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MEMORANDUM

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

FROM: Eastern Research Group, Inc.

DATE: November 20, 2011

SUBJECT: Reconsideration Proposal Compliance Cost Analyses for CISWI Units 

BACKGROUND

The U.S. Environmental Protection Agency, 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), mercury (Hg), 

particulate matter (PM), dioxins/furans (PCDD/PCDF), nitrogen oxides (NOx), and sulfur dioxide (SO2). 

On December 1, 2000, the EPA adopted new source performance standards (NSPS) and emission 

guidelines (EG) for CISWI units under Sections 111 and 129 of the Clean Air Act. In 2001 the EPA 

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 the EPA’s voluntary remand, without vacatur, of the 2000 rule. 

In 2005, the EPA proposed and finalized the commercial and industrial solid waste incineration definition 

rule which, among other things, revised the definitions of "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 commercial 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 solid 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 Administrator 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 

units to more accurately reflect the definition of non-hazardous secondary materials. The development of 

the MACT floors used to determine these options is discussed in more detail in a separate memorandum.1 

The purpose of this memorandum is to present for existing sources the nationwide costs and nationwide 

cost effectiveness associated with compliance with the proposed standards and alternatives to compliance. 

This memo is organized as follows:

I. Choosing Controls Needed for Each Unit to Meet MACT Floors

II. MACT Compliance Costs

A. Emission Control Costs

B. Stack Testing, Monitoring, and Recordkeeping Costs

1. Stack Testing

2. Monitoring Requirements

3. Recordkeeping and Reporting

C. Alternative Disposal Costs
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III. Cost Effectiveness 

IV. New Units

V. References

I. CHOOSING CONTROLS NEEDED FOR EACH UNIT TO MEET MACT FLOORS

A significant portion of the total cost for industry compliance comes from the cost of installing new or 

improving existing pollution control devices for units not currently meeting the proposed limits. In order 

to determine the control costs, it was necessary to evaluate, for each CISWI unit, how much improvement 

for each pollutant would be needed to meet the proposed emissions limits. 

In order to determine how much improvement would be needed for each unit, the maximum test average 

(i.e., the highest emission concentration) for each pollutant was determined for units having test data. 

This is assumed to be the basis that sources would base their control strategy on to ensure compliance 

with the standards. This is different from the overall pollutant average used to calculate baseline annual 

emissions2so that baseline emissions are not overestimated and more truly reflect the average 

performance of the unit. Similar to the gap-filling methodology for the baseline emissions calculations, 

data gaps were filled first by using the same measured data from similar units operated by the corporate 

entity. If these data were not available, then subcategory default values were assigned for the unit. These 

default values were the mean of all known units’ maximum emissions test averages within each 

subcategory. Once every unit was assigned with a value, these values were compared with the MACT 

floor emissions limits, and percentages were calculated to quantify the amount of improvement needed 

for the unit to meet the MACT floors. Tables 1A – 1E contain the baseline pollutant concentration values 

used for each unit in each subcategory and the percentage improvement required to meet the emissions 

limits for each unit for each pollutant. The existing CISWI units are subcategorized into five main 

groups: energy recovery units (ERUs) designed to burn liquid or gas, ERUs designed to burn solids 

materials, incinerators, waste-burning kilns, and small, remote units. The pollutant- and subcategoryspecific limits are shown in each header row of these tables. Note that in the solids-burning ERU 

subcategory, separate limits for coal-burning units and biomass-burning units were determined for carbon 

monoxide, lead, cadmium, filterable particulate matter, dioxin/furans, nitrogen oxides, and sulfur 

dioxides. In the waste-burning kilns category, separate limits for long kilns and preheater/preheaterprecalciner kilns were determined for carbon monoxide.

As discussed at proposal in 2010, control methods and cost algorithms utilized in a recent rulemaking for 

another waste combustion source category, Hospital, Medical and Infectious Waste Incinerators (HMIWI) 

were updated and utilized generally for the CISWI source category, since most of these algorithms are 

applicable to waste combustion units found in the CISWI source category. Since the 2010 proposal, there 

were two additional control technologies considered for use on CISWI units, duct sorbent injection 

followed by fabric filter (DIFF) and regenerative thermal oxidizers (RTO). Based on these required 

improvements, pollutant-specific control methods were chosen as follows for units unable to meet the 

MACT floors:

Metals (cadmium and lead) and PM: Adding fabric filters or improving existing fabric filters.

Mercury and dioxins/furans (PCDD/PCDF): Adding activated carbon injection (ACI) and adjusting the 

carbon addition rate to meet the amount of reduction required. Where ACI is required, a fabric filter 

would also need to be installed if the unit does not already have a fabric filter in place.

