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4.5.1 Cost 
Table 4-4 shows the total annual compliance cost to industry as a result 
of each option. The industrial cost is divided into two components: the addi- 
tional cost of pretreatment and the cost of disposing of the additional hazard- 
ous waste that is generated. The total cost depends significantly on the number 
of POTWs affected by each option. Excluding the Guidance Option, the total 
annual cost ranges from about 0.5 billion dollars for categorical standards 
for metal finishers including water quality waivers to about 1.9 billion dollars 
for the existing program. 
The total municipal cost contains two components: the program development 
cost (a one-time cost) and the annual cost of operating the program. Sludge 
disposal costs for the POTWs are not affected by the improvement in sludge 
quality because minicipal sludges are not now subject to federal regulations 
that require more costly disposal. If there were sludge criteria that resulted 
in more expensive disposal, then some of the options could lower the POTW cost 
(and possibly the net cotal cost for both POTWs and industry), potentially 
significantly affecting the relative cost-effectiveness of the options. 
4.5.2 Cost-Effectiveness 
Some observations about the cost-effectiveness of the options can be made 
based on”two series of assumptions regarding the effectiveness of the options: 
e First, each of the options (other than Option 6, guidance only) includes 
the general provisions of the 403 program that provide for addressing 
problems of upsets, bypass, and passthrough. If it can be assumed 
that each of the eight options is equally effective in implementing 
these provisions, then these nonquantified environmental benefits are 
noc a factor in differentiating among the options. 
e Second, the most relevant environmental difference between the options 
that can be measured is their effectiveness in reducing exceedances. Use 
of this measure involves two assumptions: 1) that the benefits of reducing 
