ECONOMIC
ANALYSIS
OF
CATHODE
RAY
TUBE
MANAGEMENT,
NOTICE
OF
PROPOSED
RULEMAKING
U.
S.
Environmental
Protection
Agency
Office
of
Solid
Waste
February
15,
2002
Page
i
Table
of
Contents
1.0
Introduction
............................................................
1
2.0
Overview
of
the
Entities
Involved
in
Generating
and
Recycling
CRTs
.............
2
2.1
Original
Users
.....................................................
3
2.2
Establishments
that
Reuse
Monitors
.....................................
4
2.3
Collectors
........................................................
4
2.4
Reclaimers
........................................................
6
2.5
Glass
Processors
...................................................
7
2.6
Transporters
......................................................
7
2.7
CSI
Handlers
......................................................
8
3.0
Methodology
and
Data
...................................................
8
3.1
Estimate
the
Number
of
Original
Users
Discarding
Computer
Monitors
...........
9
3.2
Estimate
the
Total
Number
of
Color
Computer
Monitors
Discarded
Annually
......
9
3.2.1
Total
Number
of
Computers
in
All
Business
Establishments
..............
9
3.2.2
Discarded
Computer
Monitors
from
All
Original
Users
................
10
3.2.3
Color
Monitors
Discarded
from
All
Original
Users
...................
10
3.3
Estimate
the
Number
of
Regulated
Original
Users
and
Collectors
and
the
Number
of
CRTs
They
Discard
................................................
11
3.3.1
Computers
Discarded
per
Original
User
...........................
11
3.3.2
Monitor
Weight
.............................................
13
3.3.3
Number
of
Original
Users
and
Collectors
that
are
Regulated
Generators
in
the
Subtitle
C
Baseline
Based
Only
on
the
Generation
of
CRTs
.............
13
3.3.4
Number
of
Original
Users
that
are
Regulated
Generators
in
the
Subtitle
C
Baseline
Due
to
a
Combination
of
CRTs
and
Non­
CRT
Hazardous
Waste
.........................................................
15
3.3.5
Number
of
Original
Users
and
Collectors
that
are
Regulated
Generators
Under
the
Primary
Alternative
........................................
16
3.3.6
Number
of
Original
Users
and
Collectors
that
are
Regulated
Generators
Under
the
CSI
Alternative
...........................................
18
3.4
Flow
of
CRTs
from
Generators
to
Disposal
Sites
­
Subtitle
C
Baseline
..........
19
3.4.1
Disposal
Option
Assumptions
...................................
24
3.5
Estimate
Administrative
Compliance
Costs
...............................
28
Page
ii
3.5.1
Baseline
Unit
Costs
for
Original
Users
(Generating
No
Non­
CRT
Hazardous
Waste)
....................................................
28
3.5.2
Baseline
Unit
Costs
for
Original
Users
Also
Generating
Non­
CRT
Hazardous
Waste
....................................................
28
3.5.3
Primary
Alternative
...........................................
28
3.5.4
CSI
Alternative
.............................................
29
3.6
Estimate
Disposal
Costs
.............................................
31
3.7
Estimate
Transportation
Costs
........................................
32
3.8
Estimate
Storage
Costs
.............................................
35
3.9
Estimate
Costs
for
Glass
Processors
and
Transporters
......................
37
3.9.1
Costs
to
Glass
Processors
.....................................
37
3.9.2
Costs
to
CRT
Glass
Transporters
................................
37
3.10
Estimate
the
Impact
of
Compliance
Costs
on
Affected
Entities
.................
38
3.11
Methodology
for
Subtitle
D
Management
Baseline
.........................
39
3.12
Limitations
of
the
Methodology
and
Data
................................
43
3.12.1
Assumptions
...............................................
43
3.12.2
Limitations
.................................................
46
3.12.3
Other
Factors
..............................................
47
4.0
Cost
Results
and
Sensitivity
Analysis
for
Subtitle
C
Management
Baseline
.......
49
4.1
Costs
Under
the
Subtitle
C
Baseline
....................................
49
4.2
Primary
Alternative
.................................................
50
4.2.1
Costs
Under
the
Primary
Alternative
..............................
50
4.2.2
Incremental
Cost
Difference
Between
the
Subtitle
C
Baseline
and
the
Primary
Alternative
.................................................
51
4.2.3
Sensitivity
Analysis
for
the
Primary
Alternative
......................
52
4.2.4
Incremental
Cost
Between
the
Subtitle
C
Baseline
and
the
Primary
Alternative,
Including
Currently
Unregulated
Monitors
and
Televisions
..............
54
4.3
CSI
Alternative
...................................................
55
4.3.1
Costs
Under
the
CSI
Alternative
................................
55
4.3.2
Incremental
Cost
Difference
Between
the
Subtitle
C
Baseline
and
the
CSI
Alternative
.................................................
56
4.3.3
Sensitivity
Analysis
for
the
CSI
Alternative
.........................
57
4.3.4
Incremental
Cost
Between
the
Subtitle
C
Baseline
and
the
CSI
Alternative,
Including
Currently
Unregulated
Monitors
and
Televisions
..............
59
Page
iii
5.0
Cost
Results
and
Sensitivity
Analysis
for
Subtitle
D
Management
Baseline
.......
60
5.1
Costs
Under
the
Subtitle
D
Baseline
....................................
60
5.2
Primary
Alternative
.................................................
61
5.2.1
Costs
Under
the
Primary
Alternative
..............................
61
5.2.2
Incremental
Cost
Difference
Between
the
Subtitle
D
Baseline
and
the
Primary
Alternative
.................................................
62
5.2.3
Sensitivity
Analysis
for
the
Primary
Alternative
......................
63
5.2.4
Incremental
Cost
Between
the
Subtitle
D
Baseline
and
the
Primary
Alternative,
Including
Currently
Unregulated
Monitors
and
Televisions
..............
65
5.3
CSI
Alternative
...................................................
66
5.3.1
Costs
Under
the
CSI
Alternative
................................
66
5.3.2
Incremental
Cost
Difference
Between
the
Subtitle
D
Baseline
and
the
CSI
Alternative
.................................................
67
5.3.3
Sensitivity
Analysis
for
the
CSI
Alternative
.........................
68
5.3.4
Incremental
Cost
Between
the
Subtitle
D
Baseline
and
the
CSI
Alternative,
Including
Currently
Unregulated
Monitors
and
Televisions
..............
70
6.0
Economic
Impacts
......................................................
71
7.0
Qualitative
Environmental
Benefits
........................................
79
8.0
Other
Administrative
Requirements
.......................................
81
8.1
Environmental
Justice
...............................................
81
8.2
Unfunded
Mandates
Reform
Act
......................................
81
8.3
Protection
of
Children
from
Environmental
Health
Risks
and
Safety
Risks
........
82
8.4
Regulatory
Flexibility
...............................................
82
9.0
Discussion
of
Findings
and
Summary
.......................................
82
Page
iv
Appendix
A:
Number
of
Establishments
and
the
Number
of
Employees
for
all
Two­
Digit
SIC
Codes
A­
1
Appendix
B:
Ratios
of
Computers
per
Employee
Calculated
for
Each
SIC
Code
............
B­
1
Appendix
C:
Disposal
Cost
Source
Details
.......................................
C­
1
Appendix
D:
Flow
of
CRTs
in
Both
Number
and
Tons
..............................
D­
1
Appendix
E:
Average
Shipment
Sizes
for
Each
Type
of
Establishment
Distributing
CRTs
to
Each
CRT
Management
Option
..........................................
E­
1
Appendix
F:
Revenues
per
Establishment
for
All
Two­
Digit
SIC
Codes
..................
F­
1
Appendix
G:
List
of
Parameters
to
Which
the
Analysis
Results
are
Relatively
Insensitive
......
G­
1
Appendix
H:
Telephone
Contacts
..............................................
H­
1
Appendix
I:
Bibliography
.....................................................
I­
1
Page
1
1.0
Introduction
Computers
and
televisions
are
in
almost
every
household
and
business
in
the
United
States.
Several
hundred
million
computers
and
televisions
are
in
use
and
many
more
millions
are
believed
to
be
in
storage.
Both
computer
monitors
and
televisions
typically
contain
a
cathode
ray
tube
(CRT),
which
creates
the
images
seen
on
the
television
or
computer
monitor.
The
glass
in
CRTs
from
color
computer
monitors
and
color
televisions
can
contain
enough
lead
to
qualify
these
devices
as
hazardous
waste
(D008,
characteristically
hazardous
for
lead)
when
they
are
discarded.
Under
current
Resource
Conservation
and
Recovery
Act
(RCRA)
regulation,
post­
consumer
CRTs
from
many
commercial
and
industrial
generators
are
hazardous
waste
whether
disposed,
or
sent
for
reclamation,
such
as
disassembly
and
glass
recycling
(40
CFR
§261.2(
C)(
3)).
CRTs
that
are
sent
for
refurbishment
or
reuse
are
not
considered
a
solid
waste
under
RCRA.