Hydrogen chloride (HCl): Adding wet scrubbers, or improving already installed wet scrubbers. For 

energy recovery units with average stack gas flow rates greater than 75,000 actual cubic feet per minute 

(acfm), a duct sorbent injection/fabric filter (DIFF) combination was prescribed instead of a wet scrubber 

as commenters argued that larger units would likely use this technology rather than a wet scrubber.
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Carbon monoxide (CO): For incinerators and small remote units, an afterburner retrofit was the 

prescribed technology for CO control. For waste-burning kilns, the assumed control technology for CO 

control was addition of a regenerative thermal oxidizer (RTO). For energy recovery units, the control 

prescribed depended on the maximum CO test average of the unit. For liquid/gas-burning units, a tune-up 

was assigned for units under 36 ppmvd, advanced combustion controls (linkageless boiler management 

system) for units in the 36 to 96 ppmvd range, and a CO oxidation catalyst for units over 96 ppmvd. For 

biomass-burning units, a tune-up was assigned for units under 735 ppmvd, advanced combustion controls 

(linkageless boiler management system) for units in the 735 to 1,960 ppmvd range, and a CO oxidation 

catalyst for units over 1,960 ppmvd. For coal-burning units, a tune-up was assigned for units under 69 

ppmvd, advanced combustion controls (linkageless boiler management system) for units in the 69 to 184 

ppmvd range, and a CO oxidation catalyst for units over 184 ppmvd. 

Nitrogen oxides (NOx): Adding selective non-catalytic reduction (SNCR) systems. 

Sulfur dioxide (SO2): Adding wet scrubbers, or improving already installed wet scrubbers. For energy 

recovery units with average stack gas flow rates greater than 75,000 actual cubic feet per minute (acfm), a 

duct sorbent injection/fabric filter (DIFF) combination was prescribed. For energy recovery units adding 

DIFF and requiring greater than 70 percent improvement, a wet scrubber in addition to DIFF was 

prescribed, unless the unit already has a wet scrubber, in which case the addition of caustic to the existing 

scrubber was prescribed. If an energy recovery unit already having DIFF or SDA/FF installed cannot 

meet the limit, adding a wet scrubber as a polishing scrubber was assumed to be sufficient to meet the 

limit.

Further descriptions of these controls and their associated costs are listed below in Section II.

II. MACT COMPLIANCE COSTS

This section presents the nationwide costs estimated for existing CISWI for (A) the emission controls 

used to comply with the MACT floor; (B) the monitoring, testing, recordkeeping, and reporting activities 

used to demonstrate compliance; and (C) the alternatives to compliance. Total capital cost for all existing 

CISWI units to meet the MACT floor emission limits is estimated at approximately $921 million. Total 

annual cost for compliance for all units in all subcategories is about $285 million, but is about $270 

million for the lowest cost alternative. As presented above, the existing CISWI units are subcategorized 

into five main groups: liquid/gas-burning ERUs, solids-burning ERUs, incinerators, waste-burning kilns, 

and small, remote units. Tables 2A-2E present costs for emission controls, stack testing, monitoring, and 

reporting and recordkeeping for each unit within each subcategory, as well as costs for alternatives to 

compliance where applicable. Table 3 summarizes total compliance costs, as well as the lowest cost 

alternative (where alternative disposal methods are possible) for all units. 

A. Emission Control Costs

Emission control technologies and other control measures that can be used to comply with the MACT 

floor options for existing CISWI units include wet scrubbers, fabric filters, selective non-catalytic 

reduction (SNCR), activated carbon injection (ACI), duct sorbent injection followed by fabric filter 

(DIFF), regenerative thermal oxidizers (RTO), oxidation catalysts and various other control measures 

designed to obtain incremental emission reductions. This section presents the costs that were estimated 

for each of these control measures.

The retrofit factors for the capital costs were assumed to be 40 percent for wet scrubbers, fabric filters, 

and 20 percent for SNCR and ACI.3, 4 Downtime costs for the retrofits were assumed to be negligible. 

Most CISWI are expected to be outdoors with adequate space to install an emission control system 
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without shutting down the incinerator for an extended period. Commenters have suggested that additional 

footprint required for controls for small remote incineration units in certain parts of Alaska may be costly 

to construct and permit. However, no data were provided that would assist in developing any cost 

adjustment factors to estimate additional footprint costs. It was also expected that connecting the 

ductwork could be performed during a scheduled downtime for maintenance, thereby minimizing 

expected downtime.5

The capital and annual costs for the emission controls were estimated in units of dollars ($) and

$/flow. The $/flow costs were calculated by dividing the capital/annual control cost estimate for each unit 

by the average gas flow rate assigned to that unit. Table 4A is a summary of the parameters used for each 

unit (e.g., incinerator charge rate, stack gas flow rate, incinerator operating hours, and concentrations). 

