9
“CURRENT DEVELOPMENTS
TARLE f
Costa and Cost-Ef fect ivnens of EPA's Freponed Rules for Radlosctive
ard Toric Subatancen
1
Cost of
7
Radtanuet fase
DOF Prehiti tern
Capital
.
tnorcearic Arsente
Ninh Arsenic Ferd
Lorper Seeltera
Low Arrenty Fea4
Coprernr Seelrera
Glas: Manet acturing
Total
:
3.%
440
—
to
.
-
Requisted
Beguiated
-
@.98
@.c04
‘
a 7
c/
_
_
1.00
a
a.s$
6.04%
6.01
. @.14 to 0.¢01
a
0.25
0.05
0.17 to 0.003
27.
4.06
e/
'
inclwiiag Entecest and depreciation,
Onkyv tee enurees requlated; both anurces have alellar characteristics tn
teres of population exposed and the coat of meeting the propored atandard.
cf
Rot ape ilcabte,
@/
im data for inelvidual sources,
ef
Only ane anurce requlated,
.
~
U.S. Fuvironmental Protection Agency,
In fact, most of the public health gains projected for these
rules result from the control of emissions at a distinct subset
of these plants. Regulation of the remaining plants (or sites)
yields relatively little in additional expected public health
gains. In the case of the proposed rule for low arsenic-feed
copper smelters, for example, regulation of the secondary
ernissions from converter operations at three smelters
{ASARCO-EL
Paso, ASARCO-Hayden,
and
Kennecott-
McGill) accounts for 88 percent of the total reduction in
cancer indcidence under EPA's proposed rule (covering both
converter and matte and slag operations), Much of the cost
of EPA’s proposed standard (65 percent) is associated with
the control of smelter operations contributing only 12 percent of the expected public health gains. In the case of
radionuclides as well, 97 percent of the public health gains
can be achieved at forty percent of the cost by only regulating underground uranium mines.
As a result, an alternative regulatory strategy that emphasizes the effectiveness of further control can achieve
most of the public health gains at substantially lower cost.
For example, EPA estimates that its proposed standards for
sources emitting these two hazardous pollutants would
achieve an expected aggregate reduction in cancer incidence of 4.06 cancers per year at an aggregate cost of $27.1
million per year. An alternative regulatory strategy establishing the proposed BAT level of control only for those
plants where the effectiveness of further control is relatively high could achieve an estimated reduction in cancer
incidence of 3.92 cancers per year at an aggregate cost of
$7.4 million per year. In other words, 96 percent of the
expected health benefits of EPA's proposed rules could be
achieved underthis alternative strategy at only 27 percent
1-13-84
tenge for
Bources
i)
bs
Sourcer
Awerage for
Sources
1.5
.
"6.5
a7 Sire Ul ainal cesta,
'
|
"@.0
4.6
3.8
77.4—,
Lo
of Espendituce
i
4.2
@.0
6.0
.
Cancers Avoided
Fer Million Bellare
in Concer. Incidence
Annualized a/
24.0
MACHT beens.) Pactititien
Urtarum M nag
Elerecntsl Phoaphorme
Thanta
Expected Change
Froposed Standard
Weolfacain ATi fonay
;
4
2 tat
of the expected costs. EPA's proposed standards requiring
further control for the remaining plants (not regulated
under this alternative strategy) would achieve an additional
estimated reduction in cancer incidence of only 0.13 cancers
per year at a cost of $19.7 million per year.
-
C. Reliance on BAT Approach for Standard-Setting
In setting standards for source categories posing a significant risk, EPA relies on a BAT approachthat focuses on the
application of “feasible” contro) technologies taking into
account such factors as the “economic impacts” of meeting
the required level of control. Although EPA does not provide
criteria specifying what might constitute unreasonable economic effects, EPA in its BAT determination typically
considers a variety of factors, including~
—the technical feasibility of the proposed control requirements; and
—the economic effects of the proposed requirements,
including the effects on industry profitability, product
prices, and likely plant closures.
As a part of its BAT determination, EPA mayalso
establish subcategories reflecting a variety of factors including differences in technology, age of plants, or economic
characteristics.
*In its proposed rule for source categories emitting inorganic
arsenic, for example, EPA cites each of these factors in its decision
not to regulate individual source categories. 48 FR 33112.
Environment Aeporter