United States
Environmental Protection
Agency
Solid Waste and
Emergency Response EPA/530-SW-91-073B
(OS-312)	September 1991
& E PA Addendum to the
Regulatory Impact
Analysis for the Final
Criteria for Municipal
Solid Waste Landfills

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Addendum to the Regulatory Impact
Analysis for the Final Criteria for
Municipal Solid Waste Landfills
Prepared for
Regulatory Analysis Branch
Office of Solid Waste
U.S. Environmental Protection Agency
Prepared by
Temple, Barker & Sloane/Clayton Environmental
Consultants
ICF Incorporated
August 1991

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1 - /
I. Introduction
Background
The December 1990 Regulatory Impact Analysis (RIA) was prepared to evaluate the
U.S. Environmental Protection Agency's (EPA's) revisions to Subtitle D criteria for municipal
solid waste landfills (MSWLFs). This addendum supplements the RIA. These regulations are
a major rule-making according to Executive Order 12291 (aggregate compliance costs are
greater than $100 million per year); therefore, an RIA is required as part of this rule-making.
The analysis in the RIA evaluates the hybrid approach (referred to in the RIA as the final
rule) relative to four regulatory alternatives in terms of costs, economic impacts, impacts on
small entities, health risk, and resource damage and discusses the overall rationale for the
Agency's final choice. The RIA also includes a Regulatory Flexibility Analysis (RFA) that
assesses impacts to small entities.
This analysis represents EPA's best efforts to quantify the costs, economic impacts,
and benefits (health risk and resource damage) of the regulatory options. It should be noted,
however, that as in any analysis, the results are necessarily based upon incomplete data and
on simplified assumptions. A discussion of limitations of the analyses is included in the RIA.
Introduction
After the analysis for the December 1990 RIA was completed and the document
prepared, several changes were made to the regulatory analysis. These changes affect costs,
economic impacts, risks, and resource damage because they
•	Reflect a modified baseline (i.e., take into account additional requirements already in
place as a result of state landfill regulations)
•	Reflect changes in the analyses to better represent flexibility incorporated in the final
rule language
•	Exempt certain small landfills from compliance with the provisions of the regulatory
options
Because changes to the baseline and the final rule occurred after the RIA was completed,
EPA did not revise all of the analysis found in the complete RIA. Instead, this document
summarizes the principal changes in the baseline and final rule that affect costs and benefits,

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I - 2
the approach taken to incorporate these changes into the cost, economic impact, risk, and
resource damage analyses, and the results of the revised analyses. The final rule and the
limited rale option (ground-water monitoring, corrective action, and location standards ~
Alternative 4 in the RIA) have received the most scrutiny; these two options are the focus of
this addendum.
The most significant change in the cost and benefit estimates resulted from an
expanded review of current state landfill regulations. Landfill owner/operators are already
obligated to comply with state standards so, to the extent that revised federal criteria for
landfills duplicate existing state requirements, the federal criteria would impose no additional
cost. Similarly, any benefits resulting from these existing state requirements are considered
part of the baseline and are not attributed to the federal criteria. In the RIA, only a limited
number of state requirements were included in the baseline of state requirements. EPA has
since examined these regulations in more detail and expanded the characterization of baseline
practices.
A second change in the analysis resulted from changes in the modeling assumptions to
reflect flexibility incorporated into the final rule language, but not modeled in the RIA. RIA
assumptions that were changed relate to the cost of conforming with "best engineering
practices" in landfill construction, assumed cover requirements for existing landfills, use of
alternative points of compliance (POCs) for landfills, and the frequency of ground-water
monitoring.
Third, the final rule provides for an exemption from the requirements for small
landfills in approved states meeting certain criteria (e.g., low rainfall or seasonal interruptions
in operation). These exemptions were not reflected in the RIA cost estimates, but are
included in this addendum.
Chapter II of the addendum summarizes the changes in the methodology for the cost
and risk analyses. The revised cost results are presented in Chapter HI, economic impact
results in Chapter IV, risk and resource damage results in Chapter V, and other benefits in
Chapter VI.

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x.~ i
II. Revised Assumptions
Incremental costs and benefits estimated in the RIA have been changed to reflect
current state requirements that overlap with the revised federal criteria, additional flexibility in
the implementation of the rule, and exemptions for small landfills that were not modeled in
the RIA. This chapter briefly reviews the relevant assumptions made in the RIA and
describes the new methodology that was used to produce the results summarized in Chapters
III through V.
Credits for State Requirements
Cost Analysis
Assumptions in the RIA
Research conducted by EPA in 1987 indicated that many states already had
requirements for ground-water monitoring and containment systems. As described in the
RIA, these requirements were factored into the cost and economic impact analysis; they were
not considered in the risk and resource damage assessment. Based on 1987 data, the RIA
assumed credit for ground-water monitoring capital costs for landfills in 24 states (2,702
units) and for at least a portion of containment system costs in 22 states.
1991 Revised Assumptions for the Addendum
In the spring of 1991, EPA expanded the scope of the review of state requirements to
include a broader range of regulatory requirements and state regulations that had been
promulgated since 1987. While the 1987 analysis only included synthetic liner and ground-
water monitoring requirements, the 1991 review addressed all containment systems (including
synthetic liners, clay liners, composite liners, and leachate collection systems), covers,
ground-water monitoring, and corrective action. Credit was given for these additional
requirements in the results presented in this addendum. For the purposes of this analysis,
state regulations were categorized into a simple framework to develop assumptions about
costs. This analysis should not be used as an authoritative or comprehensive source on state
landfill regulations.

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II- 2
The rationale for providing credits is relatively simple. If the federal criteria overlap
with current state landfill requirements (i.e., require similar actions) no incremental cost is
attributable to the federal criteria. Since landfills must already comply with state regulations
the federal criteria will only affect the landfill to the extent that the federal requirements are
more stringent The approach EPA adopted is to identify relevant state requirements and only
attribute to the federal rule incremental costs beyond state requirements.
To model costs, design requirements for individual landfills were determined using the
Subtide D Risk Model. If, based on the performance standard criteria and model results, a
landfill is assigned to a synthetic liner design under the final rule and state regulations already
require the liner, then the cost of the liner is not counted in total compliance costs. These
cost credits are, of course, integrated with the credits already provided to landfill in the RIA.
The cost modeling approach proceeds state-by-state and identifies all landfills incurring the
cost for a requirement already in state regulations. The cost of state requirements is
subtracted from the total compliance cost, and the remaining costs are aggregated to estimate
revised national cost totals. A description of each of the state requirement categories is
provided below.
Containment Systems
The review of state containment system requirements addressed clay liners, synthetic
liners, composite (synthetic plus clay) liners, and leachate collection systems (LCS). For the
purposes of this analysis, the three liner designs analyzed were assumed to be equivalent in
cost and performance to similar designs modeled in the RIA. For example, state requirements
for clay liners were assumed to be equivalent to the clay liner modeled in the RIA (two feet
of recompacted clay with a permeability of 10"7).
The results of the state review are summarized in Table II-1. EPA assumed that 33
states (containing 4,626 landfills) require a clay liner, 29 states (containing 3,413 landfills)
require a synthetic liner, and 19 states (containing 1,766 landfills) require composite liners.
However, not all of the landfills in these states were required under the final rule to have
these designs. The actual credit provided for individual landfills depended on the design to
which the landfill was assigned in the RIA. For units assigned to a synthetic liners, for
example, if the state already required a synthetic liner or composite liner, no additional cost
was attributed to the federal criteria. If the state required only a clay liner, the federal criteria
would impose only the difference in cost between the clay liner and a synthetic liner. In the
case of composite liner requirements, landfills in states with composite liner credits incurred
no additional cost from the federal rule. If the state mandated either a synthetic or clay liner,
the landfill received credit for the less expensive of the two (assuming the landfill owner
would comply with the less expensive state requirement); the federal criteria would then
impose additional costs on the landfill for the remaining composite liner components.

