p.1 

OAR Box 1875 

Prepped by Ollie Stewart 

Document Number: 

62) ll-F-9 

Docket Number: 

A-90-19 

Printed 12/1/200811:12:48 AM Sheet 62 of 86 
P.2 

A-90-19 

ll-F-9 

Attached are materials distributed by the EPA at a meeting 

with OMB on August 13, 1992. Below is a list of attendees. 

EPA 

Allen Basala 

Bruce Jordan 

Jan Meyer 

Andrew Otis 

Allyson Siwik 

Tom Walton 

Lydia Wegman 

Mike Winer 

OMB 

Steve Aitken 

Rick Belzer 

Troy Hillier 

Tim Hunt 

Shantale Wong 

h\ ncr, \\ \99Z d.-
P.3 

t 

i 

Hazardous Organic NESHAP (HON) 

The Control Decisions 

August 13, 1992 
P.4 

Key Considerations 

• Decision criteria for selecting level beyond the r for 

MACT standards: 

technical feasibility 

nonair quality health and environmental im .acts 

cost 

energy impacts 

• Statutory goal to achieve maximum degree of emission 

reduction considering statutory criteria 

• Consistency with past NSPS for same emission points 

in the category is desirable for sources and 

implementing authorities 

Overall Rationale for Decisions 

• Controls are demonstrated and reasonable 

• C/E in range of CAA cost estimates and consistent with 

previous benefits analyses 

• Cost estimates are overstated 

assume 1 control device for each emission point 

assume the most expensive means of compliance 

rule is structured to encourage pollution 

prevention, but these cost savings are not included 

• Costs are a small fraction of production costs 

• HON facilities are high risk point sources and are 

located in populated areas 
P.5 

Process Vents 

Largest contributor to overall emissions 

TRE format allows lower cost compliance through 

product recovery and process changes 

Also get significant control of VOC's 

NSPS decisions have marginal C/E of $3,090/Mg in 

1990$ 

Existing Sources 

Option 

1 

2 

3 

Emission 

Reduc 

Mg/yr 

HAP 

228,190 

233,556 

236,177 

Percent 

HAP 

Reduc 

91 

93 

94 

Annual 

Cost, 

$1000 

per yr 

57,114 

65,939 

73,880 

Average 

$/Mg 

250 

282 

313 

Incre. 

$/Mg 

HAP 

1,640 

3,030 , 

Baseline emissions: 250,664 Mg/yr HAP 

Floor element is Option 1. 

Option 1 control vents with TRE c/e of <$1500/Mg. 

Option 2 control vents with TRE c/e of <$2000/Mg. 

Option 3 control vents with TRE c/e of <$5000/Mg. 
P.6 

Wastewater 

• Major contributor to overall emissions 

• Important cross-media benefits from control at source 

less groundwater contamination 

reduction in volume of hazardous waste 

• Costs do not include savings from pollution prevention 

• Significant co-control of VOC's 

Option 

1 

2 

Baseline en 

Emission 

Reduc 

Mg 

HAP/yr 

112,810 

127,000 

lissions: 14 

Existing Sources 

Percent 

HAP 

Reduc 

77 

87 

•5,585 Mg/ 

Annual 

Cost, 

$1000 

per yr 

30,800 

80,400 

Average 

$/Mg 

HAP 

275 

635 

yr HAP & 529,920 Mc 

Incre. 

$/Mg 

HAP 

3,500 

l/yr VOC 

Floor element is no control. 

Option 1 - control streams >10 Ipm and >1000 ppmw HAP. 

Option 2 - control streams > 1 Ipm and > 500 ppmw VHAP. 

New Sources 

Option 

1 

2 

3 

Baseline en 

Emission 

Reduct 

Mg 

HAP/yr 

17,790 

24,170 

24,270 

lissions: 27 

Percent 

HAP 

Reduct 

64 

87 

88 

,660 Mq/y 

Annual 

Cost, 

$1000 

per yr 

6,400 

16,500 

17,200 

rHAP & 10 

Average 

$/Mg 

360 

685 

710 

0,685 Mg/ 

Incre. 

$/Mg 

1,595 

6,990 

yr VOC 

Floor element is Option 1 
P.7 

Large Storage 

• C/E of $2500/Mg is reasonable and consistent with 

NSPS decisions C/E 

• Control of large tanks saves product 

Existing Sources: 40,000 gallon capacity and greater 

Option 

1 

2 

3 

Emission 

Reduct 

Mg 

HAP/yr 

1,700 

4,776 

8,629 

Percent 

HAP 

Reduct 

17 

48 

86.6 

Annual 

Cost 

$1000 

per yr 

4,057 

7,290a 

17,068 

Average 

$/Mg 

HAP 

2,390 

1,526 

1,978 

Incre. 

$/Mg 

HAP 

1,051 

2,538 

Saseline emissions: 9964 Mg/yr HAP 

Floor element is Option 1. 