Businesses
that
discard
(i.
e.,
"generate")
post­
consumer
CRTs
must
comply
with
RCRA
regulations
and
dispose
of
computer
monitors
and
televisions
by
treating
them
for
lead
and
sending
them
to
a
Subtitle
C
or
D
landfill
or
sending
them
to
recyclers
or
smelters.
Households
are
excluded
from
RCRA
Subtitle
C
hazardous
waste
regulation
and
many
smaller
businesses
do
not
generate
enough
CRTs
to
trigger
RCRA
generator
requirements;
these
entities
tend
either
to
store
old
electronic
equipment
or
to
send
it
to
Subtitle
D
landfills.
Most
of
the
current
disposal
methods
(Subtitle
C
and
D
landfilling
and
lead
smelting)
do
not
take
advantage
of
the
full
intrinsic
value
contained
in
CRT
glass
or
in
other
CRT
components
that
can
be
recycled
back
into
high
value
products,
such
as
new
CRT
glass
or
recovered
gold
and
copper.
While
there
is
already
a
demand
for
the
CRT
glass
contained
in
computer
monitors
and
televisions,
RCRA
regulations
that
can
apply
for
applicable
hazardous
waste
generators
can
be
burdensome
and
may
discourage
this
type
of
recycling.
The
requirements
under
the
current
RCRA
regulations
include:
storage
limits,
manifesting,
recordkeeping,
safety
training,
and
biennial
reporting
by
large
generators.
The
administrative,
transportation,
treatment,
disposal,
and
storage
costs
associated
with
the
current
regulations
add
to
the
cost
of
recycling
old
CRT
glass
back
into
new
CRT
glass,
and
also
tend
to
discourage
glass­
to­
glass
recycling.

To
remedy
this
situation
the
Common
Sense
Initiative
(CSI)
Council
tasked
the
Computers
and
Electronics
Sector
Subcommittee
with
recommending
regulations
that
encourage
environmentally
sound
recovery
of
CRTs
and
that
eliminate
unnecessary
regulatory
burden
for
recycling
post­
consumer
CRTs
back
into
new
CRT
glass.
In
June
1998,
the
CSI
Computers
and
Electronics
Sector
Subcommittee
recommended
changes
to
the
current
regulations
specifically
for
CRTs
that
encourage
recycling
CRT
glass
back
into
new
CRT
glass.
The
recommendations
included
extended
storage
limits,
no
manifesting,
reduced
recordkeeping
requirements,
and
no
biennial
reporting.
EPA's
proposed
regulation
builds
on
the
CSI
recommendation
by
further
streamlining
the
requirements
and
by
also
reducing
the
regulatory
requirements
for
CRTs
sent
to
lead
smelters.
EPA
believes
that
the
additional
capacity
at
lead
smelters
may
be
necessary
to
recycle
all
of
the
CRTs
generated
and,
therefore,
to
achieve
the
greatest
reduction
in
CRTs
requiring
disposal.
The
proposed
regulation
is
expected
to
encourage
glass­
to­
glass
and
other
types
of
recycling,
reduce
the
costs
on
the
regulated
community,
and
maintain
or
increase
the
degree
of
protection
provided
to
human
health
and
the
environment.
Page
2
The
purpose
of
this
analysis
is
to
analyze
the
costs
and
economic
impacts
of
EPA's
proposed
rule
(primary
alternative)
and
the
CSI
alternative
related
to
encouraging
environmentally
sound
recycling
of
CRTs.
To
achieve
this
purpose
the
analysis
estimates
the
incremental
cost
of
the
alternatives
over
current
regulations
(the
"baseline").
The
analysis
uses
two
different
baselines:
one
that
models
full
compliance
with
RCRA
Subtitle
C
requirements
(referred
to
as
the
Subtitle
C
management
baseline),
and
one
that
reflects
what
is
possibly
current
CRT
disposal
practice
(referred
to
as
the
Subtitle
D
management
baseline).
The
remainder
of
this
report
is
organized
as
follows:
Section
2
provides
an
overview
of
the
types
of
entities
involved
in
generating
and
recycling
CRTs.
Section
3
describes
the
methodology
used
to
estimate
the
costs
of
the
proposed
rule
and
to
calculate
the
first
order
economic
impacts
associated
with
the
costs.
Sections
4
and
5
present,
respectively,
the
results
of
the
cost
analysis
for
each
of
the
two
baselines.
Section
6
presents
impact
analysis
results.
Section
7
discusses
environmental
benefits
associated
with
the
proposed
regulatory
changes.
Other
administrative
requirements
are
addressed
in
Section
8.
Finally,
Section
9
concludes
with
a
summary
of
the
analytical
results.

2.0
Overview
of
the
Entities
Involved
in
Generating
and
Recycling
CRTs
This
section
describes
the
entities
involved
in
generating,
collecting,
transporting,
reclaiming,
and
recycling
CRTs
from
televisions
and
computer
monitors.
CRTs
from
televisions
and
computer
monitors
are
treated
the
same
when
discarded,
so
the
same
entities
typically
handle
both
types
of
CRTs.
However,
this
analysis
models
the
management
of
CRTs
only
from
color
computer
monitors
because
these
CRTs
comprise
the
vast
majority
of
CRTs
discarded
by
regulated
entities.
CRTs
from
televisions
only
are
included
in
a
sensitivity
analysis
that
includes
televisions
from
unregulated
entities
(see
Sections
4.2.4
and
4.3.4).

The
seven
economic
based
entities
involved
in
generating
and
managing
CRTs
are:
original
users,
reusers,
collectors
(including
exporters),
hazardous
waste
disposal
facilities,
reclaimers,
glass
processors,
and
CRT
glass
manufacturers.
Exhibit
2­
1
is
a
simplified
diagram
of
how
CRTs
flow
between
these
entities.
In
this
analysis,
original
users
are
businesses
that
first
use
monitors
and
televisions
for
their
intended
purpose.
They
may
be
regulated
generators
or
they
may
be
unregulated
under
RCRA,
as
discussed
in
Section
2.1.
Establishments
that
reuse
computers
are
similar
to
original
users,
but
are
typically
not
regulated
(see
Section
2.2).
In
this
analysis,
collectors
are
intermediaries
that
accept
discarded
CRTs
from
original
users
or
reusers
prior
to
sending
the
CRTs
or
CRT
glass
to
other
entities.
Like
original
users,
collectors
may
be
regulated
generators
or
they
may
be
unregulated.
Collectors
are
described
in
more
detail
in
Section
2.3.
Reclaimers
considered
in
this
study
consist
of
lead
smelters,
and
are
described
in
more
detail
in
Section
2.4.
Glass
processors
prepare
CRT
glass
for
introduction
into
a
CRT
glass
manufacturer's
glass
furnace,
and
are
the
subject
of
Section
2.5.
Hazardous
waste
facilities
and
CRT
glass
manufacturers
are
included
in
Exhibit
2­
1
for
completeness
but,
because
these
types
of
entities
are
not
affected
by
the
proposed
alternatives,
they
are
not
discussed
further
in
this
overview.
Section
2.6
briefly
discusses
the
transporters
of
CRTs
that
move
CRTs
from
one
entity
to
the
next.
Finally,
under
the
CSI
alternative
a
category
of
entities
is
defined,
CSI
handlers,
that
can
be
either
original
users
or
certain
collectors.
CSI
handlers
are
described
in
more
detail
in
Section
2.7.
Page
3
Exhibit
2­
1:
CRT
Life­
Cycle
Flow
Diagram
2.1
Original
Users
Original
users
are
establishments
that
first
use
and
discard
CRTs.
Original
users
include
entities
that
use
computers
and
televisions
in
the
normal
course
of
their
business
operations
and
that
periodically
discard
them.
For
example,
original
users
range
from
large
multinational
corporations
down
to
small
local
real
estate
offices.
Original
users
send
CRTs
for
reuse,
recycling,
reclamation,
disposal,
or
to
collectors.
As
considered
in
this
analysis,
original
users
do
not
include
entities
that
are
explicitly
excluded
from
hazardous
waste
requirements
(e.
g.,
households).