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U- 3
Table lt-1
Analysis Assumptions Regarding State Containment System
Requirements for Municipal Landfills
(Assumed universe of 6,034 landfills)
—-	Liner Systems	
Leachate Collection
State
Clay
Synthetic
Composite
Systems
Alaska
¦
¦
¦
¦
Alabama
¦
¦

¦
Arkansas
¦
¦
¦
¦
Arizona
¦
¦
¦
¦
California
¦


¦
Colorado
¦
¦
¦
¦
Delaware
¦
¦
¦
¦
Florida
¦
¦
¦
¦
Georgia

¦

¦
Iowa
¦


¦
Indiana
¦


¦
Kentucky
¦
¦
¦
¦
Louisiana
¦
¦
¦
¦
Maryland
¦
¦
¦
¦
Maine
¦
¦

¦
Michigan
¦
¦

¦
Minnesota
¦
¦

¦
Missouri
¦
¦

¦
Mississipi
¦
¦

¦
Montana
¦


¦
Nebraska



¦
New Jersey
¦
¦
¦
¦
New York
¦
¦
¦
¦
Ohio
¦
¦

¦
Oklahoma
¦
¦
¦
¦
Oregon



¦
Pennsylvania
¦
¦
¦
¦
South Dakota
¦
¦

¦
Tennessee
¦
¦
¦
¦
Texas
¦
¦

¦

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n- 4
Table 11-1
(Continued)
Analysis Assumptions Regarding State Containment System
Requirements tor Municipal Landfills
(Assumed universe of 6,034 landfills)
Liner Systems	
Leachate Collection
State
Clay
Synthetic
Composite
Systems
Virginia
¦
¦
¦
¦
Vermont
¦
¦
¦
¦
Washington
¦
¦
¦
¦
Wisconsin
¦


¦
West Virginia
¦
¦
¦
¦
Wyoming
¦
¦

¦
Total States
33
29
19
36
Total Number




of Landfills
4,626
3,413
1,766
5,017

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n- 5
All state landfill liner requirements were assumed to include leachate collection
requirements as well. Thus, no additional costs were assigned for leachate collection systems
in 36 states (containing 5,017 landfills).
Cover Systems
The cover systems modeled in the RIA are either a vegetative cover or a synthetic
cover. The status of state requirements for covers is summarized in Table II-2. For new
units, EPA assumed that 21 states (containing 1,900 landfills) either require synthetic covers
explicitly for new landfills or have a performance standard which, when coupled with the
state's liner requirements, effectively require a synthetic cover. For existing units, however,
EPA assumed only 6 states (containing 489 landfills) require synthetic covers. Again, only
landfills assigned to synthetic covers in the RIA modeling received credit for the state
requirements.
Ground-Water Monitoring and Corrective Action
EPA assigned credit for ground-water monitoring and corrective action differently for
existing landfills and for new landfills. EPA assumed that new landfills in 39 states
(containing 5,149 units) are subject to state ground-water monitoring requirements (Table II-
3). As a result, the federal criteria would not impose additional costs on these landfills for
ground-water monitoring wells or for hydrogeologic studies of the site to determine well
placement and other background data. However, since the sampling requirements in the final
rule are relatively comprehensive, EPA assumed that no state receives credit for the sampling
costs. The total cost of ground-water monitoring equals sampling costs for all landfills and
also well and study costs for landfills in the 11 "non-credit" states.
Ground-water monitoring requirements for existing landfills were less clear in these 39
states. Because many of these regulations are relatively new, EPA assumed that only half of
the existing landfills in these states would have wells in place and would not incur costs for
wells and studies. The remaining existing landfills would incur full costs as a result of the
ground-water monitoring requirements. As with the new units, EPA assumed all existing
landfills will bear the full cost of the sampling requirements.
Twenty-three of the states with ground-water monitoring requirements also require
some type of corrective action for releases from municipal landfills. Given uncertainty over
the state requirements (i.e., the stringency of state requirements and the types of constituents
that must be controlled), only partial (50 percent) credit was given toward corrective action
costs for new landfills that trigger corrective action in these states. These corrective action
requirements also extend to existing landfills in these same sates, but due to limited ground-
water monitoring and other uncertainties, EPA assumed that the credit would be lower than
that provided to new units. Only existing landfills in states that were already monitoring

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n- 6
Table 11-2
Analysis Assumptions Regarding State Cover System
Requirements for Municipal Landfills
(Assumed universe of 6,034 landfills)
State
New Units1
Existina Units
Alaska
¦

Arkansas
¦

Arizona
¦

Colorado
¦

Delaware
¦
¦
Florida
¦

Kentucky
¦

Louisiana
¦

Maryland
¦
¦
Maine
¦
¦
Minnesota
¦
¦
Missouri
¦
¦
New Jersey
¦

New York
¦

Oklahoma
¦

Pennsylvania
¦
¦
Tennessee
¦

Virginia
¦

Vermont
¦

Washington
¦

West Virginia
¦

Total States
21
6
Total Number


of Landfills
1,900
489
1 Stales with existing unit requirements have an explicit synthetic cover requirement for all landfills. The other
states require synthetic covers through a performance standard.

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II - 7
Table 11-3
Analysis Assumptions Regarding State Ground-Water Monitoring and
Corrective Action Requirements for Municipal Landfills
(Assumed universe of 6,034 landfills)
State
Alaska
Alabama
California
Colorado
Connecticut
Delaware
Florida
Georgia
Iowa
Idaho
Indiana
Kentucky
Louisiana
Maryland
Maine
Ground-Water
Monitoring1 Corrective Action2
Michigan
Minnesota
Missouri
Mississippi
North Carolina
1 Credit is provided for ground-water monitoring wells and hydrogeologic studies only. All new landfills
receive the credit Only half of the existing landfills in these states receive credit; within each state, the
existing landfills that receive credit were chosen randomly.
^ New landfills in these states receive credit for half of their corrective action costs. Existing landfills that
received credit for ground-water monitoring receive credit for 25 percent of their corrective action costs. No
other credit is provided.

