Analysis - The Institute for Southern Studies

11. Regulatory offsite disposal costs (hazmat trucking, RCRA manifests, RCRA TSDF permits for offsite)
EPA assumed that Subtitle C options add extra cost to (a) truck hauling to offsite disposal, and (b) all offsite landfills must become RCRA
Subtitle C permitted. This cost estimate does not include taxes/trans-state government fees associated with off-site disposal.
11a & 11b. Added truck hauling cost (Subtitle C options)
Assumptions:
Affects the 12% (15 million tons per year) annual CCR generation currently trucked offsite to non-haz LFs (2005)
6 miles average one-way trucking distance to offsite LFs 65
$0.19/ton/mile hazardous waste truck operating cost
12 tons CCR per full truckload (source: Gambrills MD case study); (15 million tons/year) / (12 tons/load) = 1.25 million
truckloads per year
Cost Calculations:
11a. RCRA manifest cost: (1.25 million truckloads) x ($53 per manifest per load average cost from EPA 2007 ICR 801.15) =
$66 million per year
11b. Trucking cost (distance + operating cost): (15 million tons/year) x (6 miles) x ($0.09/ton/mile added truck operating cost
for hazardous waste loads) = $8.1 million per year
Subtotal (11a manifest + 11b trucking): $74.1 million per year
11c. Added cost for RCRA Subtitle C permits for all offsite CCR landfills under Subtitle C
Assumptions:
Added operating cost to offsite CCR landfills for meeting engineering control requirements under each of the regulatory options
evaluated in this RIA are included in the “Engineering Control Costs” section above, so are not again calculated here to avoid
double-counting. Only the paperwork burden cost for obtaining a RCRA permit is estimated here.
Industry average cost per waste disposal permit:
($440 66 average RCRA Part A permit application cost per-plant per-year) + ($68,960 67 average RCRA Part B application cost
per-facility per-year) = $69,400 per Subtitle C permit per year
($69,400 per permit per year) x (3 years ICR annualization period) = $208,200 per permit
(149 offsite CCR landfills) x ($208,200 per permit) = $31.02 million
Amortized industry cost with a capital recovery factor of 0.07246 (@7% discount rate & 50-years) = $2.25 million/year
65 Source: based on actual distance reported for a MD plant at http://www.rachel.org/en/node/445). Note: a broader range of 2.4 miles to 25 miles in one-way offsite landfill
distance was reported by an OH plant at http://www.columbusdispatch.com/live/content/local_news/stories/2008/04/14/Powerfills.ART_ART_04-14-
08_B1_FF9TI0U.html?sid=101, and a WI plant, respectively at http://www.lacrossetribune.com/articles/2007/09/21/news/03landfill0921.txt
66 $440 unitized cost derived for this RIA from EPA Information Collection Request (ICR) No. 0262.12 “RCRA Hazardous Waste Permit Application and Modification
Part A”, Federal Register, Vol.74, No.17, 28 Jan 2009, page 4958; http://edocket.access.gpo.gov/2009/pdf/E9-1804.pdf
67 $68,960 unitized cost derived for this RIA from EPA Information Collection Request (ICR) No. 1573.12 “Part B Permit Application”, Federal Register, Vol.74, No.100,
page 25237, 27 May 2009; http://edocket.access.gpo.gov/2009/pdf/E9-12285.pdf
74