ATSDR - LAND APPLICATION OF BLEACHED PULP & PAPER …Land Application of Bleached Pulp & Paper Mill Wastewater Treatment Sludges Regulatoiy Impact Analysis U.S. Environment Protection

us EPA RECORDS CENTER REGION 5

494780

JOINT CENTER AEI-BROOKINGS JOINt CENTER EOR REGULATORY STUDIES

Land Application of Bleached Pulp & Paper Mill Wastewater Treatment Sludges

Regulatoiy Impact Analysis

U.S. Environment Protection Agency Office of Toxic Substances

April 19,1991

This analysis was issued by the agency and collected by the ABI-BFookings Joint Center in order to promote regulatory transparency. The views expressed in this document are those of the agency and do not necessarily mfliect those of the Joint Center.

,20V0-

Regulatory Impact Assessment for Land Application of

Bleached Pulp & Paper Mill Wastewater Treatment Sludges

Final Report

ApiU19,t991

Prepared fpn EPA Office of Toxic Substances

Economics and Technolo^ Division Regulatoiy Impacts Branch

Costing Analysis Prepared by: Eastern Researeh Gioup, Inc.

6 Whittemore Street Arlington, MA 02174

Benefits Analysis Prepared by: Abt Associates

Hampden Square, Suite 500 4800 Montgomery Lane

Bethesda,MD 20814

ACKNOWLEDGEMENTS

This report wu prepared for the EPA Office of Toxic Substances (GTS), Economics and Technology Division (ETD^ Regulatoiy Impactt Branch (RIB), by Abt Associates of Cambridge, Massachusetts and Eastern Research Group, Inc., of Arlinôn, Massachusetts under EPA C>3ntract No. 68-D0'O020; Task 1-06. Pat Szarek and Lyiuie Blake^Hedges of GTS served as EPA Task Managers.

Regulatory Impact Assessment for Land Application of

Bleached Pulp & Paper Mill Wastewater Treatment Sludges

Final Report

April 19,1991

Piepared fon EPA Office of Toxic Substances

Economics and Tecbnolo^ Division Regulatory Impacts Branch

Costing Analysis Prepared by: Eastern Research Group, Inc.

6 Vniitfemore Street Ailington/MA 02174

Benefits Analysis Prepared by: Abt Associates

Hanmden Square, Suite 500 4800 Montgomery Lane

Bethesda, MD 20814

TABLE OF CONTENTS

SECnON ONE Bcecutive Summary M

SECnON TWO Introduction 2-1

2.1 Scope 2-1 2.2 Pulp and Paper Mill Sludge 2-1 2.3 Land Spreading of Sludge 2-3

2.3.1 IVpet of land spreading 2-3 2J.2 Sliidj^ transportation and application 2-4 2 J.3 Site preparation 2-5 2J.4 Number of mills engaged in land spreading 2-5

2.4 Risks from Land Spreading 2-5 2.4.1 Background to the &caan issue 2-6 2.4.2 Contaminants of concern 2-6 2.4.3 Consent decree 2-7

SECnON TWO REFERENCES 2-8

SECnON THREE Profile of Curfent Sludge Generation: Treatment. Handling. anil Pi^powl Fr4cii«?ey. sjudge qonmninflhi Uvels 3-i

3.1 Introduction 3-1 3.2 Sludge Generation Profile 3-1 3 J Sludge Treatment and Handling 3-3 3.4 Current Sludge Disposal Practices 3-6

3.4.1 Numlmr of plants and sludge disposal methods used 3-6 3.4.2 Relative volumes disposed using each disposal method 3-8

3.5 Dioxin Concentrations of Bleaching IÛs 3-10 3.6 Technical Considerations Affecting Current Disposal Practices 3-12

3.6.1 Technical fectora related to land application * , J-12 3.6.2 Technieal.fisctors related to incineration 3-15 3.63 Technical fectois related to landfilling 3-18

3.7 Regulatory Factors limiting Sludge Disposal 3-18 3.7.1 Land application and landfiUing 3-18 3.73 Incineration 3-19 3.7J Regulatory antrdpation 3-20 3.7.4 Future regulations 3-20

SECnON THREE REFERENCES 3-21

SECTION FOUR Rewlatorv Options 4-1

4.1 Introduction 4-1 4.2 Option 1: Baseline Land Aplication Practices 4-1 4.3 Options 2-12: Unift>rni Soil Concentration Limits

With Management Practices 4-3 4 J.l Soil concentration limits 4-3 4 J.2 Sludge management and control requiremenu . 4-S

4.4 Option 13: Ban on Land Application " 4-13 4.5 Options 14-24: Soil Concentration Plus Area Limits 4-13 4.6 Option 25: Uniform Sen! Concentration Limit -with

Site-Specific Runoff Controls 4-15 4.7 Option 26: Site-Specific Risk Assessment 4-16 4.8 Other Options 4-16

.. V 4.8.1 Berms 4-16 k.8.2 Endangered species impacts 4-16

SECTION FOUR REFERENCES 4-17

SECnON FIVE Coats of Disposal Praetices and Compliance Proieetiona 5-1

5.1 Introduction 5-1 5.2 Use of BPA Handbook for Estimating Sludge Management Costs 5-2 5.3 Use of Engineering Costs . 5-2 5.4 Gosu of Berms Around Apfdication Sites 54 5.5 Costs of Sludge Management Requiremenu 54

5 J.i Sludge sampling and testing 5-5 5.5.2 Recordkeeping requirements 5-8 5.5 J Notification of EPA 5-9 5Ji.4 Vegetative cover 5-9 5.5.5 Restrict flow of base flood 5-10 5J.6 No application to frozen, snow-covered or flooded land 5-11

5:6 Total Current CosCi of Land Application 5-11 5.6.1 Costs including management practices 5-12 5.6:2 Costa induding berms 5-12

5.7 Total'CurrentCbsts of Alternatives to Land Application 5-14 5.8 Potential Cbsts of MUl-Conducted Risk Assessment for Permit Options 5-18

5 J.1 National Standard Permits 5-19 5.8.2 Site^pedfic Penniu 5-19

5.9 RelativeCoita of LBiid Application and Disposal Alternatives 5-23 5.10 Liiaitations of Cost Mbdelittg 5-23 5.11 Projections of CbmpUance Under Alternative Regulatory Scenarios 5-26

5.11.1 Soil concentration limits 5-26 5.11.2 Area limitt ^ 5-27

5.12 Costs to KfiUs Versus Costs to Others 5-29

SECnON FIVE REFERENCES 5-32

SECTION SIX Aggregate Economic Ttnpact of Regulatory Ontinm 6-1

6.1 Introdiiction 6-1 6.2 Non-MUi Costt and Benefits of Land Application 6-1 63 Non-Mill Costs and Benefits of Alternative Disposal Methods 6-2 6.4 Regulatory Enfisrcement Costs 6rS

6;4.1 Non permitbased options 6-5 6.43 Permit-based options 6-5

6.5 Total Costs and Impact of Regulatory Options 6-8 6.6 Additional Ecpnomic lmpacts of Sludge Land Application Rule 6-13 6.7 Technical Process Alleniatives for Reducing Dioxin Concentration in Sludge 6-16

6.7.1 Oi^n delignification practices 6-17 6.7.2 Alternative bleaching practices 6-IB 6.73 Sludge management 6-18 6.7.4 Other inethods 6-18 6.7.5 Conclusions regarding technical process alternatives 6-19

SECTION SIX REFERENCES 6-20

SECTION SEVEN Eeonomie Benefits of Regulatorv Options 7-1

7.1 Introduction 7-1 7.2 Human Health Benefits of Regulatory Options 7-1

73.1 Calculating net risk 7-2 7.23 Sensitivi^ to MEX risk based regulatoiy options 7-3 733 Permitting options 7-6

7.3 Etological Benefits Of Regulatory Options 7-6 7-6

733 Characterization of land application sites 7-9 733 Ecological benefits of regulatory scenarios 7-15 7.3.4 Sensitivity to MEI risk 7-20 733 Permittii^ options 7-20

7.4 Relating Benefits to Costs 7-20

SECnON SEVEN REFERENCES 7-22 e'

APPENDIX A Modeling Asnimotions and Cost Methodoloev A-1

A.1 DaU Sources' A-1 A.2 Approach A-1 A.3 Modeling Assumptions A-2

A3.1 Categories of costt A-2 A33 Sludge volumes modeled A.6 A33 Matt balance calculations A-6 A.3.4 Model parameters and model descriptions A-8

A.4 Nutrient and Gonditioiung Value of Sludge A-22

APPENDIX B ScMitivitv Calculatiorw B-1

B.1 Sensitivity to Transportation Distances B-1 B.2 Sensitivity to Land Values for Onsite Disposal Facilities B-3 B3 Sensitivity to Five-Year Application Assumptions B-3 B4 Sensitivi^ to Assumption of Mill Control Over Land Application B-6

APPENDIX c Alternative Spwifiwiipn pf Limitu c-i

SECTION ONE

EXECUTIVE SUMMARY

This Regulatory Impaa Analysis (RIA) addresiei the costs, benefits, and economic impacts of proposed EPA rules to limit or prohibit the land application of process wastewater sludges from pulp and paper mills that use the chlorine bleaching process. Recent investigations have linked chlorine bleaching with the generation of dioxins. a toxic family of chlorinated organic compounds. A joint EPA/Paper Industry study of all 104 bleaching mills in the U.Si pulp and paper industry found diogdn to be present in the pulp, sludge, and wastewater of most facilities (USEPA, 1990).

Current Land Application Practices 1*

At the time of the 104>miU stutfy, twelve mills utilized land application for disposal of their wastewater sludge. The majority of the 104 mills used landfills^ while others used surface impoundments or incinerators to dispose of sludge. Because sludge contains organic material such as wood fiber, it can contribute beneficial nutrienu and soil conditioning properties when applied to agricultural and forestry sites, as well as assist in the stabilization of disturbed soils such as are found at abandoned stripmine sites. Of the twelve mills engaged in land application, one was applying sludge to agricultural land, four were applying sludge to forestry sites, two were providing sludge for use in stripmine reclamation, and five were distributing and marketing sludge as a soil amendment to smaller volume users.

Risks Associated with Land Application

Risk assessment studies have found that the dioiin in sludge that is land-applied poses several risks of concern and possible concern to exposed humans and wildlife. The bioaccumulation of dioxins in mammalian and avian spedea that iiihabit land application sites presenu perhaps the greatest risk, although quantification of such risksiis made difficult by the lack of fieiddata. Human cancer risks and non-cancer human health risks are also of concern. Human health risks are associated with ingestion of fish from surface waters that receive runoff from land application sites, or ingestion of crops, meat and dairy products raised on contaminated soil. EPA has deemed these risks of sufficient potential significance to justify regulatory action.

Sumimiy of Regulatory Requlremcnta

A total of twenty five regulatory options (in addition to the baseline option of no regulation) have been considered in this anaiySiis. Eleven of these consist of different soil concentration limits for dioxin, and another eleven> involve limits on the land area receiving sludge in addition to concentration limits^ Two other options will require mills to submit information to EPA in the form of a permit application. The permit information will enable EPA to make a finding of reasonable or uitreasonable risk on a case4ty-case basis. The final two options cover no regulation of land application (i.e., continuation of current practices) and a ban on land application.

The soil concentration limitt for dioxin will control risks to humans from ingestion of crops, meat, and dairy productt and to wildlife from ingestion of prey exposed to diaxin-oontanlinated

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sludge. When sludge is applied to the surface of the site, the oOncentration of dioxin in the soil is equated to the concentration in the sludge. In some cases, the sludge is incorporated into the soil, resulting in soil concentrations that are less than that in the sludge. Dioxin will accumulate in such soils, however, so repeated applications can increase its concentration. Thus, testing of slud^ and soil will be required to determine whether soil, concentration limits are being eaceeded. The effectiveness and coiu of several alternative soil conoentratlon limits are investigated in this RIA.

The area Umitt would, additionally, set a maximum number of hectares to be used for land application within an individual water drainage area. These additional limits wguld protea against risks from runoff of contaminated sludge and soil into surface waters and the bioaccumulation of dionn in aqtuitic species.

For land application programs that meet the soil (or soil and area) limits, EPA is proposing new management practices to ensure that sludge is used in a safe and responsible manner. Mills engaging in landnpplication will be required to maintain records of foe sludge quantities disposed through, land application, foe location of appUieation sites, foe names.and adfoesses of site owners, the totU quantiqr of sludge applied at midi site, foe application rates used, and the dioxin concentrations of foe sludge. (Mills that do not engage in land application will not be subject to such requirements.) EPA will also require notification in writing of any proposed land application programs, including extension of ongoing programs to new sites.

EPA has considered several further requirements to control mnoff of contamiiuited sludge or soil from land application sites. These indu^ application of sludge in such a manner that it will not potentially affect the flow of a base floofo or reduce temporaiy flbodidain storage capacities. EPA is also proposing vegetative covers for land application sites that comply with Department of Agriculture specifications^ Finally, a separate requirement under consideration would involve oonstruction of beims surrounding land apidication sites to control surfece water runoff

These regulations are part of EPA^ overall strategy to control the release of dioxin from pulp and paper mUls.-I1ie 01^ of Water (OW) plans to revise effluent ,limitations guidelines and standards for foe pulp, paper, and paperbqard industiy. The OW regulations are scheduled to be proposed in Jufy 1993 and promulgated in June 1995L* As of April 1991, the rulemaking effort is in a data collection jfoase. COinpliance with wastewater regulations could affect foe characteristics of wastewater treatment sludges*

Analysii of Sefnlatory Impacts

QtO used informatioii on sludge generation^ disposal methods, and dioxin concentration collected by the 1044nill' study dted alê for the aiudyris of regidatoiy costs and impacts. The current costs of sludge management and disposal, including land application and other methods, were developed fbr five representative size classes of mills. Existing EPA cost algorithms for analyus of munidpal sludge disposal costs were adapted and mofofiedi for use in developing these estimates. Meior components of foe sludge disposal costs include dewatering, transportation, site

Û.S;Enviroamentai,Protection Agenqr, Officeof Water RegulationsiandStandards, Supporting Statement for the Offtce of hfanagement end Budget (0MB) Review: 1990 National Census of Pulp, Paper, and Paperboard Manufacturing Facilities, May 1, 1990;

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preparation, and land application. Engineering models were used to calculate costs of disposal to landEU and surface impoundment.

These analyses show land application to be the least costly current means of disposal, assuming that all mills fiue the same set of market and technological factors. Site-specific circumstances such as distance to suitable apfdication sites or other considerations may vary, however, and partially explain why all mills do not currently use land application- Sensitirity analyses contained in the appendices indicate that overall results are not greatly affected by assumptions made concerning traiuportation costs, land costs, and other variables.

For an average-sized mill (generating an estimated 22,500 dry metric tons (Dh^ of sludge per year), the total oosu and costs per ton of the various disposal options are shown in Table M. Costs for liind-applying sludge are generally lower than costs for other disposal methods. At $30.35/DMT, mining application is the least costly ^pe of application, partly because it is assumed that the mining company, rather than the mill^ incurs the coats of transporting and applying the sludge. In agricultural application (S40.40/Dhfr), the mill delivers the sludge to farmers, who perform the application, while in forestry application ($75.56/DMt) the mill transports sludge and applies it to Its own sites.

It should be noted that the eosts to the mill are used to project compliance scenarios (see Table 1-1), but that the total costs of land application are used to calculate the costs of the regulatory options shown in Table 1-2.

When restrictions or prohibitions to land application are introduced, mills may be led to adopt alternative disposal methods. The most attraetive (lowest cost) alternative to land application is disposal to surface impoundment ($9S.4ti/DMT). Thus, mills that cannot comply with the proposed sludge land application rules are projected to elect surface impoundment as their preferred alternative. CoUg for surface impoundment are higher than land application because of the larger capital oOstt associated with impoundment construction, It must be noted that disposal to surface Impoundmena require oonsi^rable available land in close proximity to the mill's wastewater treatment facility. In scmie cases a lade of available land could limit the feasibility of this option. If land is available but is located at some dstance from the wastewater treatment plant, then cosu could be higher than those eatuaated.

The considerably higher cost of disposal to munidpal landfill ($162iX)/Dhfr) reflecu the general trend towards hi^r tipping fees for hi^ volume wastes such as sludge. Disposal to onsite landfills is estimated to cost $113 J4/DNrr, while construction and operation of a dedicaied sludge incinerator will cost $139.73fDhfr. Incineration costi Indude estimated cosu of required air pollution control eqnipmenL

Depending on the stiingenqr of the land application regulations, some mills are projected to discontinue land application and adopt surfece impoundment disposal. Under the 10 parts per trillion (PPT) soil concentration limit being proposed, the analysis precUctt that six mills continue land application and six switch to surfece impoundment.

Cost impacts were calculated for all twenty five regulatory options, including eleven concentration limits, eleven combinations of concentration plus area limits, a ban on land application, and two permit options. To calculate the total costt of each option, the current costs

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TABLE M

Current Estimated Total Co»ti Per Year and Corta Per Ton

Total 1 cost Cost/ 1

Type of Disposal ($OCO/yr) DKfT

Agricultural $909 $40.40 1 Forestry $1,700 $75.56

NCmlig S683 $30.35 $2,072 $92.11

Onsite landfill $2,555 $113J4

Surfime impoundment $2,148 $95.46 1 Incineration $3,144 $139.75 1 Minidpal landfill $3,645 $162.00

[a] KGU is assumed to generate and dispose of 22^00 dry metric tons of sludge per year, based on sludge generation daU presented in tJSEPA (1990).

Source; ERG estimates.

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of land application are subtracted from the projected costs of surface impoundment for those mills that discontioue land applicatioik The costs of land application include not only the costs borne by the mills, but also cosu to farmers and inining companies. The beneficial value of sludge in these applications is iitciuded as a cost (or lost benefit) when the mill discontinues land application. The inclusion of die beneficial values of sludge lowen the cost of land application relative to the cosu of the disposal altematives^ and in turn, raises the costs of each regulatory option. The beneficial value of sludge is estimated to be $11.00 per DKfT in agriculture and forestry, based on its plant nutrient content, and $6.62 per DMT in mining. The value in mining is a weighted average of the nutrient value of sludge and its value as fill material.

Table 1-2 shows compliance projections and total costs of sludge disposal under baseline conditions, under seven of the eleven alternate soil concentration limits, and a ban on land application. As the concentration limitt become more restrictive, additional-milli switch to surface impoundment. At the 200 PFT limit, 10 of 12 mills continue land application, at 10 PFT six mills continue and six mUls cease land application, at 1 PPT three mills continue land application, while below 1 PFT all but one mill discontinues land af^lication.

Baseline costs of sludge disposal are estimated at $26.2 million per year. Under a 10 PPT soil concentration limit, six mills switch to surfoce impoundment disposal, resulting in additional Qosts (including lost benefits) estimated to be $5 J million per year. The costs under a land application ban, which causes all mills to switch to surfkce irhpoundment disposal, are $39.S million per year, or $133 million per year above the current costs.

The costt of options 2 to 12 include estimated Agency cosu of $0.1 million per year for enforcement and administration. Cosu for berm construction are not shown in Table 1-2, but would be highest at $63 million per year under a 200 PFT soil limit.

Compliance projections and estimates of costs have not been developed for the permit options at this time. Under these regulatory options, EPA will develop guidance documenu to assist mills and permit writers in the collection and evaluation of the data necessary for the permit apidication. Until this guidance is developed, the cuts to the mill of the permit application, and the likelihood that the permit will be granted, cannot be forecast Based on EPA risk assessment methodologiea, prelhniiuiy estimates of the cutt of conducting a site-specific assessment of risks from land appliution are in the range of $50,000 to $150;000 per site.

»• Limitations of the Regulatory Analysis

Due to a ladk of relevant industry data, or because of assumptions made to simplify the modeling procedure, several fscton can be identified that would, with more complete information, tend to eidier increase or decrease the estimated cutt of the proposed regulatory actions.

Cuts of-4he regulation may be overestimated if the following are true:

• The analysis asiumes that mills engaged in land af^lication apply all of their reported sludge volumes. In some cases, miUs in fact Umd-apply only a portion of their sludge. The costs to such mills of discontinuing land application is likely to be overstated.

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TABLE 1-2

pf RmUwry OptiQM Alternativa Coacemration Limits

Annual Costs (Smillions) |

Option Na[a]

Cone. Limit (PPT)

No. of Mills Current^ Land

Appiying or Able to Meet Regolatoiy Limit

Total Cosu of Sludge Disposal

Cost-of Option Above

Baseline [b]

Incremental Cost of

Option (c] 1

1. Baseline 12 S26.2 . "

2. 200 10 SZ7J S1.3 $1.3

.. 3. 100 8 S30.1 S3.9 $2.6

4. 30 7 $31J SS.1 $1.2

5. 10 ti J31.7 SS.S $0.4

6. 5 S38.7 S12.S $7;0

& 1 S38.8 $12.6 $0.1

OJ S39;6 $13.4 $0.8 1 Ban 0 S39J $133 (M.1) 1

Columiu uuy not add doe to Rnmdiof. Costs of Options 2^12 incinde estimated Afency oosu of S0.1 aofliion per year for ejaforcemeiit and administFation. Under several cif the optional ao niilla are predicted to continue land appiication. Since there js no assurance that this will actualiy oocnr, cnforcemBai and administrative cosu ate assnmed to'^be incnrrcd fay the Agenq^. Costs of option 13 QMa on land appUcatiim) are lower than t^tions 2>12<^ SO.l million, since administrative and enforcement actMtics will not be need^

[a] Cosu not shown for all options enmined. See Sectton 6 for more complete results. [b] Total ocuu of optum miBua cosu of current practices. [c] Total cosu of option mbus cosu of previous option.

Source: ERG estimates.

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• The analysii uses data from EFA's 104-Mili Study to establish the baseline sludge disposal practices for the industry. Since the time of that study, at least two of twelve mills are believed to have discontinued land application. The current baseline costs of the regulation include any additional costs to these mills when switching from land application.

• The 104-1^11 Study was also used to determine baseline dioxin concentrations In sludge. Some mills may have succeeded in lowering dicodn concentrations through proc^ modifications or other means. This might enable some mills projected by the analysis to cease land application to continue, resulting in lower cosu than those esdmatecL

• The analysis does not consider the possibility that additional mills may bepn land application following promulgation of the regulation. To the extent that entry would occur, the costs of disposal to the mills^ would decrease^ This would lower the current baseline costs of disposal, and increase the costs attributed to the regulation.

• Little dau wu available regarding the transportation distances between mills and land application sites. If transporution distances for mills are in fact greater than esttmatcai, then the cosu of land application would be higher, and the costs attributed to the relation would be lower. (Appendix B examines the sensitivity of costs to assumptions regarding transportation distances).

On the other hand, costs of the regulation might be underestimated if the following are true:

• If transportation disttnces to alternative disposal sites are lower than estimated, then the cosu of switching from land application would be lower.

• Surfoce impoundment is identified by the economic models as the least costly alternative to land application. Site^pedfic fimtors not captured by the models may cause some mills to switch to more expensive disposal alternatives such as landfills or even indneratiom This could occur ih for some reason, surface impoundment costs are higher than estimated.

• Mills awaiting promulgation of a regulation may be currently incurring hiêr costs for dispoui thu they would under land application. If these milts were^r^nted from iwitdiiog to lis^ application because of the restrictiveness of the regulation, it could be argued that the additional cosu they incur (e.g., for landfill dspossl) ahould be attributed to the regulation.

With the available data and time, the potential impacu of these uncertainties could not be quantified. AppendiGea A, B, and C discusi some of the assumptions In more detail, and provide several sensitivity analyses. Appendix Table A-3 also indudes a listing and description of over 40 variables used in the analysis.

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Benefits of Regulatoiy Actions

Benefitt from relating land application of pulp and paper sludge accrue in the form of reduced human health risks and reduced risks to wildlife whose domain includes sites at or near which sludge is currently applied. Reduced risks to humans due to a land application regulation are eaamined in terms of the predieted.reduction in the number of cancer cases experienced by the exposed population resulting from changes in land application practices. Other human health benefits identified but not quantified in this analysis include reductions in health costs and non-lethal effects such as reproductive effects.

• V "

These risk reductibiu are based upon examination of the predicted oomiîance scenarios of the twelve mills reporting land application in the liM-mill Stutfy resulting from alternative regulatory options restfiming soil eonoentration limits of diosins and frirans. These options are designed primarily to reduce risk to a level of one in ten thousand (ICT*) for subsistence fishermeii by setting soil coneenttation and apfdicatlon area limits. The subsistence fisherman is identified as the maxipially exposed individuai (MEI) based upon a runoff exposure pathway. These combination options^ also control for risk to the subsistence farmer by setting concentradon limits. The subsistence former is identified as the MEI associated with the contaminated food ingestion pathway although risk is not necessarily coiitrolled at a 10** level under all options described in the analysis. Lastly^ these options also address wildlife risk through limits on soil concentration. However, hmnun health benefits of eachof the regulatoiy options are examined in terms of the risk reduction to the entire exposed population (which is inclusive of the MEI). These reduced risks are shown in Table 1-3.

