1598 ENVIRONMENT REPORTER Tadle Til Removal Costs for the Inorganic Arsenic Emissions from Glass Manufacturing Furnaces ok _ ‘ oe Existing Furnaces Without Acd-on Control Devices 1 : : 8 9 10 “3 poof Se ; il Arsenic .. Emissions (Mg/Year) 1 2 3 4 5 6 7 Uncontrolled 6) - ($/Mg) 36,100 112,300 132,400 123,000 194,000 299,400 83 “21.27 O.910.76 © -~ = = = = = 3 . 0.73 0.55 0.55 0.45 16 17 18 19 0.04 0.04 0.04 0.04 a - 137,800 - 23€,000 295,100 726,500 447,000 €52,000 714,000 795,000 0.12 . Erission reduction 15.20 3.35 3.09 3.09 1.99 1.83 12 13 ' 44 15 -, Cost per Unit . 1,200,000 b/ b/ b/ d/ ~ . a/ 9,666,700 9,666,700 9,666,700 9+ 666,700 Y a/ Plants with uncontrolled arsenic emissions above this cutoff weuld be b/ These four furnacesare vented through a single stack. Fequired to install controls under EPA's proposed rule. 48 FR 33157. Although EPAcites cost-effectiveness as one of the major criteria used in setting BAT,’ there are important differences across source categories in the level of removal costs that EPA finds to be reasonable. Thus, the BAT removal costs for controlling secondary emissions at copper smelters generally fall below $400,000 per megagram of arsenic removed." In the case of glass manufacturing plants, however, EPA finds that removal costs up to $800,000 per mega- clear set of criteria applied in a consistent fashion that "48 FR 33116. * The estimated removal costs of controlling secondaryemissions for matte and slag operations at the ASARCO-El Paso p!ant are matte and slag operations of these additional low arsenic feed copper smelters would be controlled at an additional cost (annua- gram are “reasonable.” * As a result, we could not identify a $382,000 per Mg removed, however, the proposed rule exempts these operations at two smelters with estimated removal costs of roughly $350,000 per Mg. ‘Emission standards imposing removal costs on some plants in one source category double the maximum costs imposed on plants in another source category are unlikely to be cost-effective. In fact, EPA could achieve a more cost-effective outcome by using a removal cost ceiling of $500,000 per Mg arsenic removed. Under this cost-effectiveness cutoff, the secondary emissions from the 1-13-94 differentiates those facilities subject to the proposed more stringent BAT requirements from the remaining plants. Because the purpose of these regulations is improved public health, it is difficult to know what would be a “costeffective” or a “reasonable” removal cost without considering information on the public health effects of alternative control strategies. For example, an emphasis on adjusting a particular mix of regulatory requirements to yield more “cost-effective” reductions in arsenic emissions may not be lized) of $780,000, but, four glass manufacturing furnaces would no longer be required to control emissions at a cost savings of $1,500,000. This regulatory approach would achieve the same reduction in inorganic arsenic emissions as that proposed by EPAat a net cost savings of $700,000 per year. EPA did not consider public exposure in selecting its cutoff levels and this outcome is “costeffective” only in terms of a reduction in emissions. As outlined below, an alternative decision process giving explicit consideration to public health gains might well result in a different regulatory outcome. Published by THE BUREAU OF NATIONALAFFAIRS,INC., Washington, 0.C. 20037 aloes, Source: