judgjrtent;
sorno sensitivity analysis
Industry data, estimates
from EPA and other pub]i-
cations, and informed
j udgment
Reporting data, survey
data, industry data, esti-
mates from EPA and other
publications, and informed
j udgment; some sens i t i v i ty
ana lysis
Reporting data, survey
data, case study data,
Industry data, estimates
from EPA and other publi-
cations, and informed
judgment; some sensitivity
Impacts !n
Not estimated
Estimated percent change
In prices and production
lev*I *
Not estimated because not
expected to be significant
Not estimated because not
expected to be significant
Exposure	Number of peopI* exposed
estimates	in air, groundwater, and
surface water; no expo-
sure levels or durations
Number of peopI# and steady-
state average exposure in
air, groundwater, and sur-
face water; assumed 70-year
exposure duration
Number of people and steady-
state average exposure in
air with 70-year exposure
duration; number of people
and moving average exposure
in groundwater with ^403
year total and 70-year indi-
vidual exposure durations
Estimates of
cancer and
other harmful
heaIth effects
Discussed for typical
chemicals but no quanti-
tative estimates
Cancer cases for used oiI
use in 10 model facilities
and national aggregates;
exposure levels relative to
Rf-D for noncarc i nogens
Cancer and noncancer cases
for disposal in landfills
and to PGTW
Discussed very br efIy
(conti nued)

Contingency plan
Used if i 1
Reportable quanti ti«*
Estimates of
ottitr harmful
ef fects
Nona --briefly discussed
None - briefly discussed
None--br1ef1y discussed
Estimates of
Engineering compliance
costs and regulatory
Reel resource cost* from
projected impacts on
products markets
Eng1neerIng comp1i ance
costs and regulatory
Engineering compliance
costs and regulatory
Co*t-b*n«fi t
comparisons in
use f u 1 format
Us#fi»l tab la for proposed
regulation, but compar-
ison of alternative new
regulations not included
Useful table presenting
cost-effectiveness ratios
for *11 alternatives
None glv«n
Table for costs only for
two a I terns t i ve regu1a-


Top i c
Inc i nerat i on
Land, ban
D i ox ins
So 1 vents
Nature of
Stack emissions from
hazardous waste incin-
Land-disposed wastes
Disposal of dioxin-
containing wastes, espe-
cially 1 and d i sposa1
Di sposa1 of so 1 vent
wastes, especially land
d i sposa 1
author i ty
Ragti I atory
a i ternat i ves
Some quantitative anal-
ysis for two alternative
reguI at t ons
Quantitative analysis for
four alternative regula-
ti ons
Quantitative analysis for
proposed regulation only
Quantitative analysis for
two alternative regula-
Data sources
Reporting data, survey
data, case study data,
industry data, estimates
from EPA and other publi-
cations, and informed
judgment; some sensitiv-
i ty analysis
Survey data, estimates from
EPA and other publications,
and informed judgment;
uncertainty analysis for
exposure estimates
Reporting data, survey
da ta, i ndustry da ta,
estimates from EPA end
other publications, and
informed judgment; uncer-
tainty analysis for expo-
sure estimates
Survey data, estimates
from EPA and other publi-
cations, and informed
judgments; some sensitiv-
ity ana Iys i s
Impacts in
Not estimated
Not estimated
Not estimated
Not estimated
esti mates
Number of people and
steady-state exposure
level in air; assumed
70-year exposure dura-
Distribution of number of
people and steady-state
exposure levels in air,
groundwater, and surface
water; assumed 70-year
exposure duration
Not presented
Number of people not esti-
mated; average level and
actual duration of expo-
sure In air and ground-
water; 70-year exposure
duration assumed for
health risk estimates
Estimates of
cancer and
other harmfuI
heaIth effects
Cancer cases for inhala-
tion of air emissions
from incinerators; poten-
tial to be above safe
threshold for noncarcin-
Cancer and noncancer cases
for multiple disposal meth-
ods; weighted by sevari ty
Cancer cases for multiple
disposal methods; no esti-
mates for noncarcinogens
Cancer cases for multiple
disposaI methods; exposure
level relative to RFD for
noncarci nogens
Estimates of	None	None--briefIy discussed	None	None—briefly d cu sad
other harmful
(conti nued)

Top i c
Inc i n«rati on
Land ban
D i ok i ns
So 1 vents
Estimates of
Engineering compliance
Engineering compIi ance
Engineering compliance
Engineering compliance
No; costs estimated for
None g1 von
No, discussion is
Compares percent change
comparison# in
comp1iincs with current

in costs to percent
usef u1 format
regulations oriiy: corre-

change in benef its. Does

sponding benefits not

not look at abso 1uto

est imated

changes. Duration of

disposal different for

costs and benefits

and current management practices. The other half primarily use reporting data
and previous EPA reports for their waste characterizations. Estimates from
data provided in a report from a subcontractor or from a previous EPA report
are used extensively as well as estimates from the research literature. In-
dustry sources are used in many of the RIAs for data on current practices,
costs, and resources available for cleanup programs.
All eight RIAs identify and discuss in some detail the markets that would
be affected directly by the regulations. Impacts on market prices and output
rates constitute "primary" economic impacts of regulations. Seven of the
eight RIAs do not project these prices and output impacts at all. Of these
seven, two explicitly state that price and output impacts are expected to be
insignificant and are thus not projected. Others discuss price and output
impacts qualitatively. The Used Oil RIA projects price and output impacts
both in percentage and absolute terras.
"Secondary" market impacts include impacts on employment and impacts on
capital utilization/industry growth. None of the eight RIAs quantitatively
project employment impacts, though some do discuss possible impacts. Seven of
the RIAs do not discuss potential impacts on existing or new capital at all.
The Contingency Plan RIA does discuss possible changes in the cost of capital
following regulation.
In the exposure analysis, the two CERCIA RIAs do not estimate actual
release rates from the toxic chemical spills because the variability in size
and chemical content was considered too great and the data too sparse to allow
for adequate waste characterization. The RCRA RIAs all generate quantitative
estimates of release rates from model waste streams to some or all of the
media—air, groundwater, and surface water--for different waste disposal
methods. Although the two CERCLA RIAs discuss releases to soil, none of the
RCRA RIAs estimate exposures via soil contamination.
The number of persons exposed for each regulatory alternative is esti-
mated in one CERCLA RIA (Contingency Plan) and all but one of the RCRA. RIAs
include estimates of the number of persons exposed. For the RCRA RIAs, esti-
mates of exposure levels are obtained using release, fate, and transport
models for air, groundwater, and surface water. Only two of these RIAs gen-
erate estimates for the duration of this exposure corresponding to a given

duration and method of waste disposal. All of the RCRA RIAs assume lifetime
exposure for the health risk estimates for all disposal methods. Plant and
animal exposure is discussed in only three of the RIAs and other environmental *
impacts are discussed in four.
The two CERCLA RIAs discuss health benefits but perform no quantitative
estimates. The six RCRA RIAs all generate quantitative estimates of cancer
risks attributable to the toxic chemicals for various disposal methods. Five
out of six of these RIAs also generate quantitative estimates of noncancer
risks attributable to the toxic chemicals for various disposal methods. All
these estimates are used to determine the reduction in risk with the regula-
tion. None generates quantitative estimates of other harmful effects, al-
though most discuss such effects and the Solvents RIA assumes exposure ceases
when the water concentration is above the taste-odor threshold because people
switch to alternative water supplies. The costs associated with switching are
not estimated, however.
None of the RIAs explicitly estimates the timing of avoided cancer or
noncancer cases relative to the time of exposure. In some cases the issue is
discussed briefly. In these RIAs, the cancer cases are assumed to occur over
the next 70 years or, in one RIA, over the next 400 years. None of the RIAs
attempts to estimate or even discuss a dollar value that might be associated
with a case of environmentally induced cancer or other adverse health effect.
None of the RIAs attempts to discount the avoided cancer cases and only one
even discusses the issue of discounting health benefits. In three of the RCRA
RIAs the results of either sensitivity or uncertainty analyses for the esti-
mates of avoided cancer risks are presented.
For the cost estimates, all but one of the RIAs use estimates of engi-
neering compliance costs to estimate the real resource costs of the regula-
tion. In the Used Oil RIA, the results of the products markets analysis are
used to estimate the real resource costs of the regulation. None of the RIAs
estimates costs of unemployment or displacement of capital. The three RIAs
that estimate the regulatory costs are those in which such costs are likely to
be significant.
Most of the RIAs present some comparison of the benefits and costs of new-
regulations. The Reportable Quantities RIA estimates net-monetized benefits

but for changes in compliance costs only. The rest of the RIAs do not gen-
erate estimates of net-monetized benefits because health effects are not
assigned a monetary value. However, in most cases some cost-effectiveness
comparisons are attempted. These vary in their degree of quantification and
in their clarity. In the Used Oil RIAt the ratio of annual dollar costs of
the regulation to the annual number of avoided cancer cases is calculated.
Annual avoided cancer cases are assumed equal to the avoided cancer cases for
a single population cohort divided by 70. These ratios are used to compare
regulatory alternatives. In the Contingency Plan RIA, although quantitative
health effects are not generated, a useful tabular listing of benefits and
costs is presented and discussed. The Smal1-Quantity Generators and Dioxins
RIAs discuss the relationship between benefits and costs for different regu-
latory alternatives, but no attempt is made to quantify the relationship and
no table is presented. The Solvents RIA compares the percentage reduction in
cancer risks or noncarcinogenic exposure ratio with the percentage increase in
compliance costs. The Incinerator RIA does not compare costs and benefits at
all. The costs estimated are the compliance costs to move existing incinera-
tors into compliance with the current regulations. Comparable benefits are
not estimated, only health risks when complying with the current regulations
and the health risks mandated by a possible alternative regulatory approach.
Based on the framework outlined above and our comparative analysis of the
eight RIAs, we have developed a set of specific suggestions of ways in which
hazardous waste RIAs might conform more closely to EPA's guidelines in the
future. These suggestions are described below under 12 general headings.
ES.3.1 Broader Perspective
The adverse effects of the releases .of hazardous substances, in addition
to health effects, should be discussed and, where possible, estimated. For
example, if contaminated well water is detected, the health effects may be
zero, but the costs of alternate water supplies and aquifer cleanup may be
large. However, care must be taken to avoid double counting of adverse ef-
fects .
ES 11

Releases to all relevant media should be estimated as well as all rele-
vant routes of exposure from each medium. Thus, care should be taken to omit
media or exposure routes from the benefits estimates only if their effects are
likely to be insignificant.
ES.3.2 Quantitative Analysis of Several Alternatives
Future RIAs should generate quantitative estimates of benefits and costs
for the proposed regulation and at least one regulatory alternative. The
regulatory alternatives analyzed should represent significantly different
approaches to that of the proposed regulation. These alternatives should be
selected from those that have been considered during the regulatory develop-
ment process. To the extent that only a narrow range of options was consid-
ered during regulatory development, the RIA will necessarily have a narrower
ES.3.3 Derivation/Presentation of Input Parameter Values
Data sources should be described clearly and references included where
appropriate. Survey data are a good, reliable source of data from industry.
In RIAs that rely more heavily on reporting data, discussions of the limita-
tions of that data and the likelihood and extent of under- or overreporting
should be included. In RIAs that use estimates provided by a subcontractor,
the primary data sources, whether industry sources, engineering estimates, or
informed judgment, should be indicated so that the degree of certainty about
the estimates may be ascertained.
Input parameter values should be tabulated for each estimation model
used. Although uniformity in parameters estimates "is not necessarily desir-
able or possible, all RIAs should Include tables that list the values (or
distributions) assumed for all input parameters so that the reader can easily
compare the parameter values used in different RIAs.
FS.3.4 Methods for Cost Estimates
The effects of the regulation on the products markets should be described
in an economic framework. For example, a supply/demand framework might be
The estimation method chosen should be selected on the basis of clearly
defined decision rules. For example, such decision rules might be derived

using a simulation approach to determine when the more simplistic models are
likely to misrepresent significantly the true costs of the regulation. The
degree of misrepresentation might depend on the magnitude of the compliance
costs relative to total industry costs and the elasticities of supply and
demand in the products markets.
Cost estimates should include a broader definition of costs than industry
compliance costs. For example, the degree to which these costs are passed on
to the consumer as higher product prices should be estimated. Also, costs due
to unemployment and dislocation of capital should be estimated.
£S.3.5 Products Markets Trends and Exposures
The regulations' compliance costs may change the volume of hazardous
waste generated in future years. Such changes may change exposures and should
be discussed and estimated if likely to be significant.
Some attempt should be made to incorporate into the analysis overall
market trends for the affected industries. Such trends can have a major
effect on the projected benefits and costs of a regulation over a multiyear
period. For example, if generation of a hazardous waste is likely to decline
in the future, the cost and exposure impacts of the regulation will be less
than if more hazardous waste is likely to be generated.
ES.3.6 Release, Fate, and Transport Models
Use or develop transport models that allow variability in both leve] and
duration of releases. For example, the Wilson and Miller Groundwater Trans-
port model assumes a steady-state release whereas the PLUME and RANDOM WALK
Groundwater Transport models are able to estimate exposure levels and dura-
tions that result from variable release levels and durations. The latter
models or other similar models should therefore be used in future RIAs.
Make more realistic assumptions for models estimating releases of toxic
chemicals from landfills for: degradation of the toxic chemicals in the land-
fill, concentration of toxic chemicals in leachate, concentration of toxic
chemicals in free liquids, total volume of leachate, volume of leachate
collected in leachate collection system, content of leachate collected in
leachate collection system, and fate of leachate collected in leachate collec-
tion system. The existing models have either ignored or made overly simplis-
tic assumptions about some of these factors (for example, no degradation of

the chemical in the landfill). Models estimating releases to groundwater
should be reviewed carefully by EPA and an approach developed that explicitly
deals with all the factors listed above as well as other relevant factors.
ES.3.7 People Affected by the Regulation
Distinguish between people affected by compliance activities and people
affected because of changes ,in releases of the toxic chemical. Among those
affected by compliance activities, include a discussion of the relative impor-
tance of business owners, employees, and consumers.
Develop a more consistent methodology for estimating the number of people
exposed to contaminated groundwater, surface water, and soil. The RIAs ana-
lyzed vary greatly in the methods used to estimate the number of people
exposed by route of exposure. Because this is a key variable in determining
health effects, it might be useful for EPA to develop a methodology for popu-
lation exposed to soil, surface water, and groundwater to complement the EPA
GEMs Modeling System for air. In this way, a more consistent approach to this
estimation would be encouraged for future RIAs.
ES.3,8 Real istic Tiining
Choose a common period of waste disposal for the estimates of benefits
and costs. Because the goal of an RIA Is to enable comparison of the benefits
and costs of new regulations, it is important that a common basis be used for
estimating these benefits and costs. The most logical approach is to choose a
period of waste disposal--either 1 year or 20 to 30 years--and compute the
benefits and costs attributable to the new regulations for that disposal
period. For a given disposal period, duration of release to the different
media should also be estimated explicitly for different disposal methods. For
example, releases to air from incineration occur only during the disposal
period, while releases to groundwater from landfills may occur for up to 200
years after the end of the disposal period. Based on the duration of release
to the environment, the duration of exposure from the different routes and
disposal methods should also be estimated explicitly.
Discuss and present estimates, if possible, of the timing of the harmful
health effects relative to time of exposure. There is an important difference
in timing for cancers and noncancers that should, at a minimum, be discussed;