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n- 8
Table 11-3
(Continued)
Analysis Assumptions Regarding State Ground-Water Monitoring and
Corrective Action Requirements for Municipal Landfills
(Assumed universe of 6,034 landfills)
Ground-Water
Monitoring1 Corrective Action2
New Hampshire
¦

New Jersey
¦

New Mexico
¦
¦
New York
¦
¦
Ohio
¦
¦
Oklahoma
¦
¦
Oregon
¦

Pennsylvania
¦

Rhode Island
¦
¦
South Carolina
¦

South Dakota
¦

Tennessee
¦

Texas
¦

Virginia
¦
¦
Vermont
¦
¦
Washington
¦
¦
Wisconsin
¦
¦
West Virginia
¦
¦
Wyoming
¦

Total States
39
23
Total Number


of Landfills
5,149
3,175

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n- 9
groundwater were assumed eligible to receive credit toward corrective action costs. Further,
EPA assumed that existing landfills that triggered corrective action would receive credit for
only 25 percent of their corrective action costs.
Risk and Resource Damage Analysis
Baseline
In the RIA, baseline risk and resource damage were simulated under the assumption
that new landfills were unlined, had vegetative covers, and that none performed corrective
action. To revise the RIA results to account for compliance with state requirements in the
baseline, our basic approach was to use the results of the 1991 state review to determine how
many landfills are in states that require more advanced designs or corrective action, and to
recalculate risk and resource damage with the appropriate state requirements in place.
Implementing this approach rigorously would have involved simulating risk and
resource damage for every type and combination of liner and cover systems that states
require. For the purposes of this analysis, we took a more simplified approach. To account
for compliance with state liner and cover system requirements in the baseline, we matched the
various state-required designs with one of the three designs that had already been simulated
for the RIA: (1) no liner/vegetative cover; (2) no liner/synthetic cover; and (3) composite liner
with LCS/synthetic cover. Our assignment of state requirements to the three available designs
is shown in Table II-4:

Table 11-4

Assumptions for Assigning Liner and Cover Designs
to Reflect State Requirements In the Baseline
Stat* Requirement
ami resource Damage Estimate
Liner
Cover

None
None
No liner / vegetative cover
Clay
None
No liner / vegetative cover
Synthetic or
Composite
None
Composite liner / synthetic
cover
Synthetic or
Composite
Synthetic
Composite liner / synthetic
cover

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n-10
The decision rules for making these assignments reflect the following conclusions:
•	Clay liners are much less effective at controlling releases than synthetic
membranes. In dry regions, clay liners may increase the time of travel of
leachate from the waste to the underlying aquifer by several years, but are not
likely to significantly reduce the rate at which leachate is released once the
liner becomes saturated. In wetter regions, the time delay is much shorter, and
the reduction in leachate release rates is likely to be significant only in regions
with very high net infiltration rates. Synthetic membranes are much less
permeable than clay liners and drastically reduce releases for as long as they
are intact. Given the choice between assigning landfills with clay liners to the
unlined design versus the composite liner, we believe that the unlined design
reflects clay liner performance more accurately.
•	State leachate collection system requirements were not an important factor in
assigning landfills to one of the three designs. Of the 36 states requiring LCSs,
29 also require synthetic or composite liners. Two states require LCSs but do
not require liners, and five states require LCSs and only clay liners. Because
the efficiency of the LCS depends to a great extent on the permeability of the
underlying layer, and synthetic membranes are much less permeable than in-
situ soils or typical clay liners, we believe landfills with LCSs overlying natural
soils or clay liners behave more like unlined landfills than composite-lined
landfills.
•	All landfills in states requiring synthetic or composite liners were assigned to
the composite liner/synthetic cover design, regardless of the cover requirement.
Of the 29 states requiring synthetic or composite liners, only 7 have no cover
requirements. We do not believe that many landfills would actually be
designed this way, given the potential "bathtubbing" effect associated with
landfills whose liners are less permeable than their covers.
As discussed above, some states also require ground-water monitoring and corrective
action in the baseline. For the cost analysis, credit was given toward corrective action costs
for only 50 percent of the new landfills that trigger corrective action in the 23 states with
corrective action requirements. For the risk and resource damage analysis, we assumed that
only half of the landfills in these 23 states that exceed MCLs would be assigned corrective
action in the baseline. As in the RIA, we assumed that landfills with the composite/synthetic
design would never trigger corrective action because the containment systems would remain
intact until the end of the post-closure care period, when ground-water monitoring would
cease.
Using these decision rules, about 56 percent of landfills were assigned the composite
liner/synthetic cover in the baseline, and about 44 percent were assumed to have no liners and

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n-11
only vegetative covers. About 4 percent of landfills were assumed to have corrective action
in the baseline, all of which have the unlined/vegetative cover design.1
Final Rule
To revise the RIA risk and resource damage estimates for the final rule, we started
with the design assignments under the revised baseline. If a landfill met the MCL-based
performance standard with the state-required design in place, it retained that design under the
final rule. If the state-required design was not sufficient to meet the performance standard,
we assigned a more stringent design. Because landfills that trigger corrective action in the
baseline do not meet the MCL-based performance standard with the unlined/vegetative cover
design, we assigned them to more stringent designs under the final rule. (As in the RIA, the
most stringent design assigned to any landfill was the composite/synthetic design.)
Using these criteria, the design assignments for landfills under the final rule were
assumed to be as follows:
Table 11-5

Revised Design Assignments for New Landfills: Final Rule
(Assumes Compliance with Baseline State Requirementsf
-: jFJrtai ButeOeslgn
Percent of tandfllls
No liner / vegetative cover
29 %
No liner / synthetic cover
<1 %
Composite or synthetic liner / synthetic cover
71 %
Due to state requirements
— 56%
Due to linal rule
— 15 %
100 %
'This split among designs is not exactly the same as that used for the cost analysis, but
the differences are very small and do not significantly affect either the risk or cost results.
2These design assignments are based on a 10-meter point of compliance.

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II - 12
As shown on the table, 29 percent of landfills were assigned to the unlined/vegetative cover
design under the final rule. About 0.3 percent of landfills were assigned to the
unlined/synthetic cover design, and 71 percent to the composite/synthetic design (56 percent
due to baseline state requirements and 15 percent due to the final rule). No new landfills
were assumed to trigger corrective action under the final rule.
Limited Rule Option
We adopted a similar approach for estimating risk and resource damage for the limited
option. If the state-required baseline design was not sufficient to meet the performance
standard, we assumed that the landfill would trigger corrective action. Using these criteria,
56 percent of landfills were assumed to have the composite liner/synthetic cover design due to
state requirements and the remaining 44 percent have no liners and only vegetative covers.
About 12 percent of all landfills trigger corrective action (4 percent due to state requirements
and 8 percent due to the limited option), all of which have the unlined/vegetative cover
design.3
Table 11-6

Revised Design Assignments for New Landfills: Limited Option
(Assumes Compliance with Baseline State Requirements f
Limited option Design
Percent of Landfills
No liner, vegetative cover,
no corrective action
32 %
No liner, vegetative cover,
corrective action
12 %
Due to state requirements
— 4%
Due to limited option rule
— 8 %
Composite liner, synthetic cover
(all due to state requirements)
56 %
100 %
3The Subtitle D Risk Model indicates that if all landfills are unlined and have vegetative
covers, between 30 and 35 percent of unlined landfills trigger corrective action. When
landfills are assumed to be in compliance with state liner requirements, the proportion of
landfills that trigger corrective decreases to about 12 percent.
"These design assignments are based on a 10-meter point of compliance.