Additional information on the calculation of flue gas flow rates specifically for energy recovery units and 

waste-burning kilns can be found in Tables 4B and 4C.

Total capital cost for controls for all subcategories is estimated at approximately $921 million, and total 

annual cost for controls for all subcategories is about $285 million. Costs are on a 2008 basis, and 

annualized costs assumed an interest rate of 7 percent. Tables 5A-5J present a summary of the parameters 

and equations used in the cost algorithms for each emission control device.

1. Adding a fabric filter.

Fabric filters can be installed either alone or with other add-on controls. The cost algorithm for 

installing a fabric filter for waste-burning kilns, incinerators, and small remote incinerators is 

presented in Table 5A and is based on algorithms in the Model Plant Description and Control Cost 

Report for HMIWI.5 For energy recovery units, calculations were based on an algorithm originally 

utilized for HMIWI, but incorporating slight modifications to make them consistent with those being 

utilized by the boilers NEHSAP development to accommodate typically higher flue gas flow rates. 

Calculations specific to fabric filter installations for energy recovery units are presented in Table 5B. 

The fabric filter capital costs range from approximately $767,000 to $28.2 million, and annual costs 

range from approximately $136,000/yr to $6.1 million/yr. Sources for specific cost data are noted 

below Table 5A.

2. Adding a wet scrubber.

Wet scrubbers can be installed alone or after a dry scrubber/fabric filter. The cost algorithm for 

installing a packed-bed wet scrubber is presented in Table 5B and is based on algorithms in the Model 

Plant Description and Control Cost Report for HMIWI. The packed-bed wet scrubber capital costs 

range from approximately $282,000 to $9.6 million, and annual costs range from approximately 

$77,000/yr to $6.7 million/yr. Sources for specific cost data are noted below Table 5C.

3. Adding a selective non-catalytic reduction (SNCR) system.

In an SNCR system, a nitrogen-based reducing agent, or reagent, such as ammonia or urea, is injected 

into the post-combustion flue gas through nozzles mounted on the wall of the combustion unit. The 

cost algorithm for installing an SNCR system is presented in Table 5D and is based on algorithms in 

the OAQPS Control Cost Manual.

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 The SNCR capital costs range from approximately $48,000 to 

$3.4 million, and annual costs range from approximately $5,300/yr to $379,000/yr. Sources for 

specific cost data are noted below Table 5D.

4. Adding an activated carbon injection (ACI) system.
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Injecting activated carbon before the fabric filter has been demonstrated to improve the removal 

efficiency of both Hg and PCDD/PCDF from CISWI. The cost algorithm for installing an ACI 

system to incinerators, small-remote incinerators, and waste-burning kilns is presented in Table 5E 

and is based on algorithms in the Model Plant Description and Control Cost Report for HMIWI5. The 

cost algorithm for installing an ACI system to energy recovery units is presented in Table 5F and is 

based on algorithms in the IPM Model - Revisions to Cost and Performance for APC Technologies, 

Mercury Control Cost Development Methodology10. Adjustments to the carbon injection rate were 

made to account for how much reduction was required to meet the emission limit, and whether a 

packed-bed scrubber was either being added or would be improved, since scrubbers may also assist in 

reducing Hg emissions. The packed-bed scrubber adjustment is a ten percent Hg reduction, and is 

based on input from the boiler NESHAP development. The ACI factor compares the carbon grain 

loading originally assumed to achieve 90 percent control of mercury or 98 percent control of 

PCDD/PCDF to the amount of reduction the unit will need to meet the final emission limits. For the 

incinerator, small-remote incinerator, and waste-buring kiln subcategories, the highest factor (Hg or 

PCDD/PCDF) is then used to adjust the carbon injection rate calculation of the algorithm. For the 

energy recovery unit subcategories, the fuel-based fly ash waste rates are also included in the carbon 

injection rate calculation of the algorithm. However, the carbon injection rate is not a variable in this 

algorithm, so therefore was not adjusted based on the amount of reduction in Hg or PCDD/PCDF 

required to meet the emission limit. ACI capital costs range from approximately $4,700 to $160,000, 

and annual costs range from approximately $3,400/yr to $3.7 million/yr. Sources for specific cost 

data are noted below Table 5E and 5F.

5. Adding an afterburner/secondary chamber retrofit.

Afterburner, or secondary chamber, retrofits include retrofitting an incinerator with a larger secondary 

chamber (with a longer gas residence time, e.g., 2 seconds) and operating it at a higher temperature 

(e.g., 1800°F). The cost algorithm for installing an afterburner retrofit with an incinerator or small, 

remote unit is presented in Table 5G and is based on algorithms in the Model Plant Description and 

Control Cost Report for HMIWI.5 Afterburner capital costs range from approximately $77,000 to 

$451,000, and annual costs range from approximately $15,000/yr to $281,000/yr. Sources for 

specific cost data are noted below Table 5G.