Option 1 - control tanks storing HAP's with vp > 1.9 psia. 

Option 2 - control tanks storing HAP's with vp >0.75 psia. 

Option 3 - control tanks storing HAP's with vp >0.1 psia. 

New Sources: 

Option 

1 

2 

Emission 

Reduct 

Mg 

HAP/yr 

558 

1,640 

40,000 gallon capacity and greater 

Percent 

HAP 

Reduct 

29 

87 

Annual 

Cost 

$1000 

per yr 

1,760 

2,555 

Average 

$/Mg 

HAP 

3,155 

1,5588 

Incre. 

$/Mg 

HAP 

734 

Cost decrease due to credits from controlling large tanks with vp 

between 0.75 and 0.1 psia. 

Baseline emissions: 1893 Mg/yr HAP 

Floor element is Option 1. 
P.8 

Attachment 3 

EXTENDED BENEFIT ANALYSIS 

for the 

HAZARDOUS ORGANIC NESHAP (HON) 

BRIEFING TO OMB 

AUGUST 13, 1992 
P.9 

OUTLINE 

Potential Scope (Emission Points and Effects 

Categories) 

Sample (Emission Points and Effects Categories) 

Methodology 

Results 

Conclusions and Qualifications 

? 
P.10 

POTENTIAL SCOPE 

Emission Points: Turn to Histogram on Page 4 

Effects Categories: Turn to Table on Page 5 
® 

TOTAL HON EMISSIONS 

By Emission Point 

Total HON Emissions (Mg/yr) 

300,000 

250,000 

200,000 

150,000 

100,000 

50,000 

0 

ST W W EL PV 

Emission Point 

TR 
P.12 

POTENTIAL PHYSICAL EFFECTS CATEGORIES FOR 

THE HON REGULATION 

Human Health Effects 

Mortality Due to Chronic Exposure 

Mortality Due to Acute Exposure 

Morbidity Due to Chronic Exposure 

Morbidity Due to Acute Exposure 

Reduced Activity Days 

Human Welfare Effects 

Worker Productivity Losses 

Odors 

Non-Human Bioloqical Effects 

Agriculture 

Forestry 

Recreational Fishing 

Ecosystem 

Soilinq & Materials Damaqe 

Residential/Commercial/Industrial 

Facilities ,* 

Miscellaneous Materials 

Climate & Visibility "Effects 

Local Visibility 

Non-Local Visibility 

Climate 

Visibility at Parks 

Transportation Safety 

Direct 

HAP 

1* 

1 

1 

1 

3 

3 

1 

2 

2 

2 

1 

2 

2 

NA 

NA 

3 

NA 

NA 

VOC/ 

Ozone 

3 

2 

2 

1 

1 

1 

2 

1 

2 

3 

3 

1 

1 

NA 

NA 

2 

NA 

NA 

PM 

2 

2 

1 

1 

2 

2 

3 

2 

2 

2 

2 

1 

1 

2 

.2 

2 

2 

2 

Legend: 

1 - Documented effect. 

2 - Effect likely, minimal documentation. 

3 - Effect possible, not documented. 

NA - not applicable. 

* - quantified for the HON Benefit Analysis Extension 

b 
SAMPLE 

(Emission Points and Effects Categories) 

Selected Subset of Process Vent and Wastewater 

Emission Points-With Known UTM Coordinates: 

Process Vents 

28 % of HAP Emissions 

36 % of Total Cost 

24 % of All Facilities 

Wastewater 

20 % of HAP Emissions 

29 % of Total Cost 

14 % of All Facilities 

Effects Categories 

Air Toxics Mortality 
P.14 

METHODOLOGY 

Exposure Assessment 

Mortality Risk Assessment 

Risk Reduction Valuation 

7 
METHODOLOGY: EXPOSURE ASSESSMENT 

(Concentrations To Which People Are Exposed) 

Regulatory Options Modeled Include: 

Process Vent & Wastewater Options Selected 

for Proposal 

A Less Stringent Option: 

Process Vents: MACT Floor 

Wastewater: Intermediate Option Above 

Baseline 

Dispersion Modeling to Predict HAP Soup 

Concentrations 

Local Meteorological Data for Modeled 

Facilities -

50 km Radius of Facility's UTM Coordinates 

Estimated Population Exposed to Predicted HAP 

Soup Concentrations 

Receptor Points Within the 50 km Radius 

1980 Population Data at Block 

Group/Enumeration District Level 

8 
P.16 

METHODOLOGY: RISK ASSESSMENT 

(Predicted Incidences of Cancer) 

Developed Proxy for Aggregate Inhalation Unit 

(IUR) Risk Factor for HAP Soup 

80 HAPs Produced by Process Vents and 

Wastewater Emission Points* 

CRAVE verified IUR Factors Available for 13 

of the 80 HAPs** 

Using verified IURs, calculated mean IUR = 

2.4 x IO"4 per jiig/m3*** 

Other HAPs are emitted from process vent and wastewater emission points but 

are not the products that are being manufactured. 