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n -13
Modeling Flexibility in the Final Rule
Cost Analysis
Since the R1A was completed, we have refined out modeling assumptions to better
capture some of the flexibility provided to states in the rule's language. These assumptions
relate to indirect capital expenses at baseline landfills, assumed cover requirements for
existing landfills, the point of compliance, and the frequency of ground-water monitoring.
In the RIA, the baseline landfill (from which incremental costs were measured) was
assumed to be designed and operated in accordance with best engineering practices. Despite
this, we had assumed that landfills would incur additional costs under the final rule for higher
engineering fees, inspection, and testing of the unlined/vegetative landfill design. Given
existing state requirements and the language of the rule, this cost is more appropriately
considered as part of the baseline, rather than attributable to the federal criteria.
Existing landfills were assigned to either synthetic covers or vegetative covers in the
RIA, depending on the level of net precipitation at the landfill site. If net precipitation was
positive, we assumed that a synthetic cover would be necessary to comply with the
performance standard. Given the current language of the rale which requires the cover to be
less permeable than the liner, and the widespread practice of using graded soil covers (at
least) on existing landfills, we determined that the assignment to synthetic liners was
excessive and not stipulated by the final rule. Since most existing landfills are either unlined
or have soil liners, a soil and vegetative cover would likely meet the final rule criteria.
Therefore, the revised costs exclude synthetic covers at existing facilities.
The final rule provides flexibility to states in determining the point of compliance
(POC) for the performance standard. The flexibility regarding alternative POCs is discussed
for the 1988 proposal in the RIA. Briefly, an approved state can set the POC where the
MCL-based performance standard must be met. The POC can be set at the edge of the
landfill (the 10-meter distance is used in the RIA as the proxy for this POC), or at a point no
more than 150 meters from the edge of the landfill provided that the POC is still on the
municipal solid waste landfill owner's property. To bound the analysis, we used an
alternative POC 150 meters downgradient from the edge of the landfill and estimated costs
and benefits using the alternative POC. Given the greater distance, slightly fewer landfills are
assigned to the more stringent designs under the performance standard. As a result, costs
decrease somewhat. Because of uncertainty over which landfills would be able to use an
alternative POC, for the development of a best estimate we assumed that half of all landfills
would use a 10-meter POC and half would use a 150-meter POC.
The final difference between the RIA estimates and these revised results is a lower
cost of ground-water monitoring brought on by less frequent sampling. The RIA assumed

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n-14
that all landfills sampled groundwater twice each year from each well at the facility. In order
to ease compliance costs and economic impacts, EPA has provided flexibility for this
requirement and the RIA assumption of semi-annual monitoring has been changed as well.
The revised cost estimates reflect only annual monitoring during the active life and the post-
closure care period for both the final rule and the limited approach.
Risk and Resource Damage Analysis
As discussed above, the cost analysis was revised to capture flexibility in the final
rule, but only the compliance point affects the risk and resource damage results for new
landfills. For the cost analysis, we assumed that half of ail landfills would use a 10-meter
POC and half would use a 150-meter POC. For the risk and resource damage analysis, we
used the simplifying assumption that landfills with no downgradient wells within one mile (46
percent of all landfills) would use the 150-meter POC, while those with downgradient wells
within one mile (54 percent of all landfills) would use the 10-meter POC.
Because pollutant concentrations in ground water may decrease with increasing
distance from the landfill, increasing the POC from 10 to 150 meters could result in less
stringent designs for some landfills under the performance standard. This phenomenon is not
reflected in the design assignments shown in Tables II-5 and II-6, nor did we rigorously
assess the effects of extending the compliance point on risk or resource damage. From a risk
perspective, extending the compliance point at landfills that have no drinking water wells —
and therefore no exposure - has no effect on estimated risk; these landfills have no risk either
in the baseline or under any of the regulatory alternatives considered. From a resource
damage standpoint, relaxing the design requirements at landfills without drinking water wells
would have decreased option value slightly. However, because option value resource damage
comprises only a small portion of total resource damage (about ten percent), the reduction in
total resource damage would have been negligible.
Exemptions from the Federal Criteria
Cost Analysis
The final rule contains an exemption for small communities that meet particular
criteria. These are designed to mitigate compliance cost burdens and service interruptions for
small landfills in remote or arid areas. For the purpose of capturing this exemption in the
cost analysis, EPA assumed that all landfills 20 TPD or smaller and that receive 25 inches or
less precipitation annually would be exempt from the regulatory requirements. This
assumption exempts 1,028 landfills or about 17 percent of all landfills. This analysis may
overestimate the number of landfills receiving the exemption since there are additional criteria

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II- 15
to qualify for this exemption in the final rule (e.g. no practicable waste management
alternative).
Risk and Resource Damage Analysis
In the risk and resource damage analysis, landfills are characterized differently than
for the cost analysis. For example, precipitation is measured in terms of net infiltration rates
rather than precipitation rates. To define the exemption for selected small landfills, we
assumed that the smallest landfills (the 10 TPD category) in the lowest net infiltration rate
category (0.25 inches per year) would be exempt, (This exempts 21 percent of landfills,
compared to 17 percent in the cost analysis). As it turns out, these landfills never exceed
MCLs at the compliance point in the modeling. Even without the exemption, the final rule
would not have imposed designs that are more stringent than the baseline, and corrective
action would not have been triggered under the limited approach. Therefore, exempting these
landfills from the final rule and/or the limited option rule does not change our assessment of
the risk and resource damage effects of these regulatory options.

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T'S T ¦ i
III. Revised Cost Results
All of the changes in assumptions since the RIA have reduced the estimated
compliance costs for the regulatory options. Before presenting the new results and showing
how the new assumptions changed the costs, we will review the national cost estimates from
the RIA. The previous cost estimates are described in detail in Chapter VII of the December
1990 RIA.
The cost estimates were based on the Subtide D Cost Model, developed for the RIA in
1987. The model is an engineering cost model that provides the specifications for a baseline
municipal waste landfill to which the user can add hundreds of additional components. The
model computes the year-by-year costs of designing, constructing, operating, and closing a
landfill, given the design and operating parameters specified by the user. Analysis of the
baseline costs and regulatory costs for landfills of various sizes and designs can be found in
Chapter VII of the RIA.
National Costs in the RIA
The national cost estimates were presented as a range in the RIA to reflect
Flexibility in the length of the post-closure care period that would be required
•	Uncertainty over the trend toward larger, regional landfills that replace fewer, small
facilities
•	Uncertainty over future reduction in waste disposal resulting from source reduction,
expanded recycling, and expanded use of combustion as a disposal option
The upper end of the range of costs was defined by a scenario in which all landfills were
required to have 40 years of post-closure care, no additional regionalization occurred, and the
future volume of waste discarded in landfills stayed constant (i.e., diversion of waste through
recycling and other alternatives increased at the same rate as total generation). The
annualized combined cost for the final rule was $1,040 million. The same cost under the
limited option rule (Alternative 4 in the RIA) was $755 million per year.
We also developed a scenario for compliance costs in the future, assuming that all
landfills had 10 years of post-closure care instead of 40 and that regionalization and shifts

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m - 2
away from disposal and toward combustion, recycling, and source reduction would continue.
The methodology behind the projected regionalization and expanded waste diversion are
described in Chapter IV of the RIA.
Under this lower bound scenario, annualized combined costs were about 40 percent
lower than the upper bound estimates. This scenario was based on an assumed population of
landfills that would remain in operation after 20 years of regionalization occurred. Also, the
quantity of municipal solid waste placed in landfills was assumed to decline by the end of
this 20-year period reflecting the effect of additional source reduction, recycling, and reliance
on combustion. In the lower bound, the annualized combined cost for the final rule was
estimated at $620 million and the annualized combined cost for the limited option was $447
million (see Table VII-36 in the RIA).
A most likely estimate was not reported in the RIA, but has been developed by EPA
since the RIA was completed. It is very difficult to determine where in this range the true
cost of the options would fall. This most likely, or "best" estimate was designed to provide a
point estimate of costs, taking into account the likelihood of future regionalization and the
extent to which landfills would continue to close and consolidate. This is only an estimate,
however, the actual cost could fall anywhere in the range presented. The most likely annual
cost estimates for the final rule and limited option rule RIA costs were $700 million and $510
million respectively.
The best estimate assumes that a portion of the regionalization would occur. The
simulation described in Chapter IV of the RIA indicated that virtually all small landfills could
save more money on disposal in larger facilities than they would pay in higher transportation
costs. After 20 years, the projected population of landfills would decrease from the 6,034
that were active in 1986 to approximately 1,800 based on economic decisions. Of course,
regional landfills might not always be available to every community that wants to use one.
Siting difficulties, transportation restrictions, or a community's desire to keep the landfill
under its own control would all work to slow the spread of regionalization.
For the purposes of this analysis, EPA estimates that approximately 3,000 municipal
landfills would still be active in 20 years, rather than the 1,800 originally projected. The
most likely estimate reflects this projection. The shift in the number of landfills also affects
the distribution of landfills across size categories. Table ni-1 summarizes the distribution of
landfills across seven size categories before and after the projected regionalization.

