MEMORANDUM

TO: Toni Jones , U.S. Environmental Protection Agency

FROM: Eastern Research Group , Inc.

DATE: November 30 , 2012

SUBJECT: Revised Economic Impact Analysis Inputs for Existing CISWI Units

B ACKGROUND

The U.S. Environmental Protecti on Agency (EPA), under section 129 of the Clean Air Act (CAA), is required to regulate emissions of nine pollutants from Commercial and Industrial Solid Waste
Incineration ( CISWI ) units : hydrogen chloride (HCl), carbon monoxide (CO), lead (Pb), cadmium (Cd ), m ercury (Hg), particulate matter (PM), dioxins/furans ( P CDD/ P CDF), nitrogen oxides (NO

x ), and sulfur dioxide (SO 2 ).

On December 1, 2000, EPA adopted new source performance standards and emission guidelines for
commercial and industrial solid waste inc ineration units established under Sections 111 and 129 of
the Clean Air Act. In 2001 EPA was granted a petition for reconsideration regarding the definitions
of "commercial and industrial waste" and "commercial and industrial solid waste incineration unit ." In 2001, the United States Court of Appeals for the District of Columbia Circuit granted EPA’s voluntary remand, without vacatur, of the 2000 rule. In 2005, EPA proposed and finalized the
commercial and industrial solid waste incineration definition r ule which revised the definition of “solid waste,” "commercial and industrial waste," and "commercial and industrial waste incineration unit." In 2007, the United States Court of Appeals for the District of Columbia Circuit vacated and
remanded the 2005 c ommercial and industrial solid waste incineration definition rule.

On March 21, 2011, the EPA promulgated revised NSPS and EG as its response to the voluntary remand that was granted in 2001 and the vacatur and remand of the commercial and industrial sol id waste incineration definition rule in 2007. In addition, the standards re

- development included the 5

- year technology review of the new source performance standards and emission guidelines required
under Section 129. Following that action, the Administ rator received petition s for reconsideration and identified some issues that warranted further opportunity for public comment. In addition, data were received that enabled the EPA to revise the CISWI inventory of waste

- burning kilns and energy

recovery un its to more accurately reflect the definition of non

- hazardous secondary materials. On December 23, 2011 the EPA published proposed amendments that incorporated these changes and allowed public comment on specific issues identified for reconsideration. T he EPA has developed a series of maximum achievable control technology (MACT) floor options to su pport that re

development. The development of the MACT floors used to determine these options is discussed in
more detail in a separate memorandum

. 1 The purp ose of this memorandum is to present the
information required for an economic impact analysis for existing sources

.

E CONOMIC I NPUTS

EPA’s solid waste definition rule define s which non

- hazardous secondary materials that are used as fuels or ingredients in combustion units are solid wastes under Subtitle D of RCRA. Table 1 s howseconomic inputs for the 7 6 facilities with existing CISWI units that we anticipate will still be in operation as of the rule’s implementation.

Facility information comes primarily from responses to the Phase 1 survey 2 , and has been provided by the actual respondent. This includes the small/large entity classification.

In a few cases, incomplete responses to the survey resulted in data gaps. Many of these were filled in by review ing the corporate entities ’ website or business data websites for general number of employees or annual sales information. Then, by comparing this data to the U.S. Small Business Administration’s ( SBA ) small business definitions, determin ations were made on whether the corporation is a small or large entity.

Annual sales data were obtained through online resources, mainly through business information websites and corporate U.S. Securities and Exchange Commission report data. The URL s for the
sales data are listed in the spreadsheet. In a few cases, facility specific sales data were unavailable. In these instances, a subcategory average value was used. If this average exceeded corporate sales, then the corporate sales value was assumed for the facilit y.

Compliance costs associated with compliance with the final emission limits are presented in the MACT Compliance TCI ( total capital investment ) and MACT Compliance TAC ( total annual costs ),
and are the results of control and monitoring cost calculations presented in the cost analysis. 1 Note that costs are annualized at a 7% interest rate. For subcategories of units that may have the option of disposing of waste in a landfill or municipal waste combustor, the cost of hauling and tipping fees
have been s ummed up and presented for the facilities that this may apply to. The lowest cost
alternative (i.e., compliance or alternative to combustion) is presented in the Lowest Cost columns.



### R EFERENCES

1. “ Final Reconsideration Compliance Cost Analyses for CIS WI Units” Memorandum from Eastern

Researc h Group, Inc. to Toni Jones , U.S. Environmental Protection Agency . November 26 , 201 2

.

2. Questionnaire for Boilers, Process Heaters, Incinerators and Other Combustion Units: Survey

Overview . OMB Control No. 2060

- 0 616, http://survey.erg.com/ss/wsb.dll/s/7g8d