under the proposed regulations for the three benzene source
«+
categories that EPA recently determined should be withdrawn,
in part because the risks from these sources would not be
appreciably reduced by the proposed regulations.
See EPA
Background Paper, supra.
Finally, the proposed EPA regulations are clearly not cost
effective.
EPA has estimated the capital costs of compliance
with the proposed standard for DOE facilities to be approximately
$25 million.
48 FR 15081 (April 6, 1983). 37/
Assuming the
control technology installed for this $25 million would be
effective for 30 years, the most optimistic benefit from the
capital outlay of $25 million would be saving 1 life in 30
years.
See EPA Draft Background Information Document,
supra.
The costs estimated for compliance with the proposed
regulations for DOE facilities are roughly equivalent to those
required by proposed standards for benzene emissions from
coke by-product recovery plants, but the capital outlay of
$30.9 million for compliance with the proposed benzene emission
standards would result in saving 2.37 lives per year as
opposed to 1 in 30 years.
See EPA Background Paper, supra.
Further, the estimate of $25 million in capital costs is
considerably greater than the $16.4 million in capital
outlay estimated to have been required to comply with the
proposed benzene emission standards that EPA has announced
its intent to withdrawn.
See id.
With respect to emissions
of benzene, EPA determined that an expenditure of $16.6
77
Although EPA has not estimated the annual operating
costs and DOE has no hard estimates, such costs no doubt
would substantially increase-the total costs of compliance.