The baseline number of annual cancer cases under current practices is predicted to be 0.33. When a restrictfam on soil concentration levels of dioxin is the control strategy and levels are limited to 200 PPT, the number of annual cancer cases is predicted to decrease by 0.04 cases per year to 0.25 cases annually. At soil concentrations of 30 and 10 PPT. population cancer cases are estimated to decrease by OJl to an expected 0*02 cases per year, and are further rediiced to zero below a soil concentration limit of 5 PPT.

Although ecological risks cannot be quantified, benefits from, reducing those risks are an important consideration in this rulemaking Risks to wildlife resulting from land application of TCD0/TCDiF contaminated pulp and paper mill sludges may include such adverse effecte as embryonic heart malfoimatibns in birds, reduced reproductive capability, reduced hatchability, and moitaliQF in individuals. Potential also exists at some risk levels for the reduction of numbers in populations and the reductfoo of species diversity at or ih proximity to land apftiication sites if sufficient damage occur to individuahu Affected species cOuld indude migratory fislu sonîrds such as bluebird^ laptpra such as screech and bam owls, and mammals Including otter, skunk, and dCer mice. Addition^, endangered species of plants and animals oouldipotentially suffer damages:. These species include the bald eagle.

Thciregulatoiy optiona ooBaJdeied luive geiieralfybeen associated with risk quotient (RQ) values in the wildlife risk assessment. These RQ values are a fiinôn of exposure and threshold toxicity values and are indicative of the degree of risk reduction whidi may be achieved. RQs are extrapolated from the risk assessment and coupled with economic descriptions of benefits to arrive at a qualitative discussion of potential benefits. Economic benefits to wildlife are derived from the

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TABLE 1-3

Annual Redueriona in Human Health Rhta rPoDulation Cancer Alternative Concentration Umita

1 Option 1 N«>- n>i Soil Concentration Limit

Total Annual Population Cancer Cases

Net Change in Population Cancer Cases [d][er]

1. Baseline 043 [c] 0

2. 200PFT 0.29 -0.04

3. 100 PPT 0.18 -0.15

4. 30 PPT 0.02 -041

1 10 PPT 0i)2 -041

1 5 PPT 0.0 [el •0.33

8. IPPT 0.0 -043

9. 04 PPT 0.0 •0.33

13. Ban 0.0 •0.33 1

a] Non-cancer and sub-lethal health cfiiBcts of TCDD/TCDF exposure are excluded. b] Costt not shown for all options examined. See Secdon 6 for more complete results. c] Predicted cancer cases attributable to the 12 mills cunently applying sludge to land.

Additional risks incurred minus risks avoided by switching disposal practice. bj Residual risks of 0:0002 and below are rounded to zero.

Source: Abt Associates and ERG estimates.

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association of wildUfb with .activities such as hunting and birdwatching and from the belief that the healthy ensttnoe of wildlife has intrinsic value. Th^ vaiy depending on the characteristics of land application sites, spedes present and aoceu for recreation. It was not possible to quantify ecological benefits given the lack of site-specific information, but regulatory options were ranked on a relative basis.

The results of the ecologieal benefits analysis are presented in Table 1-4. Ecological benefits are likely at soil concentrations of 5 PPT and below based upon mills compliance scenarios and evidenced by decreasing RQ values. Maximum potential for ecological benefits is attained at a level of .03 PFT and from a ban where all land spreading activity is predicted to cease. Under each regulatory côn. some mills arc predicted to cease land application and to. begin disposing of sludge in surfrce impoundments.. Based upon the assumption of stringent management practices these are believed to eliminate risk to aquatic spedes allowing recreational fishing benefits to accrue, while the degree of risk reduction achieved for terrestrial spedes U uncertain. It is argued that the smaller erqxwure area resulting from surfrce impoundmentt disposal may result in risk reduction to terrestrial spedes.

" ^ .The concentration of contamirumu in runoff from a land application site are not only dependent on the soil concentration of dioxiiis and furaru, but also on the surfrce area to which the pulp and paper sludge is applied. Total risks posed by a particular site are therefore assodated with site si». Alternative regulatory options which account for site size as well as soil concentration limits are presented in Appendfr C Generally, restricting site size along with soil concentration increases land application costs and causes firms to shift to alternative disposal practices. Because of this, human h^th and wildlife risks are reduced

MO

TABLE 1-4

'B?« Eatimatfii' 9f EcQlQgiffll Benefits

Option 1 Np,[a]

Concentration Limit WildUfe Risk Quotient Relative Benefit *• Baseline N/A 0

200 PPT 100 +

3. 100 PPT 50 +

4. 30 PPT 10 +

5. 10 PPT 5 + •

6. 5PPT 2.5 ++

8. IPPT OS ++

9. 0.5 PPT 0.25 +++

13. Ban N/A

0 = no beneEt s low potential benefit

•i"i> B likely potential benefit ++-f B hi^y likely potential benefit


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SECTION TWO

INTRODUCTION

2.1 SOBS

This Reîatoiy Impact Analysis (RIA) evaluates the oosu, benefiu, and economic impacts of proposed Environmental Protection Agen^ (EPA) regulations covering the land application of pulp and paper mill sludges. Sludge from some mills has been found to contain traces of diosin (National Dioodn Studyi 1987; USEFA. 1988; USEPA^ l99Qa), an extremely toxic family of chlorinated organic chemicals. When applied to land, the dioxin in the sludge may pose unacceptable health risks to humans and animal species.

EPA has considered a variety of options to control the . risks from dioxin. The primaty control method being proposed is a limit on the concentration of dioxin that is allowed to build up in the soil at sites where slu^ is land-applied. The soil oonoentration level would be determined from the concentration of dioxin in the sludge, the number of applications at the site, the sludge application rate, and the sludge incorporation depth (if incorporated). ERG has developed costs for compliance with requirements that would limit soil concentration to any of 11 alternate levels considered by EPA. as well as for a complete ban on land application. EPA is also proposing management practices that will ensure close tracking of slud^ disposal and responsible use of sludge. These will require mills to: maintain records of the quantity of sludge generated and how and where it ia disposed; develop agreements among the partlea generating, distributing, and applying the sludge covering permissible application rates and other precautions; provide written notices informing EPA of proposed land application activities: restrict sludge application near suifoce waters; establish appfi^riate vegetative covers on sludge-appUed land; and guard against possible effects of sludge runoff during Imse floods. A separate option would require construction of beims surrounding application sites.

Limitations were also considered on the total number of hectares of land to which sludge can be applied within an individual drainage area. These would protect against risks from runoff

corresponding soil ooncnetration limits.

2.2 Pulp anii fgpgr Mill S1B4«

Pulp and paper mills use large amounts of water in their pulping, bleaching and papermaldng prboeucSi One source estimates that a mill making 100 tons per day (tpd) of paper reqmres two miliioii gellona per day (gpd),of fresh water (Kline, 1982). The same volume also would be ditdiarged e^ day as procett wiistewater; Under the federal Qean Water Act of 1977. this water must be treated b^re discharge to reduce the amount of suspended solids, BOD, color, etc. contained in the wute eCfluent Sludge ia produced as a byproduct of this treatment. It oonsistt of suspended solids that are removed during settling of the wastewater (see Figure 1).

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Figure 1 Alternative Effluent Treatment Systems

for Pulp and Paper Mills

MBI WkiM

Con* Scraaning

Stitlonvy

£ TriMlling zzy—

Suspihdsd •i SdUda

Sadlmaniatfan Lagoan -

ClBiHIar

If

Sludgato^ . - — - ^ i

BOORtmoval i

AanM SMiiliiaBon amn

BOORwnoval SoHdt Sattirwntation

or SMUoral Diidaiga

UnU

t Shidg* I Rtum

PbaiStoraga

~T Foam Trap and OVfuatr Outfall

Lagand: Waitaliow Shidgaflow

Saiirca:Ediandackaraiid>Sinthaiiain, 1BB1.

2-2

Pulp and paper sludge is comprised mainly of wood fiber; however, other materials also may be present, Qay, fillers, and other additives used in the papermaldng process, as well as sand, grit, and dirt from the wood chips, can also be present in the sludge. Raw slud^ is highly aqueous, containing from 93 to 99 percent vMter. Subsequent sludge, treatment processes, such as thickening and dewaterinfr can reduce the water content substantially.

Because it contains organic material and wood fiber, the sludge can be put to beneficial use. When applied to agricultural land, it acts as a soil conditioner and provides some of the nutrients necessary for crop growth, On forestry lands, it can be used as a soil top dressing, and has been found to stimulate tree growth. Sludge has also been tised as a topsoil substitute in land reclamation projects, such as abandoned strip mine sites.

In each of these settings, the application of sludge has the potential to improve the site charaaeristica by provitfng nutrientt and Conditionirig the soil. The nutrient value of sludge is derived from its nitrogen, phosphorus, potassium, caldum, and magnesium content. Nitrogen, phosphorous, and potassium are the primary nutrientt found in commercial fertilizers. Calcium is a liming agent that is used to raise the pH of the soil, and mapiesium is a micronutrient. The soil conditioning benefits of sludge stem from its high fiber content, which aids in building the organic structure of the soil. This opnditioning improves the tezture and physical properties of the soil, leading to better water retention, increased aeration, and increased cationic exchange capacity, which improves the soil's ability to store nutrients.

Among the 104 bleadied pulp rnills that will be affected by the EPA Euleniaking, sludge generation ranges from 2,300 to 318^000 dry metric tons (DMI) per year (USEPA, 1990a}. The average for all mills is 26^644 DhfT per year, or dose to 73 tons per day (tpd). Sections 3.2 and 3.4 provide further analyais of the quantities of sludge generated and dispo^ practices used.

The term "land spreadingT refers ooUectively to land appU«tiott and distribution and marketing of sludge. Land sfgdication indudes the spreading or spraying of sludge on or below the surface of agricultural; forestry, or mining land Distribution and marketing (DAM) is defined as the give-away or sale of smalieiyolumei of puip sludge for spreading on home gard^ or for use by nurseries, golf ooutaca, recieation, park^ and public worka departmenta, farmers, and others, Sludge used for such puipoaea ia often composted with organic fiber nuuerial such aa wôd chips.

2J.1 lypeaof land apraedlng

Four separate lypea of land spreading are considered in this report The typical features of each are deaqribed in more detail below^ It should be rioted that practices may vary considerably among regiona, milla, and application sites. The characteristics presented here are based on descriptions fbuiid in the literature, and on cliacusaionB with individuaii femiliar with land spreading and land application programa. The recent EPA/paper industry study of all 104 bleaching miUs in

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the U.S. (USEPA, 1990a) providea information on the ^pe of land application used I7 inills, but lacks additional information to more fiilly charaaerize these practices.'

Anolication to agricultural land • Some pulp and paper mills make sludge available to formen for spreading on their fields. Farmers generally apply the sludge using their own equipment. Sludge is normally incorporated into the s^ while the fields are being prepared for crop planting. The same field or fields may receive one or more applications of dudge per year, over one or more years^ Both crop-growing and non-crop^growing fields may be used-

Application to forestry land - Sludge application to forestry land is tnually accomplished by spreading it on areas just prior to seeding or by spraying it in liqujd form either over or under the canopy of established tree growth. The forest areas are generally owned by the mill. A given site may receive an application only once every seraral years.

Application to marainal land • Sludge has been used succeufully in land reclamation or soil amendment programs in areas where soil conditions or topography have been greatly disturbed. Eanlples indude reclamation of abandoned stripmine, construction, or excavation sites. The goal of sudi programs is to improve the hospitality of the site to vegetative growth or to restore or improve the contour of the land. Eadi site normally receives a single, heavy application of sludge.

Application through distribution and marketine fP&Ml - DAM refers to distribution of sludge to home gardens, nurseries, farms, andiother commercial and non-commerdal users. Sludge destined for such uses is often oomposted, which increases both the content and bioavailability of the nutrients in the sludge^ For home use, the sludge may be packaged and distributed by a broker. Larger volume users may receive the sludge in bulk form, either directly from the mill or through a broker or other intermediary. Distribution to home users is probably not as common for pulp sludge as it is for municipal sewage sludge^ Many municipalities are currently operating programs for beneficial reuse of sewage sludge that includes distrilmtion for home garden use.

2J.2 Sludge fmnsportatlon and application

A variety of means of tranqmrt are available for moving sludge from the mill to the application site. Trucking is by for the most common, although pipeline, barge, and rail transport have also been used. Dewateredtsludge resembles inanure in its consistetuy and can be transported in general purpose, open-bed trucks, liquid sludge, commonly used in forestry application, is more watery and must be transported in unker trucks.

Sludge cut be applied to soils using the same trucks that transport it or with specially-equipped aîcatiOn vehicles. FCM' agricultu^ application, trucks may be equipped wth flotation tires to prevent soil compaction in wet conditions. Manure spreaders may be towed or attached to the rear of the trudc to achieve a more even distribution. Sludge can be incorporated into the soil by disking hamndn^ or plowing and this can occur either during or after application. In

' A survey being, prepared by the Office of Water in support of Qean Water Act revisions will provide some additional descriptions of land application and other sludge disposal practices among all pulp and paper mills in the U.S. Preliminary survey results are not expected until Spring of 1991.

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forestty application, liquid sludge is often pumped over or under the tree canopy using cannon-equipped tanker vehicles.

J Site preparation

Application sites commonly require some preparation prior to receiving sludge. The type and amount of preparation will vary from site to site, depending on the consistent of the sludge, iu nutrient profile, theNtype of. crops or vegetation being cultivated, and other site characteristics. Site preparation may be necessary for access of transportation and/or application vehicles, control of runoff and erosion, storage of sludge prior to application, or control of public access to application sitea.

23A Number of mills engaged In land spreading

Land spreading of sludge is a relatively recent practice in North America. The challenges of sludge management and dbposal practioes has arisen only with the more widespread practice of wastewater treatment that has occurred since the passing of the Qean Water Act. By fitr the largest source of sludge used in lend applieation are the more than 15,000 publicly-owned sewage treatment Csdlities that operate in the U.S. Recent dau show that about one-third of the sludge generated by these fimilities is now land-applied (USEPA, 1990h).

In the pulp and paper industry overall, there is currently no data available to indicate the total number of mills that use land application, or the quanti^ of sludge that is land-âppliedL The National Council of the Paper Industry for Air and Stream Improvement (NCASI) is preparing a Technical Bulletin that win Summarize the resultsof a survey on sludge disposal'practices; however, that information is w)t due until early in 1991 (Maltby, 1990). This will provide fiirther information on sludge dsposal practices lor both bleaching and non-bleachiiig mills. The Office of Water survey will also collect information covering the industiy ai a whole.

For the Ueacbed segment of the pulp andipaper industry, considerable data is available from vacioua cooperative EPA/tnidustfy'itudies. In 19M; EPA andNCASI jointly sponsored a study that

pracdce chemical bleachii^ of pulps (USEPA. 1990a); At the tune of the stucfy a total of twelve mills, used land apfdicatkm to ̂ pose of all or parf of their sludge. These mijlii accounted fbr 12 peroent of totalindui^ sludge generation. Of the twelve; -

1 <• >

• Qttsjiiill WIS praviding sludge fbr use in agricultural application • Twoi ihilti were piovidii^ sludge for use in sttipmine re^mation • PiQur miils were apptviny sludpe to forestry land • Fivemills were involved in distribution and marketing of sludge

is discussed in more detail in Section' Three.

From the EPA/NCASI data and other sources, the number of bleaching millsi current^ engaged in landappUcation is relatively small and in foct is declining. At the time of the study, five miUi indicated tlud th^ had previously used land application but had switêd to an alternative disposal method. Since then, at least two other miils are known to have suspended land

2-5

application' (Sullivan. 1990). These 'mills in particular have cited concern over diocdn contamination of aludgp aa their reasons for discontinuing land application.

Land application and ^tri^tion and marketing of sludge is an attractive medans of disposal because of itt low cost and the environmental benefiu it can produce. Alternative means of sludge disposal, such as landfillingand incineration, are costly and raise their own environmental concerns. Landfill ca|;raty Is becoming scarce, and high-volume wastes such as sludge are being refused by many municipal fodlities. Incinerator siting procedures are extremely difficult and expensive ill some states. Because of this, the beneficial reuse of sludge via land spreading is favored by a number of mills.

Recently, however, coiicem has been raised over possible contaminants in pulp and paper sludge, and the potential rislci they may present. In particular, a considerable amount of attention has been paid to the issue of dioaiis and fiirans (a related compound), in such sludge.

.w \

2L4.1 Baekgronnd to the dioxln Issue

Pulp and paper mills were first identified as a possible source of dioodn by the National Dioodn Stu^, whidi was begun io 1973 and published in 1987. Based partly on these findings, in 1986 theÂ entered into an agreement with the American Paper Institute (API) and NCASI to investigate diosin production and release in the pulp end paper industiy. The initial stutfy sampled five bleached kraft mills (USEPA, 1988), and found measurable concentrations of diaxin in the pulp, wastewater, and wastewater sludge generated at these mills? A subsequent study of all 104 bleached kraft and sulfite mills in the United States (USEPA 1990a) confirmed that dioxin's presence is correlated with the practice of chlorine bleaching. Data collected during this study, including quantities of sludge generated; disposal methods UsetL and dioxin concentrations, form the basis for mudi of the analysii of this report.

2A2 CentaminanCsofeoncarn

Diaadii is the generic name gtven to a fsmily of 75 chlorinated organic compounds. Of these, the seventeen 23*7i8-substituted oogenets are conudered to be of 'toxic concern' (Macartfi, 1991). The proposed regulations focus on two of the most toiic dioxin cogeners, 2J,7,8* tetrachlorpdibenzo-p-dloxin (TCDD) and 23Ji8-tetrachlorodibenzo-furan (TUDF)'. "FCDO has been classified by EPA as a "BT probable human carcinogen. Tests on laboratory am'mais have shown it to be exttcm^toaic'in low doaes^TCDF has a toxic equhmlency equal to 0.1 parts of TCDD (i.e., 10 parts TCDF equals 1 part TCDD). Theae compounds are part of the larger fomily

' At the time of the 104-mlll study die mills, both located in Wisconsin, were owned by Nekoosa Papers. Since then, the mills have come under the control of Oeorgla-Pactfie.

' Throughout this report, the terms dioxin, CDD/CDF, and TCDD/TCDF will be used interchangeably. TCDD and TCDF are the two of the most tagdc cogeners of dioxin and are alio two of the most common found in bleached pulp and paper mill slu^.

26

of polyhalogeiiated dibenzo-{hdioadns and dibenzofiirans (FHDDs and PHDFs) that are addressed by the SPA's May 1990 "Strategy for the Regulation of Discharges of PHDDs and PHDFs from Pulp and Paper Mills to Waters of the United States."

ZA3 Consent dscne

On October 22, 1984, the Environmentai Defense Fund (EDF) and the National Wildlife Federation (NWF) filed a citizen's complaint under Section 21 of the Toxic Substances Ccmtrol Act (TSCA), requesting EPA to use itt statutory authority to regulate dioxin emissions from bleached krafk pulp and paper mills. EPA initially denied the petition, prompting the petitioners to file a lawsuit in March of 198S fEnvironmental Defense Fund and National Wildlife Federation vs. Thomas. No. 85 - 09731. Before the case got to trial, a settlement between the plaintifEi and EPA was reached and a conspnt decree was signed on July 27,1988. The consent decree required EPA to perform a multiple pathway risk assessment to evaluate possible ecological and human health risks.

In response to these findings, an interagenqr work group was formed between the Food and Drug Administration (FDA), the Consumier Product Safety Commission (CPSQ, and several program offices within Â EPA's Office of Toxic Substances (GTS) was assigned the task of developing the integrated exposure and risk assessment. That report ("Integrated Risk Assessment for Dioixins and Futans firam Chlorine Bleaching in Pulp and Paper Mills") evaluated risks from the use and disposal of paper products, the discharge of paper mill effluent to water bodies, and the disposal and use of pulp and paper mill wastewater, sliic^

Hie GTS risk assessment identified six significant risk areas associated with pulp and paper productiom Three of these areas involved aqfosute through land application, including one classified as a "risk of ooncem' and two others as "risks of possible concern." These risk areas are:

TYPE OF RISK POPUIATION/SPEaES AT RISK

Risk of Concern aiqfiiication of pulp and paper sludge

Risk of Possible Concern

To humans and aquatie life firam oOiitamiiiated runoff originating from land-apfdied- pulp and paper sludge

Risk of Possible Concern

To fiarmers fiom lanttapfdied pulp and paper sludge

As a direct result of these findingib a decision was made on April 30, 1990 to propose regulations on the land appUeation of alut^ from bleadiing mills. These regulations uould be developed under the authority of the Toxic Substances Control Act (TSCA) and are to be published in the Federal Realster bv April 30.1991. ^ >

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SECTION TWO REFERENCES

Kline, James E 1982. Paner and Pacerboard; Manufacturing and Cbnverting Fundamentali. Miller Freeman, San Frandsoo.

Macardi, 1991. Personal communication between Jeff Cantin of ERG and Harry Macardi of the USEPA OWRS Sample Control Ceaten Aleiandiiai VA^

Maltby, 1990. Fersonai communication between Jeff Cantin of ERG and Van Maltby of National Council of the Paper Industry fbr Air and Stream Improvement (NCASI)^ Mlc^tt Region, Battle Creek, bfidiigan. November 27,1990.

Sullivan, 1990. Personal oommunication between Jeff Cantin of ERG and John Sullivan of Wisconsin Department of Natural Resources. December 7,1990.

USEPA, 1987. Tho Watitanal Dimdn Studv. tiers 3.S.6.and 7. (EPA^/4-874X)3). February, 1987.

USEPA, 1988. U.S. EPAff>ager Industry Qxmerative Diosin Screening Studv (llie S Mill StudjO-EPA-44(Vl-88^). March, 1988.

USEPA. 1990a. U.S. EPAff»aoer Industry Cooperative Diosin Studv (The 104 Mill Study*). Stttlsdcal Findings and Analyses. July, 1990.

USEPA, 1990b. Tgchnieal Simoort Documentation for Part 1 of the National Sewage Sludee Survey Notice of Availabilitv. Science Applications International Corporation (SAIC), Midxan, Virginia. Prellmiiiary Draft. (EPA Contract No. 68-GD-003S, Work Assignment 0-2). October 8, 1990.

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SECnON FIVE

COSTS OF DISPOSAL PRACTICES AND COMPLIANCE PROJECTIONS

S.1

This section develops estimates of the current costs of agricultural, fbrestiy, and mining land application of sludge; distribution and marketing of sludge; and disposal of sludge via landfill, surface impoundment, or incineration. Costs are developed for five representative size classes of mill. The cost estimates are based largely upon aigoiithms developed by EPA to estimate disposal costs for municipal wastewater sludge. These models have been adapted where necessaiy to reflect different^ beta^n the sludge produced by municipal wastewater treatment plants and that from pulp and paper mills, as well as differences in the handling, treatment, and disposal of such sludges.

The costs of land application and the costs of alternative methods of sludge disposal are used to project the complice choices of mills uiuler altematiye regulatory scenarios. These projections are also developed in this section.

Costs and compliance projemions far the regulatory alternatives are evaluated according to the following assumptions, wMch have been made for modeling purposes:

• A ban on land annlication cauaea mills to adopt the next least Cost disposal method. To assess the costs of alternatives^ costs have been developed for disposal using landfills, surfsoe impoundments, and incinerators. The additional costs of the alternative disposal options over land application are used to estimate the costs of a ban as well as any regulation that leads mills to discontinue land application.

A regulation that ifoposes concentration or concentration, and area limits causes mills that exceed the limits to diiwontinue land appUcatioiu Mills are assumed not to decrease their sludge application rate (to reduce the amount of dioxin entering the soil, posnbly enabling them to meet the soff concentration limits) or, alteniafively, increase the application rate (to enable them to meet area limits). While a range of application rates may be feeble in eadi case, the application rate is generally detenhined by the characteristics of the sludge and the soil, with the goal being to maximizB the benefito to the soil and vegetation. Since thb ana^ proceeds under the assumption that land appUcatibniS undertaken not merely as a meaiu of disposing of sludge, bid rather to ptovide some benefits, mills are assumed to not a<yust sludge application rates in order to meet regulatory limitations on soil concentration or on the size of land application sites.

Less sirineent limits that permit continuation ofland aoollcation leave mills that are ciurently engaged in land application unaffected, so long as any additional costs imposed by the regulation are less than the cost advantages of continuing land application If a mill meets all of the technical requirements of the option, yet irUhirs sufficient additional costs (e.g., for monitoring sludge ContaminSnU), land' application may cease to be the least-cost disposal alternative. In such cases, the

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mill ii assumed to abandon land appUcation in favor of the least costly alternative means of dispoul.