6. Adding duct sorbent injection/fabric filter (DIFF).

Duct sorbent injection is a control technique for SO2 control where a sorbent such as limestone is 

injected into the duct upstream from the particulate matter control device. The flue gas stream may 

be humidified and cooled to get the gas stream to the desired reaction temperature. In this instance, 

we have assumed a fabric filter is the particulate matter control device. Calculations were based on 

an algorithm originally utilized for HMIWI, but incorporating slight modifications to make them 

consistent with those being utilized by the boilers NESHAP development. Commenters have argued 

that energy recovery units with flue gas flow rates over 75,000 acfm would use DIFF control rather 

than wet scrubbers for acid gas control. Therefore, this control has been assumed for SO2 control in 

these size energy recovery units. If the percent reductions exceed those expected from DIFF (70%), 

then a wet scrubber as a polishing step was also added to the control requirements for the unit, if no 

wet scrubber already existed for that unit. Calculations specific to DIFF installations for energy 

recovery units are presented in Table 5H. DIFF capital costs range from approximately $6.7 million 

to $33.4 million, and annual costs range from approximately $1.9 million/yr to $8.8 million/yr. 

Sources for specific cost data are noted below Table 5H.

7. Adding a regenerative thermal oxidizer (RTO).
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Carbon monoxide control for waste-burning kilns may be accomplished using a regenerative thermal 

oxidizer (RTO). In this device, flue gas is pre-heated over ceramic media prior to the combustion 

chamber where the carbon monoxide is oxidized to carbon dioxide. The flue gas then exits the 

combustion chamber and transfers heat to the ceramic media to help preheat the incoming flue gas. 

This heat transfer helps reduce the amount of fuel needed to maintain combustion chamber 

temperatures required for oxidization. The cost algorithm for installing an RTO with a waste-burning 

kiln is presented in Table 5I and is based on cost analyses conducted for the final amendments of the 

Portland Cement NESHAP. RTO capital costs range from approximately $6.0 million to $19.5 

million, and annual costs range from approximately $1.5 million/yr to $6.3 million/yr.

8. Incremental Controls.

In some instances, it may not be necessary to install a new control system to achieve the emissions 

reductions necessary to comply with the control options. An incremental reduction in emissions may 

be achievable by improving existing controls, such as increasing the amount of caustic used in the wet 

scrubber, increasing the flow of lime prior to the fabric filter, increasing wet scrubber horsepower, 

improving fabric filter performance, or increasing the amount of NOx reagent injected into the postcombustion flue gas. Table 5J presents the algorithms used to determine the annual cost of these 

incremental controls. There are no capital costs for incremental controls. Sources for specific cost 

data are noted below Table 5J.

a. Improving the performance of an existing fabric filter.

One strategy to reduce PM and metals emissions further is to improve the performance of the 

fabric filter by replacing the filter bags used to capture emitted particulate. Costs to improve 

fabric filter performance were estimated using the same equations for bag and cage replacement 

employed in costing fabric filters and range from $8,600/yr to $257,000/yr.

b. Increasing caustic.

One strategy to reduce acid gas emissions further is to increase the amount of caustic used in the 

wet scrubber to react with and neutralize the acid gases in the gas stream. The addition of caustic 

is assumed to sufficiently reduce emissions without requiring any changes to the wet scrubber. 

Costs to increase the amount of caustic were estimated using the same caustic equation employed 

in costing packed-bed wet scrubbers and range from approximately $350/yr to $430/yr.

9. Additional Control Options.

a. Adding advanced combustion controls.

The costs to add a linkageless boiler management system (LBMS) are based on a 2008 quote 

provided to the U.S. Department of Energy. The installed cost for a LBMS on a 20 mmBtu/hr 

unit was $19,127. The DOE noted that costs are relatively fixed, regardless of the size of the unit. 

Therefore, this cost was used as a fixed capital cost estimate for CISWI units required to add 

advanced combustion controls.

b. Adding a CO catalyst. 

Cost estimates for adding a CO oxidation catalyst were based on the Air Pollution Control Cost 

Manual.

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 Capital cost per unit ranges from $452,000 to $2.5 million, and annual costs range 

from $195,000/yr to $1.4 million/yr.
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c. Tune-up. 

Cost for performing a tune-up were based on a cost estimate provided in a report by Dr. H.M. 