Current
RCRA
Regulatory
Requirements
Because
color
CRTs
contain
leaded
glass
that
typically
qualifies
as
hazardous
waste
when
disposed,
any
entity
that
uses
computers
or
televisions
may
be
a
regulated
generator.
However,
under
current
EPA
policy,
used
CRTs
with
the
potential
for
reuse
are
assumed
to
be
products
and
not
wastes
if
there
is
the
possibility
that
the
CRTs
will
be
refurbished
or
reused.
Therefore,
original
users
that
discard
intact
CRTs
are
only
regulated
generators
if
they
send
the
CRTs
for
intended
disposal
(e.
g.,
a
landfill),
to
a
lead
smelter,
or
to
a
glass
processor
that
does
not
refurbish
any
of
the
CRTs
it
receives.
Original
users
that
discard
broken
CRT
glass
are
regulated
generators
regardless
of
where
they
are
sent.
This
analysis
assumes
that
original
users
only
discard
intact
CRTs.

Original
users
are
regulated
if
they
produce
hazardous
wastes
in
quantities
above
a
threshold
of
100
kilograms
(kg)
per
month.
Original
users
that
produce
less
than
100
kg
per
month
of
hazardous
waste
are
conditionally
exempt
from
RCRA
requirements
and
are
not
included
in
this
analysis
(40
CFR
§261.5).
Original
users
that
produce
between
100
and
1,000
kg
per
month
of
hazardous
waste
are
Page
4
small
quantity
generators
(SQGs)
and
must
comply
with
storage
limits,
manifesting,
recordkeeping,
and
safety
training
requirements
(40
CFR
Part
262
generally).
Original
users
that
generate
more
than
1,000
kg
per
month
of
hazardous
waste
are
large
quantity
generators
(LQGs)
and
must
comply
with
the
same
or
more
stringent
requirements
as
SQGs
and
must
also
comply
with
biennial
reporting
requirements.
Due
to
the
100
kg
per
month
threshold
(equivalent
to
approximately
seven
CRTs),
only
relatively
large
original
users
are
likely
to
qualify
as
regulated
generators
based
solely
on
their
generation
of
postconsumer
CRTs.
However,
facilities
that
generate
hazardous
waste
other
than
CRTs
may
qualify
as
a
regulated
generator
with
less
than
100
kg
per
month
of
CRTs.
The
treatment
of
these
generators
in
this
analysis
is
discussed
in
Section
3.3.4.

Primary
and
CSI
Alternatives
Under
the
primary
alternative,
CRTs
that
are
sent
to
reclaimers
and
glass
processors
(see
Sections
2.4
and
2.5)
are
excluded
from
the
definition
of
solid
waste.
Thus
the
original
users
that
send
CRTs
to
these
CRT
management
options
will
no
longer
be
considered
generators
of
CRTs.
Original
users
that
send
their
CRTs
for
disposal
continue
to
be
regulated
generators
under
the
primary
alternative.

Under
the
CSI
alternative,
CRTs
that
are
sent
to
glass
processors
(see
Section
2.5)
are
excluded
from
the
definition
of
hazardous
waste.
Therefore,
the
original
users
that
send
CRTs
to
glass
processors
are
no
longer
considered
generators
of
CRTs.
Original
users
that
send
their
CRTs
for
disposal
or
to
reclaimers
continue
to
be
generators
under
the
CSI
alternative.
Thus
the
CSI
alternative
also
reduces
the
number
of
original
users
subject
to
the
rule,
but
not
by
as
many
as
does
the
primary
alternative.

2.2
Establishments
that
Reuse
Monitors
Establishments
that
reuse
CRTs
include
schools,
foundations,
and
other
not­
for­
profit
entities.
Although
reusers
of
CRTs
can
face
the
same
regulatory
conditions
as
original
users
of
CRTs
(i.
e.,
because
RCRA
regulations
do
not
define/
distinguish
between
them),
the
analysis
assumes
that
establishments
that
reuse
monitors
do
not
discard
enough
CRTs
to
trigger
the
RCRA
requirements
or
they
are
exempted
entities.
This
category
of
establishments
is
included
in
the
analysis
for
completeness
of
the
CRT
life
cycle
flow.

2.3
Collectors
The
analysis
recognizes
a
category
of
entities
called
CRT
"collectors,"
which
includes
intermediary
entities
that
collect
intact
televisions
or
computer
monitors,
and
then
send
the
CRTs
or
CRT
glass
for
reuse,
recycling,
reclamation,
or
disposal.
Because
collectors
often
make
a
decision
to
either
refurbish/
reuse
CRTs
or
to
dispose
of
them,
they
frequently
trigger
the
hazardous
waste
regulations,
becoming
potentially
regulated
generators
when
opting
to
send
CRTs
for
disposal,
reclamation,
or
recycling.
Like
original
users,
collectors
are
unregulated
if
they
send
CRTs
to
entities
(e.
g.,
other
collectors)
that
might
refurbish/
reuse
them.
1
Collectors
that
are
SQGs
are
assumed
to
not
crush
the
CRTs
because
the
large
capital
costs
of
the
crushing
equipment
and
the
relatively
low
volumes
of
CRTs
that
they
handle
does
not
make
crushing
economically
viable.
Collectors
that
are
LQGs
are
assumed
to
crush
the
CRTs
because
the
larger
volumes
of
CRTs
they
handle
combined
with
the
disposal
cost
savings
for
crushed
versus
whole
bare
CRTs
makes
the
purchase
and
operation
of
the
crushing
equipment
economically
feasible.

2
Bare
CRTs
are
televisions
or
monitors
that
have
had
the
casing,
electronics,
and
electron
gun
removed
from
them,
leaving
only
the
panel
and
funnel
glass
that
are
still
fused
together.

Page
5
The
category
of
collectors
covers
a
wide
variety
of
entities.
For
example,
this
category
includes
establishments
that
primarily
refurbish
CRTs
for
reuse
and
also
establishments
that
primarily
dismantle
CRTs
for
recycling.
Collectors
that
primarily
refurbish
CRTs
for
reuse
tend
to
be
smaller
organizations,
including
non­
profit
entities.
Collectors
that
primarily
recycle
CRTs
are
typically
small
to
medium
for
profit
businesses.
Since
not
all
CRTs
can
be
refurbished
for
reuse,
the
collectors
that
refurbish
CRTs
typically
send
unusable
CRTs
to
collectors
that
primarily
recycle
CRTs.
Some
collectors
that
primarily
recycle
CRTs
break
and
grind
the
CRTs
to
separate
out
the
metal
from
the
glass.
Separating
the
metal
from
the
glass
also
reduces
the
CRT
management
costs
of
the
glass
if
it
is
sent
to
glass
processors.
The
grinding
process
increases
the
density
of
the
CRTs,
thus
reducing
shipping
costs,
and
also
results
in
a
better
price
from
the
glass
processor.
The
collector
category
also
includes
brokers
that
arrange
for
large
quantities
of
electronic
equipment,
including
CRTs,
to
be
sent
to
electronics
recycling
facilities
or
for
export.
This
analysis
assumes
that
collectors
that
are
SQGs
discard
bare
CRTs
and
collectors
that
are
LQGs
discard
broken
or
crushed
CRT
glass.
1
Collectors
are
assumed
not
to
generate
hazardous
waste
other
than
CRTs.