A final assumption concerns whether some mills not currently involved in land application might switch to land application once regulations ate in place. This mi^t occur, for eaample, among mills that previously used land application but which stopped the practice because of concern over diagdn releases or regulatoiy action. Other mills may have resisted the economic incentive to use Uiid appUcation for simiiar reasons. A ngulation that permits continuation:of land application could potentially lead mote miUs to begin this practice. For this report, ERG has not considered the effi^ of miUs switching to land appUcation under leu restrictive concentration UmiUi The posslbie impaess of mills that may revert to land appUcation or svntching to land appUcation from some other disposal method foUowtng pubUcatfon of the regnlation may be examined at a later date.

In 1985, EPA published a handbook entitled Estimatina Sludee Management Costs (EPA/62S/6ÂllO), to be used by municipalities in estimating tiie costt of matuging sludge from wutewater treatinent frdUties (hereafter referred to u the EPA Handbook). Ihe manual wu designed to permit ea^ comparison of costs among a number of different tiudge management altemativu. Coet curves for each proeou were derived that aUow the user to obtain approximate capital and operating and nmintenance (O&KQ costs for a variety of sludge maiugenient ptocesses. Ihe cost curves, and the algorhluns on which thqr are based, were used to develop estimates of regulatory hnpacts for proposed munldpal sludge disposal regulations under the Qean Water Act (EPA, 1989).

The cost curves were of limited use for this arialysis, because they relate treatment and disposal oosu to annual sludge volume only, and do not account for other variables that could affect cost. The curves, however, were developed from computer algorithms that can accommodate site-specific values to predia more accurately the management costt for a particular facOitir. ERG converted these algorithms to spreaddieet format in order to modify them to reflect differences between management and disposal of municipal wastewater sludge and bleached pulp and paper mill sludge.

Spreadsheet models were developed for each sludge disposal method, including separate components, vtiiere appropriate, fon (a) transportatioii of sludge to dispo^ sites; ^) dewatering and,composting of riu^; and (c) final dispo^ either throu^ land application, distribution and marketing or indneration. Enêering estimatea, as es|dalned below, were used to develop costs for dispose via landfill and surfsce impoundments.

ERG also made use of engineering estimates of costs to model the disposal of sludge to landfills and surfece impoundments. These costs were developed for ERG by DPRA, Inc., an engineering contractor to the EPA Office of Solid Waste (Lou|^ and Smith, 1^). -

5-2

Estimates of the volume of sludge (in gallons) generated annually by mills in each of the Sve hypothetical size classes were protdded by ERG to DPRA. DPRA then calculated the size of landfill or impoundntent required to hold this volume using standard engineering assumptions regarding facility depth and lifetime. For surface impoundment, it was further assumed that three facilities would be built per site. This is based upon the observation of Abt Associates (USEPA, 1990a) that industrial facilities in an EPA survey of nonhazardous waste disposal had an average of three impoundmenU per site (USEPA. 1985). DPRA then used the size of landfill or imfûndment to calculate construction costs and annual operating and maintenance expenses using their own costing algorithms.

Costs for construction and operation were developed under two scenarios regarding regulatory requirements for the fadlitiea The first assuined no special requirements for construction of landfills or surfoce impoundments while the second incorporated a 3-foot day liner for surface impoundments and a liner plus leachate collection system for landfills. Several states contacted by ERG, induding Maine, Wisconsin, Georgia, Mississippi, and Maryland, require lining and leachate collection for industrial sludge landfills. This list indudes most of the states where mills currently using land application are located. It was assumed, therefore, that mills switching from land application to landfill or surface impoundment disposal as a consequence of the regulation would incur costt of induding such protective measures.

DPRA also generated estimates of the costs of complying with alternative facility closure requirements that inillt may foce. Federal requirements for dosure are performance-oriented, and provide only guidelines for use 1^ the states in setting standards. States, therefore, may have requirements in jdace that spedfy the actions that must be taken following dosure of a landfill or surface impoundment fadlity. DPRA provided estimates of coStS for three different types of dosure oplfon. These are described below:

• Final Cover - uSe of native soil to construct a pyramid-shaped cover over the landfill or surface impoundment. The purpose of the coyer is tO' prevent erosion of buried materials and to promote drainage of surface water resulting from predpitation.

of the impoundment to grade following the draining or pumping off of free surface water.

• Berm constructioA of an earthen berm to enclose the landfill or surfrice impoundment The purpose of the berm is to contain suifoce water run-Off due fo predpitation. The berm would be btult IS meters from the edge of the fadlity and would have a heigfot of 18 inches.

• Stormwater Basin - Installation of a lynthetio-lined basin for storing surface water run-off Run-off would then be pumped back to the wastewater treatment fadlity.

Detailed infonnation oa states' dosure requirements for sludge landfills and surface impoundments has not been collected to date. EPA requested, however,^t costs for final cover construction should be induded in estimates of the costs for landfill and surfsce impoundments.

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5.4 Coat! for Bcnn« Around Application Sltet

Costs for ooiutruction' of benns to surround application sites were calculated from data provided by DPRA. Inc. ERG adopted DPRA's berm coste for landfills and suriface impoundments and extrapdated these to berms for application sites. The beim costs have severd components, which have been adopted for land application sites as follows:

MgWlfaatiPn/^lempbiliMtign of wnatnifftign MWiPlfffflt- ERG regressed these costs against the landfill size to obtain an equation that permitt calculation of ooiutruaion equipment cosu for any sized site,

• Construction costs. The DPRA algorithm uses a unit cost of $21.90 per linear meter for calculation of berm construction costs. Given the dimensions of the application site, construction costs can be estimated using this unit cost, ^rplication sites of even dimensions were assumed to fadUtate calculations,

.• \ Engineering chtsjgn copMnPtioniiwwglwn fw Tliesc fees are set at S percent of the construction cosu, as per DPRA's cost estimation methodology,

• Contractor's overhead and nrofit. This is set at IS percent of berm construction costs, as per DPRA's cost estimation methodology,

• Contingency. A contingency equal to 5 percent of total cosU (Including fees and overhead) is induded, also per DPRA's cost estimation methodology.

As shown in Table 5-2 (Section 5.6), the cosu for berms range from $140321 for a mill generating 3,750 DNTT per year of sludge and applying this volume to agricultural or forestry land at a rate of 49 DMT/hectare, to $666,063 for a mill produdng 75300 DhO*. These cosU assume two application sites per mill. Cosu for berms at forestry sites could in fact be more expensive than

, estimated if significant additional land dearing is required. For miningi agricultural, and D&M sites, the berm construction cosu are assumed not to be borne by the mills, but rather by farmere, mining companies, or others. In mining projects, the sludge application rate is higher, hence the size of site - and foe cost of bemu - is lower. The reverse is true for DAM, as application rates are assumed to be only 10 Dhfl/ha, versus 49 DNfT/ha for agriculture and forestry.

5.5 CoaU of Sludge Management Reauirementa

The proposed regulation will Indude additional requiremenu to insure responsible use and distribution of sludge. These management requiremenU were presented in Section 43. and include:

Sludge and soil sampling and testing; Recordkeeping requiremenu; Notification of EPA; Vegeutive covers; Restricting flow of base flood; and No application to frozen, snow-covered, or flooded land.

5-4

The costs of most of the management requirements will be home by the mills themselves. In some cases, sludge may be distributed for land application by an outside party, where this occurs the distributor may also incur some compliatice costs. Without further information on the use of distributors, it is assumed that all sludge is distributed by the mills.. Owners of land application sites may also incur some costs, as explained below.

Estimates of the cosu of the sludge management requiremenu are presented in Table 5-1. Part A of the table covers costs that will apply to mills engaged in land application, while Part B covers costs to any parties beside the mills (distributors, land application contractors, fanners, etc.) involved in land application activities. For each mill* there are assumed to be two such "other" parties, who will be required to sign agreements with the mill to ensure adherence to all procedures specified in the rule. Depending on their involvement in land application activities, they may also incur compliance oosts^

f • • •

To simplify the analysis* the costs of complying with the sludge management requirements have been assumed not to vary with the size of Ae mill or with the quantity of sludge generated. In actual practice, some variation may occur. Larger mills, for example,:may set up more elaborate tystems for traddng sludge volumes, keeping records, and sampling sludge. The cosu are estimated, however, asauming an average-sized mill generating an average volume of sludge.

The categories of eosU are discussed belOw. Tn some cases the cosu of certain management practices are either neîgible or were judged to be captured by the scope of other requirements. Sudi requiremenu are induded in the disiîon, but estimates for their cosu do not appear in the cost table. Some of these management practices may already be in place at some mills, depending on the state regulations that apply or cunent mill practices. AttempU have not been made to aeobunt for such praedees, rather all identifiable cosu are assumed to be incurred by all mills.

5J5A. Sludga sampling and tasting

The mills will be required to follow a protocol for sampling and analyzing sludge. The procedures are relatively straightforward, but require some combining and mixing of samples to ensure ihey are representative. The mills will likely draw the samples themselves and send them to a laboratory for independent analysts. Part A of Table 5-1 iiidicates the burden hours and cdsu assodated with dudge sampling; Ih^ estimates assume relatively liquid sludge stored in a lagoon. Sampling will tlmefore require use of a small rowboat and relatively more time to draw the required sample. Sampling of dewatered sludge unll be mitch less oomiriicated. SampUng.will require approziiiiately 36 person-^houfs each quaiter, for a total burden of 144 hours and $2,685 per year (collectitm acthdly #4).

As Indicated; sampling will occur quarterfy; with oife sample submitted for analysis each time;. The samites are to be assessed using an analytical protocol known as Method 1613, developed by the bidustrial Technofogy Division (TTD) of the ̂ A Office of Water. Laboratories

the testa in aooordance with it CCMU per sample using Method 1613 will range front between $1,450 and $2,000 per sample (Millie* 1990). For thia analysis* it was assumed that one sample per quarter will be tested at an average cost per sample of $1,800 each,

5-5

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5JJS Reoordkieeping requirenicnts

Each mill that diaposes of or distributes and markets bleached sludge using laiid application will be required to develop and maintain records on the quantity of sludge land applied or distributed and marketed. Specific items that the mill must record and maintain include:

• Location of the site, including full legal description;

• Area of the site, in hectares;

• Original United States Geological Survey (7.5 minute series; or if that is unavailable, 15-minute series) topographic map. indicating application site location and boundaries;

• Prersludge application TCDD/TCDF soil concentrations at the site;

• Total quantity of sludge applied to the site, by weight;

• Total amount of sludge applied to each hectare, by weight;

• TCDD/TCDF concentrations levels of the sludge applied at the site;

• Original laboratory reports Concerning sludge and soil TCDD/TCDF testing for the site;

• Method used to apply the sludge (e.g., surfisce spraying, spreading, or injection into the soil) and a statement about wheAer and how the sludge will be incorporated into the soil;

• Biannual site inspection observations and dates;

• Last date of application for the site.

Mitts or others that distribute and market sludge will be required to maintain records of the names, addresses, and telephone numbers of all persoiu receiving sludge, the amount of sludge received by each, and the most: recent TCDD/TCDF testing results on the sludge. In addition, for each application site, the site*spedflc infbrmation listed aê will be required

As shoiwn in Fart A of Table Si-1, the recordkeeping requirementsirelatedto land application are estimated to impose an annual'burden of 120 hours and cost of $1,669 ibr each mill engaged in land application (collection activity #2).

Sludge distributors or Othen engaged in sludge application are required to si^ a statement or agreement, to be kept on file by the mill, in which th^ agree to comply with all of the procedures covered in the regulation. Costs for familiarization with the regulation and review of the agreement have been asrigned for such individuals. An average of two parties per mill are assumed to be involved in the land application program, These could be either brokers, distributors, application contractors, farmers, or others. It Is assumed that each of these incurs costs

5-8

of $1,438 based on 10 hours review of the agreement and the regulation by legal counsel and 10 hours by management staff (T^le S-1, Part B).

SJJ Notification of EPA

Each manufacturer or generator of chlorine bleached pulp sludge is required to provide 4S days written notice to EPA prior to the commencemerit of land application activities. Each notice is to contain information on the following:

• Name and address of the manufiscturer or generator of the sludge;

• Name and address of the distributor of the sludge;

• Name arid address of the person applying the sludge to land;

• TCDD/TCDF concentration of soil at the site;

• TCDDflCDF concentration of sludge to be applied;

• Originai United States Geological Survey (7.5 minute series, or if that is unavailable. 15-minute series) topographic map, indicating application site location and boundaries;

• Certificate stating that the mill has the legal rigjits to apply sludge at the site;

• Certification that all information supplied in the notice is accurate and complete.

The costt for collecting this information or otherwise satis^ng the requirements of the notification are included under items discussed elsewhere in this section (e.g., recordkeeping). The costs of providing this information to EPA once compiled is assumed to be minimal^ requiring 8 hours of labor at the technical level (collection activity #3, Part A of Table 5-1). .

55A Vegatathe covsr

Thetegulatfon will require a permaiient vegetative cover to be established on all stiea vdthin 30 days of reoeiviag an appfieation of bleached pulp and paper mill sludge^ The intent of this requirement is to ensure that land apfdication sites are not left bam, and hence subject to erosion, following sludge applicatimi. Once established, the integrity of the cover must be verified twice annually throu^ ihspection by a certified agronproist or soil scientist.

Since aiudge is often applied just prior to planting (e.g., at agricultural or forest nurseiy sites), or applicia itO'established gtoaah areas, (cg^ woodlands), this requirement is generally satisfied under current practices. To the eatent that there may be land application sites that are not immediately used for idantin^ or which are seeded with species that will not emerge within the 30-day period, some additional costs may be incurred. Based on discussions with a contractor involved in pidp sludge land application, some representative costs for the establishment of a permanent vegetative cover have been developed. The estimates are based on a Site size of 459 ha,

5-9

which would be the amount of land used a mill to apply 22,500 DMT of sludge at 49 DMT/ha (22,500 DMT is the middle range of sludge generation volumes used in this analysis).

Cost Category A4)plication Rate Cost

Annual seed* $0.18^$0.60/lb x 80 IbVacre $14.40^$48;00/acre Perennial seed $lJ50-$3.00/lb z 35 lbs/acre $52.50-$105.(X)/acre Application $20.00-S60;00/acre Incorporation S50.00'$60;00/acre

Range of Cost $136.90^$243.00/acre For site of 1,134 acres (459 ha) $155,245-5275^62

Source: Ginn (1990). *

Note that these estimates represent the costs that would be charged by a contractor. Where an individual land owner undertakes the seeding, coats could be lower. One estimate of the costs to farmers for seed, seeding, and incorporation in Cumberland County. Maine ranged from $60 to $85 per acre (Truilaw, 1990)^

In some cases noncompliance may occur because the crop or tree species planted do not emerge within the required 30-day period. Here, a cover of cut hay or mulch could be applied temporarily. ERG obtained estimates of $413 per acre for a cover of cellulose wood mulch (Grey, 1991) and a range of $500 to $1,125 per acre for cut hay (Gallo, 1991). The range for cut hay reflecu dififercnpes in costs arising from application to sloped Sites. The costs include both costs of material and costs of application. Using an average of $500 per acre for either hay or mulch, the costs of covering a 459 ha site (1,134 acres) is $567,095. Both these costs and the costs for seeding are provided for informational purposes only. Current practices at land application sites are assumed to satisfy the regulatory requirements. Given these considerably hiêr costs, it is likely that hay or muldi would be used only where vegetation could not be readily established.

Compliance with the requirement for inspection of vegetative covers will impose an estimated burden of 32 hours per year at a cost of $810, These estimates are based on the assumption of two sites being iiupected twice each year by a certified agronomist or soil scientist at a professional wage of $2530.

5SJ5 Reatrici flow of base Qood ' V

Under the regulation, sludge may not be applied in such a manner that it (1) restricts the flow of a base flood, (2) reduces the temporary water storage capacity of the floodplain, or (3) poses a hazard to human health, wildlife, or land or water resources because of sludge in die runoff of a base flood. ERG has not interpreted this requirement to indicate that additional studies or analyses are necessary to identify whether sludge application may interfere with base flood activities, only that appUera should •avoid application in areas that esperience frequent flooding. Noi additional costs are ascribed to this requirement

* Some annual seed is included to ensure more rapid appearance of the cover.

5.10

53.6 Nd application to frozen, snow<covercd, OF flooded land

Application of sludge is to be limited to sites that are free of frost, snow, or flooding. It is not anticipated that compliance with this requirement would require changes in practices, as application to such sites would provide little benefit

The Current costs to milis of land application have been developed for five represexitative size classes of mill, those generating and disposing of 3.750,11.250,22300.40,000, and 75,000 diy metric tons/year (DMT/yr). these costs are used to derive the baseline costs of sludge disposal for those mills currently engaged in land application.

*

A minority of the 104 mills, as noted in Section Three, use more than one disposal method. For example, several mills dispose of some sludge to landfills and distribute and market the remainder. The disposal costs shown below in Tables 5-2 and S-3 indicate there are economies of scale with regard to disposal volumes. Thxis, mills will benefit from lower per-ton disposiai costs if they use a single disposal method. ERG recognizes that other factors not captured 1^ the models may lead some mills to use nsore than one disposal method. It was not possible, however, within given time constraints, to consider eveiy possible combinatiqn of disposal choices.

In light of the above, the six milb that currently Use land application in oonjunction With one or more additional disposal methods are modeled as thou^ they land-apply their entire sludge volume. This results in an overestimate of the total quantity of sludge that is disposed of through land appUcatipn or distribution and marketing. The magnitude of the overestimate is unknown. Of the 352,470 DUCT of sltidge estimated to be land-applied, however, the six miils that use land application plus one or more other methods aoodunt for tq^rozimately 37 percent. To the extent that some of this sludge volume is not land-applied, the obsts and benefits of the land application regulation will likewise be overstated.

ERG developed a set of assumptions regarding the categories of opsu borne 1^ mills involved in land apitiication. These assumptions are bas^ either on judgements made iby indnstiy petaoimel, case studies reppFted in the literature, or assumptions needed to describe the paitibiilar inill drcumstances. Because of the amalli number of mills involved in land application and the paucity of infonnatipn concerning their operations, this characterization of land tq^cation programs is sutijea to some uncertainty. Variatkms on these praotices could be expected due to case^pecificla^n that cannpt be fully anticipated. Nonetheie^ the foUowing represent the main assumptions reganSng land applicatidn programs:

Agricultural aoplicatibn - Mills are assumed to dewater their sludge and deliver it to farms partidpating in the land application program. Farmers incur ai^ costs of site preparation as Wdl ai the costs of'applying the sludge. The oosbi to the fanner are not consi^red'by the mill in making decisions regarding sludge disposal. In Section Six however, they are counted as part of the total cotta of this disposal option.

Forestcv aoriication - Mills are assumed to transport liquid sludge to forested areas which they own. The mills incur the costs of both transportation and appiicaiion. Site preparation

5-11

ooita, such as the oonstrucdon of xoad^ys for sludge application vehicles, are assumed to be incurred as a matter of normal forestry practices and are not included in the cosu.

Mining aopHcation • Dewatered sludge is provided free by the mills. Mining compaiiies involved in land reclamation projects incur the costs of transporting sludge, preparing the site, and applying the Sludge^ These assumptioiu are reasonable given that the mines would othermse have to purdiase suitable material to use for fill, conditioner, and fertilizer.

Distribution and marketing - Composted sludge is assumed to be sold to a broker, who arranges for transport of the sludge to his storage and distribution fadlity. The mill incurs the costs of-Gomposting but receives payment for its sludge to of&et these additional costs. The broker in turn sells the sludge in smaller quantities to a variety of types of users.

Other assumptions concerning the value of variables and parameters that were chosen and Used as input to the cost algorithms are discussed in Appendix A.

6ased on these assumptions. Table 2-2 shows the cosa incurred by mills for agricultural, forestiy, and mining application as well as distribution and marketing. The table shows the total costs and the oostt per ton of each land application option for five hypothetical mills generating between 3,750 and 75,000 DMT/yr. The table shows there to be economies of scale associated with each type of disposal, as lower costt per ton are associated with larger volumes of sludge^ These economies may affect the ranking of alternatives for different sizes of mill. For example, forestiy application is less costly than DAM for mills in the first four size classes only. Above 40,000 DMTtyr, mills would choose D&M over forestiy application.

Hie relative costs of the various land application options can be compared by considering a mill in size dau lU, assumed to generate 22^100 DMr of sludge annually. The costs to this mill of the various disposal options, ranked (font lowest to Ughest, are: mining apidication ($30 J5/DMT), agricultural' application ($40.4Q/DMr), forestiy application ($75.56/Dh^, and distribution and marketing (S92.il/DMT).

5.6.1 Costs incindlng management practices

Regulatoiy Options 14 through 24. which impose soil concentration and area limits on land application^ will also require mills to adopt certain new management practices. These practices ate designed to ensure that the land apfdication, distribution and marketing and disposal of sludge is carefully monitored and controlled.

Theoostiofthe management practices are summarized in Table 5-1. Fart Ashowsthe costs for mills engaged in land.application or distribution and marketing of sludge. The cost to each mill of complying with the management requirements is estimated at $23,086 per year. In Part B, costs to other parties engaged in distribution and marketing or application of sludge are calculated to total $1,438 per party.

5.6.2 Cbsti including benni

The requirement for oonstructibn of berms surrounding application sites increases the costs of land application substantially. In agricultural application, the costs to a mill in the smallest size

5-12

TABlES-l

h'FN'i'inmnrimw

tiiiii M Olapaaid UaOwO • II III IV V

COMB iMiumd by Uilla •owMiing TimpeitMian

8177.830 884»

8388087 ' 8138048

8882041 8328078

81031087 8408072

81027.410 . 8720228

Toiii CoWOMt

S241.7SB 804.47

8821,818 84808

8808920 840.40

91.439088 S3IOO

82.047.838 827.30

CcoPOMT BomdpOon

CoMOWT illl 8a3joao

848.41 8248718

8700S

823088 841.42

8381038 8S708

823088 83808

8478008 84848

823.088 827.81

8888083 83848

ForoMy AppHoadon

CoM lfieufiod by una

®8b prop * opploodon 8222010 8104084

8808478 8310028

81027040 8828280

82042044 81.102001

84.382.171 82.007082

(841080) l2123JSai (8347000) 9440000) (8828000)

CbMiHT 8288010

tn.i7 8081082

87807 81.700.000

S7308

B it 88094.423

87408

OOM^' BonnOpden

CoipDMr

822000 88302

8140021 811804

822088 877J2

8aw«

822080 87000

83B1J38 88202

220080 878.70

8470008 88740 ili

i

MbdngiAppaoMtan

CooiiliieunodbyidUis OowiiiiinB 8177.830 $308487 1882041 S1O31087 81027.410

TaM CiM«Dlfr

COMIDMT BiimOp|ioii(el

CMOUT

OMMonAMiriMlnB

tlTTMO UIM

tUfM tssin

S«410 t70.14

S389M7 IMJB

t23jM i3Bja

S10IU012

ssi»S4t . sabJS

uivsr S13a2M

•M.it

S1^M7 S2SJP

sasAo S2tJ7

S9IJ1

stja7.4io 117.70

S23.dU ItOill

S2S9i02l 821.70

PpbiliilltB

Ravinua (Ida alpdaipaa0(8]

8177030 8382413 (1110 JWIB

$9UJ949 (818209d

8882041 81.784,740 (9388.187)

81.021087 82O84043 (8049022)

81027.410 83474.080 (81417431)

Tool CoMfpMT

8480078 81290B

81.127019 810028

82072094 892.11

83087000 884.10

8SO84409 871.78

CpMlOMr BannOpOen

CoMIOMT

822098 813104

8310OH U18uB8

822090 810230

iiilitril 81S24B

823090 8813.13

81821027 812904

823080. . 884.70

81,130042 811301

823.088 872.10

81418049 80348

M UMIIMGI dnrmNio

pondM vrnmnuen rnd d^pomttajBOi ujao.2zaao.*afiao.wid78M» (DHt) olipulp:andpi|wiluilao:iMrvav.

[b] 8l1pwl)¥rel«lutfîppild*baMdanmiMmi«ainpa {a| QatMopOaiililMtaOTOv.ihnitaiingippltsiilanawiipiMd

•iudg* •ppBplon IMM pMinii MMMT ipplleMlon oiio itM lora (d| Bond on an aiiiiinpOon of 83joaryd3 or 88 Jt/lan;lor eompoiiH

•nriboMUM

5-13

class under both the berm requirement and the management practices are 52 percent higher than the costt under management practices only. Cost increases for mills generating larger quantities of sludge would be lower. Since the perimeter of the application site increases at a lower rate than the area of the site, the cost of beims per hectare or per ton of sludge applied will decrease as the area or sludge volume rises. In forestry application, the berm requirement increases cost for the smallest nulls by 45 percent, while in mining the Increase is 31 percent. In D&M. the inclusion of the berm requirement increases costs in the first size class by 64 percenL It should be remembered that the berm costs are calculated using an assumption of two land application sites per mill. Also, in some cases the mill will incur the costs Of berm coiutruCtion while in others the costs may be incurred by the owner of the land application site.