Eckerlin and E.W. Soderberg9. This report indicated that the initial set-up for boiler tune-up was 

$3,000 to $7,000 per boiler, thereafter; annual tuning costs $1,000 per boiler. An average $5,000 

per boiler initial set-up costs was annualized over 5 years at a 7 percent rate, and added to the 

subsequent year tune-up costs. Subsequently, an estimated flat cost of $1,580 annually was 

applied for units requiring tune-ups.

B. Stack Testing, Monitoring, and Recordkeeping Costs

1. Monitoring Costs

Initial and continuous compliance provisions for CISWI units were selected to be as consistent as 

possible with comparable regulations. For energy recovery units, requirements were developed to be 

consistent with stack testing, monitoring, and recordkeeping requirements for major source boilers 

units adapted to reflect the CAA section 129 pollutants and provisions of section 129. For wasteburning cement kilns, monitoring requirements were based on the Portland Cement NESHAP and 

NSPS requirements for cement kilns and adapted to reflect the CAA section 129 pollutants. For the 

other three subcategories, requirements were as consistent as possible with current CISWI and 

HMIWI provisions. This section presents the costs that were estimated for each of these 

requirements.

The total capital cost for stack testing, monitoring, and recordkeeping and reporting for all 

subcategories is estimated at approximately $8.8 million, and the total annual cost is about $6.6 

million per year. Cost estimates were based on algorithms recently utilized in the HMIWI regulatory 

development. Costs were updated to a 2008 basis, and annualized costs assumed an interest rate of 7 

percent. Tables 6A-6E present a summary of the parameters and equations used in the cost 

algorithms for each monitoring component, where applicable.

a. Inspections. 

Consistent with HMIWI regulations, it was assumed that annual control device inspections will 

be required for any units having control devices in place or requiring further controls to meet the 

MACT floors. In this context, control devices include fabric filters, afterburners, wet scrubbers, 

ACI systems, SNCR systems, DIFF, RTO, or oxidation catalysts. The cost was estimated at a flat 

rate of $1000 per year. See Table 6A for further details and sources.

b. Parameter monitors.

Monitoring of operating parameters can be used to indicate whether air pollution control 

equipment and practices are functioning properly to minimize air pollution. Based on the existing 

CISWI regulations and HMIWI regulations, it was assumed that parameter monitoring will be 

mandatory for all units required to add fabric filters, wet scrubbers, SNCR systems, or ACI 

systems. Costs for each monitoring system were estimated as follows:

 For a fabric filter bag leak detection system, capital cost was estimated at $25,500 and 

annual cost at $9,700/yr. 

 For a wet scrubber monitoring system, capital cost was estimated at $24,300 and annual 

cost at $5,600/yr. 

 For an SNCR monitoring system, capital cost was estimated at $10,300 and annual cost at 

$3,200/yr. 
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 The cost for ACI monitoring depends on a unit’s annual operational hours. There are no 

capital costs for ACI monitoring. Annual costs ranged from $600 to $10,100.

 While not reflected in the cost analysis, energy recovery units over 100 MMBtu/hr heat 

input will be required to operate a continuous oxygen monitoring system if they do not 

have one already. The capital cost for this system is estimated at $8,523 and annual costs 

of $1,436.

For default parameters and equations used for monitoring costs, see Table 6B. Sources for 

specific cost data are noted below the table.

c. Continuous emissions monitoring systems (CEMS). 

The most direct means of monitoring compliance is the use of CEMS to measure the emissions of 

a pollutant on a continuous basis. The following text describes the CEMS for each subcategory 

of existing CISWI units that is included in the final regulation. The costs for Hg and PM CEMS 

are presented in Table 6B.

 For waste-burning kilns, it was assumed all units will require Hg CEMS, but that they 

would likely have installed these already to comply with the requirements of the Portland 

cement NESHAP. Capital cost was estimated at $231,000 and annual cost at $112,600/yr, 

but these were not applied to cement kilns. 

 PM CEMS is required for energy recovery units having design capacities greater than 250 

MMBtu. The capital cost for adding PM CEMS was estimated at $158,000 and annual cost 

at $56,100/yr. 

 Continuous opacity monitoring is required for energy recovery units that don’t have wet 

scrubbers, fabric filters with bag leak detectors, and have design capacities less than or 

equal to 250 MMBtu/hr. Cost was based on a quote from the Midwest Research Institute6

and adjusted to 2008 dollars. Capital cost was estimated at $43,146 and annual cost at 

$14,660/yr.

2. Testing Costs

a. Initial Stack Testing. 