Current
RCRA
Regulatory
Requirements
Under
current
EPA
policy,
CRTs
that
are
discarded
are
assumed
to
be
products
and
not
wastes
if
there
is
the
possibility
that
the
CRTs
will
be
refurbished
or
reused.
Therefore,
under
current
requirements,
collectors
that
discard
intact
CRTs
are
only
regulated
generators
if
they
send
the
CRTs
for
intended
disposal
(e.
g.,
a
landfill),
to
a
lead
smelter,
or
to
a
glass
processor
that
does
not
refurbish
any
of
the
CRTs
it
receives.
Collectors
that
discard
bare
CRTs
or
broken
CRT
glass
are
regulated
generators
regardless
of
where
they
are
sent
because
it
is
assumed
they
cannot
be
reused
at
this
point.
2
Collectors
are
regulated
if
they
produce
hazardous
wastes
in
quantities
above
a
threshold
of
100
kilograms
(kg)
per
month.
Collectors
that
produce
less
than
100
kg
per
month
of
hazardous
waste
are
conditionally
exempt
from
RCRA
requirements
and
are
not
included
in
this
analysis
(40
CFR
§261.5).
Collectors
that
produce
between
100
and
1,000
kg
per
month
of
hazardous
waste
are
small
quantity
generators
(SQGs)
and
must
comply
with
storage
limits,
manifesting,
recordkeeping,
and
safety
training
requirements
(40
CFR
Part
262
generally).
Collectors
that
generate
more
than
1,000
kg
per
month
of
hazardous
waste
are
large
quantity
generators
(LQGs)
and
must
comply
with
the
same
or
more
stringent
requirements
as
SQGs
and
must
also
comply
with
biennial
reporting
requirements.
3
Cutter
Information
Corp.
's,
Product
Stewardship
Advisor,
"The
Long­
Term
Future
of
CRT
Glass
Recycling:
How
NEC
Is
Planning
Ahead."
Volume
I,
No.
6,
November
1997.

Page
6
Primary
and
CSI
Alternatives
Under
the
primary
alternative,
bare
intact
CRTs
that
are
sent
to
lead
smelters
and
glass
processors
(see
Sections
2.4
and
2.5)
are
unconditionally
excluded
from
the
definition
of
solid
waste.
Used
broken
CRTs
are
conditionally
excluded
when
stored
in
containers
or
buildings.
Therefore,
the
collectors
that
send
CRTs
to
these
disposal
options
are
no
longer
considered
generators
of
CRTs.
Collectors
that
send
their
CRTs
for
disposal
continue
to
be
generators
under
the
primary
alternative.

Under
the
CSI
alternative,
CRTs
that
are
sent
to
glass
processors
(see
Section
2.5)
are
excluded
from
the
definition
of
solid
waste.
Consequently,
the
collectors
that
send
CRTs
to
glass
processors
are
no
longer
considered
generators
of
CRTs.
Collectors
that
send
their
CRTs
for
disposal
or
to
lead
smelters
continue
to
be
generators
under
the
CSI
alternative.
Thus,
the
CSI
alternative
reduces
the
number
of
collectors
subject
to
the
rule,
but
not
by
as
many
as
does
the
primary
alternative.

2.4
Reclaimers
Current
RCRA
Regulatory
Requirements
Current
requirements
do
not
recognize
or
specifically
define
any
category
of
CRT
reclaimers.

Under
current
RCRA
Subtitle
C
regulations,
entities
that
disassemble
televisions
or
computer
monitors
and
break
CRT
glass
for
land
disposal
or
smelting
are
"treating"
the
CRT
glass
(40
CFR
§
260.10).
Treatment
of
hazardous
waste
is
often
subject
to
administrative
and
technical
standards
and
requires
a
permit
(40
CFR
Parts
264,
265,
and
270).
However,
some
forms
of
treatment,
such
as
reclamation,
are
not
subject
to
regulation
(e.
g.,
CRT
disassembly
for
smelting)
(40
CFR
§
261.6(
C)(
1))
or,
treatment
may
be
conditionally
exempt
if
the
treater
generated
the
waste
(40
CFR
§§
262.34,
264.1(
g)(
3),
and
265.1(
c)(
7)).

Primary
and
CSI
Alternatives
Reclaimers
include
entities
that
use
CRT
glass
as
a
substitute
for
raw
materials.
Under
the
primary
alternative
only
lead
smelters
are
recognized
as
reclaimers.
Other
types
of
reclaimers
that
are
not
recognized
under
the
primary
alternative
include
establishments
that
turn
the
CRT
glass
into
a
usable
product,
such
as
glass
construction
blocks.
Another
example
is
a
reclaimer
that
has
a
value
added
process
that
turns
the
CRT
glass
into
a
marketable
product
called
LeadX,
which
can
be
used
as
a
sand­
blasting
abrasive
suitable
for
the
abatement
of
leaded
paint.
3
The
primary
alternative
only
changes
the
RCRA
regulatory
requirements
for
lead
smelters,
but
not
for
other
types
of
reclaimers.
The
CSI
alternative
does
not
change
the
RCRA
regulatory
requirements
for
any
reclaimers.
4
Pre­
consumer
CRTs
are
not
addressed
in
this
analysis.

Page
7
2.5
Glass
Processors
Current
RCRA
Regulatory
Requirements
Current
requirements
do
not
define
any
category
of
CRT
glass
processors.
CRT
glass
processors
are
currently
captured
under
the
regulations
as
treatment,
storage,
and
disposal
facilities
unless
they
also
conduct
refurbishment.

Primary
and
CSI
Alternatives
Glass
processors
disassemble
the
televisions
and
computer
monitors,
intentionally
break
the
CRT
glass
and
prepare
the
CRT
glass,
by
cleaning
and
sorting
it,
for
shipment
to
CRT
glass
manufacturers.
Glass
processors
receive
discarded
post­
consumer
televisions
and
computer
monitors
from
both
original
users
and
collectors,
and
off­
specification
pre­
consumer
CRTs
from
manufacturers
of
televisions
and
computer
monitors.
4
Although
a
subset
of
collectors
perform
some
of
the
same
processing
steps
as
glass
processors,
the
primary
difference
between
glass
processors
and
collectors
is
that
glass
processors
prepare
the
glass
for
input
directly
into
a
CRT
glass
manufacturers
furnace,
while
CRT
glass
from
collectors
requires
further
processing
before
it
can
be
sent
to
a
CRT
glass
manufacturer.

2.6
Transporters
Current
RCRA
Requirements
Under
current
requirements,
transporters
of
any
hazardous
waste,
including
discarded
CRTs,
are
required
to
be
certified
as
hazardous
waste
handlers.
(40
CFR
Part
263)

Primary
and
CSI
Alternatives
Under
both
regulatory
alternatives,
any
non­
hazardous
material
carrier
may
transport
whole
televisions
and
computer
monitors
between
original
users
and
collectors
and
between
generators
and
glass
processors
without
being
certified
hazardous
waste
handlers.
Under
the
primary
alternative,
any
non­
hazardous
material
carrier
may
transport
intact
or
broken
CRTs
between
generators
and
reclaimers
and
between
glass
processors
and
reclaimers.

2.7
CRT
Handlers
Current
RCRA
Regulatory
Requirements
Current
requirements
do
not
recognize
or
define
any
category
of
CRT
handlers.
Page
8
Primary
Alternative
The
primary
alternative
does
not
recognize
or
define
a
category
of
CRT
handlers.