5.7

Ihis section develops estimates of the costs of using alternative methods of sludge disposal. These estimates will be used to calculate the costs to mills that fail to meet the requirements of the regulatibn, and subsequently abandon land application.

The primary alternatives to land application are:

• Disposal of sludge into dedicated sludge landfills. These are assumed to be coiutructed on site and operated by the mill

• Disposal of sludge into surface impoundments, built and operated on site by the mill • Inctneration of sludge using dedicated, fluidized bed incinerators • Disposal of sludge in municipal landfills. The mill pays a "tipping fee to the

munidpaJity, generally based on the weight of sludge disused.

To develop costs for. mill-coiutructed landfills and surface impoundments, ERO used estimates provided by DPRA. Inc. for the five size dasses of mill being evaluated. For indneration,

. the EPA Handbook wai used. It contains a costing dgorithm spedfie to the burning of sludge in fluidized bed indnerators. For mills using municipal landfills, obtained several estimates of tipping fees charged for disposal of pulp and paper sludge, and also compared these costs with general tipping fees for munidpal solid waste provided by the National Solid Waste Management Assodation (NSWMA)^

As with land apidication, several assumptions were made regarding the logistics assodated with each of the dispel alternatives:

Dedicated landfill - The mill is assumed to construct the lahdfili on company<awned property, pewateied; sludge will be transponed by trudc to the landfill, whidi is located approiimately 2 miles from the wastewater treatment plant. The landfill capadqr is destgncd assuming a 14-year lifetime (DPRA assumption). For ground water oontamination control, the landfill is assumed to include a 3-fbot day liner with a leachate collection s]^tem. This is consistent with regulations in place in many states, including those in which there are mills currently involved in land application. Upon closure, the mill is assumed to cOnstiiiGt a vegeutivc cover over the landfill, also in accordance with the mirrent requiremenu In several states.

5-14

Surface imiaoundment - The mill is auumed to construct three impoundments whose oombined capacity will hold 14 years' worth of liquid sludge. The modeling of three impoundinenu is based upon EFA's survey of nonhazardous waste disposal, which indicated an avenge of three impoundmenu per site (USEPA, 198S; cited In USEPA, 1990). The impouncbnents are assumed to be used on a rotating basis. Sludge is pumped to the impoufidments where it is allowed to settle for a period of time. Free surface water is pumped off prior to the impoundment being placed in service again. The impoundments are also assumed to be built with 3>fbot day liners and to be dosed with a vegetadve cover at the end of their useful life.

Fluidized bed incinerator - The indnerator is assumed to be housed in its own fadlity at Or near the mill. Cosu of oonstruction of the indnerator are Induded in the analysis. Indnerator size is primarily a function of the volume of sludge to be burned, the sludge water content, and its volatile solids content Dewatered sludge with a 4S percent solids content is assumed to be burned; To achieve this degree of dewatering^ the mill incurs dewatering costs that are 30 percent higher than normal^ Operation of the indnerator is on a continuous basis, with 6 days per year of shutdown assumed; The EPA algorithm does not indude costs for pollution control due to the wide variety of state and federal requirements. ERG has induded a cost premium of 2S percent on both annualized construction and annual GiftM costs to capture the cost of compliance with regulations in a relati^ly res^ctive geographic location (the range of cost increments could be between S and 45 percent, based upon conucu with several manufacturers). With the exception of diagdni indnerator ash is assumed to be relatively benign. According to NCASI, it is not possiUe to make a general condusion concerning the fate, of dioadn in sludge that is incineraied (Miner, .1990). The effectivenessof indnerators in destro^ng dionn will depend upon mai^ Esctors, induding sludge characteristics and. incinerator operation, and has not been subject to detailed investigation. For this analysis, incinerator ash is assumed to be disposed of onsite, consistent with current practices ̂ SEPA1990), in landfills. Costt for sudi disposal are derived using the engineering cost estimates used for landfill disposal of sludge.

Disposal to munidoal landfills - Of the 62 mills that dispose of some sludge to landfills, at least IS use muhidpal landfills. In most cases, mills enter into Contractual arrangements with the landfill and pay a spedfied rate for sludge disposal, usually on a perrton basis. In others, mills would be charged the regular per<*ton disposal rate that would be paid for disposal of municipal solid waste. made contact with several landfills whididirrently receive pulp and,paper mill sludge to determine the arrangements made and the costs. Fees Of $10420 per wet ton of sludge were being charged at such Eadlities (costs on a dry ton basis would be considerably hijêr). A comparison of these charges with the rates charged for municipal solid waste was performed Using the results of the 1988 Annual Tip Fee Survey conducted by the NSWMA (see Section Six for more information), the average fee among Esdlities surveyed was $26.93 per ton. Based on this comparison, tipping fees of $30 per ton for dewatered sludge were used, this cost is higher than that currently received for disposal of sludge, but is justified because facilities willing to accept such wastes are

' For a 22,250 DMT/year mill, this increases the total costt of indncraticm by 7.0 percent. The total costs, therefore, are not paiticulariy sensitive to the cost increase foctor chosen.

5-15

beooming increuingly diSGciilt to find. Mills switdiing from land application to contract disposal would almost certainly face tip fees of S30 or more per ton.

Table 5-3 shows the estimates of disposal oosu for land disposal alternatives for the five size classes of mill; In pomparison with the costs for land application,.shown in Table 5-2, the disposal alternatives are more costly. For a mill in size dass III (22,500 DMT/yr of sludge), land application oosu would range from $30JS/PMT for mining applicatim to $92.il/DMT for D&M. For the

surfoce impoundment) to $l(QiOQ^Mr (disposal at munidpal landfill) per year. The cost results for a mill in the middle size dass under each alternative, along with some ezplanatoiy notes, are summarized below in decreasing order of costs:

Disnoaal to munidoal landfill - Costs of Slfi2.G0/DMT were obtained under the following assumptions: (1) thte mill transports dewatered sludge 40 miles round trip to a munidpal landfill: (2) tipping fees paid at the landfill average S30 per wet ton; (3) Since dewatered sludge is 75 percent water, the cost per diy ton would tw four times the wet ton fee, or

* )tl20i. It must be noted ttet, while these are reasonable estimates of the costs to mills currently using this disposal option, not all mills would feoe the same costs if they wished to use munidpal dispoMl. RoBent trends indicate that tipping fees are rising rapidly, and few mills would be able to obtain sludge disposal services at the rates dted above. For some mills, munidpal diapoaal may not even be an optiom depending on their location.. Munidpal landfill space iS becomiiig more scarce in many regions, and states are already restricting the disposal of sludge into munidpal landfills. Thus, udiile these costs may be low, making the option seem attractive, in practice it is quiddy becoming less cost-effective.

Indneration - Incinmation costs would average $139.75 per DMT using fluidized bed indneratipn. The costs indude the costs for construction of the indnerator as well as annual maintenance and operating eipenses. As the costs generated by the EPA algorithm do not indude the cosu for pollution control equipment, ERG incorporated a fector of 25 percent into the model. This represents the approximate increase in both construction and annual operation and maintenance costs that would be required to comply with regulations in a relatively restrictive geographic location, based on discussions with indnerator manufecturen. (The range of cost increment is from 5 to 45 percent). A further adjustment was necessary to reflect the frmt that sludge must be dewatered more thoroughly to achieve the solids Content of 45 percent for incineration. ERG estimated the cost increment that would be associated with attempts to dewater sludge to this solids content. ERG estimated that costt of dewatering sludge to 45 percent solids would be approdmatdy 30 percent higher. Ash disposal cOsts, as modeled, contribute a considerable component to the overall cost of this option. «

Dedicated landfill - Construction, operation, and closure of landfill disposal sites on company land is estimated to cost S113^4/DhO' for a mill in the 22^500 DMT/yr class. This includes corutniction of the landfill, including day liner and leadiate collectionsystem, truck hauling of dewatered sludge to the onsite landfill (assumed to be 2 miles from the wastewater treatment plant), and construction of a final vegetative cover prior to dosure.

Surface impoundment - SurfeCe impoundment represents the lowest cost disposal alternative for all size classes of mill. For a mill disposing of22,500 DMT^, the costs of %9S AS/DMT

5-16

TABLE 9â

tUSba M Olipoul MMted IV

LM\d«pi|

Cominramdbyuiito

TraMpwoiliMlel CtoMM - FIMICOVW

10AM

Sub-Toui CoMOUT

SuftaM t(b|

CMalhoumdbyUnA AiHiwIMeonMiiGiiaii and OAM CtoMM-^niuiCeiiMr

COM«MT

CM OMMMdnoM InalMiMla

n l!M

Sub-ToMl CMUOUT

iMipMiandlia

CdMI

Tm TIppfeigtaN

Su»<^TaMl ObaUOMT

i by Mais

(dl

9177330 9200,163

139,7U

9009^497 9901300

979,930 OOOiSOl

91300393 9ilZ093 9904390

91.031397 92.090398

9190314 9411.730

91.327.410 94.992349

9201.722 S900L779

9991.407 914709

91399,701 913091 it 94321.417

910AO4 97.472.450

900.93

9091309 991,009

9030343 9104309

91,731303 9419390

92,097.040 9701330

99.431339 91.999309

94101030 91iai4

91,130,939 90030

92.147343 98930

93.790.479 90424

87390334 90431

92391700 9400379 9100320

974300

9001.107 0079300 0319300 0104303

8037303 91300390

9379404 9374303

91341393 92.400300

9907297 9907300

91.729333 94^00307 91302,034

9909L974 9210.11

91.707,170 919039

U,144370 113970

99.039.909 912930

901414.763 911220

9177300 990.701

tUHMMW

9309497 9134329

-91300300

9902341 9209100

98,700300

91331.997 9494340

94300300

91327,410 9919374

19.000300

9710331 OlOdiO

91390303 910020

93344341 910800

99200338 9197:40

91.1.143.494 914939

(a| HMSOMilSiSM > BIIMPOIIIIID gynwilsiianddhpcsMaa0.780111300.03300.4B(,0fl0.sw<79300 maoto ioM (OMl) el pulp andipapar akidBOipar yMT,

tU AaiaianaBlaiidOUMatiillMlmpauiiOmaMlioonaOuoiadoniaompaiiy-ewiioOland |e| AaaianaB4-mllif«md:bip. |d] DMiMeibiBCcaM awiOOMWqhaalafaludgaibuimd In iiialhaiMBie baaeuaa atowamwIabaeqGnMmlB

nquirart. (a| inebidaa29%pMiiilHnilorpo0u9anaanBBleeaM. (iq OiyaiMwalghilaaaaima(Oiebe2dKaliludgaiAialMalQM.Oiua(

20%af.OwcaaMelatodfleMiidaBno:(bMiiidli»B dawaiaibiui. AebialeaaMeaiddbahlBliarBwat ionibbar ayaiaaMiaia liaad; ae atb tarn ienibban Miln abiiiy,lenii.

til AMMiMBdO^miindolp.

alaaiidlapaaalaM

IM ,Maa iwy ibbiihOlO »e 020 par met wn^ler laniOina at rtuMi>Bniia.;hc»iawari amJbi'nmieh NohMaolM « wan 9p In

li«W F«

ihalis73»i lin,:l

r aaoapOnp piilp andpap IdlauGhMdii MiMannoemaM Aae.-ilM'Oabparian la lar

•mseatpMaay lonlaasOOa arOlSIVOMt

byOiaNaOqiiaiOaiM al900:parion

SduraniERO

5-17

include: cosu of conitruction. including clay liner; coiu of operation and maintenance; and coati of closure (vegetative cover); Since impoundmenu are assumed to receive liquid siudge, there are no cosu for dewatering. Also, the costs of construction include costs for equipment to pump the sludge to the impoundment, hence there are no transportation costt.

Based on these per-ton costs^ disposal to surface impoundment is currently the least expensive alternative disposal option. An important caveat to this conciusion, however, concenu the implicit assumption that suitable land in sufficient quantity is available nearby for construction of such facilities. To avoid high pumping and pipeline costs, surfiace impoundments must be located quite dose to the mill's wastewater treatment fodlities. As calculated by DPRA, a mill generating 22,500 DMT of pulp sludge per year would construct three surface impoundments having a combined surface area of approanmately 90 acres (36 ha). Such facilities would have a lifetime of approximately 14 years. Were the miU unable to obtain access to suffidently large acreages nearby, it is possible that the surfocc impoundment option may become much more expensive or even unfeasible. The same caution must he extended to the option of onsite landffil construction, aitiiiough the mill may be able to more easily accommodate a moderate increase in transportation costs if fadlities must be constructed further away.

Also, cosu of land used for construction of surface impoundments or onsite landfills have not been induded, as information on the value of land that would be used for construction of such fadlities-was not available. Sensitivity analysis indicates^ however, that even if land values were available and could be induded as a cost of surfime impoundment or landfill disposal, they would not be great enough to cause mills to select either of the alternatives, i.e., indneratibn or disposal to munidpal landfill. Appencfix B shows that land would have to be valued at well over $10,000 per acre before either alternative became attractive. These costs are well in excess of the range of land values likely to be found in actual practice.

One final caveat concerns the relative cosu of surface impoundmenu for smaller-sized mills that are currently engaged in D&M. The estimated cosu of D&M for the first two size classes of mills (Table 5*2) are hiêr than the cods of surfsce impoundment (Table 5-3). This would suggest that mills in these size dasses would not distribute and market sludge, since surface impoundment Is less costly. The cost models, however, have been developed using generic assumptions regarding the cost fai^n fsced by the mills for etmh disposal option. That some mills in these dasses may be currently using DAM, even though the modd predicu lower cosU using surface impoundmenu, indicates tW in some cases the gmieiic assumptions do not hold. No doubt these mills face somewhat di&erentccst fimtors that make DAM more attractive than surface impoundment in their particular case. For these millSi the costt for DAM are not set at the cost shown in Table 5-2, since a regulation-induced switdi to surfime impoundment could result in 4ower cosu for the mill. Instead, the costt of DAM are assumed to be equal to the costt of surface impoundment. This change is made only for mills in the first two size dasses. since costs of DAM for mills in the larger size dasses are lower than the costs of surface impoundment.

5JB Potential

Options 25 and 26 will require the mill to provide EPA with suffident information to make a determihation of unreasonable risL Potential costs of these options are developed below.

5-18

s.8.1 Stftnslftrd P<rnffita

Under Option 25, a soil concentration limit will be set nationally for all mills, while additional hectare limiu stall be imposed based on a site-specific assessment of risks. Compliance with the permit option will require collection and analysis of data necessary to address the risks from surfisce water runoff.

To evaluate the risks from runoff under Option 25, mills are assumed to perform a site-spedfiC risk assessment using a raethodologjr that is similar to that contained in the national risk assessrnent (USEPA, 1990a). The data inputt for such an analysis will include: background dioxin ooncentratidiu in soil, dicann concentration in sludge to be applied to the site, and site characteriaation. The site characteriaatiori will require collection of data necessary to estimate soil loss from the site due to erosion, and transport of contaminated sludge and/or soil into nearby surface waten.

Applicant costs include staff time to collect and analyze the primaiy and secondary data, equipment costs for sample collection, and laboratory fees to analyze the samples. Low and high cost estimates for this ojôn are contained in Tables 5-4 and 5-5. At the low range (Table 5-4), the site characterization is completed using mostly secondary data sources, such as U.S. Geological maps and local data from agricultural extension services. The high range cost estimate (Table 5-5) assumes extensive primary data cdllectioii.

ERG assumed that an experienced technical staff person, with a commensurate salary of $25 per hour* is required to complete the application. Laboratory fees comprise 27-34 percent of the total costs, while labor accounts for 37-50 percent. The estiinated total costs for applicants range from about $10,550 to $13,250 per application, depending on the extent of primary ̂ ta coltection.

5.82 Siteôedfie Permits

In Option 26, no soil concentration limits will be set, and the unreasonable risk finding may encompass surfoce water runoff and any relevant exposure pathways. The mill, therefore, may have to provide information related to several types of site-spedfic risks.

EFA wiU be devdo^ng gudance to assist mills in the collection and evaluation of infonnatimt necessary for the detemiination of unreasonable risk. Until such guidance is ivqilablc, it is difficult lb estimate the magnitude of the costs that would be incurred for such collection ac^vities. The risk assessment, at a initiimum, will consider the luture and magnitude of mqxosed human and wildlife populations, runofificontrolS, other sourcesofTCDD/TaDF, drainage area size, site slopersite area, soil type, local eoonomic conditions, aiid benefits from land application.

equipment costs for samplecoUectkin, and laboratory fees to at^yze tlw samples. Costs, to conduct risk asscssmentt for appUcation sites will vary considerably, depending on such factors as availability of secpnda^ disla,.oomplczityof the baielinc conditions and risks, and sludge contamination levels. As shown in Table 541, the eatimated cbsu for site-spedfic permit applicanu could range from $50,000 to $lS0d)0O per applicatimi, based on PRG discussions with oonsultantt experienced in

5-19

TABLE S^4

(Mia eompoiMM Baaiafaraalimata Houia

Oaiarnrina bMi^rouiid dio •Bon In I Labor - 20 tampMa par TOO ba tal

Oatarmino durrart dioriR eanoantradoii In aludga Ubof-Maamplaaibl

Praparalor abn ohainiaailMllBn VSLEIaeiaralcl

R-nimna K -arodiMMRf L.S - langih. tlopa C - vafl. anvar P'- iupBon praedoaa

Siiaol.dfalnngaaran OaHvaiy ratio tor aba OaUMiy rado lor draJnagaaraa Otardn acoiMMdallan In lab Flail oonaumppon Total houra

Avaragowagnrataldl •ub-totafc^labwaloata

B paraona a 40 hrs <24 IIIIA. par aampia: lOO aaniplaBl

a paraona a 12 hra <aa min. par aamplat 20 aamplaa)

1 paraon-^day

Conaub arUiag. aaniaaa 1 parapn-dav.M clmmturitm aba 2 paraon-dayata cobaci data 1 paraen-day tdaharactariio aba ConduolPd Id aamo tbna aa vag, eovar charadaiinllon

Dalarnilnad'by EPA (ualng OEMS| EPA IP uao iwiioiMl data EPAtouaoiiiiidnaldata EPAlOiiaoiiailaiialdala EPAiouaoiiailotiaidaia

30

2 a

IB a

laa

moo S3.BM

Equlpmanli Bobaampang Sludga aampHng Sub-loiai: agidpinani aoaia

mil a. aamplng A maaaorlng ogulpl rowboat, mlaa. aampUrig A manauiing agulpl

ssoo B1.000 21.300

Lab ooaia 8oil MRipHllQ [•] Bludga aarnpUig |a| Sub-ioial: lab ooaia

1 aob aampia a B1.8PCiiMaipl# 1 fludga aampia xSi.aoiVaainpla

TOTAL COO*. ^ ^4^.

21.000 OLBOO 23.600

•lasso

|a)

S! (dIA

ior aoB aamplng dowalapod by EM. bvNPC.,ino.(109i).

daidapad by EM In i

laJTwoi ual aalary 01240.000 pliaa 30K tar non-a

abhthaUBDAOobCa ittaii

• (bna oaob tar aob and aludga) wHlAa prapi . and 40 houra par woak lor oawaoha.

ad bom ab aamplaa cobaciail and aiibmbiadliir amiyala.

Souroa: ERO i

5-20

TABLE S-S

AMIillMd SIM 8ii«; soon*

dita componant Baatohir MUnMH Hours

Datannjiia baoki und dioidn < ilfii Labor - SO saaiploa pair 100 ba [al

DatainilnoaurronidMn conoawwdun In aludgo Ubor-20aaniplaa|b|

Praparaiar aSaoharaaMdi uSLEiacieralel

R-ratidal K - vodStUSy

L,S-laiigth.ilopa

C - yaoi eowar

P - iuppeil pnwtfoaa

SiiaatdnlMsaaraa •sSwanr ratio lor alM DailMiv. rada lor dratnaga araa OloaliaaeeuiiiuladaninSah Fish eonauiapden total boiira

Aaarago waga nda idl Sub-ioial: lobar.

3 paraaaa a 40 bra <84 mln, pa pla; 100 samplaa)

3 partona a U bra (30 lain. par aainpla: 20 samplaa)

2 paraan«daya

ConsuS aiSh ag, saiyieaa 1 parsbn*dav/300 lia to charaeiariia aha Cofiipllalnloraiadoii 2 paiion-daya/'iOO ha to coliaal data Coinplto liiiorniadon I paraon--day/200 ha to charaetaHza aba CpinpUalntarmadiln Condueiad at aaaia lima as vag. eovar eharaetartaadc

Oatarminad by EPA'<ualng OEliB) EPAtauaanadoiaddaia EPA Muaa nation EPA la uaa national daia EPA la wo national data

11

2 20

4 M

4 20

4

2SS

S2S:00 SOlOSO

Equlpmaid;! SoiaampHng Sliidgaaainplliig

inlse. aamptlng A maaaurlng aqiiipt rowboati rnlao. sampUngOi maasurbig agulp't

ssoo 01.000 SIISOO

Sol:aanipang(a] SludgaaampBiig(a| Sub-total: Ml ooalB

1 sob aampia a SliiOOraainpia 1 aludgaoaiaplaBS1.MKVaanipla

01.000 01,800 03.000

013.200

|a|; Baltmataa lar aea.aawplngdewuleped.bv EM; WSa .(1901).

htha U80A Sol Conaataadan Smviaa; {e| Eadmataa lor IMLE dawaiopad by ERS bi i id] Aaaumaa annual aaMrel SaOiOOOiplw 30% tar non-amga aaaia aiid banalba, and 40 houraipar waak tar SI iraahs. [a| Tarn aompoadaaamploa.iana aaah tar aoO and dudtia) aWba praparad bom aUaamplaa oollactM.and aubnrittM tar anatyala.

Sourer. ERO

5-21

TABIC 6-e

iaW»fcA>—•Miiwt

u« K

Low coat* Mighcoalo dhnala

I 1 Porcantct eicMt Houra Coattal Houra CpallaJ

1. DataErahiaBoh CoUaalmlBalngdala

0

40K 800 $20j000 4400 $60,000

OslOTiyM bMitti# dto condMlofw

ASS#M #i(po0Ui# IQUIM ASSMS populfldoos

• A$8#$S IIIO^ ̂ Hposcd indMriutl

3C% 600 ftS^ 1,800 $45400

DfliMllM fifcWiCS 9fMl o*W 0 <0 0 $0

4. Slsk£haraeladta;ioq Cdoutadan of human hoahh Impacla aoK 400 SIO^ 1400 $30,000

SonaKMlranalraaa KM 200 $S^ 600 $t5400

Non-labor coaia/ oonhaotaaiviBaa

no no

no no

no na

no no

no no

Told Maun and Coata SfiOO SSOLOOO 6,000 $150400

M - Ml aatiniaiad; mqr Vuy conaidarataly ctaptndMg on amount of primaiy data collacdon raqulrad M Aaaumaa labor waga of 1^00 par hour jb] Aaaumaa taodeh^ chMadattntfan for dkaina and Ikirana wW bo provMad by ERA.

SouiCK ERS asiiiiimM tmaod on cStouaMona wMi riak asaaaamont eonauttanla.

conducting onsite risk assessments. These compliance requirements are difficult to predict, however, so these figures provide only a preliminary esdinate of possible costs.

The lower oost estiniate is for a relatively simple assessment with small primary data collection reqtiirementt. The higher estimate assumes that the applicant has a very complex situation, for example a large site, highly contaminated sludge, scarce secondary data, and a large drainage area with many affected neigl^rs. Note that neither estimate includes nou'labor costs or costs for contract services such as laboratory aiudysis. The magnitude of these costs will vary depending on the need for such services in preparing the permit application.

S.9 Ralativa Costa of Land Apnlicntion and DianoanI AltematHras

The preceding analysis focuses on the current costs of land application and the current costs of altenuitive means for disposing of pulp and paper mill slui:!^. When costs for sludge management practices or construction of berms are introduced, the cosu of each land application option may be impacted differently from the costs of the alternative disposal methods. Thus, while the costs developed so far indicate generally lower costs for land application, the cosu under a regulation that includes management practices or berms may differ.

The costs of sludge management practices are shown as a line item for each land application option shown in TafHe 5^2. The cost per ton Is calcuiated using the sumi of disposal cosu and the costs of the management practiees. To assess whether a mill continues land application under the regulatory optiDns, it is neeessaty to examine whether the costs of land application, including management costs, are lower than the costs of the disposal alternatives.