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in - 3


Table II1-1


Number and Percentage of Landfills by Size Category
Before and After Regionalization
Size Range
{Tone/Day)
Unreglonallzed
Number
<6,034)
Percentage
Regionalized
Number
(3,000)
Percentage
< 17.5
3,100
51
1,200
40
17.5 - 50
1,000
17
420
14
50 -125
790
13
290
10
. 125 - 275
440
7.3
310
10
275 - 563
330
5.5
350
12
563- 1,125
190
3.1
240
8.0
>1,125
160
2.6
180
6.1
The most likely estimate also assumes that half of all landfills will provide post-
closure care for 40 years and half for 10 years. Similarly, half of all landfills will operate
assuming their POC for design and corrective action is 10 meters from the landfill and half
will have a 150-meter POC. Finally, EPA assumes that source reduction, recycling, and
combustion will reduce the total quantity of municipal solid waste landfilled by 1 percent per
year. The approach for computing the most likely estimate will be used for the revised cost
results presented later in the chapter. The assumptions associated with the most-likely
estimate are summarized below.
Most Likely Estimate
•	50-50 split between 10- and 40-year post-closure care period
•	50-50 split between 10-meter and 150-meter POC
•	Some regionalization (universe of 3,000 landfills after 20 years)
•	20 percent additional waste diversion over 20 years (1 percent decrease per year)
Revised National Costs
Taking into account the changes since the RIA was completed, the national costs for
both regulatory options have declined by more than 50 percent. For the final rule, the range

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Ill - 4
of annualized combined costs (shown in Table III-2) is between $300 million and $490
million with a most likely estimate of $330 million. The drop in costs was even larger for
the limited option rule which has a range of $160 million to $270 million and a most likely
estimate of $180 million per year.5

Table 111-2

Summary of Revised Annualized Combined Costs
Annual Costs 20 Years After the Effective Date

(dollars in millions)

'lliilllllllillll
Final Rule
limited
Option Bui®
Range of Costs
$300 - $490
$160 -$270
Best Estimate
$330
$180
The most likely estimate combines the assumptions as follows: the landfills are
evenly split across the post-closure care and POC options, a universe of 3,000 landfills is
projected for 20 years after the effective date, and 20 percent of the waste currendy disposed
is diverted through source reduction, recycling, and combustion.
The most likely annualized combined costs for the final rule decreased by 53 percent
and the costs for the limited approach fell 64 percent compared to the RIA estimates. These
significant changes resulted primarily from EPA's analysis of current state landfill regulations
and the resulting change in the costs attributable to the federal criteria. As a rough estimate,
factoring in additional state requirements accounted for about half of the reduction in cost for
the final rule and over three-quarters of the reduction in cost for the limited option. The
other assumptions regarding flexibility and exemptions for small landfills account for the
remaining decrease.
5 Only two of the five options analyzed in the RIA are addressed here. The most
expensive option, the Subtitle C option described in the RIA, would still be significantly more
expensive than these options. Given state credits, the most likely estimate for the annualized
combined cost would still be over $1.3 billion.

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Ill-5
Table III-3 shows the components of cost for the two options. These costs assume 40
years of post-closure care, no regionalization, and a constant waste generation rate since 1986.
This upper-bound scenario was chosen for reporting purposes only and the cost estimates
have been rounded to simplify the discussion. The table indicates that liner and leachate
collection system requirements account for the largest portion of final rule costs, 40 percent
of the total; ground-water monitoring is the next most expensive component of costs adding
another 27 percent to the cost. The limited option rule is nearly evenly split between ground-
water monitoring and corrective action costs.

Table 111-3

Components of Final Rule and Limited Option Rule Cost
Annual Upper Bound Cost Scenario Only
Cost Component
Final Rule
Percent
Limited Option
Percent
Ground-water Monitoring
27 %
48 %
Synthetic Covers
17 %
0 %
Liners/LCS
40 %
0 %
Corrective Action
8 %
52 %
Other Costs
8 %
0 %
Total Cost
100 %
100%

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jr/-1
IV. Revised Economic Impact Results
The revised costs summarized in Chapter III have also changed the results of the
economic impact assessment described in Chapters V and VIII of the RIA. In general, the
incorporation of existing state requirements into the baseline costs decreases the severity of
the economic impacts just as it decreased the incremental costs. It is important to emphasize
that the economic impacts computed here reflect only the incremental burden on communities
and households resulting from the various federal regulatory options. To the extent that state
requirements are already in place, local governments are already bearing those increased
burdens.
The economic impact results were computed based on the most likely estimates of
incremental costs presented in Chapter HI. For example, these results reflect the expected
impact of regionalization on incremental costs and impacts. As such, the results simulate
impacts in the future after the waste management system has adjusted to new costs.
This chapter briefly summarizes the measures of economic impact (described in more
detail in Chapter V of the RIA), presents the results, and analyzes major differences between
these results and those in the RIA.
Measures of Economic Impact
The impact analysis focuses on communities and on individual households. The
measure of community impact is incremental annualized cost as a percentage of total annual
community expenditures (CPE). This measure illustrates how expensive the regulations
would be relative to communities' current operating budgets. We established a significant
impacts threshold at 1 percent of current expenditures.
The other two impact measures focus on households in the community: cost per
household (CPH) which spreads the incremental costs over all of the households in the
community, and cost as a percentage of median household income (CPMHI) which is a more
appropriate assessment of the impact of the regulations on households. CPMHI is computed
as the CPH divided by the median household income for the community. A threshold of
$220 per household was used to indicate significant impacts for CPH and the CPMHI
threshold was 1 percent.

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IV - 2
Results
The most likely annualized cost estimates for the final rule and the limited option rule
are $330 million and $180 million respectively; these costs will not impose significant
impacts on over 98 percent of the communities served by municipal landfills. The summary
of results shown in Table IV-1 indicates that the significant impact threshold is exceeded only
for the CPE measure and then only for 1.4 percent of all jurisdictions (396 jurisdictions out of
29,017 jurisdictions under the final rule and 402 under the limited approach). No significant
impacts on households are projected for either option. These results include the exemption
for landfills 20 TPD or smaller located in dry climates.