It was conservatively assumed that initial stack testing will be required for each pollutant for 

energy recovery units, incinerators, and small, remote units. Because PM, Hg, and HCl CEMS are 

required for cement kilns, it is assumed initial stack testing will be required for all pollutants 

except these. Additionally, initial opacity testing will not be required for kilns because of the PM 

CEMS requirement. Costs for each required stack test were summed and multiplied by 2/3 to 

adjust for economies of scale when multiple pollutant tests were being performed on a unit. The 

annualized costs were calculated assuming a capital recovery factor of 0.10979 (15 years at 7 

percent). The basis of these cost estimates for each stack test is summarized in Table 6C. 
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b. Annual Stack Testing.

It was assumed that all units, to some extent, will be required to demonstrate ongoing compliance 

with the emissions limits for certain pollutants. Provisions in the final CISWI regulations 

indicate that testing for all pollutants must be conducted once, and if the resulting concentration 

for any of the pollutants is less than a certain threshold percentage of the emission limit, the 

source qualifies for reduced annual testing provisions for this pollutant. For the purposes of this 

cost analysis, the maximum annual testing requirement for each unit was assumed. Stack testing 

costs are presented in Table 6C.

c. Visible emissions testing.

All CISWI units except for cement kilns will likely have ash handling operations. Therefore, 

these units would be required to demonstrate compliance to a 5 percent visible emissions limit for 

fugitive emissions generated during ash handling (similar to HMIWI). We are requiring that 

energy recovery units, incinerators, and small, remote incineration units will be required to 

conduct annual performance tests for fugitive emissions from ash handling using EPA Method 

22. Costs for this annual test include a capital cost of $250 and an annual cost of $200, based on 

the Revised Compliance Costs and Economic Inputs for Existing HMIWI memo.7 Further details 

regarding this cost estimate are included in Table 6D.

3. Recordkeeping and Reporting Costs

For all units, a flat rate of $2,989 per year was estimated as the annual cost for recordkeeping and 

reporting. Further details regarding this cost estimate, including hourly labor assumptions, labor 

rates, and associated sources, are included in Table 6E.

C. Alternative Disposal Costs

Certain CISWI units may have waste disposal alternatives other than combustion available to them. 

These alternatives may prove to be less costly than the controls and monitoring required for compliance 

with the CISWI standards. For example, some facilities may be able to simply divert their waste to a 

landfill or municipal waste combustor (MWC). To attempt to quantify the alternate waste disposal costs, 

for incinerators and small, remote units, the cost of alternative waste disposal methods such as landfilling 

or hauling waste to a MWC were also estimated.

For incinerators, unit capacity, annual operating hours, and a default tipping fee and hauling cost, were 

used to calculate annual costs for landfilling the waste that would otherwise be incinerated. Annual 

landfilling costs varied widely, reaching a maximum of about $2.5 million/yr. Table 7A summarizes the 

parameters and equations used to calculate these cost estimates.

An additional option for incinerators would be to haul the waste to an MWC. Unit capacity, annual 

operating hours, and a nationally averaged tipping fee were used to calculate annual costs, which ranged 

up to $3.6 million. Table 7B presents the basis for these cost estimates. In most cases, hauling waste to 

an MWC was found to be cheaper than complying with the limits, but still more expensive than 

landfilling. 

Commenters contended that the landfill cost algorithm used for the incinerator subcategory was not 

considered appropriate for small, remote units, due to the increased difficulty in transporting waste to 

landfills in these locations (e.g. weather, much longer distances, or the need for air or marine transport 

rather than hauling by truck). To account for this, the cost per ton of waste diverted was estimated at a 

flat $15,000 per ton of waste diverted. This value is based on a half of the maximum estimate provided by 
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public commenters, since some units may be able to use conventional methods of transport whereas 

others may have the maximum cost to transport wastes. Annual landfilling costs for small, remote units 

ranged from $433,000/yr to $24.6 million/yr. Table 7C summarizes the parameters and equations used to 

calculate these cost estimates.

An additional option considered for small, remote units was waste segregation and add-on controls. It is 

generally less expensive for these facilities to segregate their waste and divert the nonferrous metal and 

chlorinated plastic to a landfill than to landfill all of their waste. This practice could allow them to meet 

the emission limits for mercury, HCl and PCDD/PCDF without having the need for add-on controls for 

these pollutants. Many facilities already practice some form of waste segregation, but would have to 

further expand their existing system to accomodate the broader range of materials to be segregated, 

primarily all metals and PVC from the waste stream. Annual costs for this option ranged from about 

$4,000/yr to $224,000/yr, and were calculated based on the waste disposal rate for the facility, the waste 

disposal costs indicated above and cost estimates facilities provided for implementing their existing waste 

segregation systems. The calculations for these costs are presented in Table 7C. 