Other HAPs have IURs. but are not yet CRAVE verified. 

'* Emission Weighted Mean: 3.8 x 10"* per jxg/m3 

Production Weighted Mean: 2.3 x \0^ per Mg/m3 
METHODOLOGY: RISK ASSESSMENT 

(Predicted Incidences of Cancer) 

(Continued) 

Estimated Cancer Incidence Reductions 

Combined exposure assessment results with 

mean inhalation unit risk factor for modeled 

process vent and wastewater facilities at 

baseline and the regulatory options 

Aggregated predicted number of incidences 

across facilities for each modeled regulatory 

option and baseline 

Subtracted predicted incidences for each 

modeled regulatory option from baseline to 

yield incidence reductions 

10 
P.18 

METHODOLOGY: RISK VALUATION 

Air Toxics Mortality 

$1.7 to $9.4 million per statistical life saved 

(incidence reduced); 1989 $'s 

Implicit Valuation for Proposed Wastewater 

Option* 

Beyond what $ per megagram number would 

the non-HAP VOC benefits have to be for the 

proposed option to maximize net benefits 

Calculate incremental cost net of incremental 

incidence reduction credit between the less 

stringent and proposed options 

Estimate incremental non-HAP VOC emission 

reductions between the less stringent and 

proposed options 

Divide incremental cost net of incidence 

reduction credit by the incremental non-HAP 

VOC emission reductions 

Implicit valuation for process vents not warranted. To be discussed in the 

results section. 

11 
P.19 

RESULTS: INCIDENCE REDUCTIONS * 

Emission Point 

Process Vents 

Wastewater 

Reductions 

for Less 

Stringent Option 

275.8 

69.6 

Reductions 

for 

Proposed Option 

276.5 

73.2 

Incidence reduction estimates are carried out to several digits to reveal the calculated 

differences between options. The number of digits is not an indicator of the precision 

of the estimates. 

12 
P.20 

RESULTS: MORTALITY RISK REDUCTION BENEFITS 

VERSUS CONTROL COST 

Emission Point 

PROCESS VENTS 

Less Stringent 

Proposed Option 

WASTEWATER 

Less Stringent 

Proposed Option 

1 ly 

Incremental 

Cost/Life 

(Millions)* 

$.08 

$1.9 

$.46 

$14 

Net Benefits 

(Millions)** 

$447.5 

to 

$2,570 

$447.4 

to 

$2,580 

$ 86 

to 

$623 

$ 43 

to 

$607 

** 

Benefit/Cost 

21 

to 

117 

20 

to 

111 

4 

to 

20 

2 

to 

8 

** 

For the sample facilities, incremental control cost for the 

option divided by the estimated incremental incidence 

reduction 

The ranges result from the valuation of incidence reductions 

($1.7 to $9.4 million/statistical life saved). The 

calculations are carried out to many digits to clarify how 

small the differences are between some options. The number 

of digits is not an indicator of measurement precision. 

13 
P.21 

RESULTS: IMPLICIT VALUATION FOR 

PROPOSED WASTEWATER OPTION 

Proposed Wastewater Option is Preferred to the 

Less Stringent Option if: 

Mortality risk reduction credit is $1.7 Million 

per reduced incidence and the non-HAP VOC 

emission reduction credit is greater than $1140 

per megagram. 

Mortality risk reduction credit is $9.4 Million 

per reduced incidence and the non-HAP VOC 

emission reduction credit is greater than $410 

per megagram. 

14 
CONCLUSIONS AND QUALIFICATIONS 

Given Data Inputs and Analytical Procedures 

Conclusion Applicable to Both Process Vent and 

Wastewater Emission Points 

All considered options represent economic 

efficiency gains relative to baseline control 

levels 

Process Vent Conclusions 

The proposed option for process vents cannot 

be discarded on economic efficiency grounds 

The difference in calculated net benefits 

between the proposed and less stringent 

options is too close to call 

— -Because proposed option generates more 

opportunities to duct multiple vents to a 

single control device, costs are expected to 

be less than estimated 

Wastewater Conclusions 

The proposed option for wastewater emission 

points cannot be discarded on economic 

efficiency grounds 

Benefit coverage is incomplete 

15 
CONCLUSIONS AND QUALIFICATIONS 

(Continued) 

— Implicit valuation numbers for non-HAP 

VOC emission reductions are plausible, 

e.g.: 

— Over 60% of emission reductions for 

wastewater emission points occur in 

ozone non-attainment areas. 

— CEA estimates marginal cost of 

control in such areas at between $2000 

and $10,000 per megagram of VOC 

reduced 

Qualifications of the Analysis 

Lack-of specific HAP emission information for 

each emission point 

Incomplete coverage of emission points and 

facilities 

Incomplete coverage of the benefits 

Uncertain dispersion modeling as well as risk 

assessment and valuation 

16