When the Sludge management practices are induded, the costs of land application increase by $23,086 per mill for all mill size classes. The costs of disposal alternatives do not change. Table 3-7 indicates that consideration of these oosU-may lead some mius to abandon land application in favor of surface impoundment disposal. This is the case for mills in the first two rize classes that are engaged in distribution and marketing of sludge., The post-regulatory costs of distribution and marlmting are higher than the oostt for surface impoundment.

When berm costs are included^ the oosts of land application increase even further. Thus, surfiace impoundment beoomes attractivte to a under range of milli (see Table 5-8).

i-% w

Under a regulation that includes either sludge management practices or management practices in cbnjuncdcn with berm oonstniction, the relative costs of the disposal options may change. The decision of the mill to continue or abandon land appiication may be affeêd by the incorporation of these additional costs into their decision-mal^g. The assumptions regarding disposal choices under these regulatoiy options are discussed further in Section 5,11 beiow.

In each of the regulatory cost models, considerable effort has been made to ensure that the values chosen for all variables are as accurate as possible. Nevertheless, the magnitude of these costs and the relative ranking of options could differ fiar a pardcular mill if it foces somewhat

5-23

TABLE 5-7

gomparijon qf of Land Application rinduding Cost« of Management Practicea^

With Costi of Surface Imnoundmenta

Disposal Option

Size Qass of Mill

Disposal Option I II in IV V

Agrioxlture $70.62 $48.41 $41.42 $36.58 $27.61

Forestiy $82J2 $77.72 $76.58 $75.70 $74.90

Mining $53.50 $36J2 $31J7 $26.37 $18.00

Distribution Marketing

Surfoce Impoundment

1 $131.24 1 $102J0 $93.13 $84.76

$94.24

$72.10

$94J1

Distribution Marketing

Surfoce Impoundment $110.14 $99.60 $95.46

$84.76

$94.24

$72.10

$94J1

Note: boxes indieste disposal costs for land application that are higher than costs of the least-cost disposal alternative (surface impoundments).

[a] The size dasses correspond to generation and disposal of 3,750, 11,500, 22,500, 40,000, and 75,000 diy metric tons (DMT) of pulp and paper sludge each year.


5-24

TABLE

Compariion of Cogte of Land Application flnduding Costs of Management Practices and Bermsl

With Costa of Surface Impoundments

Size Qass of Mill

Disposal Option I II III IV V

Agriculture $108.04 $70.25 $57.06 $48.48 $36.49 f 1

Forestry 1 $119.74 $99 $92.22 $87.60 $83.78

Mining S70.14 $45.92 $38.19 $31.51 $21.79

Distribution St Marketing $215.68 1 $152.48 1 $129.64 1 $113.01 $93.68

Surface Impoundment $110.14 $99.60 $95.46 $94.24 $94.51

Note: bcon» indicate disposal costs for land application that are hiêr than costs of the least-cost disposal alteniative (surfoce impoundmenu).

[a] The size classes correspond to generation and disposal of 3,750, 11,500, 22,500, 40,000, and 75,000 dry metric tons of pulp and paper sludge each year.


5-25

different cost faclbn. At an example, it waa neoeaaary in each model to make an aasumption regarding the diatance from the mill to the application or disposal ute. For agricultural, forestry, and mining application, the round: trip distance between the mill and the applihation site was assumed to be 10 milesi TraiAport oostt account for the highest share of costs in forestiy application (78 percent), the sensitivity of total transpomtion costt to haul distance is not that great, however. If haul diatanoe is assumed to be 20 miles rather thhn IGi the costs for a 22,500 DNFT/yr mill would Increase by only 12 percent. Fbr onsite landfills, the round trip distance was set at four miles, vriiile for municipal landfills it was auumed to be 40 miles. Doubling these distances would remit in only 2.1 and 43 percent increases in total costs. Depending on the actual distances to application or disposal sites, total costs for each option could vary to such an extent that the relatiye rankings of disposal options might differ from those projected by the economic models. Other variables contained in the models may have similsir iinp^ on costs and rankings. Nône, however, are likely to both be subject to the same uncertain^ and have the same inQuence on costs as the distance variable. Appendix B examines the sensitivity of costs to different assumptions about transporution distances to disposal fedlitiea and land values for construction of landfills and surfece impoundmente.

5.11

Hie disposal choices of mills under laltemative regulatory scenarios; will be made based on, a comparison ofthe fieasibUiQr and costs of complying with all of the requirements of the regulation, and the costs of using alternative means of dispoml. Mills will continue land application if they (1) can meet the technical requirements of the reguintion, e.g., soil concentration or area limits, and (2) can incur costt for such complianoe without makfog other disposal options more attractive.

Compliance scenarios have been developed for a regulation that implements the soil ooncentration limits alone and the concentration limits in conjunction with the area limits. These are discussed in turn in Sections S.11.1 and 5.11.2. As disdussed above, the inclusion of costs for sludge management practices or management practices and berms may affect relative rankings of

•options. For this analysis, it is assumed that mills will inobipdrate foe costs of complying with sludge management requirementt into their compliance decision. The analysis of compliance under a regulation that indudea construction of berms is difficult because it is unknown whether the mill itself would bear the oostt of'berm construction. Since foe beno option is not being pursued as a primary regulatory option by EFA, the oostt for berms will be calculated separately from foe oostt of each option. Were foe mill to incorporate berm costs into the coniptiance dedsioni additional toiills may be expected to abandon land application.

5.11.1 Soil concentration limits /

The soil conoentratioa Ifanitt will sffea mills diffemntly dependiog upon whether they do or do not incorporate sludge into foe soil. If they do not incorporate sludge, then they either meet or exceed the requirements, depending on the levels of TCDD/TCDF in their sludget thus, for mills engaged in forestiy or mining • application foe concentration of dioxin in their sludge determines whether th^ ooihj^ ornot.

When sludge is incorporated, dioxin is dilated, and foe ooncentration in foe soil is less than the ooncentration in the sludge, the resulting concentration in soil can be calculated using the

5-26

formult presented in Section Ifour. The soil concentration depends on several factors: the concentration in the sludge, the application rate, the incorporation depth, and the number of years over which sludge has been applied to the soil. Repeated applications of sludge will serve to increase the concentration of diozin in the incorporation layer. Thus, mills engaged in agricultural ai:^lcatiod or DAM need to consider not only whether they initially meet the soil concentration limits, but also whether they will meet the limits over the entire period during which they wish to use each application site.

For reasons of logisticg and costs, mills may prefer to use the same sites each year, if possible, particularly if other parties such as land owners are involved. Sites may also be difEcult to secure if the land owner knows that application must be limited to one year because of tozic substances in the sludge. For this reason, it is assumed that mills that incorporate sludge will continue application o^y if they calculate that soil concentration limits will be met after five years of site use. As shown in 'Appendix ̂ this additional assumption does not greatly affect the number of mills that continue land, application under a concentration^based limit.

the impacts of alternative soil concentration limitt on compliance is shown in Table S-9. Beginning with the most liberal concentration limit considered, 200 PPT, two mills will discontinue land application and adopt surface impoundment disposal. At 10 PPT, six mills meet the limit while six do not. Only one mill has a sufBdently low TEQ level to enable it to meet limits below 0.5 PPT.

As discussed in Section Four, the mills are not assumed to reduce application rates in order to meet soil concentration limits, 'thus, the complianoe projections assume that the mill applies sludge at the same application rates assumied in the economic modeling.

MU Ana limits

An additional control method* ooiiaidered fey EPA would place a cap on the number of hectarei that may be used for land application within an individual drainage area. These requirements would be in addition to the soil concentration limits, llie area limits protect against

' the risb from runoff of oontaminated sludge into nearby surface waters. The ingestion by humans of fish tiiat inhabit such waters has been identified as one of the major risk exposure pathways (USEEA* 1990a).

Aa detailed in Section Four, the area limits will be set at a level that will limit expokuxe risks from runoff to a level of Iff*, the risk level is related to the amount of soil or sludge that erodes or is otherwise carried into surftoe waters, and its dioxin content. According to the risk assessment methodolbgy. erdrionoceurs from the itop layer of soil only, hence the total risk in a given drainage area Is a fonôn of the number of hectares of land treat^ with dudge and the concentration of dioxin in the loil. For a given level of risk, therefore, there, is an inverse relationship between the concentration in the amended soil and the number of hectares to which sludge is applied.

The area limits associated with each soil concentration limit were calculated to yield a level of riak equivalent to that of a 10 NT and 1,000 ha limit combination. Thus. Options 14 through 24 include combinations such as 5 PPT and 2,000 ha, 30 PPT and 333 ha, etc. (see Table 44).

5-27

TABLE 5-9

Impact of Alternative Soil Concentration Litniti on Land ApplicatiPn Practieei

Option 1 No.

Soil Concentration Limit (Combined TCDD/TCDF)

Number of Mills Currently Land Applying or Able to Meet Limit

1. Bueline n-2. 200PPT 10

3. . 100 PPT 8

4. 30 PPT 7

- 5. , 10 PPT 6

6. 5 PPT 4

7. 3 PPT 4

8. IPPT 3

9. 0 J PPT 1 1 10. OJPPT . 1

11. 0.05 PPT 1 1 12. 0.03 PPT 0 1 13. Ban on Land Application 0 1

Source: ERO estimates.

5-28

In setting the alternatives in this manner, it is apparent that mills that create soil concentrations below the limits would not be permitted to apply sludge to a greater area within the drainage area. Thus, the actual level of risk could be lower under these options than the level associated ^th a 10 PFT and UOOO ha combination. An alternative interpretation of the area limits, one Which wcmld permit the maximum area receiving sludge to vary with soil concentrations created by the mill, is therefore presented in Appendix C

For Options 14 through 24, the analysis of compliance proceeds by first determining whether the mill meets the soil concentration limit, and then whether it can apply all of its sludge without exceeding the area Umit. The number of hectares reqtiired to apply sludge is calculated by dividing the total sludge volume of the mill by the application rate , appropriate to the type of application. Thus, a mill that generates 22,500 DNTT per year Of sludge ât to engaged in forestry application is assumed to require (22,500 DMT * 49 DN^/ha) = 459 ha of land, These land requirements are then compared to the area limit to determine whether the mill, would exceed the permissible number of hectares. If the area limit is greater than the miU's requirements, then land application is assumed to continue. If the required number of hectares exceeds the area limit, then the mill is assumed to disoontinue land appHcatiom As with the toil concentration limits, the oompliance analysis assumes that mills do not vary the application rates in order to meet these limits.

Table 5>10 thaws the effect on oompliance of introducing area limits in addition to soil concentration limits. For each combination, the number of mills that meet the soil concentration limits and the combined soil concentration and area limits, are shown. These results may be somewhat non-intuitive at first glance, No mills meet the 200^ 100, or 0i03 PFT soil concentration and associated area limits, one mill meets each of the 30, 0,5, OJ, and 0.05 PPT limit, two mills meet the 10 and 5 FFT limits^ and three mills meet the 3 and 1, PFT limits. The explanation lies in the ftot that the area limits increase as the soil concentration decreases^ For example, under the 30 PFT and 333 ha limit there are 7 mills that meet the soil cpncentration limit, yet all but one of these requires more than 333 ha of land application area^ Under the alterhative interpretation of the relation shown in Appendix C, the results differ somewhat, since the area limit will vaiy depending on the actual soil concentration created by the miU^ rather than the soil ooncentradon limit.

S.12 Cpyta Pt Mlllf Venma Coyts^ Qthere

Regulatory actions have the potential to affect the coonomlo behavior of producbnânfVor consumers by altering the relative coats of producing goods or services. In the case of land application of sludge, if we asaume that land application is the least cost disposal option for a particular mill, then a limitation on this practice could force the mill to use an alternate, higher cost^ disposal method. The cost of the regulatory action to the mill to represented by the cost differendal between disposal using land application and disposal using the higher cost alternative.

The dupoaal of sludge^ howeveri like mat^ other economic activities^ may have associated with it a variety of costs (and possibly benefits) which are not necessarily considered by the mill in its decision-maJdng process. For example, assume that sludge used in agricultural land appli^tion is provided ffee by the mill, but that farmers must transport and appty the sludge themselves. If the mill can no longer land apply, die benefit received by the former, for example, will be lost, and should he considered. Also, in choosing landfill dispo^, the mili wilt foce costs which may not

5.29

TABLE 5-10

furi $Qil Arw Un^jt^

Option No.

Sou Gonointration Limit (PPT)

No. of Milk Meeting SoU Cone. Limit

Area limit (ha)

No. Of Mills Meeting Area

Limit

N6.ofKfills Meeting SoU Conoentration

and Area Umit

W- 200 10 50 0 0

15. 100 8 100 1 0

16. 30 7 333 2 1

17 10 6 1,000 7 2

18. 5 4 2,000 9 2

19. 3 4 3,333 10 3

20. 1 3 10,000 12 3

21. OJ 1 20.000 12 2

22. 03 1 33,333 12 2

23. 0.05 1 200,000 12 2

24. 0.03 0 333,333 12 . 0

y


reflect the true cost (to society) of that option. The mill may not include the total social costs for the land in its estimate of lantffill disposal cost. In the long run, landfill space is becoming more and more scarce. Therefore^ even if the mill were to use current prices in valuing its land, the costs may still be underestimated.

Understandably, the mill will base iu disposal choices on economic fiactors which only affect it directly^ The change in disposal practices, acpordingiy, is projected using only those economic factors fiiced by the mill; The total costs of the regulation, however, will be equal to the costs incurred by the mills as a result of changing their disposal pracflces to comply, plus any additional private or non-private costs (net of benefits) that are associated with these changed practices.

A further issue to addreu is the question of who bears the regulatoiy costs. In the current case, sludge disposal costs are part of the overall costs of producing pulp and paper. If these costs rise because the least cost disposal option (i.e.. land application) is no longer permitted, then the cost of producing pulp and paper will rise some amount. Depending on the market conditions, the mill may be able to pass along some (or all) of this cost increase to its customers by raising prices. If the mill has sufficient market po^r, then there may be little resistance to a small price increase. In a highly competitive intenutional market, however, the mill may be unable to pan along such cost increases^ Foreign competitors, who are not subject to the same regulatoiy requirements, would not feel the same pressure to raise prices. A price increase by domestic suppliers only might result in a loss of customers to foreign competitors.

ERO has not investigated the potential impacts of these regulations on variables such as prices, trade, employment, GNP, eta In the future, such analyses may be provided, if requested.

5-31

SECnON FIVE REFERENCES

Crane, 1990. Teleiihone communication between John Reinhardt of ERG and Mr. Kevin Crane of the Maine Departmetit of Environmental Protection. September 10, 1990.

Greyi 1991. Telephone communication between John Reinhardt of ERG and Norman Grey of Transit Seeding Inc., Norwood, MA. Januaiy 25,1991.

Gallo, 1991. Telephone oOmmuniiation between John Reinhardt of ERG and John Gallo of Caprera Landscaping, Boyleston, MA. Januaiy 25, 1991.

Ginn, 1990. Telephone communication between Peter Pfitdnger of ERG and Mr. Bill Ginn of Resource Conservation Services, Yarmouth, Maine. December 27, 1990.

Hill, 1990. Telephone communicatiDn between John Reinhardt of ERG and Mr. Greg Hill of the , Wisconsin Department of Natural Resources. November 9,1990.

Lough and Smith. 1990. Memo firom Chris Lough and Shirley Smith of DPRA, Inc. to Prisdlla Haiioran, OSW/CAD. "Cost Resuits of Landfill and Surface Impoundment Model FadliUes." September 25,1990:

Millie, 1990. Telephone communication between John Reinhardt of ERG and Dr. Michael Millie of ENSACO, Inc., West Sacramento, CA. December, 1990.

NFC, Inc., 1991. "Sludge Sampling Protocol*. Memo from Dr. Vince Piccorillo of NPC, Inc., Sterling VA to Pat Godfrey of MathTech, Falls Church, VA. January 18,1991.

Truslow, 1990, Telephone communication between Peter Pfitzihger of ERG and Ms. Sandy Truslow of the Agricultural Stabilization Conservation Service, Cumberland County, Maine. December 27,1990.

• USDOL. BLS, 1990. WhitcCollar Pav: Private Goods-Produdng Industries. March, 1990. Bureau

of Labor Statistics, U. S. Department of Labor

USEPA, 1985. Summary of Data on Industrial Non-Hazardous Waste Disttosal Practices. Office of Solid Waste and Emergenqr Response. Washington, D:G. December^ 1985.

USEPA, 1990. Asaessment of Risks ,from Eznosure of Humans. Terrestrial and Avian Wildlife, and Aqwtiff ILife lo Piorim and Fyrani frpm Piswial and pf gfrdge from Bkached Kraft and Sulfite ?ult> and Paoer Mills. EPA 560/S-9(W)13 (July 1990). tJ.S. Environmenttl Protection Agrnicy, Washington, D:C.

5-32

SECTION SIX

AGGREGATE ECONOMIC IMPACT OF REGULATORY OPTIONS

S.l. Introduction

The costs of land application and alternative disposal methods faced by the mills determine the compliance choices made under each of the regulatory options. The analysis of each regulatory option^ however, must include not only the costs to the mill of compliance, but also any costs incurred by, or beneSts accruing to, other parties. This section identifies any nonvmill costs (or benefits) and adds them to the costs incurred by the mill to derive the total costs for each disposal method. The total costsare used to develop estimates of the costs of current disposal practices and the costs of practices that would occur under each regulatory alternative. The non-mill costs and benefits are discussed separately for land application and other disposal methods in Sections 6.2 and 6.3.

6.2 Non-MIII Costa and Benefits of Land AnnHcation

The nature of the non-^mill costs and benefits for land application considered in this analysis are discussed below:

Aen'cultural atmlication • The tnethodology assumes that mills incur the costs of transporting sludge to farms, but that farmers are responsible for applying the sludge. The farmers will also incur the costs of any site preparation that may be requiredi such as grading of soil or Sludge treatments^ At the same time, however, the farmer receives a benefit from the sludge that can be quantified according to the value of the nutrients contained in the sludge^ These costs and the benefit must Im included: ERG has calbul ated the value of sludge at $11.00 per PhfT, based upon several analyses of sludge nutrient content and prices for such nutrient supplements (see Appendix A for more information). Both the former^s costs and the benefits they accrue are considered in the estimates of current disposal costs.

Forestfv aoolication - The mill transports the sludge and applies it to its own forested areas. The benefits of the sludge to the land have alreat^ been ascribed to the mili in detetTnining the cost to the mill (see Table 5-2). Thus, there are no additional costs or benefits that need to be considered.

MInitta application - The mill is assumed to incur costs only for dewatering the sludge. The mining company incurs the costs of transport, site preparation, and application, and also reeetyes the benefit from sludge as a fill material and as a soil nutrient for mined land reclamation. While slud^ is applied in land redamation at a rate of 247 DMI/ha, the nutrient benefit received is only calculated for the last 49 DMT/ha applied. Le., the rate at which sludge is applied In agricultural applications. This is because the initial layers of sludge serve primarily as fill, and hence do not have the same value as sludge which is providing needed nutrients^ The top 49 DMT/ha is valued at $11.00 per DMT. The remaining 198 DMT/ha that serves as fill has been valued at $S.34/DNrr, which is the price

64 '

paid by the Ohio Department of Natural Re30urces for topsoil used in mine Fcdamation (MacDonald^ 1990). The weighted average nutrient and fill value of the sludge is $6.62/DIyfr. Therefore, regulatory options that reduce the amount of sludge applied to mined laxids generate costs (a loss of resource value at the rate of S6^67/Dh^.

Distribution and Marketing - In D&M, the mill is assumed to dewater, then compost ito sludge. The mill sells the composted sludge to a broker. Based on contacts with sludge distributors, the mills receive approximately S3.00 per cubic yard ($5.55 per ton) for this material (Collinson, 1990; Page^ 1990).

Most compost is sold to bulk purchasers. ERG used a price of $10.72 per cubic yard ($19.80 per ton) for the bulk purdiasers, based on estimates provided by these same sources. The broker's transportation, storage, and distribution costt. as well as his profit, are covered by the differential between the price paid to the mill and the price received from the end user or$7.72 per cubic yard ($14.26 per ton). The benefits of the sludge for users can be inferred from the value of the nutrients in the sludge. While the nutrient content of sludge was valued at S11.00/DMr. the sludge used in D&M is normally composted with organic materials such as wood chips prior to use. Composting can greatly increase the amount and availability of the nutrients, hence estimates based on sludge nutrient content would imderestimate the value of the sludge considerably.

In the absence of datt on nutrient content of composted sludge. ERG has assumed that the nutrient value of the composted sludge, and therefore its value to the consumer is, on average, et least 10 percent higher than the $10.72 per cubic yard paid by final users. Thus, a value of $11.79 per cubic yard (or $21.78 per ton) has been placed on composted sludge sold to final users. Note that under this assumption the value of compost is calculated at less than $0 JO per SO lbs.

Table 6-1 shows the oosu to the mill and any non-mill costs and benefits for five size classes of mill. The figures show that, once all costs are accounted for and beneficial uses of the sludge are considered, the least cost option is agricultural application, followed by mine reclamation, forestry application, and distribution and marketing.

64 Non-MIII Costs aiid Benefits of Alternative Dlanogal Methods

The alternatives to land application may also have associated with them various costs and benefits that impact parties other than the mills. Although several categories of non-millcOsts or benefits are discussed, modifimtions to the cost estimates were not justified.

Dedicated landfill - Mills that construct dedicated sludge landfills incur the costs of construction, costt of operation and maintenance, and costs of compliance with any regulatory requirements they may face. In this analysis, the landfills are assumed to include liners and leaChate collection j^tems at time of construction, and construction of a final vegetative cover prior to closure of the facility. Nevertheless, other environmental concerns may be raised by the use of landfills for sludge disposal. The primary issue is the difficulty of Siting landfills. Citing of municipal landfills is particularly difficult, given the growing scarcity of landfill space. For industrial landfills,<particularly in rural areas where most pulp

6-2

9^

l| S 3 SBSS E

I

IS

!t 1 I

I I

i

!|!

i iUlfliillif llHlfll illl liirilil

m fiiiiiii ... |j

i! !il[ fliiii i! Ill I ii il ii itiHi

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and paper millit are locatedi, space may be more readily available. Siting and permittingi hoareyer, are becoming more difficult virtually eveiywhere. Siting authority over industrial landfills is priinariiy in the hands of state regulators, and many states are currently restricting the niimbef of such facilities permitted, or are passing more stringent environmental compliance requirements.

The costs for mills to construct, operate, and dose landfills may not reflect this increasing scaidqt of landfill space or ppssible siting difficulties. ERO did not find any basis, however, for revising the costs for this option to aocount for such factors, These issues are not expected to impact sludge disposal to the extent that land becomes unavailable or siting permits prove unobtainable. The influence of landfill scarcity will be lessened by the fact that pulp and paper mills are generally located in rural areas and usually have large holdings of land available.

To summarize, the landfill costs as calculated here may understate the cost of using landfill (fisposai. Adjustment of the current costs is inappropriate, however, because many mills are located in less populated regions,, and these regions may not be experiendng the shortage of landfills that is true of urban areas, In many regions, tip fees for MSW remain low. Thus, ERG did not make any adjustmenti to the landfill costs obtained from DPRA, Inc.

Surface impoundment - The issues regarding surface impoundment are rimilar to those discussed for dedicated landfills. Suchduties require a significant amount of land and are becoming more diflBcult to site, in both cases, however, there is no overriding evidence to suggest that the engineering costs need to be adjusted.

Incineration • The costt developed in Section Five for incineration included costs for construction and opemtion of die indncnttor. Costt for pollution control equipment were also included. These additional costs reflect the environmental compliance requirements. Thus, the environmental externalities of incinerators, i.e., creation of air pollution, can be assumed to be captured by including costs for compliance with stringent pollution control requirements. No other external costs (or benefits) were identified for this option.

Municipal landfill - The costt of disposal to municipal landfill include costs for dewatering, transportation, and tipping foci, llpiang fees at several landfills contacted by ERG that currently accept sludgps were in the range of $10 to $20 per wet ton. Disposal of such high-volume wastes to landfill, however, is becoming more difficult. Existing contracts for sludge disposal are not being renewed, and additional permits for sludge are not being issued. The costt died abo^ are probably not representative of the costs that would be incurred by mills switching from land appUcation to disposal to munidpal landfill.

According to the National Solid Waste Management Assodation (NSWMA), the costs for sludge disposal would be similar to the costs for disposal of munidpal solid waste (Reps. 1990). The most recent NSWMA suiVi^ of rounicipar facUities (data for 1988) found that the Mghest "tip fees' were in the Northeast, and ranged from $40 to $100 per ton. In other areas of the country, tip fees averaged $10 to $30 per ton. For this analysis, a cost of $30 per wet ton was assumed, Since wet sludge is 75 percent water, this corresponds to a cost of $120 oh a diy ton basis. ERG has thus attempted to indude a disposal' cost that reflects the potential increases in disposal costs that mills face.