CSI
Alternative
The
CSI
alternative
defines
handlers
as
including
entities
that
collect
and/
or
store
whole
televisions
or
computer
monitors,
including
those
generated
by
the
entity
itself,
and
then
send
them
to
glass­
to­
glass
recycling
facilities
(also
called
"glass
processors")
or
to
other
handlers.
Handlers
also
include
any
entity
that
disassembles
televisions
and
computer
monitors
and
sends
the
whole
CRTs
to
a
processor
or
another
handler.
Note
that,
under
the
CSI
alternative,
entities
that
are
generators
under
current
requirements
become
handlers
for
CRTs
if
they
send
their
CRTs
to
glass­
to­
glass
recycling
facilities
or
to
other
handlers.
Under
the
CSI
alternative,
handlers
are
exempt
from
RCRA
generator
requirements.
Large
quantity
handlers
(LQH)
include
handlers
that
collect
and
store
more
than
40
tons
of
CRTs
for
more
than
seven
consecutive
days.
Small
quantity
handlers
(SQH)
include
handlers
that
collect
or
store
more
than
100
kg
per
month.
Handlers
are
believed
to
send
CRTs
to
processors,
smelters,
or
other
handlers.

3.0
Methodology
and
Data
This
section
describes
the
methodology
used
to
quantitatively
estimate
(1)
the
type
and
number
of
entities
impacted
by
the
proposed
rule;
(2)
the
cost
savings
expected
to
result
from
the
proposed
rule;
and
(3)
the
impact
on
the
regulated
entities.
To
obtain
these
results
the
analysis
models
the
flow
of
discarded
CRTs
from
generation
to
final
disposal.
The
following
ten
steps
broadly
outline
the
analytical
methodology:

(1)
Estimate
the
number
of
original
users
discarding
computer
monitors;
(2)
Estimate
the
total
number
of
color
computer
monitors
discarded
annually;
(3)
Estimate
the
number
of
regulated
original
users
and
collectors;
(4)
Estimate
the
flow
of
discarded
CRTs
to
each
disposal
alternative;
(5)
Estimate
the
administrative
compliance
costs
for
the
regulated
establishments;
(6)
Estimate
the
CRT
management
costs
(i.
e.,
costs
for
disposal,
recycling,
reuse);
(7)
Estimate
the
transportation
costs
for
shipping
CRTs;
(8)
Estimate
the
storage
costs
for
storing
CRTs;
(9)
Estimate
the
costs
for
glass­
to­
glass
processors
and
transporters;
and
(10)
Estimate
the
impact
of
the
compliance
costs
on
the
regulated
establishments.

These
steps,
along
with
the
applicable
data
and
assumptions
used,
are
described
below
in
Sections
3.1
through
3.10.
Section
3.11
describes
the
methodology,
data,
and
assumptions
used
to
analyze
the
Subtitle
D
management
baseline
where
a
large
percentage
of
CRTs
are
disposed
in
Subtitle
D
landfills
without
treatment.
This
baseline
may
more
closely
represent
current
CRT
disposal
practices.
Section
3.12
identifies
key
assumptions
and
limitations
of
the
methodology
and
data.
It
is
worth
noting
at
this
time
that
the
CRTs
from
televisions
are
addressed
only
in
a
sensitivity
analysis
presented
in
5
U.
S.
Bureau
of
the
Census,
"Computer
Use
in
the
United
States:
October
1993."
www.
census.
gov/
population/
socdemo/
computer/
compwork.
txt
and
"Computer
Use
in
the
United
States:
October
1997."
September
1999.

Page
9
Sections
4.2.4
and
4.3.4.
For
reasons
discussed
in
Section
3.12,
this
is
not
believed
to
have
a
significant
bearing
on
the
results.

While
not
a
limitation
to
the
analysis,
note
also
that
the
analysis
reflects
generators
of
non­
CRT
hazardous
wastes
only
to
the
extent
that
these
entities
generate
more
than
30
CRTs
per
year.
For
reasons
discussed
in
Section
3.12,
this
is
consistent
with
least
cost
behavior
on
the
part
of
these
entities.

3.1
Estimate
the
Number
of
Original
Users
Discarding
Computer
Monitors
Computers
are
used
in
all
industries;
it
is
rare
to
find
a
business
establishment
without
at
least
one
computer.
However,
businesses
utilize
computers
at
different
rates.
For
example,
financial
institutions
are
far
more
likely
to
have
high
ratios
of
computers
per
employee
than
are
farms.
Given
that
computers
are
used,
and
therefore
discarded,
by
virtually
all
establishments,
the
total
number
of
establishments
in
all
two­
digit
SIC
codes
provides
an
estimate
of
the
number
of
business
original
users
discarding
computer
monitors.
These
data
are
currently
available
for
1995
from
the
U.
S.
Bureau
of
the
Census.
The
total
number
of
establishments
in
all
SIC
codes
in
1995
is
6,613,188.
In
addition
to
obtaining
the
total
number
of
establishments
in
each
two­
digit
SIC
code,
the
distribution
of
establishments
by
size,
as
measured
by
the
number
of
employees
per
establishment,
was
obtained
for
use
in
subsequent
steps
in
the
modeling
process.
Appendix
A
contains
a
table
of
the
number
of
establishments
and
the
total
number
of
employees
for
all
two­
digit
SIC
codes.

3.2
Estimate
the
Total
Number
of
Color
Computer
Monitors
Discarded
Annually
The
second
step
in
the
modeling
process
estimates
the
number
of
color
computer
monitors
discarded
by
the
original
users
identified
in
the
first
step.
To
do
this,
the
analysis
estimates,
in
turn,
the
total
number
of
computers
in
use,
the
number
discarded
each
year
and,
finally,
the
number
of
these
discarded
monitors
that
are
color
monitors.

3.2.1
Total
Number
of
Computers
in
All
Business
Establishments
To
determine
the
total
number
of
computers
in
use
by
all
original
users,
an
estimate
of
the
ratio
of
computers
per
employee
is
developed
for
each
two­
digit
SIC
code
based
on
two
surveys
taken
by
the
U.
S.
Bureau
of
the
Census.
5
The
first
survey,
completed
in
1993,
contained
a
detailed
listing
of
computer
use
at
work
by
two­
digit
SIC
classification.
The
second
survey,
completed
in
1997,
only
contained
a
summary
of
computer
use
at
work
by
fifteen
major
SIC
classifications.
This
analysis
uses
the
less
detailed
1997
survey
to
extrapolate
the
more
detailed
1993
survey
results
to
2001
by
assuming
the
same
percentage
increase
occurred
between
1997
and
2001
as
occurred
from
1993
to
1997.
This
assumes
a
linear
growth
in
computer
use.
The
average
increase
in
the
percent
of
employees
using
6
Matthews,
Scott
H.,
McMichael,
Francis
Co.,
Hendrickson,
Chris
T.,
Hart,
Deanna,
J.,
Disposition
and
End­
of­
Life
Options
for
Personal
Computers,
Carnegie
Mellon
University:
Green
Design
Initiative
Technical
Report
#97­
10,
July
7,
1997.

7
National
Safety
Council,
Electronic
Product
Recovery
and
Recycling
Baseline
Report,
Recycling
of
Selected
Electronic
Products
in
the
United
States.
May
1999.
page
29.

8
Monochrome
computer
monitors
are
assumed
not
to
contain
enough
lead
to
qualify
them
as
hazardous
waste
when
discarded
and
thus
are
excluded
from
the
analysis.
Source:
Overview
of
Cathode
Ray
Tube
Recycling,
February
27,
1997,
page
8.
The
original
source
in
the
referenced
report
is
a
letter
from
Robert
Dodds,
Sony,
to
Nancy
Helm,
EPA
Region
X,
dated
July
8,
1996.

Page
10
computers
is
six
percent.
The
range
of
percentage
increases
in
the
percent
of
employees
using
computers
at
work
is
from
one
to
14
percent.
Appendix
B
lists
the
ratios
of
computers
per
employee
calculated
for
each
SIC
code.
The
ratios
are
multiplied
by
the
total
number
of
employees
in
each
two
digit
SIC
code.
The
resulting
products
are
summed
to
obtain
an
estimate
of
the
total
number
of
computers
in
use
by
all
original
users.
The
model
estimates
there
are
55,555,000
computers
used
by
all
original
users.