Table IV-1


Economic Impacts: Cost as a Percentage of Expenditures
lor the Final Rule and Limited Option Rule

Based on Most Likely Costs After Reglonallzatlon

Regulatory
Optfott
Minimum
- " -'CPE -
Median Maximum
^.-CPE -Vl/^C/
Number of
jurisdiction*
Wtth CPfe>; 1
P&rcentage
WW! CPE »1%
Final Rule
0.0%
0.20% 3.1%
396
1.4%
Limited
Option Rule
0.0%
0.11% 2.6%
402
1.4%
The communities with significant impacts account for a very small share of total
jurisdictions providing landfill services. The communities facing significant impacts are
typically small, about 90 percent have fewer than 5,000 people, and the landfills serving the
communities are small as well, over 80 percent are smaller than 17 TPD. The maximum CPE
under the final rule occurs in communities of between 1,000 and 5,000 people served by
landfills smaller than 17 TPD that were assigned to the uniform design. The maximum CPE
under the limited option occurs in the same situation, only the landfills were assigned to
corrective action, not the uniform design.

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IV - 3
No jurisdictions exceed the household significant impact thresholds. Table IV-2
summarizes the impact estimates for the two options for cost per household. The median
CPH is less than $10 for both options and the CPH averaged across all households in the
United States is $4.10 for the final rule and $2.30 for the limited approach. The maximum is
$62 for the final rule and $52 for the limited approach; only 13 communities have CPH
greater than $50 under either option.
Since no communities exceed the significant impact threshold for CPH of $220 per
household, we used a more moderate impact threshold of $100 per household for reporting
purposes only. However, even with the more moderate CPH threshold, no jurisdictions
exceed the $100 CPH level.


Table IV-2

Economic Impacts: Cost per Household
for the Final Rule and Limited Option Rule

Based on Most Likely Costs After Reglonallzatlon
JteSiriatory
Option
Minimum
Number of
Average Median Maximum Jurisdictions
:tm -CPH	 WfthCPH>$*00
Final Rule
$0.20
$4.10 $6.10 $62 0
Limited
Option Rule
$0.12
$2.30 $3.30 $52 0
* National most likely cost divided by national number of households.

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IV - 4
Finally, the CPMHI is well below the threshold level for both options. Table IV-3
indicates that the maximum CPMHI for the final rule is 0.33 percent and for the limited
option it is 0.32 percent, compared to a significant impact threshold of 1 percent

Table IV-3

Economic Impacts: CPU as a Percentage
of Median Household Income for the
Final Rule and Limited Option Rule
Based on Most Likely Costs After Regionalizatlon
Regulatory Minimum
Option CPMHI
Median
CPMHI;
Maximum
CPMHI
Number of
Jurisdictions
With CPMHI»t%
Final Rule 0.0%
0.026%
0.33%
0
Limited 0.0%
Option Rule
0.015%
0.32%
0
Regulatory Flexibility Analysis
The RIA contains analysis of the incidence of significant impacts on small
communities. In Chapter VIII of the RIA, we summarized the indicators of impacts (the
same as those described above for economic impacts) and the definition of small entities.
Small communities dominate the affected population with nearly 86 percent of all
jurisdictions containing 10,000 or fewer people, and nearly 77 percent of all jurisdictions
containing 5,000 or fewer people.
Since the impact thresholds were exceeded only for CPE, we have summarized this
measure for small jurisdictions below. As indicated earlier, smaller communities are
somewhat more likely to incur these significant impacts. Table IV-4 indicates, however, that
the difference between the incidence of impacts in all jurisdictions versus small ones is quite
similar. Using the final rule as an example, 1.4 percent of all jurisdictions face significant
impacts; similarly, for communities smaller than 10,000, 1.4 percent incur significant impacts;
and for communities smaller than 5,000, 1.6 percent incur significant impacts. There is some
difference confirming that small communities do incur greater burdens, but the differential

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IV - 5
between small and large communities is relatively slight. Further, only a few hundred
communities will incur these impacts.
There is a large reduction in the number of significantly impacted small communities
from those presented in the RIA. This reduction is a result of the change in assumption
regarding the frequency of ground-water monitoring (from semi-annual in the RIA to annual
in this addendum). This assumption reflects the flexibility offered to approved states in the
rule. If states require more frequent monitoring, the number of significantly impacted small
communities increases.
Table IV - 4


Jurisdictions Incurring Significant impacts

By Size of Community: Final Rule and Limited Option Rule

Aif
Population
Population
Population
Jurfscficttons
<10,000
<5,000
<1,000
Total Jurisdictions 29,017
24,883
22,205
13,211
Final Rule: CPE > 1% 396
355
355
201
(1.4%)
(1.4%)
(1.6%)
(1.5%)
Ltd Opt: CPE > 1% 402
393
356
181
(1.4%)
(1.6%)
(1.6%)
(1.4%)

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V. Revised Risk And Resource Damage Results
The changes in the modeling and the regulatory options since the RIA was completed
have reduced estimated risk and resource damage for the baseline and regulatory options.
This chapter discusses human health risk first and then resource damage for the baseline, the
final rule, and the limited option rule. For both risk and resource damage, a summary of the
results presented in the RIA precedes our presentation of the revised results. A full
discussion of the RIA results can be found in Chapter IX of the RIA. We have also added a
section on the frequency of ground-water contamination at landfills.
Health Risk
Health Risk in the RIA
In the RIA, we did not account for any state requirements when computing risk or
resource damage. In the baseline, all landfills were assumed to be unlined and to have
vegetative covers. The baseline maximum exposed individual (MEI) risk (i.e., risk to a
person exposed at the closest well) ranged from zero to about 10"4. About 60 percent of the
landfills posed no risk, 54 percent because there were no downgradient wells within one mile
and 6 percent because constituents did not reach the nearest well during the modeling period.
About 17 percent of landfills posed risk greater than 10"fi. The estimated number of cancer
cases over the 300-year modeling period, summed for 6,034 facilities, was 23.1. The results
presented in the RIA showed that the final rule and limited approach reduced the number of
cancer cases by approximately the same amount, 16 cases.
Revised Health Risk
The RIA risk and resource damage results were based on a universe of 6,034 landfills.
The number and size distribution of landfills are changing due to regionalization (i.e.,
construction of larger landfills serving many communities). Although regionalization was
addressed in the cost analysis presented in the RIA, it was not taken into account in the risk
and resource damage analysis. In this addendum, we present risk and resource damage results
using the best estimate of regionalization (3,000 landfills with the following size distribution:
53.5 percent in the 10 TPD category, 35.4 percent in the 175 TPD category, and 11.1 percent
in the 750 TPD category). The results also reflect current state requirements as described in
Chapter n.

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V - 2
Assuming a universe of 3,000 landfills in compliance with state requirements, the total
number of cancer cases in the baseline is 5.7 over 300 years.
Table V-l summarizes the revised risk results for the baseline, final rule, and limited
option for the regionalized universe of 3,000 landfills. The revised number of cancer cases
for the final rule is equal to the revised number of cases for the limited option — both have
3.3 cases over 300 years. These are lower than predicted in the RIA.

Table V-1

Revised Risk Reduction
With State Requirements and Reglonallzatlon
(3,000 MSWLFs)
v
Regulatory Scenario
Total Cases lrt s Cancer Cases
Modeling Period Avoided Percentage Decrease
Baseline
U1
1
1
i
Final Rule
3.3 2.4 42.1 %
Limited Option
3.3 2.4 42.1 %
The effectiveness of both regulatory options is also lower than predicted in the RIA.
Using the regionalized universe of 3,000 landfills, the number of cancer cases avoided under
the final rule and the limited approach drops to 2.4 cancer cases over 300 years. The
percentage decrease in risk is 42 percent, lower than the 68 to 70 percent reduction predicted
in the RIA.
The final rule now results in 0.8 percent of landfills having risks exceeding 10'5.
About 10.4 percent of landfills have moderate risk (i.e., between 10"6 and 10"s), and about
19.9 percent of landfills have low risk (i.e., between 10"g and 10"6).
The limited option rule results in 1.3 percent of landfills with risks exceeding 10"5.
About 9.4 percent of landfills have moderate risk (Le., between 10"6 and 10"5), and about 19.7
percent of landfills have low risk (i.e., between 10"8 and 10"6).