viz for cancers there is generally a long lag time after exposure (20 to 30
years) while noncancer effects may be experienced immediately. The lag time
of the health effect determines the average age of the persons likely to
experience the harmful health effects.
ES.3.9 Valuation of Health Benefits
Dollar valuation of health benefits should, at a minimum, be discussed in
future RIAs. A large literature exists on the topic, and the EPA RIA guide-
lines describe appropriate methods that can be used to value both morbidity
and mortality. Thus, it should also be possible to assign dollar values to
the health benefits. An alternative approach is to estimate threshold values
for the health benefits, at which values the benefits would just exceed the
costs of the regulation.
ES.3.10 Benefit-Cost Comparisons
Comparisons of health effects with other dollar costs or benefits should
be made for comparable durations of disposal. Annual costs, for example,
should be compared to the change in health effects attributable to a single
year of waste disposal. If this is not done, such cost-effectiveness esti-
mates will be misleading for decisionmakers.
So that the decisionmaker will have information available in a useful
format, the comparison of benefits and costs should be presented in a table as
well as being discussed in the text. Both qualitative and quantitative esti-
mates of the benefits and costs should be presented in this table so that the
decisionmaker can make his/her own judgment about whether the unquantified
benefits and costs are likely to be of sufficient importance as to change the
decision he/she. might make on the basis of the quantitative estimates alone.
The discussion of the table should provide a summary of the implications of
the entire analysis for the decisionmaker.
ES.3.11 Sensi ti vi ty/Uncertainty Analysi s
Sensitivity analysis should be performed when there is considerable
uncertainty about the values of some of the input parameters. For example,
the results of the exposure impacts analysis and the dose-response relation-
ships both are estimated with considerable uncertainty. Sensitivity analysis

should be performed for the exposure estimates and the dose-response relation-
ships to provide information about the impact of changes in these parameter
values. Full-scale uncertainty analysis should be used only to the extent
that the results can be presented in a way that improves the decisionmaker's
ability to make informed judgments.
ES.3.12 The RIA as a Complete Document
The RIA should include a combination of text and appendixes such that the
results are reproducible by the reader from the RIA alone. Since the methods
used for performing benefit-cost analyses for hazardous waste regulations are
not standardized, it is important for all methods used to be described
clearly. Equations should be presented in appendixes where appropriate. The
results of each stage of the analysis should be presented in tabular form
(e.g., waste characterization, release rates, and exposure concentrations) so
that the reader can easily follow the steps of the estimation process. Refer-
ences to supporting documents cannot substitute for such detail within the RIA
document, even, if the bibliographical reference is complete. The supporting
document may not be readily obtainable.
The text should avoid lengthy background discussions and should clearly
and concisely present the benefit-cost analysis methodology and results. If
more detailed discussion seems necessary (e.g., for the derivation of input
parameter values), it should occur in an appendix. For example, only the
summary of data derived froi the industry profile should be included in the
text. The industry profile should be presented in an appendix.
In order to facilitate the implementation of all these suggested improve-
ments, we recommend that EPA prepare a reference handbook that would comple-
ment the RIA Guidelines. Such a handbook light include: a brief but detailed
description of all relevant, currently used estimation models and a set of
decision rules for choosing among them; for each estimation model, tables of
commonly used input parameter values and their sources; and a listing of major
data sources that might be useful for hazardous waste RIAs. The handbook also
should present suggested refinements to currently used methods, where appro-
priate. The appendixes for the RCRA Risk-Cost Analysts Model and a more
recent report Risk Assessment Methodology for Hazardous Waste Management pro-
vide a convenient starting point for such a reference work.

With the use of such EPA reference documents, the increase in resources
needed to achieve all the improvements suggested above may not be large. Some
of them involve only clearer presentation of the results of the analysis,
including data sources and parameter values used (3), cost-benefit comparisons
(9), and overall organization of the report (12). The other suggested
improvements might require the use of additional models, but the burden on the
preparer of the RIA can be minimized by developing a centralized listing of
all such models and central access to the computer programs for them. Even if
resource or data limitations prevent additional modeling, all these other
suggested improvements can be addressed qualitatively, clearly presenting the
methods used in the analysis and how more extensive modeling is likely to
affect the results.