3.2.2
Discarded
Computer
Monitors
from
All
Original
Users
To
determine
the
total
number
of
computers
discarded
by
all
original
users,
the
estimated
number
of
computers
in
use
by
all
original
users
is
divided
by
an
estimate
of
the
average
computer
monitor
life.
The
analysis
assumes
that
computer
monitors
last
an
average
of
3.5
years
in
businesses.
A
literature
search
yielded
a
wide
range
of
estimates
for
monitor
lifetimes.
For
example,
a
1997
study
by
Carnegie
Mellon
suggested
lifetimes
of
four
to
five
years,
6
while
a
1999
report
by
the
National
Safety
Council
estimates
that
monitor
lifetimes
would
be
2.8
years
in
the
year
2000.
7
The
model
results
are
sensitive
to
monitor
lifetime.
The
estimated
total
number
of
computers
discarded
per
year
by
all
original
users
is
15,873,000.
This
value
includes
monitors
that
are
sent
by
original
users
to
organizations
that
will
reuse
the
monitors.

An
implicit
assumption
in
this
calculation
is
that
businesses
discard
computers
continuously,
or
in
small
batches
annually,
rather
than
replacing
all
computers
once
every
3.5
years.
This
is
a
reasonable
assumption
as
most
businesses
purchase
new
computers
on
an
as
needed
basis,
and
the
computer
stock
in
any
one
company
is
not
all
of
the
same
age.

3.2.3
Color
Monitors
Discarded
from
All
Original
Users
To
determine
the
total
number
of
color
monitors
discarded,
the
model
subtracts
out
laptop
computers
(which
do
not
use
CRTs)
and
monochrome
monitors
(which
do
not
use
glass
with
high
lead
concentrations)
from
the
total
number
of
computers
discarded.
8
After
these
subtractions,
described
9
National
Safety
Council,
Electronic
Product
Recovery
and
Recycling
Baseline
Report,
Recycling
of
Selected
Electronic
Products
in
the
United
States.
May
1999.
page
31.

10
U.
S.
Bureau
of
the
Census,
"Computer
Use
in
the
United
States:
October
1993."
www.
census.
gov/
population/
socdemo/
computer/
compwork.
txt.

Page
11
below,
the
resulting
number
of
color
monitors
discarded
per
year
by
all
original
users
is
estimated
at
11,714,000.

Percent
of
Discarded
Computers
that
are
Laptops.
The
model
assumes
that
18
percent
of
all
discarded
computers
are
laptops.
Laptops
have
become
an
important
segment
of
the
computer
market
over
the
last
five
to
eight
years.
Computer
sales
estimates
from
1998
indicate
that
18
percent
of
computer
sales
are
laptops.
9
The
model
results
are
only
slightly
sensitive
to
the
percent
of
laptops
discarded.

Percent
of
Discarded
Monitors
that
are
Color.
The
Census
survey
from
1993
reported
that
61
percent
of
households
with
computers
have
color
monitors.
10
This
analysis
considers
that
figure
to
be
a
lower­
bound
estimate
for
businesses,
based
on
the
assumption
that
businesses
are
more
likely
to
have
color
monitors
than
households.
Since
color
monitors
have
become
much
more
common
over
the
last
eight
years,
the
model
uses
an
estimate
of
90
percent
for
the
percent
of
color
monitors
discarded
from
businesses.
The
model
results
are
sensitive
to
the
percent
of
color
monitors
assumed
as
a
percentage
of
all
monitors
discarded.

3.3
Estimate
the
Number
of
Regulated
Original
Users
and
Collectors
and
the
Number
of
CRTs
They
Discard
The
next
step
in
the
methodology
is
to
determine
the
number
of
original
users
and
collectors
that
are
subject
to
RCRA
requirements
for
generators
and
that
would
be
affected
by
the
regulatory
alternatives.
This
section
also
estimates
the
number
of
CRTs
that
are
discarded
by
original
users
and
collectors.
To
complete
these
calculations,
the
number
of
computers
discarded
per
establishment
and
an
estimate
of
monitor
weight
is
required.
The
report
then
explains
the
methodologies
used
to
estimate
the
number
of
establishments
for
three
types
of
entities:
original
users
that
are
currently
generators
solely
due
to
CRTs;
original
users
that
are
generators
due
to
a
combination
of
CRTs
and
non­
CRT
hazardous
waste;
and
collectors
that
are
currently
generators.

3.3.1
Computers
Discarded
per
Original
User
To
estimate
the
average
number
of
computers
discarded
annually
per
original
user
in
each
of
the
two
digit
SIC
codes,
the
analysis
estimates
the
average
number
of
employees
per
establishment,
Page
12
multiplies
this
estimate
by
the
number
of
computers
per
employee
(as
discussed
in
Section
3.2.1),
and
then
adjusts
for
the
number
of
color
computer
monitors
discarded.
Exhibit
3­
1
contains
the
summary
statistics
generated
by
this
analysis
for
the
number
of
color
CRTs
discarded
per
original
user
for
all
two­
digit
SIC
codes.

The
Census
reports
the
number
of
establishments
by
two­
digit
SIC
code
for
six
size
ranges
of
employees
(250
to
499;
500
to
999;
1,000
to
1,499;
1,500
to
2,499;
2,500
to
4,999;
and
5,000
or
more
employees).
The
midpoint
of
each
range
is
used
as
the
estimate
of
the
number
of
employees
in
each
establishment
within
each
defined
size
range.
For
the
largest
category
(5,000
or
more
employees),
a
value
of
10,000
employees
per
establishment
is
used.

Exhibit
3­
1:
Number
of
Color
CRTs
Discarded
per
Original
User
for
All
Two­
Digit
SIC
Codes
Statistic
Number
of
Color
CRTs
Discarded
by
Establishment
Size
As
Determined
by
the
Number
of
Employees
250
­
499
500
­
999
1000
­
1,499
1,500
­
2,499
2,500
­
4,999
>
5,000
Minimum
13
25
42
66
124
330
25
th
Percentile
32
34
107
172
321
854
Median
35
70
117
187
350
931
Average
43
85
141
225
422
1,123
75
th
Percentile
56
111
184
294
552
1,470
Maximum
79
157
261
417
781
2,082
11
The
table
below
presents
the
number
and
percent
of
monitors
sold
in
1997
and
1998
by
size
of
monitor.
The
source
of
the
sales
data
is
the
Electronic
Industries
Alliance
report,
Spring
2001.
The
15­
inch
monitor
weight
was
obtained
from
the
user
manuals
for
a
Sony
Trinitron
Color
Computer
Display
(manufactured
in
1998),
and
for
an
Apple
Multiple
Scan
15
Display
(manufactured
in
1994).
The
17­
inch
monitor
weight
was
obtained
from
the
user
manual
for
a
Sony
Trinitron
Color
Computer
Display
(manufactured
in
1998).
The
14­
inch
and
19­
to
21­
inch
monitor
weights
are
estimated
based
on
the
weight
of
glass
in
each
monitor
size,
which
is
20
pounds
and
28
pounds
respectively
Monitor
Size
(inches)
Monitor
Weight
(lbs)
1997
1998
Number
Sold
Percent
Sold
Number
Sold
Percent
Sold
<
=
14
26
4,100
14%
2,600
8%

15
31
12,800
45%
12,900
41%

17
41
10,300
36%
13,700
43%

19
­
21
48
1,200
4%
2,400
8%

Totals
28,400
100%
31,600
100%

Page
13
3.3.2
Monitor
Weight
Throughout
the
analysis,
the
model
assumes
an
average
monitor
weight
of
35
pounds,
based
on
the
percentage
and
weight
of
each
size
of
monitor
sold
3.5
years
prior
to
the
modeled
year.
11
The
analysis
uses
a
weighted
average
of
the
monitors
sold
in
1997
and
1998
to
determine
the
average
weight
of
monitors
discarded
in
the
model
year.
In
the
future,
the
average
monitor
weight
is
expected
to
increase
with
the
use
of
larger
screens,
which
would
tend
to
push
more
original
users
into
the
regulated
universe.
For
example,
by
2004
the
average
weight
of
discarded
monitors
is
expected
to
be
38
pounds.