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V- 3
Analysis of Changes in Risk from the RIA
Incorporating existing state regulations into the baseline results in a significant
decrease in the estimated number of cancer cases. This is simply because landfills with more
protective designs pose lower human health risks. The number of cancer cases also decreases
when we incorporate regionalization into the baseline; this is because there are fewer landfills
(3,000 as opposed to 6,034).6
The decrease in risk reduction for the final rule and limited option can be attributed
primarily to the assumption regarding the effectiveness of state regulations in controlling
baseline risk, particularly at the higher risk landfills. In the revised baseline, over half of the
landfills are assumed to have the composite/synthetic design; because nothing more stringent
is imposed by either the final rule or the limited approach, there is no potential for additional
risk reduction at these landfills. State regulations also reduce baseline risk for the
approximately 4 percent of landfills that trigger corrective action in the baseline.
As discussed in the methodology section, the reduction in effectiveness of the
regulatory options is in no way attributable to the new exemption for small landfills in dry
climates. Because in EPA's modeling these landfills never exceed MCLs at the compliance
point, neither the final rule nor the limited option would have imposed more stringent designs
or corrective action on these landfills.
Resource Damage
Resource Damage in the RIA
In the RIA, baseline resource damage at landfills ranged from $0 to more than $4
million. (All results were expressed as present values.) The RIA reported that 71 percent of
landfills had resource damage, with only 31 percent of landfills having resource damage
exceeding $200,000. About 13 percent of landfills had resource damage in excess of $1
million. The total resource damage for both use and option value, summing across 6,034
landfills, was about $2.6 billion. The results presented in the RIA indicated that all
regulatory options reduced resource damage from baseline levels (a reduction of $1.7 billion
'Comparing the revised baseline risks with and without regionalization shows that the risk
distribution actually shifts towards the higher risk range with regionalization. This is because
the larger landfills comprise a larger portion of the universe under the regionalization
scenario. Because regionalization results in far fewer landfills, however, the number of
people exposed is lower and therefore the number of cancer cases is lower.

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V -4
or 67 percent for the final rule; and a reduction of $970 million or 38 percent for the limited
approach).
Revised Resource Damage
Because of the assumptions adopted since the RIA was completed (i.e., compliance
with state credits, regionalized universe of 3,000 landfills), estimated resource damage in the
baseline decreases from the $2.6 billion reported in the RIA to $560 million.
Table V-2 summarizes the new results for the baseline, final rule, and limited option
for the regionalized universe of 3,000 landfills. Total resource damage decreases to $290
million under the final rule. The resource damage avoided under the final rule is now $270
million (48 percent reduction from the baseline). Total resource damage decreases to $440
million for die limited option. The resource damage avoided under the limited approach is
now $120 million (22 percent reduction).

Table v-2


Revised Resource Damage Reduction
With State Requirements and Reglonallzatlon
(3,000 MSWLFs; Present Value)

Regulatory Scenario
Tout Resource Resource Damage
Damage Avoided Pqi
"centag^D^Qrease
Baseline
$560
....
Final Rule
$290 $270
48 %
Limited Option
$440 $120
22 %
The revised results for the final rule show that 1.0 percent of landfills have resource
damage exceeding $1 million. About 87 percent of landfills have resource damages below
$200,000. The revised results for the limited option show that 3.3 percent of landfills have
resource damage exceeding $1 million. The share of landfills with resource damages below
$200,000 is 83 percent.

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V - 5
Analysis of Changes in Resource Damage Reduction from the RIA
As with risk, incorporating existing state regulations into the baseline results in a
significant decrease in total resource damage for both the baseline and regulatory options.
Again, this is because more landfills have more protective designs as a result of state
requirements, and landfills with more protective designs have lower resource damage.
Regionalization reduces total resource damage even further because there are fewer landfills.
The decrease in the effectiveness of the final rule and limited option rule can be
attributed to the effectiveness of state regulations in controlling baseline resource damage.
For landfills with the composite/synthetic design in the baseline, nothing more stringent is
required by the regulatory options, so there is no potential for additional resource damage
reduction. State regulations also reduce baseline resource damage very effectively for the
approximately 4 percent of landfills that trigger corrective action in the baseline.
As discussed in the methodology section, the reduction in effectiveness of the
regulatory options is in no way attributable to the new exemption for small landfills in dry
climates. Because in EPA's modeling these landfills never exceed MCLs at the compliance
point, neither the final rule nor the limited option would have imposed more stringent designs
or corrective action on these landfills.
Ground'Water Contamination
The RIA and addendum measure the impacts of ground-water contamination in terms
of human health risks and drinking water supply replacement costs. Both of these measures
depend largely on the presence of drinking water wells near the landfill. If there are no
downgradient drinking water wells, people are not exposed to ground-water contamination and
there is no current risk.
In Figure V-l, we compare the cumulative frequency of average baseline risk (for a
regionalized universe of 3,000 landfills in compliance with state requirements) (1) at the
assumed exposure well distribution, and (2) at a hypothetical well 10 meters from each
landfill. Figure V-l reveals that the well distance distribution has a profound effect on
baseline risk:
• While about 2.2 percent of landfills have risks exceeding 10"5 assuming the
actual well distribution, about 19.1 percent exceed this risk level at the IO-
meter well.
About 12.2 percent of landfills have risks higher than 10"6 assuming the actual
well distribution, compared to about 52.6 percent at the 10-meter well.

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V -6
Therefore, although only one out of eight landfills pose MEI risks greater than Iff6 at existing
wells, ground water near the waste management boundary is being contaminated at levels
high enough to pose risks greater than 10"6 at over half of all landfills.
The resource damage results also show a high frequency of occurrence of ground-
water contamination at landfills. The percentage of landfills with resource damage in the
baseline (assuming a regionalized universe of 3,000 landfills in compliance with state
requirements) is 62.6. This means that nearly two out of three landfills would be expected to
pollute ground water above drinking water MCLs, taste and odor thresholds, or 10"6 risk
levels.