6-4

In summaiyt the costs to the mills of using each of the land application alternatives have been reviewed in an attempt to identify any non-mill costs Or benefits that merit consideration. No such costs were judged to be relevant tp the analysis.

6.4 Enforwrntm go'tf The costs to the Agency for administering and enforcing the regulations for bleached pulp

and paper mill sludge can also be ascribed to the regulation. Estimates of costs have been developed for both the non permit-based and permit^based options.

6A.I Non permit-based optloni

Table 6-2 shows'estimates of costs to the Agency for activities related to the regulation under options involving soil concentration limits (Options 2 to 12) or concentration plus area limits (Options 14 to 24). These actions would indude:

• Enforcement, includiiig inspections and complaint investigations • Testing of sludge and/or soil samples • Administration of records of land application activities prepared and submitted by

the mills under the requirements of the regulation

As indicated in the table, the costs to the Agen^ are estimated at S122,154 per year. This is based on staffing assumptions that indude one GS-9 and one GS-tl for inspections and complaints, one GS^9 for actoinistration and approximately $10,800 in laboratory service charges for analysis of sludge and soil samples (iassuming 6 mills continue land application • see table). Staffing categories and salaries were provided by EPA.

6A<i Pennlb>baaed options

The admihistratiye cost mtimates for processing both the Nationar Standard permit applications (Opdon 25) and the site spedfic permltt (Option 26) are based on actual permit program cost data. A summary of seven permit programs are presented in Table 6-3. The estimated.administrative costs for this option of $1,900 per permit are derived'by averaging the data in the table< endusive of the costs estimated for Oregon to process sewage land application permits under the new federal rules. The exduded data Were considered unrepresentative. « ,

Typically, permit administrative processing will include reviewing applications for missing data; tedmical review and verification of the appiicatioiis (this can involve site visits); public hearings (optional); and finally approval, denial, or modification of the applications^ In addition, agency staff are required to field applicant questions.

6-S

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33

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II

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3 3 I a

II

8s

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lilt i u nil I ill

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TABLE e-3

s

1

Proflram Goal (b)

Program i • • .

Numborol PormllWYaar

Miwibtf of SteiriFTq

Hourtf POrmlKa] -«TaW Par Partrill

PidpJMI Bhida Land Appgealoii 31 S3

0.S 1.0

34 39

884,700 $49,400

3797 3832

Iowa L^fid Appllcstioii' 80 1.0 42 $48400 3988

Colorado f Appficsfloii 80 1.7 44 $88982 $1,037

Ohio LAfld ABBleallAB . 200 80 02 $298400 $1,482

VarOtent SowagoLandAppltealldn 88 80 189 $247,000 $4,491

Orogon Sawaga Und AppltoaMOn (e) SaMsa Uaid Aniileallon (d)

40 80

AS 4.8

234 489

$228300 $228300

$9,558 $11,115

NFDES. Form 2A MaiorParmlia(a] IBnorPannlte n

185 588

84 183

72 84

$218315 [fl] $528418 bl

31,180 $805

M 6^WMk•x40llr•^raM(«8;oaOlirVyMr. jb] For fllata|MesfMiii.«Munb> annual aaiaiyoi $MiOdOplMa3Mlof non-wagaanaUMid banallta. Ic] UndaraxlaUng atala rafliMionB.

EaUmais imdariwwfadanliinsuWIona [a] ForPOTWaMKl mfld. IQ For POTW «Mi 1 mgO. and graatar. [g] Annual aalaiiaa la $34,031 or giftSO par hour for a %0M hour yaai. |b] Welghlad eveiageb eakulaled aa Bvarage FtE^'houia dlyModl^ awa

Sourcaa: State dalBX ERG oaliniate lod on dlacuaalona tdlh i 2A, B>AOI!teo ol Water Entetcanionl and Slandarda, Auguat A 1

raga nwnbor of paimliai La. (4.0 a 2,000) f 130 •• 7&0

dranmantal oOiclala. NFDES data - SuppOnlng atatamant lor ICR tor prOpoaad Form

6.5 Tfttal CPIM

The total oosta of the re juiation are calculated by coaibining the projections of compliance from Section Five «dth the total costs of each disposal^ option, as estimated in the sections above.

Baseline costs

The baseline oostt are derived by taking the number of mills in each size class and multiplying by the costs of their current disposal practices. When aggregated in fhis fashion for the twelve mills cunently engaged in land af^licatioit, the baseline costs are estimated to be $26.2 million per year. This hgure includes the annualized costs of all fixed coats^ such as vehicles, facilities, and equipment, as well as all operating and maintenance costs such as wages and salaries, fuel, power, supftiies, maintenance, etc.

Costs .of soil concentration limit *

Under the soil concentration limit being proposed, mills will continue land application as long as their sludge concentration (for non-incorporators) or soil concentration (for incorporators) is below the regulatory limit. As detailed earlier, mills that incorporate sludge are assumed to continue land application as long as the calculated Soil concentration anil be below the limit following five years of annual application. If they do not meet the limit in the fifth year, then the mills are assumed to adopt the next least cost alternative, which is surfiice impoundment. As this assumption may not hold for all mills under all circumstances, the sensitivity of compliance and costs to this assumption is examined in Appendix B.

The costs of sludge disposal under each of the alternative soil concentration limiu are derived from the compliance projections in Table 54 and the disposal costs in Tables 5-3 and 6-1. The dioxin concentrations in sludge are compared to' the soil coneentratlon limits to determine whether land application will continue under each alternative limit If they are estimated to continue land application, then the costs of their current practice is found in Table 6-1. If they are unable to meet the limit then the costs are estimated from the least cost alternative, surface impoundment from Table 5-3. The total costs of each regulatory option are equal to the sum of disposal costt for all twelve mills.

Table 6-4 shows the number of mills that continue land application under each regulatory option, and the total costs of duposal, for all mills currently engaged in land application, under the regulatory option. The seoondioost column indicates the increase in costs over the current baseline. These are the costs Of the option, ixn the additional costs attributable to'the regulation. The final column indicates the increment^ costs of eadi option. The incremental cost is defined as the change in total costs that occurs when moving from one option to the next.

The least restrictive regulatory option (200 PFT soil concentration) will cause two mills to discontinue land application and adopt surfsce impoundment disposal, a higher cost disposal option. This results in additional costt of SI J million per year over the baseline. As the concentration limits become more restrictrye, fewer mills are able to continue land application and more arc forced to adopt surfime impoundment. Under the 10 PFT limit, six mills continue land applicaticn while six switd to surfrum impoundment. The total costt under this option are $31.7 million per

6-8

TABLE 6-4

COM of Regulatory Ootiona

Annual Costs (SmiUions)

Option No.

Cone. I' imit

(PPT^

No. of Mills Currently Land

Applying or Able to Meet Regulatory Limit

Total Cosu of Sludge Disposal

Cost of Option Above Baseline [a]

Incremental Cost of

Option [b]

1. Baseline 12 $26.2

2. 200 10 S27.S isi.3 S1.3

3. 100 8 S30.1 $3.9 $2.6

4. 30 7 S31.3 $5.1 $1.2. • 1 5. 10 6 $31.7 $5.5 S0.4 1 6. 5 4 $38.7 $123 $7.0

7. 3 4 $38.7 $12.5 $0.0 1 8, 1 3 $38.8 $12.6 $0.1 1 9. OJ 1 $39.6 $13.4 S0.8 1 10. 03 • . 1 $39.6 $13.4 - $0.0

11. 0:0S 1 $39:6 $13.4 S0.0

12. 0.03 0 $39:6 $13:4 $0.0

13. Ban 0 $39:5 i S13.3 (S0.1) 1

Columns may not add due to rouading. Cosu of Qptkma 2rl2 iadiide estimated Ag/eusy oostt of $01 milUoa per year for enforcement and adaiiiiiatiatidit. Undeir several of tiie options, no n^ areipredicted to continue liudnppUcation. Snce theie is no assurance that; this> wiB actiud^ oocnr, eofbitemedt and administrative ooits afe assumed tolis incurred by the Ageiicy. CdfU of option 13 (ban on land applicatipn) are lower than options 2-12 by $0.1 million, since adtdbiatntive aiid enforcetnent activities will not be needed.

[a] Total costsiof optionminos cosu of current practiims.

Source: ERG estiaaates.

6-9

year, or $5 J laillion per year above the baseline. When the ooncentratlon limit is set below 0.03 PPT, all milli discontinue land application^ i.e., this limit amounts to a ban on land application. The total costs of an effective ban on land application are $39.6 million per year, which represents an increase over the current baseline of $13;4 million per year. Under an actual ban, costs remain the same escept Agency costs for administration and enforcement are not incurred.

The costs of the regulatpiy options by type of disposal, i.e., for each type of land application and other disposal method, are shown in Table 6-S. As the soil concentration limit becomes more stringent, more mills shift from land application and adopt stirfece impoundment disposal. Thus, the costs of the land applicatloa options decline and the costs under surface disposal increase.

Soil wnCTniradpiii plvii breh limitt When area limits are introduced, mills must meet two criteria in order to be able to

continue landiapplication. To determine compliance, we Erst determine, as above, whether the mill meets, the soil concentration limits. Then, the number of hectares required by the mill are calMlated. This is done by dividing the annual quantity of sludge generated by the mill by the Sludge application rate. For example, a mill that generates 22,500 DMT per year of sludge and applies the sludge to forestry land at 49 DMT per hectare would require 459 ha of land.

If the land required by the mill for sludge application is less than the hectare limit, the mill. continues land application. This assumes that no other mills within the same drainage area are already land-applying or intend to landapply sludjge. If either case arose, then the combined area receiving sludge could not exceed the area limits. For these estimates, however, it is assumed that each mill operates within a separate drainage area.

The regulatory alternatives have been specified in terms of area limits that, in combination with the soil combination limits, result in a constant level of risk from the surface water runoff exposure pathway. For an equivaleat level of risk, there Is an inverse relationship between soil concentration and the number of hectares receiving sludge (USEPA, 1990). Thus, under all options the soil concentration limit times the area limit equals 10,000. For a soil concentration limit of 100 PPT the area limit is 100 ha, for a concentration of 5 NT, the area limit is 2,000 ha, etc.

in Table 6-6. Since the area limits are inversely related to soil concentrations, the regulatoiy options in the middle (i.e., those that combine moderately restrictive soil concentration limits with moderately restrictive area Uinits) are the least restrictive. In Table 6-3, for example, a total of 10 mills met the 200 PPT soil concentration limit only. Vlên a 50 ha. area limit is introduced in addition to the soil concentration limit (as in Table 6-5), none of these are projected to continue land application^ as all require more than 50 ha to apply their sludge.

As soil concentration limits become more stringent, area limits increase. Thus, the maximum number of mills that are projected to continue land application (three) occurs under either Option 19 or 20. Under Options 21 throu^ 24, area liihits are more generous but soil concentration limits become more restrictive, hence additional mills switch to surface impoundment disposal.

6-10

TAHI.li 6-3

Qisls tif Rceulaloiv Oplitiiis hvTVneofDMPoittl

Soil Concentfaiion IJmits

Laiid Appiicatioa

Option No.

Cone. Limit (PPH

liacoiporators w

Ntw Incorp-oratonjh]

Surface Impoiindflieat Indneratioo

Agency Costs

Total Coats

1. $12.4 $133 $03 $03 $03 — $26.2

200 $123 $103 $03 $4.3 $03 $0.1 $27.5

3. 100 $123 $3.9 $0.0 $13.3 $03 $0.1 $30.1

4. 30 $113 S3:9 $03 $15.7 $0.0 $0.1 $31.3

5. 10 $113 $2.2 $03 $173 $03 $0.1 $31.7

s 6. 5 $63 $0.0 $0.0 $32.0 $0.0 $0.1 $38.7

7. 3 $03 $03 $03 $323 $03 $0.1 $3&7

8. 1 $33 $0.0 $03 $33.1 $03 $0.1 $383

9. 0.5 $0.4 $03 $03 $39.0 $03 $0.1 $39 6

10. 03 $0.4 $0.0 $03 $393 $03 $0.1 $396

11. 0.03 $0.4 $0.0 $03 $393 $03 $0.1 $39.6 1 12. 0.03 $03 $03 $03 $393 $0.0 $0.1 $39.6 1 13. Ban WO J $0.0 $0.0 $39.5 $0.0 - $39.5 1

Cbtunins may nol add due lo loundiflg^ Costs of options 2-12 include estimted Agenty coto of SO.l million per year for enfoicement and adnunistration. Under several of the options, no mills are predicted to continue land ajp^liation. Since there is no assurance that this will actually occur, enforoemeni and adminisuaiive costs are assumed to be incunred h/ the Agenqr- Cb^ of option 13 (ban on land application) are lower than options 2-12 by $0.1 millkin, since administrative and enforcement activilies will not be neededi-

* |a) i.c., agriculture applicaiiba, dislribution and marketing I bj i.e., forestry appUeation, inine reciamalitin

Source: liKG estimates.

TABLE 6-6

Qq»H 9f RmlwwiY Qptioni Concemration LimiiB and Area Limits

Option No.

Cone. Hmtt

(PPT) Size

Limit (ha)


Applying or Able to Meet Regulatory

li'mtf

Annual Costs (Smillions) ||

Option No.

Cone. Hmtt

(PPT) Size

Limit (ha)


Applying or Able to Meet Regulatory

li'mtf

Totnl CcMU of Sludge

Dlspt^

Cost Of Option Above

Baseline [a]

Incremental Cost of

Option [b]

L Baseline — 12 S26.2 ••

-14. 200 30 0 $39.6 $13.4 $13.4

1 100 100 0 S39.6 $13.4 $0.0

1 16. 30 333 I $34.7 $8.5 ($4.9)

17. 10 1,000 2 $34.7 $83 S0;0 II 18. 5 2,000 2 $393 $133 $4.8

19. 3 3333 3 S39.4 $13.2 ($0.1)

20. 1 10,000 3 $38.8 $12.6 (S0.6)

21. OJ 20,000 1 $39.6 $13.4 $0.8

22. 03 33333 1 S39.6 $13.4 $0.0

23. 0.0S 200,000 1 $39.6 $13.4 $0.0

24. 0;03 333333 0 $39:6 $13.4 $0.0 II 13. Ban - 0 $393 $133 ($0.1) 1

Columns may not add due to rounding. Costs of options 2-12 indiide estlinated Agency costs of SO.l million per year for enforcement and adminisiration. Under several of the options, no mills are predicud to continue land application. Since there b no asiiirance that thb win actually occur, enfoieement and administrative costs are assumed to be incurred by the Agetuy. Costt of option 13 (ban on land application) are tower than dpttons 2-12 by $0.1 million, since administrative and enforcenMnt aaivities will not be needed.

[a] Total obsu of option minus cosu of current,practices. .[b] Total costt'of option minus oosU of previous option.


6-12

Because the mills that continue land application may be of different sizes and may curreritly be engaged in different types of land application, the costs of compliance will vary, even though the total number of impaaed mills may not. thus, under a 3 PPT concentration and 3,333 ha area limit, nine mills discontinue land application, resulting in additional costs of $13 2 million. Under a 1 PFT concentration and 10,000 ha limit, nine mills discontinue land application but the costs are S12^6 million.

Under the 200,100, and 0.03 PFT limits (and corresponding area limits), as well as under a ban on land application, all mills are projected to discontinue land application and adopt surface impoundment ^sposaL The total costs of disposal under each of these options is an additional $13.4 million per year :(Sl3.3 under an actual ban). Costs are minimized under Options 16 and 17, even though only one mill continues land application under the regulatory Option 16 and t^ continue under Option 17. This is because only these two options permit one particularly large mill which currently uses a low-cost disposal option to continue land application.

Table 6-7 shows the regulatory costs arranged by type of disposal, and shows land application costs for those that incorporate and those that do not incorporate sludge. As the soil concentration limit becomes more and more stringent, mills discontinue land appJication and D&M and commence disposal to surface impoundment. This is reflected in the costs for each disposal type.

Alternative RIska for Surface Water Runoff. Expressed in Different Application Area Sizes

The above analysU evaluates Options 14 through 24 using.a 10 PFT soil concentration limit and an ai^bcation area liniit corresponding to a 1:10,000 risk from surface water contamination from erosion (i.e.« 1,000 hwtares). Altemaflve application area limits, corresponding to alternate risk leveisi were also evaluated At the 10*' risk level, only 3 mills are estimated to continue land application, and the estimated additional cost for thislevel of regulation is S6.8 million. At the 10'' risk level, all mills are predicted to discontinue land application, lê estimated additional cost for this level of regulation is $13.4 million.

6.6

Additfonal analyses of econoinic impact on such variables as: industry and company profitability, emffloyment, balance of trade, and national income have not been completed for this draft of the RlA. Only initial indicators of economic impacts are discussed below

Given the relatively tow magnitude of the incremental costs of the regulatory options from Table 6rA (Le:, berween $8 J and $13.4 million per year), no significant regulatoiy impacts are expected The pulp and paper industry has recently enjoyed some of its most profitable years (Sundard- A PoorSi 1989a and 1989b; Pulp and Paper, 1990), although it is expected' to enter into a tydical SlowdoVm begiimmg this year.

The induitry u characterized by largp^ well-capitalized and diversified companies. Some recent sales and earnings data for a sample of 24 companies are shown in Table 6-8. Parem corporations of seven of the twelve mills currently engsged in land application are represented in

6-13

rAUI.li 6-7

Cosis of Ucgulalorv Oiwioiis bv Time of I

Son Coocentfatbn and Area Limits

Land Application

Option No.

Con& Limit (PPT)

InoiMporalars . w

Non Inootp orators [bj

Surface impoMndmeni Incineration

Agenqr Costs

Total Costs

1. $12A $13.8 SOD SOD $0.0 — $26.2

14. 200 $0.0 $0.0 SOD $39.5 SOD S0.1 S39.6

15. 100 $0i) SOD SOD $39.5 $00 S0.1 $39.6

W- 30 $0J} $2.2 SOD S3M $0.0 S0.1 $34.7

17. 10 $0.4 $2.2 SOD $32.0 $0.0 $0.1 $34.7

18. 5 $1J SOD SOD $37D $0.0 $0.1 $39.5

19. 3 $3S SOD SOD $35D SOD $0.1 $39:4

20. 1 tss SOD SOD $33.1 SOD $0.1 1 $38.8

21. OJ $0.4 SOD SOD $39.0 SOD $0.1 1 1 S39.6 22. OS $0.4 SOD SOD $39.0 SOD $0.1 1 1 $39.6 23. 0.05 $0.4 SOD SOD S39D SOD $0.1 $39D

24. OiB $0.0 SOD SOD $39.5 SOD $0.1 $39.6

13. Ban $OJO SOD SOD $39.5 1 SOD - $39D

Columns may not add due to loundiitg. CosU of options 2rl2 indude esttmated Agency costs of $0.i million per year tor enfoicement and administration. Und^ several of the options, no mills are predicted to oooliniie land appUcatioo. Since theie is no assurance that this win actually occur, enforcement and adnumdratiyie cods are assumed to be inaiited by the Agenqr. Costs of option 13 (ban on land applkaiibn) are lower than options 2-12 Iqr $0.1 miUibni sinpe aditpiaistraiivc and enforcement activities wiO not be needed.

[a] io., agriculture applicalibn. distribution and nurketing (bj i«.. forcstiy application, mine reclamation

Source: IiUG estimates.

TABLE 6-8

pecytFtpandalpjaalbr piilpanciPapyGoinpês

No. ConynnyNanie Year 0000) Nttlnoonie .(SOPO)

Net Income asperoent ofSalas

1 Bdsa Cascade Coipi 2 Bmitger Paper am 3 Bowterlna 4 ChanilpipnlniafrMtiral^^ S, ChBaaDealcB COOL 6 Fed^ Paper BoaidCa 7 GaôfdCcfiialnerGoipL 8 Namatonai Paper Corhpan/ 9 James HvarCoip.

Id KjrdMiiy Qark Ooip. 11 LMigviawRbreOa 12 LotiaianaPiacifieCoip. 13 MeedCoip. 14 Gieai Nonhern Netoosa Cmp. 15 Peaarlne. 16 Pope &Tallbot Inc. 17 PolatGliCbi^ 18 PraciBr&Gamble 19 Scoit Paper CCi 20 SioneContainBrCoip. 21 LMonCampCpqx 22 WaUGau Paper Jills 23 WesivaooCo^ 24 Widamene Industries

TOTALS

1989 $4,338 $268 32% 1988 $72,157 $4,656 35% 988 $1^410,400 $164,300 11.6% 988 $5,129,000 $453000 39% 989 8813,100 $47,600 39% 988 $1,116,900 $143300 128% 989 $746,000 $39,400 5.3% 988 $8,533,000 $754,000 7.9% 989 $5;871i773 $253065 4.3% 989 $6,733,600 $423800 7.4% 989 $897,725 $66,519 9.5% 988 $1,799,400 $135,200 7.5% 989 $4,61%100 $215^00 4.7% 989 $3,863100 $321,100 8.3% 988 $823281 $39,842 4£% 989 $813758 $43637 7.1% 988 $1,227,622 $136,715 11.1% 989 $21,398,000 $1,203000 5.6% 988 $4;728,400 $400,900 35% 988 $3742,489 $341,786 31% 989 $2781,337 $299,400 10.8% 989 $317,097 $20,912 6.6% 989 $2284,059 $223,090 38% 988 $1,716,021 $161,087 34%

$81,017,657 $5,900,377 7.3%

Soufoe: SEC CGhgs retrieved from the C0MPA(^C)48CL08URE data base.

this data. Combined net income of these seven for the years available is $2,581 million while total compliance costs for all 12 mills is estimated at under $14 million for the most stringent option.

It must be noted, however, that compliance impacts will be felt, and plant shutdown decisions will be made^ at the level of the liiill. Overall corporate profitability may not, therefore, be an appropriate indicator of economic impacts; The level of mill profits could be estimated using, for emmple, data on produetiom prices, and profit margins.

6.7 Twhnlcpl iPmces^ AlforpgUvîi Forlêdiiclllig P!o$in Conceptratlgn Ip glwdm

Changes in disposal options, as forecast above, may not be necessary under, a land application regulaticii if mills are able to eliminate or reduce diaadn from their waste streams. This section providies a brief summary of the status of cleaner mill production processes. For more thorough discussion, see USEPA (1990b) and y.S. Congress (1989).

,4

TCDD and TCDF are in a group of chlorinated organics that seem to be produced during the chlorine bleaching and delignification processes. Their formation, however, is not well understood. Precursors required for dioxin and foran formation most likely come from either natural sources, pipe and machine contaminants^ and/or additives such as the bleaching or defoaming. agents. The uncertainty around the precise origins of dioxins and fiirans has led to indirect and/or approximate methods of controlling their formation.

There is no single solution to reducing dioxin and furan formation. One of the most likely dioxin and furan formation processes is the interaction between chlorine and lignin. About 10 percent of the waste streams from bleaching plants in mills contain ̂ orine compounds, including dioxin and furan compounds; The amount of chlorine<oontaining waste varies from mill to mill. The most suitable approach to reducing dioxin and furan formation depends on the mill configuration, with new mills having the most flexibility and options for addressing this problem.

Dioxin and furan contamination can show up in either effluent water, sludge, pulp, or all three. Also, dioxin and fiiran concentrations vary in these three media. A survey of five U.S. kraft paper mills found dioxiiu and fiirans in bleached pulp about 40 percent of the time, in the wastewater sludge about 40 percent of the time, and in the liquid effluent about 20 percent of the time* (USEFA, 1988). The delignification and bleaching stages of the bleaching process are most likely responsible for dioxin and furan formation.

Delignification is a stage in the pulping process where lignin, the substance that binds the wood's cellulose fibers, is removed. It occurs as pulp leaves the digestion stage and enters the bleaching stage. Pulp prior to bleaching is commonly referred to as brownstock. The less lignin in the brownstock, the less bleach required to attain the same level of whiteness. In a typical pulp mill 10 percent of the liignin remains after digestion. Too much digestion of the ligm'n can result in decreases in pulpstrength, paper durability^ and pulp yield. Defbaming agents are also used to aid in washing the uribleaded pulp.

* Based on all samples taken. More than one sample may have been taken from each mill.

6-16

Ute bleaching stage continues the process of eliminating lignin, which imparts the properties of flexibility and resistance to yellowing^ Chlorine is the most common bleaching agent because of its low cost and effectiveness. The highest levels of dioxins and furans have been associated with the caustic extraction stage of the bleached kraft process, a stage designed to remove the dissolved materials after exposure to chlorine treatment. Eliminating or redudng chlorine can reduce the levels of dioxins and furans in mill waste streams. Total elimination of chlorine from the bleaching process is still eoiuidered experimental, as opposed to commercially accepted.