3.3.3
Number
of
Original
Users
and
Collectors
that
are
Regulated
Generators
in
the
Subtitle
C
Baseline
Based
Only
on
the
Generation
of
CRTs
Original
Users
To
estimate
the
number
of
original
users
that
are
regulated
solely
due
to
their
generation
of
CRTs,
assumptions
must
be
made
regarding
the
behavior
that
establishments
will
exhibit
in
discarding
computer
monitors.
The
analysis
assumes
that
businesses
will
exhibit
least
cost
behavior
to
the
extent
possible
by
discarding
monitors
each
month
just
below
the
100
kilogram
per
month
limit
for
SQGs.
An
original
user
becomes
an
SQG
if
in
any
one
month
it
exceeds
the
100
kilogram
per
month
threshold.
12
This
calculation
assumes
that,
in
any
one
month,
an
establishment
will
be
subject
to
RCRA
regulation
if
it
discards
seven
or
more
color
monitors
(7
monitors
*
15.9
kg/
monitor
=
111
kg;
100
kg
per
month
is
the
threshold
for
SQGs).
Assuming
least­
cost
behavior,
the
smallest
number
of
color
monitors
an
establishment
could
discard
annually
and
trigger
the
RCRA
requirements
for
SQGs
is
[(
11
months
*
(7­
1
CRTs))
+
(1
month
*
7
CRTs)
=]
73
CRTs
per
year.
Given
the
assumed
monitor
lifetime
(3.5
years,
for
a
turnover
rate
of
0.29),
SQGs
must
possess
a
minimum
of
73/
0.29,
or
256
operating
color
monitors.
The
numbers
for
LQGs
are
calculated
using
the
same
method,
with
the
threshold
for
discard
starting
at
63
color
monitors
per
month,
or
745
in
a
year,
for
a
total
number
of
computers
of
2,608
in
each
LQG
establishment.

13
The
database
is
the
International
Association
of
Electronics
Recyclers
(IAER)
industry
directory
that
is
located
on
IAER's
web
site,
www.
iaer.
org.

Page
14
Based
on
the
current
SQG
threshold
(100
kg/
month)
and
LQG
threshold
(1,000
kg/
month)
under
the
Subtitle
C
baseline,
and
the
assumptions
made
regarding
monitor
lifetime
and
weight,
and
the
assumed
least
cost
behavior,
original
users
who
discard
73
­
744
monitors
annually
are
SQGs
and
those
who
discard
745
or
more
monitors
annually
are
LQGs.
12
Based
on
the
assumed
monitor
lifetime
of
3.5
years,
the
smallest
SQG
possesses
256
operating
color
computer
monitors
and
the
smallest
LQG
possesses
2,608
operating
color
computer
monitors.
Under
these
assumptions
and
the
estimated
number
of
computers
discarded
per
establishment,
there
are
an
estimated
12,151
potential
SQGs
and
356
potential
LQGs
in
the
Subtitle
C
baseline
due
solely
to
the
generation
of
CRTs.
These
entities
discard
an
estimated
total
of
2,490,000
CRTs
per
year.
Some
of
these
potential
SQGs
and
LQGs
only
send
CRTs
to
collectors,
for
reuse,
or
to
glass
processors
who
refurbish
and
resell
some
of
the
monitors
they
receive.
Thus
not
all
of
the
potential
SQGs
and
LQGs
are
actually
regulated
generators.
The
analysis
estimates
that
there
are
2,066
actual
SQGs
and
61
actual
LQGs.
The
analysis
models
the
flow
of
all
of
the
CRTs
generated
by
all
the
potential
original
user
generators,
because
although
the
establishments
generating
these
CRTs
are
not
regulated,
the
CRTs
themselves
may
still
become
subject
to
regulation
with
subsequent
handlers.

Collectors
To
estimate
the
number
of
collectors
the
analysis
started
with
a
database
of
establishments
involved
in
the
electronics
recycling
industry.
13
By
comparing
this
database
with
the
names
of
electronics
recyclers
mentioned
in
the
literature
review,
a
rough
estimate
of
the
number
of
collectors
was
obtained.
The
analysis
estimates
there
are
100
potential
SQGs
and
500
potential
LQGs
that
are
collectors.
Collectors
are
assumed
to
only
be
hazardous
waste
generators
due
to
their
discarding
of
CRTs.
The
600
potentially
regulated
collectors
are
estimated
to
process
approximately
2.0
million
CRTs
per
year.
Some
of
these
potential
collectors
only
send
CRTs
for
reuse
or
for
export,
neither
of
which
are
regulated
activities
if
the
CRTs
have
the
possibility
of
being
reused.
Thus,
the
collectors
who
send
CRTs
for
reuse
or
export
are
not
considered
regulated
generators
in
this
analysis.
The
analysis
assumes
that
there
are
50
SQGs
and
250
LQGs.
14
The
ratio
of
all
hazardous
waste
generators
to
all
establishments
was
calculated
from
data
obtained
from
the
biennial
reporting
system
database
(number
of
LQGs)
and
the
Resource
Conservation
and
Recovery
Information
System
(RCRIS)
database
(number
of
SQGs
in
each
SIC
code)
and
1995
U.
S.
Census
data.

Page
15
3.3.4
Number
of
Original
Users
that
are
Regulated
Generators
in
the
Subtitle
C
Baseline
Due
to
a
Combination
of
CRTs
and
Non­
CRT
Hazardous
Waste
The
number
of
generators
due
in
part
to
non­
CRT
hazardous
waste
is
estimated
from
the
number
of
original
users
discarding
between
30
and
72
CRTs
per
year
and
the
total
number
of
SQGs
and
LQGs
in
each
two­
digit
SIC
code.
The
lower
bound
of
30
CRTs
discarded
per
year
is
based
on
the
assumption
that
generators
discarding
fewer
than
30
CRTs
per
year
do
not
send
their
CRTs
to
glass­
to­
glass
processors
due
to
the
high
transportation
costs
and
low
volume
of
CRTs
discarded.
The
upper
bound
of
72
CRTs
discarded
per
year
is
used
because
original
users
generating
more
than
72
CRTs
per
year
are
captured
as
SQGs
or
LQGs
in
the
analysis
above.

The
total
number
of
all
original
users
discarding
between
30
and
72
CRTs
per
year
in
each
two­
digit
SIC
code
is
estimated
using
the
same
methodology
as
described
in
Sections
3.3.1
to
3.3.3.
The
total
number
of
original
users
generating
between
30
and
72
CRTs
per
year
is
estimated
at
21,842.
This
number
underestimates
the
total
number
of
these
generators
because
for
some
SIC
codes
the
number
of
employees
that
generate
30
CRTs
per
year
is
less
than
250,
while
the
analysis
uses
the
total
number
of
establishments
with
250
to
499
employees
to
estimate
the
number
of
generators.
The
analysis
uses
this
larger
size
category
because
the
Census
data
source
does
not
have
a
category
for
below
250
employees
except
for
1
­
249
employees.
Because
about
97
percent
of
all
establishments
have
less
than
250
employees,
it
is
likely
that
the
estimated
number
of
establishments
discarding
30
to
72
CRTs
is
low.
To
estimate
the
number
of
hazardous
waste
generators
in
each
two­
digit
SIC
code
from
the
number
of
all
establishments
discarding
30
to
72
CRTs
per
year,
the
ratio
of
all
hazardous
waste
generators
to
all
establishments
in
each
two­
digit
SIC
code
is
multiplied
by
the
total
number
of
establishments
discarding
between
30
and
72
CRTs
per
year.
14
To
account
for
the
fact
that
SQGs
and
LQGs
are
more
likely
to
be
larger
organizations,
the
ratio
for
SQGs
is
multiplied
by
a
factor
of
1.5
and
the
ratio
for
LQGs
is
multiplied
by
a
factor
of
2.
Under
these
assumptions
there
are
2,136
potential
SQGs
and
891
potential
LQGs
because
they
generate
a
combination
of
CRTs
and
non­
CRT
hazardous
waste.
These
generators
discard
an
estimated
total
of
151,000
CRTs
per
year.
Some
of
these
potential
SQGs
and
LQGs
only
send
CRTs
to
collectors,
so
not
all
of
the
potential
SQGs
and
LQGs
are
actually
regulated
generators.
The
analysis
estimates
that
there
are
534
actual
SQGs
and
223
actual
LQGs.
The
total
number
of
original
user
generators
under
the
baseline
is
estimated
at
2,600
SQGs
and
284
LQGs.