To calculate the overall annual cost for each alternative disposal option, the costs associated with 

operating the incinerator and the annualized capital cost of the unit must also be accounted for. To 

address this, annual incinerator operational costs were subtracted from the annual alternative cost plus the 

annualized incinerator cost. The algorithms used for calculating the operational cost and annualized 

capital cost of the incinerator are shown in Table 7D. Intermittent operation was assumed for incinerators 

burning at least 1 ton per year of waste, and batch operation was assumed for incinerators burning less 

than 1 ton per year of waste. Unit-specific incinerator operational costs, annualized incinerator cost, and 

alternative disposal costs are listed in Tables 2C and 2D.

III. COST EFFECTIVENESS

The cost effectiveness of the final emission limits was calculated for each subcategory by dividing the 

total compliance cost (emission control, monitoring, testing, recordkeeping, and reporting) by the total 

emission reduction (HCl, CO, Pb, Cd, Hg, PM, PCDD/PCDF, NOX, and SO2) needed to meet the 

emission limits. Note that the emission reductions were derived in a separate memorandum.2 Tables 8A 

and 8B present the estimated cost effectiveness values for each subcategory, over all pollutants. 

Table 8A shows the estimated costs and cost effectiveness for all units to meet the final emission limits. 

The nationwide average cost effectiveness for all units to meet the emission limits was estimated to be 

$2,700/ton for liquid/gas-burning ERUs, $17,200/ton for solids-burning ERUs, $58,400/ton for 

incinerators, $388,800/ton for small, remote units, and $4,800/ton for waste-burning kilns. Over all 

subcategories, the average cost effectiveness was estimated to be $8,300/ton.

Table 8B shows the estimated costs and cost effectiveness for units to choose the most inexpensive 

option. The nationwide average cost effectiveness for all units to choose the lowest cost option between 

complying using add-on controls and using an alternative disposal method was estimated as follows: 

$2,700/ton for liquid/gas-burning ERUs, $17,200/ton for solids-burning ERUs, $7,600/ton for 

incinerators, $234,800/ton for small, remote units, and $4,800/ton for waste-burning kilns. Over all 

subcategories, the average cost effectiveness was estimated to be $7,800/ton.

 

IV. NEW UNITS
11

Based on the results of our analysis for existing units and our experiences with other CAA Section 129 

regulations, we do not anticipate that any new energy recovery units or waste-burning kilns will be 

constructed. Our experience with regulations for municipal waste combustors, HMIWI and, in fact, 

CISWI has shown that negative growth in the source category historically occurs upon implementation of 

CAA Section 129 standards. Since CISWI rules were promulgated in 2000 and have been in effect for 

existing sources since 2005, many existing units have closed. The EPA is not aware of any construction 

of new units since 2000, and therefore does not believe there are any units that are currently subject to the 

2000 CISWI NSPS. Industrial or commercial operations considering waste disposal options for their 

facilities will likely choose not to construct new CISWI units and to use alternative waste disposal 

methods or alternative fuels that will not subject them to the CISWI rule. For example, new sources 

could engineer their process to minimize waste generation in the first place, or to separate wastes so that 

the materials sent to a combustion unit would not meet the definition of solid waste to begin with. 

For incinerators and small remote units, on the other hand, it is more conceivable that some new units will 

be installed in the future, particularly in cases where alternative disposal methods are not a viable option 

and perhaps an older unit must be replaced. The total capital cost for new unit compliance over the next 

five years was estimated at approximately $7.6 million, and annual costs at approximately $2.3 million/yr. 

Tables 9A-9E summarize the assumptions and calculations made to estimate these costs.

In order to determine the costs for these potential new units to comply with the NSPS limits, it was 

necessary to determine what controls would likely be needed for the units. To do this, the average 

uncontrolled emissions resulting for each pollutant were calculated, using default control efficiencies in 

conjunction with the average baseline concentrations for each unit and its corresponding controls. These 

calculations are presented in Table 9A. This adjustment to represent uncontrolled units was unnecessary 

for small, remote units because none of these units currently have controls. A comparison of the average 

uncontrolled emissions with NSPS limits and the subsequent controls chosen are presented in Tables 9B 

and 9C. 

To cost out control and monitoring costs, defaults were determined based on subcategory averages for all 

cost inputs. These default values are shown in Table 9D. The same algorithms used to calculate controls 

and monitoring costs for existing units were used for new units. It was assumed that 1 new incinerator 

would come into operation over the next five years, while 1 small, remote unit would come online each 

year for the next five years. Table 9E shows the cost breakdown for each subcategory. The capital cost 

for each new incinerator to comply was estimated at approximately $3.3 million, and the annual cost was 

estimated at approximately $788,000/yr. For small remote units, capital cost was estimated at 

approximately $852,000 for each new unit to comply, with an associated annual cost of approximately 

$310,000/yr.