There are several ways to reduce dicodn and fiiran levels in mill waste, including:

Prc-blcathinfl rttw Increasing deligniflcation prior to bleaching Improving washing of the unbleached pulp Improving chemical mixing of the piilp Increasing pulp pH prior to bleaching Removing dioxin and fiiran precursors prior to. adding chlorine

Bleaching stena

• Using non-chlorine bleaching agents • Using chlorine dioxide after the initial dosage of chlorine • Using chlorine bleaching in several small dosages^ rather than one large application,

for example, splitting the one standard dose into three dpses

Other steps • Using nonîilrbased defpaming agents or oil-based defoaming agents widiout dioxin

and fiiran precursors (however, nonîl based dcfoamers are not effective for washing unbleached piilp)

• Improving secondary waste treatment and sludge management

In adtfltipn^, water and energy conservation measures can reduce dioxin and fiiran levels^ including:

• Rertyding; dilorination stage process water (although this may also inoreue^.the dioxin and foran levels)

• Using ooimterûrrerit washing systenu after ehlorination • Using hiêr ratios Of fiber pulp to water

6.1.1 Qiygen Deligniflcation Practices

The use of oxygen as a deligniflcation agent can reduce ditxdn and fiiran levels in the waste stream by halving the (Alorine required tO achieve the same effects. Higher levels of oxygen deligniflcation are avoided because th^ can compromise the quality of die pulp. Unlike other chlorine substitutes, however. Oxygen ts relatively inexpensive.

Oitygen deligniflcation is a world^de technology with over 30 years of commercial application. Oxygen can, also be uSed in extended digestion Operations to reduce lignin content.

6-17

it is tedinically feadble, ttlthouj^ not presently oommerdally practiced, to eliminate the total use of chlorine by prerbleaching piilp with oi^gen and substituting chlorine dioside for chlorine. While TCDD andTCDF formation are reduced substantially, data are inooncltisive about whether they are eliminated by using this combination of substitutions for traditional technologies. However, the substitution of Afferent defoaming agents and use of chlorine dioxide instead of chlorine will probably reduce dloxin and furan formation^

Q]^gen deligiiification increases the volume of wastewater that requires chemical recovery. The increased'wastewater can be managed if the process is designed into a newmill. Older mills, on the other hand, may be overloaded by its intro^ction. For example, it is estimated that adding oxygen delignification to an existing plant that is operating at foil capacity will decrease it's operating capacity fay 4 to S percent Hnally, the costs of modifying mills to use oxygen are very site-specific, maldhg generaliations very difficult

, 6.7.2 Alternative Bleaching Practices a

Alternative bleaching agents include:

• OxvEcn - This is the most promising chlorine substitute. Complete replacement of chlorine with co^gen has not been adiieved yet

• Chlorine dioxide - Chlorine dioxide is a more efficient oxidant then Chlorine. However, while substituting chlorine dioxide for chlorine reduces dioxin and foran levels, its effect on other chlorinated contaminants is unclear.

• Oxone - This agent is still experimental and not presently used in the industry.

• Hvpochlorite and hivdroeen peroxide - These are generally used as supplemental bleadiing agents.

Each of these has its strengths and weakncases. In many instances these agents are used in conjunction with one another to achieve the desired effect.

6.72 Sludge manapment

Secondary wastewater treatment, or biological treatment, is effective in removing dioxins and forans firom wastewater and concentrating it in the sludge, Effective secondary treatment can remove up to 90 percent of the TCDD and T^F from wastewater. TMs high percent removal is only achieved with careful operation and management A few studies have shown that dioxins and forans in landfilled sludge are suble and do not migrate faCcause of their adherence to particles.

6.7,4 Other methods

Extended delignification is another process that reduces the amount of lignin before bleadiing. Extended delignification requires more time, different temperatures, and different pH levels than normal digestion processes. Too much delignification will produce pulp of inferior quality and yield.

6 18

also been found to reduce the amouiit of lignin, this process involves pretreating pulp before oxygen deligiiification ̂ th nitrogen dioxide and oxygen. This pretreatment encourages removal of liîn without compromising pulp quality. ,

6J3 Conclusions regarding technical process alternatives

The pulp and paper industty is examining the viability of several alternative processes to reduce or eliminate dioxin formation. These methods are not widely-used at the present time, and applying them at existing bleaching mills will be costly and perhaps unfeasible. Nevertheless, to the extent that mills may be able to justify adoption of these techniques, the baseline Ibvels of dioxin contamination will be considerably reduced. If this were to occur, the benefldal impacts of land application of sludge codd continue to be derived.

6-19

SECTION SIX REFERENCES

Bowen J. and I Hsu, 1990, 'Overview of Eiuerpng Technologiei in Pulping and teaching,' TAPPr Journal. D 203.217. September. 1990.

Basta, O. et a]., 1990. 'Redudng Lev«ls Absorbable Organic Halons (AOX)," TAPPI Journal. p.lSS-160. April. 1990.

Collinson, 1990. Telephone communication between Peter Ffitzinger of ERO and Mr. Jonathon Colilnson of Woods End Laboratoty, Mt. Vernon, \foine. October, 1990.

Environment Ontario, 1988. Stonoing Water Pollution at its Source; Kraft Mill Effluent in Ontario. Technical Advisory Committee, Pulp and Paper Sector of Municipal/Industrial Strategy for Abatement, Onurio hfiniatiy of the Environment, Toronto, Ontario, Canada.

Hise, R; and H Hintz. "The Effect of Brownstock Washing on the Formation of Chlorinated Dtoxins and Furans During Bleaching;" TAPPI Journal, p.183-190. January, 1990.

MacDonald, Je^ 1990. Telephone communication between Peter Pfitzinger of ERG and Mr. Jeff Maônaldof the Abandoned Mine Land Group, Department of Natural Resources, State' of Ohio. November 8, 1990.

Page, Bill, 1990. Telephone communication betweien Peter Pfitzinger of ERG and Mr. Bill Page of Massachusetts Natural Fertilizer Co., Westminster, Misssachusetts. October, 1990.

Parthasarathy, W. et al, 1990. "Hydrogen^peroride-reinforced Oiiygen Delignification of Southern Pine Kraft Pulp and Short Sequence Bleaching,' TAPPI Journal. p.l77-18S. July, 1990.

Pulp and Paper, 1990. "Focus: Outlook *90," Pulo and Paper. January, 1990.

Repa, Ed. 1990. Telephone communication between Jeff Cantin of ERG and Dr. Ed Repa of the National Solid Waste Management Association. October, 1990.

Standard & Poor's, 1989a. Standard A Poor's Industry Surveys; Building and Forest Products includes Paner Current Analysis. February 9,1989.

Standard & Poor's, i989b. Standard & Poor's Industry Surveys: Building and Forest Products. December 14,1989.

US Congress, OTA, 1989. Technologies for reduafag Diorin in the Manufacture of Bleached Wood ^JJR. OTA#: 0TA-BP4}^54; Office of Technology Assessment, Washington, D.C. May 1989.

USEPA, 1988. U.S. EPA/Paner Industry Cooperative Diorin Screening Study ("The 5 Mill Study"). EPA-440/l-884}25). March 1988,

6-20

USEPA, 1990a^ U.S. EPA/Paner Industry Coooefative Dtonn Study (The 104 Mill Study'). Statistical Findings and Analyses. July 1990.

USEPA. 199Gb. Summaiv of Technologies for the Control andReduetion of Chlorinated Orminia from the Bleached Chemical Puloing Subcategories of the Puin and Paner Industry. Office of Water Regulations and Standards, Office of Water Enforcement and Permits. April 27. 1990.

6^21

SECrtON SEVEN /

ECONOMIC BENEFITS OF REGULATORY OPTIONS

7.1 imniwrttTO

EbbnoAic damages are likely to result from the exposure of humans and wildlife to pulp and paper sludge containing dioxins and fiiraits^ With regard to human health, dioxins and furans may increase cancer risks and medical costs and cause reduced fertility and sldn conditions such as chloracne for exposed individuals. For exposed wildlife, potential adverse effects identified in the

This could mean that reductipns in populations and/or species diversity are likely to occur. Associated ecological damages may include diminished recreational Opportunities (use values) and reduced aesthetic values (nonûse or intrinsic values) for an ecological ameni^. The reductiori or prevention of humnn health and/or ecological damages, therefore, constitute the benefits of a regulation on the land application of pulp and paper sludge. To the extent that damages are reduced, social welfare is increased.

Background information on cost-based compliance decisions and the likelihood of changes in disposal practices resulting from alternative reâtoiy options designed to reduce risk were presented in Section Rve. The resulting changes in disposal practices are not risk-free, however, since each disposal method poses itt own risks. Benefitt are therefore dependent on the net change in exposure and risk brou^t about by the regulation of land application. This section outlines conceptual measures of human health and eeplogicai benefits and assesses the likely magnitude of benefits which would accrue under the anticipated regulatory compliance scenarios. Lastly, a framework for comparing benefits and costs is discussed.

7.2 gumrni Byiwfltf of Regulatory ffltffoni

One of the principal motivations for environmental regulation is to reduce damages to human health. To estimate human health benefits associated with a particular regulatory al ternatlvCi the net change in human health effocts, measured In this analysis by the change in the number of cancer cases, resulting from the regulation must be calculated. Comparisons of regulatory cosU per case avmded, or directmeasures of health oostt or the value of statistical -Kves are then used to provide eooncunic measures of risk reductions.

Note that for the benefits analysis which follows, some changes and adjustments from the integrated ride aasessment (USEPA. 1990a) have been made, lliese changes have occurred because: 1) specifie new data have been acquired in the *104 Mill Stuc^ (USEPA* 1990c), and; 2)

application of municipal sludge. The new infonnafion included individual mill sludge volume, contaminant concentration and mill disposal methods. The adjustments to assumptions included drainage area size, distance of sludge management area to surCsce water* and dietary consumption by exposed individuals.

7-1

74.1 Calculating act rlik

Risk is measured in part by the probability of adverse health effects. The regulatory options discussed in the cost section were developed ^ examining the baseline risk to the maximally exposed individual (N^) as detenhined in the risk assessment. The MEI was assumed to be a subsistence fisher exposed by ingestion of fish ipontaminated through the surfoce water pathway or a subsistence fistmer exposed ingestion of food products grown on contaminated land. The Options were designed to limit the cancer risk from eqfosure to dioxin through these pathways to a level of 1 in 10,000 (above background risk levels). However, in order to calculate the health benefits attributable to the regulation, it is necessaiy to examine the magnitude of risk reduction to all individuals affected by the regulation. This implies use of a benefit analysis which focuses on the risk reduction to the exposed population rather than the MEI.

Important factors in determining risk reduction include the predicted sludge disposal method undertaken by the mill both before and after a regulatory action is taken and the populafion risk associated with ea^ method. These predicted disposal methods were based on information reported in the 104-mill study and on the estimated costs of Complyiiig with each reguiatoiy alternative, given sludge volumes^ land area requirements^ contaminant levds, and mill location.

Calculation of net health risks to exposed individuals involves two steps: (1) calculating risks avoided by prohiUting or restricting the current practice, and (2) calcuteting risks posed by the new diiq;wsal practice ado^d as a result of the regulation. If fimu switch to a dispo^ practice which poses lower risk, then net risks are negative. Only the twelve mills engaged in land application at the time of the EPA '104 Mill Stuc^ (USEPA, 1990c) were consii^red in the human health benefits assessment. Annual cancer risks for current disposal practices were estimated from information on sludge concentration of dioxin and disposai practice of the mills, potential, exposure pathways, and estiinates of exposed populations. To^ risks were estimated by summing the risks from each of the twelve mills.

Given a spedfie regdatoty option for the dioxiii soil eoticentration limit, each mill was predicted to continue or switch disposal practice based on the least costly alternative. If a mill switched disposal practice# the net change in risk was cailculiited fay subriacting, risks of the previous dispell practioe frcon risks of the new disposal practice. Under any rCguIatoiy scenario, the total net risk is the sunt of the net risks of each mill. In this manner, the benefit estimation methodology accounted for the changes in eqjosure pathwi^ and exposed populations as mills switch disposal practice. All human heddi risks are expressed in terms of the number of incremental cancer cases per year over the eaqmsed population.

Estimates of exposed populations varied with the assumed' pathways, from few exposed

individuals for some off-dte exposures (e.g^ ingestion of food grown on contaminated soil). For land appiicaripn, risks s^re estiiimted, for dermal exposure# dieUiy exposure, inhalation of vapor, inhalation of particulates# direct ingestion of sludge^ntaminated' soil, oonsunaption of oontamiiaated fish, and ing^tion of contaminated water. For distribution and marketing (D&KQ# die analysis estimated risks from all of these pathways except the fish ingestion and water consumjôn pathways, since the land areas used are assumed to be too small to result in substantial risks from these two pathways. Finally, landfills and aurfiice impoundments are assumed to have liners, runoff controls, soil covers, and restricted access, and therefore pose risks from inhalation

7-2

of volatilized compounds only. Due to the lack of site specific information, the same exposed population estimate was assumed for each disposal practice^cxposure pathway combination. In this manner, for example, the difference in risks attributed to the surface water path^y for two mills applying Sludge to forest land results from sludge concentration differences only, and not from differences in exposed population. Without further information on specific land application Sites, it is impossible to know whether exposed populations were overestimated or underestimated.

The net risks associated with Options 1 through 13 are presented in Table 7*1 for all mills combined. Risks decrease for all alternatives to current practices. A regulatory restriction based on soil concentrations only of 200 FFT and 100 PFT allows some mills to continue land application at agricultural, forestiy, and mine reclamation sites and to continue distribution and marketing. At 30 PFT, all agricultural application would be suspended. Restricting soil concentration to 10 PPT eliminates agricultural ami forestry land application programs but allows some mine reclamation and distribution and marketing to continue, At application rates corresponding to a soil con^ntration of S PFT, mine reclamation is eliminated and DAM is gradually phased out as the limit is restricted to 1 PPT. Soil concentration limits of less than 0,5 PFT are so cost restrictive that they effectively result in a ban and cause all mills to suspend land application in favor of surface impoundments.

Generally, associated cancer risks are less for mills utilizing distribution and marketing rather thanmihe reclamation as a means of disposal- This occurs primarilybecause fewer exposure pathways are associated with distribution and marketing than widi other types of land application. Specifically, the oomumption of contaminated fish exposure pathway, amich is one of the pathways of most concern, is not identified. Additionally, human health risks are reduced when pulp and paper sludge is disposed of in surfoce impoundments with liners, runoff controls, and restricted access inst^ of land applied. Net risk reductions of -0.08 to -0 cases per year from .33 cases per year are estimated tar soil oonoentradon limits from 200 PFT to 10 PPT primarily because agricultural application Is predicted to cease and mills are predicted to choose surface impoundmenu as their dispo^ option. Cancer risks are estimated to be zero at soil concentration limits; of 5 PFT and below, as distribution and marketing is phased out and mills switch to surface impoundments whidi pose lower risks than other land application programs.

The concentration of contaminants in nmoff from a land application site are not only dependent on the soQ concentration of diozins and furans, but also on the surCsoe area to which the pulp and paper sludge is applied. Options 14 to 24 combine the soil concentration limiu from Options 2 to 12 with hectare limits, Le., limits on the number ofhectores of land.applicatibn'ihat can occur within an individual drainage area, Restricting site size along with soil concentration increases land applicaticm costs and causes firms to shift to alternative disposal practices. Because of this, human health risks are decreased. Table 7-2 presents estimates of human health risk reductions associated with regulatory options that combine area limitt with soil concentration limits.

7.24 Sensitivity to MEI risk based regniatoiy options

A sensitivity analysis included examination of compliance choices made by mills under lin addition

to a level of 1 in 1,000. At the level where risk to the MEI is restricted to 1 in 1Q0;QQ0. land apfdication Is predicted to cease. Thus, benefits to the e:qx»^<l population are maximized and are predicted to result in a reduction of 0.33 cancer cases per year* Alternatively, under an option

7-3

TABLE 7-1

Annual Reductiom in Human Health Riata fPomilation Caneef fa]

i Option No.

Concentration Umit (PPl^

Option Total Annual Population

Cancer Cases Net Change in Population

Cancer Cases [c][d]

1. Baseline 0331b] -0.0

2. 200 PPT 0.29 4).04

3. lOOPPT . 0.18 •0.15

4. 30 PPT 0.02 -0.31

10 PPT 0:02 -0.31

6. 5 PPT 0.0 [d] -0.33

7. 3 PPT 0.0 •033

1 IPPT 0.0 rb.33 1 1 OjPPT 0.0 -0.33 1

10. 03 PPT 0.0 ^33

11. 0.05 PPT 0:0 -0.33

12. 0.03 PPT 0.0 -033

13. Ban ao •0J3 1

[a] Non-canoer and aubîethal human health effccu of TCDD/tXZDF exposure are exduded. [b] Predicted cancer cases attributable to the 12 mills currently applying sludge to land. [Cj Additional riska inoirred minus risks avoided by switching disjâi' practiceii [d] Residual risks of 0:0002 and below are rounded to zero.

Source: Abt Associates and ERO estimates.

7-1

TABLE 7-2

Annual Reductiom in Human Health Risks ^Population Cancer Casea^fa] Soil Goncentration Plus Area Umita

Option Number

Cone, limit (PFT)

Area Limit (ha)

Total Aimual Population i Cancer Cases

Net Change in Population Cancer Cases (c]

. 1. Baseline - 033 [b] 0.0 1 14. 200 PPT SO 0.0 •033 1 15. IQOPPT 100 0.0 -0.33 1 16. ,30 PPT 333 0.0 -033

17. 10 PPT 1.000 0.0 -0.33

IS. 5 PPT 2.000 0.0 -0.33

19. 3 PPT 3333 0.0 -033 1 20. IFET 10,000 0.0 -033

21. 0,5 PPT 20.000 0;0 -033

22. 0.3 PPT 33333 0.0 -0.33

23, 0,05 PPT 200.000 0.0 -0.33

24. 0.03 PPT , 333333 0.0 -0.33 1 1 13. Ban 0:0 -033 1

[a] Non-cancer and sub-lethal human health effects of tCDD/TCDF exposure are excluded. [b] Predicted cancer cases attributable to the 12 mills currently applying sludge to land. |c] Additional risks incuned minus risks avoided I7 switching dispo^ practice.

Source: Abt Associates and ERG estimates. .

7.5

where MEI risk U 1 in 1,000 above badcground levels, 3 mills are predicted to continue land application.

7.2J Pennitting eptlona

The additional regulatory options which include the iinplenienutiOn Of permitting systems to obntroi land application of pulp/paper sludge were described in Section 4. Compliance choices {or individual mills under these permitting options could not be estimated due to lack of Site specific information, Therefore, no specific estimates of human health benefits are possible at this time.

However, the permit systems may encourage mills not previously land applying to begin and may allow.some of the mills predicted tP cease application to continue. These activities would be exited to decrease the net benefits of the concentration and area based options because increased lan4 application activity would impfy greater exposure to the population!

•?

If the permit systems increase a mill's operating costs to the extent that alternative disposal methods become attractive, benefits could increase due to reduced population exposure. However, benefits would not be expected to increase over 0.33 cases per year whiim is equivalent to the number of cases saved as a result of a ban,

73.1 PotaiiClal ccologlGal damages ^

to dicndn may result in a variety of adverse effects. These may include reduction: in reproductive capability^ leducedihatchability for birds, embiyonic malformations of the heart, and mortality. Risk quotients (RQi) estimated in the risk assessment suggest that adverse effects may be likely for individuals of sensitive species for a variety of soil concentrations. For example* potential risks to woodcocks at contaminated forest sites are considered high for chick cardiac malformations. In adcfition, the assessment notes that fish appear to be the most sensitive of aquatic spedes to dioxin eaqxMUre of those spedes that have been tested and mortality has been identified as a potential effect of that ezposure. For certain migratory spedes such as striped bass, shad, and Atlantic salmon, there aiso eaisd a potential for adverse effectt on populations. The reduction of risks through regulation may reduce the potential for such possible adverse effects.

A

Whille concern for human health has led to the development of an analytical framework to value

associated with benefit estimation for reduced udldlife risks such as those described above. The wide ranges of reported values in published studies have reinforced views of ecological benefiu valuation as an inexact sdence. M^y assumptions are neciusaiy to make empirical work tractable and the valuation of diverse types of ecological goods and seidces requires several unique rtiethodologies. An ovetview of the conceptual basis for valuing ecological benefits is, therefore, presented below.

7-6

In valuing ecological benefits^ a basic distinction is often made between the intrinsic value of something's existence and its value in use by the human population. Use values are further subdivided into direct or indirect uses. Other valuation concepts arise from the unceitaiiity surrounding future uses for and availabiji^ of ecological resources. A classification of these valuation concepts is presented in Table 7'3.

UW benefit

The benefits of an ecological resouice will depend upon several variables that describe the attributes of the resource and its uses. Some resources will be used for recreational activities (such as fishing; boating swunmtnt hunting, bird watching)^ Other resources will be used for oommercial purposes (such as timber or fish harvesting, grazing); while other resources may be used for both recreational and commercial uses. When estimating environmental benefits, it is important to determine whether or ifot the resource can be considered a market or non-market resource (i.e„ is there an existing market for it). Ifor example, commercial fisheries have a market value refiected by the financial value of landings of a partiâr spedes. By contrast, no market exists to describe the value individuals receive from bird watching.

Direct use includes both consumfUive and non^nsumptive uses. Consumptive uses can be distinguished from non-consumptive uses in that the former excludes other uses of the same resource. For example, ducks are consumed during duck hunting. With non-consumptive uses, however, the resource base remains in the same sute before and after use (e.g., bird watching). While they are conceptually distinct attributes, consumptive use is frequently assodated with markets and non-consumptive use is frequently associated with noni>market situations. Some resources tlmt are considered market resources, however, may be used non-consumptively. The converse is also true. As an example of the first, a fee may be charged (Other than parking) to gain entrance to a state forest, however, a hiker's use of the forest is not consuming any part of the forest.

Commercial activities that are dependent on ecosystem services and resources (e.g., clean air/water, specific habitat, or key plant/animal spedes) that are not directly owned or propagated are said to benefit from indirect use. Examples would be a fishing equipment manufacturer's dependence on healthy fish stocks to induce demand for Its products or a former's dependence on habitat for wild birds whidi contribute pest control senrices. Indirect lue is also characterized by the educatioiial and entertainment value to consumers of books, magazines, movies, television programs, animal ezfaibits. etc., concerned with spedes or ecosystem subject matter. ' « -

EsUSSQfiSJZSDfifik

Existence value indicatea an individual's (and sodety's) willingness to pay to maintain a sound ecological system (or a spedfic habitat, spedes, etc.) for its own sake, regardless of any perceived or potentiai opportunity for that individual to use foe environmental resource now or in the future. That people opntrihute mon^ to "save the whales" demonstrates a wUlinjpiess to pay for the existence of an enviionmental amenity despite a low probability of ever using it in any way or even experiendng it directly. Presumably, the quality of life (utility) for these individuals will be adversely affected by the extinction of spedes and loss or degradation of relatively remote habitats.

7-7

TABLE 7-3

A aawtfication of Ecological Benafita with ExaitiolM

Benefit Class Eiamples

Use Value Direct Use Consumptive

.> \ * •

Direct Use Consumptive trapping, lumbering

.> \ * •

Direct Use Consumptive

irrigation, waste disposal

.> \ * •

Direct Use

Non-oonsumptive Bird watching, hiking, nature photograplq^ .> \

* •

Indirect Use Scenic views, pest control, 1 greenhouse gas removal ||

Eyj^tcffcq Valwff Vicarious Consumption Resource used by friends, | relatives, other people |

Eyj^tcffcq Valwff

Bequest Value Preservation for use by future 1 generations ||

Eyj^tcffcq Valwff

i Inherent Value Spedes right to exists, | ecosystem diversity |{

Undiscovered uses for plants/animals» untapped | aquifer i

7-8

While some economists have argued that intrinsic values are not germane to social welfare analysis because such analysis requires a human use orientation, others have pointed to willingness to pay evidence as an indication of the role that ethical or emotional considerations play in^ human utility functions. In other words, the existence and protection of nonhuman species has psychic value to many individuals. Additionally, certain individuals may derive benefiu firom knowing that environment^ resources exist for others to Use (vicarious consumption) or that they will be ipresetved for future generations (bequest value). Those individuals willing to pay for preservation may or may not be resource users, yet they benefit because of their affinity to eventual users,

Arguably, some use is made of everything that exists on< the planet since humans are part of a global eoo^tem^ Absorption of carbon dioxide by a remote rain forest or an 'undiscovered' species' role in a food web are examples of ecosystem services which indirectly benefit humanidnd worldwide. Existence value thus overlaps the concept of indirect use value, in that the loss of environntental resources'would have economic (income) as well as psychic (ethical) Consequences, both with Utility effecu.