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FIGURE V-1
CUMULATIVE FREQUENCY OF AVERAGE RISK IN BASELINE
3,000 LANDFILLS IN COMPLIANCE WITH STATE REQUIREMENTS
100
80

--- 10-Meter Well I

at All Landfills

	 Assumed Exposure

Well Distribution

at All Landfills
60
<
I
-J
40
20
0
1E
-10
1E-09
1E-08
1E-07
1E-06
1E-05
- —4-..
1E-04
1E-03
RISK

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VJ - i
VI. Additional Benefits
In addition to the risk and resource damage analyses, EPA believe there may be
several additional benefits which could accrue to the regulatory options. The Agency believes
all benefits, quantified and unquantified, should be considered when comparing various rule
options.
Increased Public Confidence
EPA believes that providing federal criteria which prevent ground-water contamination
above drinking water standards will increase public confidence in landfills. Furthermore,
EPA believes that with an increase in public confidence, local officials will find it somewhat
easier to site new landfills. This increased confidence will translate, for a portion of new
landfills, into fewer sites needing costly, detailed site evaluation, and therefore less time will
be necessary to complete the siting process. Through its reliance on protecting groundwater,
the final rule will provide these benefits. Hie benefits of expediting siting could translate into
a potential savings to local municipalities of up to $84 million per year.7 EPA does not
expect that the limited approach, which allows contamination to occur, will result in similar
benefits in this area.
Protection of Property Value
Property value studies of households located near waste sites indicate that property
values can be adversely affected when ground-water contamination is discovered.8 The
studies reviewed by EPA varied in methodology and complexity, types of factors studied, and
types of waste sites considered. However, the majority found property value reductions for
households located within three to four miles of the waste sties; the reductions ranged from
an average of $300 to $15,000 per household. The extent of property value loss depends on a
variety of factors including proximity to the site and initial property value. Further, it is
7 For an explanation of the methodology for the estimate, see June 14, 1991 draft letter
from Don Clay to James B. MacRae, Jr. This letter can be found in the docket to the final
criteria.
8 Ibid.

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VI - 2
difficult to separate the effect of ground-water contamination from other disamenities (e.g.
noise or appearance) when considering property value changes. While EPA has not
conducted a specific property value study regarding municipal landfills, EPA believes these
studies indicated that property value loss is a very real effect from landfill contamination of
groundwater.
The final rule will prevent ground water contamination. Thus, the potential benefits
(avoided property value loss) of the final rule could fall within this range of $300 to $15,000
per household near landfills which would otherwise contaminate groundwater above drinking
water standards. Because the limited option allows contamination to occur, significant
benefits in this area would not accrue to this option.
Existence and Bequest Values
Literature on natural resource economics also indicates that people place a value on
and are willing to pay for protecting resources even if they neither live near the resources nor
plan to use them in their lifetime. This value is motivated by several beliefs, including the
conservation ethic, and is reflected in public support for programs to protect groundwater,
despite water replacement alternatives. This value is often referred to as existence value. In
addition, the literature describes a second value people place on knowing they are passing
pristine resources onto future generations, often referred to as a "bequest value."
EPA has not traditionally quantified these benefits in RIAs for past RCRA regulations.
However, existence and bequest values are receiving increasing attention within the economic
community. EPA believes that the existence value and bequest value benefits under the final
rule (which protects ground-water resources) may be substantial. The limited approach will
accrue these benefits only to the extent that corrective action is conducted upon discovery of
contamination, and is successful at returning a contaminated aquifer to drinking water
standards.
Encouraging Responsible Waste Management Practices
Improved waste management practices may also result from the revised criteria. First,
there is concern about minimizing intergenerational inequities - reducing the need for future
generations to pay for costly cleanup of closed landfills (i.e., ensuring that today's generations
pay for today's waste disposal). Second, there is an increasing emphasis on alternative waste
management practices such as resource conservation through source reduction and recycling.
EPA believes that the final rule, through its recognition of the true cost of safe waste
disposal, will reduce financial burdens on future generations and encourage source reduction
and recycling.

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MIT-I
VII. Net Benefits
This chapter compares estimated costs and benefits for a hypothetical set of new
landfills as described in Chapter X of the RIA. This comparison also illustrates the difficulty
of interpreting these estimates because only some of the benefits are quantifiable.
Summary of Benefits
Benefits that were quantified are described in Chapter V and include risk reduction
and resource damage reduction; the unquantified benefits described in Chapter VI include
increased public confidence, protection of property value, existence and bequest values, and
encouragement of resposible waste management practices. A summary of these benefit
estimates is shown in Table VII-1:
Table VI 1-1

Summary of Benefits
With State Requirements and Reglonallzatlon

(3,000 MSWLFs)

\-;n	 y ¦">& - y ^ is ¦';/ ' 	
Resource Damage
Risk Reduction {Present value
Regulatory Scenario (Cases Avoided) Avoided}
ijther Benefits
{eeeC^ajtterVQ
Final Rule 2.4 $270 million
?
Limited Option 2.4 $120 million
?
Assuming a universe of 3,000 landfills in compliance with state requirements, the number of
cancer cases avoided from the baseline for both the final rule and limited option rule is the
same, about 2.4 cases avoided over 300 years. The revised resource damage avoided under
the final rule is now $270 million, and under the limited option rule, the resource damage
avoided is $120 million. As described in the RIA, these quantified benefit estimates are not
additive; they are alternative measures of benefits that focus on different effects. Finally, the

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vn - 2
unquantified benefits should be added to either human health risk or resource damage benefits
to compute total benefits.
Net Benefits
Human Health Risk
Table VII-2 presents the incremental number of cases avoided (cases under the
baseline minus cases under the final rule and limited option rule) and the incremental present
value cost for each of the regulatory options for one set of new landfills. The incremental
present value cost estimates include state requirements, regionalization, and the small
community exemption.
Table VII-2
Comparison of Costs and Cases Avoided
(One Set of New Landfills; 300-Year Period)
fttek Reduction increments! Cost
Begmatary scenario (Cases Avowed) (Present vatue)
Final Rule	2.4	$5,770 million
Limited Option	2.4	$2,670 million

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VII- 3
Resource Damage
Table VII-3 compares the quantified benefits using resource damage with the costs for
the two regulatory options. The calculation of resource damage reduction reflects one set of
new landfills as does the cost; the incremental present value cost estimates include state
requirements, regionalization, and the small community exemption.

Table VII-3

Comparison of Costs and Resource Damage Avoided
(One Set of New Landfills; 300-Year Period)
Regulatory Scenario
Resource Damage
Reduction
(Present Value)
incremental Cost
{Present Value) : •
Final Rule
$270 million
$5,770 million
Limited Option
$120 million
$2,670 million

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50272-10}
REPORT DOCUMENTATION ! 1. REPORT NO.
PAGE I EPA/530-SW-91-073B i
1 ;
I (

4. Title and Subtitle
ADDENDUM TO THE REGULATORY IMPACT ANALYSIS FOR THE FINAL CRITERIA FOR
MUNICIPAL SOLID WASTE LANDFILLS
5. Report Date
SEPTEMBER 1991
6.
7. Author is;
S. RASIKJSSEN/CABD/OSW
9. F'erforaing Organization Rept. No
9. Performing Organization Name and Address
U.S. EPA
Office of Solid Waste
401 fi. Street SW
Waslunqton, EC 20460
10. Pro.ject/Task/Worfc Unit No.
11. Contract(C) or Brant(S) No.
(0
•6)
12. Sponsoring Organization Name and Address
13. Type of Report & Period Covered
14,
15. Supplementary Notes

16. Abstract (Limit: 200 words}
This analysis represents CPA's best efforts to quantify the costs, economic imapacts and benefits (health risk and
resource damage) of the regulatory options. It should be noted, however, that as in any analysis, the results are
necessarily based upon incomplete data and on simplified assumptions. A discussion of limitations of the analyses is
included in the RIA.
17. Docunent Analysis a. Descriptors
b. Identifiers/Qpen-Ended Terms
c. C03ATI Field/Group
18. Availability Statement
j 19. Security Class (This Report)
2!. No. of Paqes
I UNCLASSIFIED

RELEASE UNLIMITED
j 20. Security Class (This Page)
22. Price

1 UNCLASSIFIED

(See ANSI-Z39.18)
OPT
ONAL FORM 272 <4-77)
(Formerly NTIS-35)

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