V. REFERENCES

1. “CISWI Emission Limit Calculations for Existing and New Sources for Reconsideration Proposal” 

Memorandum from Eastern Research Group, Inc. to Toni Jones, U.S. Environmental Protection 

Agency. November 3, 2011. 
12

2. “Reconsideration Proposal Baseline Emissions and Emission Reductions Estimates for Existing 

CISWI Units” Memorandum from Eastern Research Group, Inc. to Toni Jones, U.S. Environmental 

Protection Agency. November 20, 2011.

3. U.S. Environmental Protection Agency. October 2000. OAQPS Control Cost Manual. Section 4.2: 

NOX Post Combustion. Chapter 1: Selective Noncatalytic Reduction. Publication Number 

EPA/452/B-02-001.

4. U.S. Environmental Protection Agency. July 2002. OAQPS Control Cost Manual. Section 6: 

Particulate Matter Controls. Chapter 2: Wet Scrubbers for Particulate Matter. Publication Number 

EPA/452/B-02-001.

5. U.S. Environmental Protection Agency. July 1994. Medical Waste Incinerators--Background 

Information for Proposed Standards and Guidelines: Model Plant Description and Cost Report for 

New and Existing Facilities. Publication Number EPA-453/R-94-045a. (Docket item no. II-A-112)

6. Memorandum from Thomas Holloway, Midwest Research Institute, to Rick Copland, U.S. 

Environmental Protection Agency. March 17, 1997. Revised Testing and Monitoring Options and 

Costs for Medical Waste Incinerators (MWI’s) - Methodology and Assumptions.

7. Memorandum from Thomas Holloway, RTI, to Ketan Patel, EPA. July 6, 2009. Revised Compliance 

Costs and Economic Inputs for Existing HMIWI.

8. EPA Air Pollution Control Cost Manual, Sixth Edition EPA 452/B-02-001.

9. Dr. H.M. Eckerlin and E.W. Soderberg. Industrial Extension Service. USI Boiler Efficiency Program. 

A Report summarizing the finding and recommendations of an evaluation of Boilers in State-Owned 

Facilities. February 25, 2004. Accessed online at: 

http://www.energync.net/programs/docs/usi/om/boilers/ssr.pdf

10. IPM Model - Revisions to Cost and Performance for APC Technologies, Mercury Control Cost 

Development Methodology, March 2011, Project 12301-009, Sargent & Lundy LLC.
13

11. APPENDIX A. TABLES FOR MACT FLOOR COST ANALYSES

The tables referenced throughout the body of this memo are presented in this section. They are organized 

as follows:

1. Percent Improvement Required to Meet MACT Floor

1A: Energy Recovery Units – Liquid/Gas

1B: Energy Recovery Units – Solids

1C: Incinerators

1D: Small, Remote Units 

1E: Waste-burning Kilns

2. Costs to Meet MACT Floor

2A: Energy Recovery Units – Liquid/Gas

2B: Energy Recovery Units – Solids

2C: Incinerators

2D: Small, Remote Units 

2E: Waste-burning Kilns

3. Summary of MACT Compliance and Alternative Disposal Costs

4. Input Parameters for Control Cost Algorithms

5. Control Cost Algorithms

5A: Fabric Filter

5B: Detailed Fabric Filter Costs for Energy Recovery Units

5C: Packed-Bed Scrubber

5D: Selective Non-Catalytic Reduction (SNCR)

5E: Activated Carbon Injection (ACI) for Incinerators and Waste-Burning Kilns

5F: Activated Carbon Injection (ACI) for Energy Recovery Units

5G: Afterburner Retrofit for Incinerators

5H: Dry Sorbent Injection/Fabric Filter (DIFF)

5I: Regenerative Thermal Oxidizer (RTO)

5J: Incremental Controls

6. Stack Testing, Monitoring, and Recordkeeping Costs

6A: Maintenance and Inspection

6B: Monitoring

6C: Stack Testing Costs

6D: Visible Emissions Testing

6E: Recordkeeping and Reporting

7. Alternative Waste Disposal Algorithms

7A: Cost to Haul Waste to Landfill 

7B: Cost to Haul Waste to Municipal Waste Combustor

7C: Cost to Segregate Wastes and Landfill for Small, Remote Units

7D. Cost to Continue Incinerator Operation

8. Cost Effectiveness of MACT Floors: Overall and by Subcategory
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9. New Units: Cost to Meet MACT Floor

9A: Average Uncontrolled Incinerator Emissions

9B: Incinerator Emission Averages and Required Controls

9C: Small Remote Unit Emission Averages and Required Controls 

9D: Default Cost Algorithm Inputs

9E: Control and Monitoring Costs for New Units