Option benefits

Option value is the willingness to pay for having a future opportunity of using resources in known or as yet unknown ways. In a sense it is a combination of insurance and speculative value. Individuals routinely pay to store or traiisport something they are not sure they will use in the future because they recognise it would be more costly to recreate the item than to preserve it. In an ecological sense, pristine habitats and wildlife refuges are often preserved under the assumption that plant or animal species which may yield pharmaceutical, genetic, or ecosystem benefits are yet to be discovered Option value takes on particular importance when proposed development or environmental perturbations are largely irreversible or pollutants are persistent.

Summary Total valuation of natural resource benefitt involves all use and existence values as well as

option value. When> ecological resources are subject to adverse impact (past, ongoing or potential), valuation of benefits is an essential part of sodsd welfare analysis. The proper framework consists of (1) determining when damage first occurs or is obseiverh (2) identifying and rpiantifying the physical/biological damages rdative to an appropriate bas^ne, (3) identifying all affêd individuals both due to loss of direct or indirect services Or uses to losses attributable to

afCected individuikls placed on the resource prior to damage, and (5) determining the time horizon over which the resource will be restored to its prior state or to some maximum reduced state of service flow and appropriately discounting the stream of lost services,

7Jj Characterization of bnd application sites

Land application of pulp and paper sludge, in addition to serving as a method of sludge disposal, also fertilizes and conditions soil and makes use of the sludge as fill, Currendy, pulp and ipaper sludges are used on forests, applied to agricultural lant^ and used to reclaimabandoned mine sites. Pulp and paper mill sludge may also be composted with Other materials and then distributed and marketed as a soil amendment The product is then used for residential gardening and lawn care. Or for agricultural and commercial purposes. Each of these.> applications can lead to wildlife

7^9

exposures to dioxins and fiirans through ingestion^ dermal absorption and/or inhalation, The type and extent of exposure depend on the particular species, its habitat, and its place in the food web.

The most commonly occurring avian, mammaliam aquatic^ and reptilian species as well as endangered spedet have been identified (See USEPA. 1990a: USEPA, 1990b) in each state where land application of sludges occurs. For the purposes of the re^latoiy impact analysis, model agricultural, mine redamation, sihncultural, and D&M sites have been dievelpped. Speqes have been asdgned to these four model sites according to the types of land application practiced in the state in which the spedes is found In many cases the spedes listed at each -site are surrogate spedes (in terins of a spedes level in the food web or iu trophic level) for those spedes that are actually present since not eiiou^ data are available to Erectly tie spedes to specific land application sites. In other words: the representative spedes listed for each model site are the spedes found in the particular states where that form of land application is currently occurring. Since the type of sites experiencing land application differs among the states, the list of representative spedes differs among types of sites. Additionally, for each ihodd site where land applicatfon of pulp and paper occurs, a set of potential ecological benefits that mi^t apply to the site has been identified. These benefits include use values (consumptive and iiOn-consumptive), existence values (vicarious consumption: bequest: end inherent), and option values. Tables 7-4 through 7-7 characterize each of the model sites by spedes present and by the potential benefits assodated with each of the sites.

As discussed above, there are a variety of benefits firequentliy assodated with ecological resources. To fiiHy characterize the model sites, these benefits have been described according to the spedes and activities expected at each site. It should be noted, however, that at this time, it is not possible to identify exactly vdiicb activities will occur at eadi of the four model sites. It is, thereflDre, assumed that roughly the same activities and assodated benefiu will be present at all model sites. For example, at the four sites: consumptive recreational benefits such as hunting and fishing and non-consumptive recreational benefits such as bird watching, hiking, and picnicking are expected to occur. For each of these recreatioiial activities, the presence of the spedes listed in Tables 7-4 to 7-7 either directly or indirectly enhances the recreational experience.

Benefits from activities occurring adjacent to the site can also be attributed, at least in part, to the ecological resources of the model site since most of the spedes present are not stationary and are expected to rnigrate in and out of the inodel sites. Hence. the land application of pulp and paper sludges will have an. effect on the benefits assodated with both; on-site and off-site recreationai activitiea. Spedfically, runoff from the model agricultural site may severely affect a recreational fisheiy in a nearby stream^ thus redudng the benefits of angUng to recreational: fishermen. Another example would be a reduction in the number of birds fyptcally assodated with bird watdiing on and around the sitei. With less to Ibok at, bird watchers may experience a decrease in the benefits they reap from birdwatcfaing.

Where tlireat6ned.and endangered spedes are present, the benefits assodated with wildlife spedes may be signifiieant since the public may have a heightened awareness of the resource. For example, the benefit to a bird watcher of sighting a bald eagle may be great since bald eagles are relatively rare and infrequently sighted. In addtion, individuals may place a high value on the preservation of endangered spedes since the threat to their dristence is more immediate than for non-endangered spedes. the importance of endangered spedes will be paiticidarly relevant at the silvicultural model site where several endangered spedes induding the bald eagfe, are expected to

7-10

TABl£7-4

TiDtaofBanaflla (ilatValut

Nttn—CttASiufiollve ii\ CanaumalhM Ifil Elibtonct

Valut OpHon Viiut

Songtiiida RoUn X X X BluabM X X X Mtadtwtaifc X X X

RiWen SaratehOwi X X X etiiiOM X X X AmtiletoKattni X X X

Oihtrbirdt Flyotlohtr X X X Shriht X X X

Sintll Mtnimalt Bat X X X Molt X X X Shraw X X X

Laigt'Mammalt OOtr X X X X dpetaum X X X X Skunk , X X Armadillo X X. X X

nth (tografontlBpialta X X X

fM^CoekadMl WoodptfcT X X X

6iid6n(|#is0 MMIIIMIS lndtnaBto(DQit.Drtttrt» X X

(1) (Wilt to rteiMltoMl toMtt tuoh tt WrdwttoNns, tnliiMi tighllnai botdng, tnd hiking. (9 Itoltra to rttrttHonto teMhtt tuth at huntog.

7-11

TABLE 7-9

22SB$555BsH5^3I^BSSU

Tvp-«tP«nnm_ N6w-Gon«ump»w M> GoiwumpMw a>

Bdttiiiea' Option Viluo Vluo

SuvalloMf Wwlôr Vôodttyuah

OlhorMrto Flyetfehor

Small Momniala Bal Mola Bhraai

LarsaMammala OlSar Opeaaum Skunk

X X X X X X

X X X

X X

X X

X X X X X X

X X X

X X X

X X X X X X

X X X

X X X

Enda^radiMammala Indiana Bat ft<ma.piyaaiilt

(1)' Ratorate raoraailanal aeiMliaa auch aa WrdaialeMng, anknal aighttngi boakng, and hiking. (9 RafaraitoiMiaalliMal'aetlvMaaaiich MlMiirtlngi

• DiaMbullonandiMaikaangSilaaaiafoiindlnGallfoinla.WaahlngioniTaKat.. Pannaylwanla. and ONo. TMa TaUa, hoaiowar, uaaa only ihoaa apaoiaa comfflbnly foundin Pannaykmnla and OMotp charactadita dia modal dlakSwiten and maikalkig alia ainoolho acologled!ilak aaaaaamaiil ImUSEPA (IMOa) dH ndt ttddrMi ttDSolMifcMJiid tn Cailtoffll#: WuMfMHon. end Ttoiu; dwWpawWV ffd mp^miaapifia^^ vWOTamfa^pMaaai âwp o VMW*

7-12

fA8LE7-e

H.pi«>»nt««v8p.cl«»

SongbM* nobin BliMblid MawloiNiark SMMIOM WMbiw Woedttiiiith

Woodeook

SciMctiOwl BwnÔwl AIIMIICMKMM

OBiwbirda FlyoMhar Shilk*

SfliallktamiiMto Bal MM* Shnw

UigcMwimd* Ottir OpoMum Skunk

Fwh llM

EndingeiedMi Indtona Bt'(poM.,pmwH

EndnnflSfsd-RspHns EulMnlndlgtt SrailM

(pOM. prMwi^

Endangcrad^PlMili

Tvo—Bknuflti"

Nbn-CowunirttwtH Conauwumw«» Exiatanca Opkan

Vahja.

X X X X X X

X X X

X X

X X X

X X

X X

X X X X X X

X X X

X X

X X X

X. X X

X X X X X X

X X X

X X

X X X

X X X

X

X

X

(1) Raiaia loi •kondaoilv 0 fWarata raemaltoM'MkiMaaauahaaiiiiiians.

eh aabbdwaloNng, aninial alghUna baaling, and Mklng.

7-13

tABLE7-7

Tvnaa olBanallla UaaValua

AAAIOSIWIIIUIA 191 Bdalanea

Valua Opflon Vdua WIIW

Robin X X X Bluobbd X X X SwtllCM X X X WaiWw X X X Vl6>o«iuuoh X • X X

OamobM ono -J— «- . ffVOOwwOw* X X X X

OihorfaMo Flyetthor X X X

Small Momniito BOI X X X Mola X X X ShiOw X X X

LaisoMammria Onar X X X X Opoaauffl X X X X Skunk X X

Fiah Raofaadonal Spaolaa X X X

—a i >6iWBnpVfw-ainH BalSEâ X X X PIpInQ Ptovaf X X X Wooditoifc •X X X

fvOTI WoWSn IflWWi^v X X X

Ehdangarad Plah X . * X

CflOWIQWvO

KampaRldlOySoaTuiSa X X X LoggiHtiaad Son TuMo X X X

X X X (potSi praMfi$

. lEndangaradiRama a--a •* a_

ClIIUH fVnOnvQ rOpOfW X X X

EndanoaradMoluaka lomPlalatpeariaSiMi X X X

(1) Rttam loifaciwtfdnal actMUMBiichMtaiidwalehli^^ Bnlmii •IgMna.ibeaiinOi •ndhiklng. (2) (Mm to rawMtfond aoMdoO ouoh w hurillng.

7-14

be presents Birds of prey audi as the bald eagle may be affected off site as welli, since they may consume fish contaminated by runoff.

Finally, it is assumed that existence, option, and bequest benefits unll be present fbr all spedes at ail sites. Regardless of the relative abundance or populari^ of any paiticular resource, individuals are thought to place some positive value on the continuing existence of the resource regardless of any perceived or potential opportunity to use (consumptively or non<consumptively) the resource now or iii the future. In other words^ even though individuals may never see the endangered Harperalla plant if it was present at the model mine redamation site, they may experience existence benefits in just knowing that it continues to exist. Individuals are also thought to value the option of having a future dioice to use the resource. For example, runoff from the agricultural model site may end up in a stream that is not currently used for recreational fishing. Fishermem however, may associate an option value with the fish in that stream since, in the future, they may want to use it. Similarly, certain individuals may derive benefits from knowing that the species at each model site wiU be preserved for future generations (bequest benefits).

133 Ecological benefits of regulatory scenarios

To <iate^ empirical work on the valuation of ecological resources has been Very specific to certun sites, spedes^ and/or recreational uses. Heberlein and Baurogarter Research Services (1985)

preserves in Illinois because 'no two nature preserves are exactly the same.' Likewise, no two sites where pulp and paper sludge is landâpplied are exactly the same. Apart from differences in geomorphpioglcal and ecological charecteristlcsi there is likely to be a bigb degree of variability in the extent of recreational use, the availability of substitute sites, and the proximity of individuals who hold intrinsic values (i.e., existence and option values) for the affected resources. Additionally, nonuse values are often insignificant individually but quite large in the aggregate, thus total value estimates are extremely sensitive to the population over which the mean ûe estimate is extrapolated. Information on populations affected by land application of pulp and paper sludge is not available at tluS time. Furthermore, only limited information'on the location and characteristics (habitat t^, spedes present, ownership, recreational uses, eta) of land application sites is available.

Given the conceptual and empirical difficulties assodated with conducting eoolopcal benefit estimatiom ori^nal research aimed at valuing the ecological resources affeded by land.app(ication of pulp and paper sludges was not possible. Therefore, the approach taken here is to assume that wildlife risk, as evidenced by risk quotient (RC}) values, is inversely related to the types of ecological benefits outlined above. In other words* relative increases in benefits result from relative decreases in wildlife risk. Ihis approach must be viewed as crude at best and no quantitative benefits estimates are made.

Wildlife risk quotientt developed 1^ USEPA (1990b) for land application, together with infonnationon risk management at disposal sites, were used to assess whefoer potential ecological benefits are expected to be low, likely, or highly likely. Risk quotientt relate the soil concentration to the level of exposure known to produce ad^rse health e^cts in an organism. As such,, RQ's address risk to the maximally exposedÔrganism. Population effects can occur at contaminent levels below that of observed effects in individual organisms,, however. It is therefore necessary to assess risks for populations as well. To this end; we broadened our risk evaluation criteria to include

7-15

relative meaiurei of potential exposure pathways and the exposed population. Specific reference was made to the number of mills practicing land application, type of land application, the volume of sludge, mid the site management practices to control runoff.

In developing relative rankings, the following judgmental criteria were observed:

(1) As the soil concentration limit is reduced, so is wildlife risk; (2) The fevver the number of mills applying sludge, the lower the risks posed to wildlife; (3) forestry, mine reclamation, and agricultural application of sludges were judged, to

pathways and larger exposed populations. Surface impoundments were judged to pose reiatively low risk;

(4) Lower volumes of sludge pose lower wildlife risks; (5) Runoff controls greatly reduce off^te risks through the aquatic pathway.

The regulatory baseline pf current practices was assigned no relative increase in ecological benefits under the assumption that none of the above factors would be changed. A ban on land application was assigned a maximum likelihood of reduced risk. For each regulatory option between these extremes, the above criteria were used to assess the likelihood of reduced wildlife exposure. In other words, an increase from low potential benefit to likely potential benefit might ̂ result from fewer miliis applying sludge, lower concentratioris or volumes, or a change in the type of land appUcatibn. Because all of the above criteria are assessed simuluneously, and they mi^t not vary on a consistent basis among options, the change in relative rankings may not coordinate with a ̂ ange in any one particular foctor. For example, an increased assessment of benefits from likely to hi{^y likely might result from lower soilconccntrations even though the number of mills msing land application remains the same.

.Generally, lower soil concentrations of dioadns and fiirans result in lower wildlife exposure at the sites: Consequently, wildlifB abundance and diversi^ is expected to increase, thus enhancing recreational! op^rtunities and augmenting indirect and nonuse values. Additional controls for surfrce water runoff will benefit aquatic organisms off site and predator speries. Off-^site benefitt to recreational firiiermen mAy also increase due to lower risks to aquatic Organisms^

lead most milb to use alterimtive means of pulp and paper sludge disposal. If mills switched to properly managed landfills, net risks would decrease for aU teitest^, avian, and aquaric organisms due to leachate controls, and a soilcover. Little exposure to tcrrestiiail ihammais would result due to the restricted land area and the likely level of activity at the disposal site.

While ecological beiiefits will increase in atou where soil concentrattoii limits are reduced or land applicatioo is banned, a shift to-surfiue impoundments may increase risk for some species of terrestrial and avian wildlife. Certain aspects of surface! iinpounthnentt may lead to increased risks due to higher concentration of dioxiiis and fiirans. higher moisture content, standing water, abundant prey spedes, uncovered surfscct otc. Migratory waterfowl, for example, may be attracted to surface impoundments and could experience increased risk on an individi:^ basis. Population-effects ^11 depend on the number of waterfowl present, thought and it is probable that sludge

7-16

dispoial activity vnll discourage some avian species from becoming established at the site. Stringent runoff oontroU associated with surface impoundAents, however, might lead to decreased risks for off-site aquatic spedes and their predators^ increased recreational fishing benefits might be expected based on the decrease in risk to aquatic species.

Twelve mills indicated practicing pulp and paper sludge disposal by land application in the 104 mill' stucty (liSEPA, 199Qc). All twelve were projected to continue with this disposal option absent EPA regulation. Therefore, no change in wildlife exposure and no ecological benefits above baseline levels would result under a current practices scenario (Table 7-8).

Restricting land afîcation to soil concentrations oyer a range from 200 PPT to 10 PPT would gradually-eliminate all forestiy and agricultural land applieation programs in favor of surface impoundments. Some risks to wildlife have been identified with surface impoundments, however, under the stringent management controls for runoff assumed in this analysis, the risk to aquatic species is assumed to be zero. Therefore, benefits would result for terrestrial species and aquatic species both due to the control of runoff at surface impoundments and the reduced exposure given that these sites are less extensive in terms of surface area available for exposure than agriculture and forestry sites (Table 7-8). As a reisult, recreational use values^ such as hunting and bird watching, would lilmly increase at forest and agricultural sites while recreational fishing benefits might increase at affected water bodies.

Further restricting soil concentration to a range from 5 PPT to 0.05 PPT would eliminate mine reclamation and phase out distribution and marketing. Potential benefits associated widi increased hunting, birt^tching and recreational fishing are likely for reasons similar to those described above. At 0.03 PPTi the soil concentration limit is so cost restrictive that all mills would select surface impoundment as the least cost disposal alternative, amounting to an effective ban on land application and resulting in the estimated maximum potential for ecological benefits under the compliance scenarios described by the cost analysis (Table 7-8). As the risk to terrestrial and aquatic species at or near the land application site decreases, an increase in recreational benefits such as hunting fishing and bird watdting can be expected. Benefits in the form of increased existence and option vdues could also be expected. Additionally, benefits related to recreational fisheries are expected to be positive when mills switch to surface impoundments. And, although dioxin levels may be concentrated in a surface impoundment, the restricted area of exposure may lead to greater Species abundance and diversity, increasing the intrinsic values of wildlife resources. Thus, net ecological benefits associated with a switch from land application to surface impoundments are estimated to be positive. ; * « ,

The concentration of contaminants in runoff from a land application site are not only dependent on the soil concentration of dioxins and furans, but also on the surface area to which the pulp and paper sludge ia apfdied. Total risks posed by a particular site are therefore associated with site size. Options 14 to 24 control both site size as well as soil concentration. Generally, restricting site size along with soil concentration increases land application cosu and causes firms to Shift to alternative disposal practices. Because of this, wildlife risks are decreased (see Table 7-9).

7-17

TABI£ 7.8

Relative 'Bert Estimates" of Ecological Benefits Soil Copcei^tfation Limits

Option Na

Concentration limit (FFT) Option

Wildlife Risk QuoUent Relative Benefiu

1. Baseline N/A

2. 200 PPT 100 4-

3. lOOPPT 50 4-

4. 30 PPT 10 4-

lOPPT 5 + 6. 5PPt 2.5 4-4-

3 PPT 1 4-4-

8. IPPT 03 4-4-

9. 0 J PPT 0.25 4-4-4-

10. 03 PPT 0.1 +++

11. 0.05 PPT 0.025 +++ 1 12. 0i03PPT .01 -»-4-4r 1 13. Ban N/A 4-4-4- 1

0 a no benefit + » low potential benefit 4-+ s likely piotential benefit +4-4- = higl^ likely potential benefit

Source: Abt Assodatea and ERG estimates.

7-18

TABLE 7-9

"B^»t 9f RcotoiaciM Benefita Soil copcentrptipn Mmitt

Option No.

Concentration Limit (PPT)

Area Umt(ha)

Wildlife Risk

Quotient Relative 1

Benefits [aj] |

1. Baseline - N/A 0

2. 200 PPT SO too +*+

3. 100 PPT 100 50 • +++

4. 30 PPT 333 10 +++

5. 10 PPT 1.000 5 ++

6. 5 PPT 2.000 23 ++

7. 3 PPT 3.333 1 ++

8. IPPT 10.000 03 ++

9. dJPPT 20,000 035 +++

10. 03 PPT 33.333 0.1 -••+-1-IL 0 05 PPT 200.000 Q;025 ++

• 12. 0.03 PPT 333333 .01 ++-»-

13. Ban - N/A ++-I-

0 s no benefit -(• s low ixitentiiBl benefit +-f « likely potential benefit 4-+-l> 3 highfy likely potential benefit

[a] This method of site size limitation eliminates agricultural and most forestry applications. Mine redamation and DAM occur only at intermediate soil concentrations where site sizes are large enough to be cost-effective.


7-19

12iA Scniitivity to MEI risk

The qualitative efttimeteft of ecological benefits above were based on compliance icenarios developed by using regulatoiy pptioni whicb are designed to limit risic (above background levels) to the human MEI to a certain level. Options based upon alteinative risk levels were also examined in this analysis. These included opdons which set risk levels for the human MEI to 1 in 1,000 and 1 in lOOiOOO above background levels.

Under a regulatory option where risk to the MEI is 1 in 1,000,3 mills are predicted to continue land application practices. This could result in a greater number of sites contaminated and individuals of spedes exposed than under a regulation standard based upon a 1 in 10,000 risk level. This potendal increase in exposure could, lead to fewer ecological benefits than could possibly be achiev^ under a more restrictive regulation.

On the other hand^ an option designed to set risk levels to 1 in 100,000 is predicted to halt all land application activities; Based upon reduced exposure to dioxin contaminated sites, this regulatoiy option could result in increased potential for ecological^ benefits above those achieved by an optibri where risk levels are 1 in 10,000 to the MEL However, these benefits would not be expected to be greater than those which vrauld be experienced under a ban of land application.

7 J j Permitting Opdons

The additional regulatory opdons which include the implementadon of permitting systems to control land applicadon of pidp^paper sludge were described in Section 4. Compliance choices for individual mills under these permitting options, could not be estimated due ito lack of site specific information. Therefore, no relative rankings of eootogpcal benefits are possible at this time.

lA Relating Benefits to Costs

The complianoe boats Of the various regulafoiy options were presented in Section Eve. The estimates of compliance costs were based on predicted changes in the disposal practices of firms, assuming firms are profit'^maximizing and wouldûse the least cost disposal option. In addition to direct increases in disposal costt, there are other costs imposed on society by the pulp and paper sludge regulation, Since these costs are not borne directly by firins. they are externali to firms' dedsion-maldng processes but must be included in a sodal cost foamework. The total costs Of the pulp and paper sludge regulatory options amre enimined in Section Six and ref|e<x the true social costs incurredi .

I are also external to tiie firms' disposal option decisions. These benefits, human health and ecological, accrue to socieqr in general and do not result in additional revenues to paper mills, except where coiuumets choose to reward firms for "good" environmental practices. In social welfore analysis, economists contrast the benefits and costs of regOlatory actions, including those external to private sector dedsion-maldng. ,

In comparing costs and benefits reasonable observations can bemade concerning the differences in regulatoiy options. For instance, under a concentration limit only based Option, at a

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oonceiitFation level of 10 PPT, there is an ihcrcmental cost of $0.4 million per year over the preceding level of 30 PPT (Table 64). The increase in stringency from 30 PPT to 10 PPT does not

protection as the wildlife RQ decreases from 10 to 5 (Tables 7^1,7>7). although potential ecological benefits are estimated to be low at both levels^ Increasing the stringency to 5 PPT, however, represenU an incremental cost of approximately $7^0^ million annually and no increase in human health benefits. A decrease in risk to wildlife as evidenced by a decrease in the RQ value from 5 to 2.S is also predicted and estimated ecological benefits are predicted tp change from low to likely potential.

Without a monetized estimate of benefits, direct comparisons of costs and .benefitt are not possible, in this case, oonsidering numbers of cancer cases saved and the potential ecological benefits can help in comparing regulatory options. Generally, if benefits are believed to outweigh the costs, it is possible to justify ta^g a regulatory action, though ethical and distributional (equity) concerns may properly modify the benefit-cost conclusion.

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SECTION SEVEN REFERENCES

Heberlein and Baura^rter ResieanBh Services, 1985. Tlie economic value of Illinois Beach State Nature Preseive. Heberlejn and Baumgartcr Research Seiyices, Madison. WI,

USEFA, 1990a. Assessment of Risks from Emosure of Humans. Terrestrial and Avian Wildlife. and Aowatio Ufe w Pifflrim and Furans from of Slod89 from Bfeashpd Kraft and Sulfite iPulo and Pacer Mills. EPA S60/5-9Q-013 (July 1990). U.S. Environmental Protection A^n^„ Washington, D.C.

usEPA. 19900. Environmenm HisK Aaswsipem for TQPD- and TCpF-Contaminaiad Palp Sludges on Terrestrial and Anuatic Wildlife. Enviionmentel Effects Branch, Health and

, Agency.

USEPA, 1990c. U.S. EPA/Paoer Industiv Coonerative Dionn Study ("The 104 Mill Study"). Statistical Findings and Analyses. July, 1990.

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ATSDR - LAND APPLICATION OF BLEACHED PULP & PAPER …Land Application of Bleached Pulp & Paper Mill Wastewater Treatment Sludges Regulatoiy Impact Analysis U.S. Environment Protection

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