A
list
of
the
number
of
SQG
and
LQG
original
users
by
two­
digit
SIC
code
under
the
Subtitle
C
baseline
and
the
proposed
rule
is
shown
in
Exhibit
3­
2.
Under
the
baseline
there
are
generators
in
66
different
two­
digit
SIC
codes.
Page
16
3.3.5
Number
of
Original
Users
and
Collectors
that
are
Regulated
Generators
Under
the
Primary
Alternative
Under
the
proposed
rule,
the
generators
under
the
baseline
that
send
their
monitors
to
glass
processors
or
reclaimers
are
no
longer
regulated
as
generators
of
hazardous
waste.
However,
the
baseline
generators,
whether
original
users
or
collectors,
that
continue
to
send
monitors
for
hazardous
waste
disposal
will
be
subject
to
full
RCRA
Subtitle
C
regulation
and
will
qualify
as
SQGs
or
LQGs
at
the
RCRA
thresholds
of
100
and
1,000
kilograms
of
CRTs
generated
per
month,
respectively.

The
analysis
assumes
that
two
percent
of
original
users
(both
SQGs
and
LQGs)
will
send
their
monitors
for
disposal
under
the
primary
alternative.
This
assumption
is
based
on
the
high
costs
associated
with
disposal
of
intact
CRTs
and
anecdotal
evidence
regarding
the
current
disposal
practices.
For
original
users
under
this
assumption,
there
are
286
SQGs,
25
LQGs,
and
2,573
former
generators
under
the
primary
alternative.
For
collectors,
the
analysis
assumes
that
80
percent
of
collectors
will
continue
to
send
at
least
one
shipment
per
year
for
disposal.
Thus
the
analysis
estimates
there
are
two
SQG
collectors,
ten
LQG
collectors,
and
288
former
generators
that
are
collectors
under
the
primary
alternative.

Exhibit
3­
2:
Original
User
Generators
Under
the
Baseline
by
2­
digit
SIC
Code
Industry
SIC
Code
Potential
SQG
Establishments
Potential
LQG
Establishments
Due
to
CRTs
Only
Due
to
Other
Haz.
Waste
Total
Due
to
CRTs
Only
Due
to
Other
Haz.
Waste
Total
AGRICULTURE
Agriculture
service
7
1
0
1
0
0
0
Forestry
8
2
0
2
0
0
0
MINING
Metal
mining
10
24
7
31
0
1
1
Coal
mining
12
21
6
27
0
1
1
Oil
&
gas
extraction
13
52
6
58
0
1
1
Non­
metallic
minerals,
except
fuels
14
5
1
6
0
0
0
Administrative
&
auxiliary
­
37
7
44
0
1
1
CONSTRUCTION
General
contractors
15
8
0
8
0
0
0
Heavy
construction
16
24
1
25
0
1
1
Special
trade
contractors
17
5
0
5
0
0
0
Administrative
&
auxiliary
­
0
1
1
0
0
0
MANUFACTURING
Food
&
kindred
products
20
178
139
317
3
13
16
Tobacco
products
21
10
9
19
1
2
3
Textile
mill
products
22
56
44
100
0
5
5
Industry
SIC
Code
Potential
SQG
Establishments
Potential
LQG
Establishments
Due
to
CRTs
Only
Due
to
Other
Haz.
Waste
Total
Due
to
CRTs
Only
Due
to
Other
Haz.
Waste
Total
Page
17
Apparel
&
other
textile
products
23
9
2
11
0
0
0
Lumber
&
wood
products
24
3
1
4
0
0
0
Furniture
&
Fixtures
25
30
18
48
0
6
6
Paper
&
allied
products
26
208
119
327
0
32
32
Printing
&
publishing
27
328
56
384
0
9
9
Chemicals
&
allied
products
28
297
192
489
4
159
163
Petroleum
and
coal
products
29
44
23
67
0
12
12
Rubber
&
misc.
plastics
products
30
225
122
347
0
38
38
Leather
&
leather
products
31
5
2
7
0
1
1
Stone,
Clay,
and
glass
products
32
22
8
30
0
2
2
Primary
metal
industries
33
72
221
293
5
150
155
Fabricated
metal
products
34
62
251
313
0
112
112
Industrial
machinery
&
equipment
35
483
123
606
7
19
26
Electronic
&
other
electronic
equipment
36
578
309
887
12
133
145
Transportation
equipment
37
459
202
661
51
100
151
Instrument
&
related
products
38
121
28
149
0
11
11
Miscellaneous
manufacturing
39
19
7
26
0
2
2
Administrative
&
Auxiliary
­
212
4
216
0
1
1
TRANSPORTATION
Local
&
Interurban
passenger
transit
41
7
5
12
1
1
2
Trucking
&
Warehousing
42
98
12
110
12
2
14
Water
transportation
44
16
4
20
0
0
0
Transportation
by
Air
45
78
15
93
20
5
25
Pipelines,
except
natural
gas
46
1
1
2
0
1
1
Communication
48
303
0
303
11
0
11
Electronic,
gas,
&
sanitary
services
49
255
81
336
4
55
59
Administrative
&
Auxiliary
­
43
3
46
5
1
6
WHOLESALE
Wholesale
trade­
durable
goods
50
168
6
174
0
0
0
Wholesale
trade­
nondurable
goods
51
213
7
220
0
3
3
Building
materials
&
garden
supplies
52
1
0
1
0
0
0
Administrative
&
Auxiliary
­
98
5
103
1
1
2
RETAIL
TRADE
Industry
SIC
Code
Potential
SQG
Establishments
Potential
LQG
Establishments
Due
to
CRTs
Only
Due
to
Other
Haz.
Waste
Total
Due
to
CRTs
Only
Due
to
Other
Haz.
Waste
Total
Page
18
General
merchandise
store
53
28
23
51
0
1
1
Food
stores
54
2
1
3
1
0
1
Auto
dealers
&
service
station
55
1
6
7
0
0
0
Apparel
&
accessory
stores
56
4
0
4
0
0
0
Furniture
&
home
furnishing
stores
57
2
0
2
0
0
0
Eating
&
drinking
places
58
6
0
6
0
0
0
Miscellaneous
retail
59
31
0
31
0
0
0
Administrative
&
Auxiliary
­
96
7
103
1
1
2
FINANCE,
INSURANCE,
AND
REAL
ESTATE
Depository
Institution
60
339
0
339
18
0
18
Nondepository
Institution
61
87
0
87
5
0
5
Security
&
commodity
brokers
62
86
0
86
5
0
5
Insurance
carriers
63
482
0
482
14
0
14
Insurance
agents,
brokers,
&
servicers
64
27
0
27
0
0
0
Real
Estate
65
74
0
74
0
0
0
Holding
&
other
investment
offices
67
37
0
37
3
0
3
Administrative
&
Auxiliary
­
23
6
29
0
1
1
SERVICES
Personal
services
72
6
1
7
0
0
0
Business
services
73
1,432
20
1,452
22
5
27
Auto
repair
services
&
parking
75
1
2
3
0
0
0
Miscellaneous
repair
services
76
2
0
2
0
0
0
Motion
picture
78
15
0
15
5
0
5
Amusement
&
recreation
services
79
69
1
70
3
0
3
Health
services
80
3,177
20
3,197
65
2
67
Legal
services
81
52
0
52
0
0
0
Educational
services
82
580
0
580
33
0
33
Social
Services
83
18
0
18
0
0
0
Museums,
botanical,
zoological
gardens
84
3
1
4
0
0
0
Membership
organization
86
83
0
83
6
0
6
Engineering
&
management
service
87
365
0
365
31
0
31
Services,
n.
e.
c
89
8
0
8
0
0
0
Administrative
&
Auxiliary
­
134
0
134
7
0
7
Industry
SIC
Code
Potential
SQG
Establishments
Potential
LQG
Establishments
Due
to
CRTs
Only
Due
to
Other
Haz.
Waste
Total
Due
to
CRTs
Only
Due
to
Other
Haz.
Waste
Total
15
See
telephone
interviews
with
Noranda
and
Doe
Run
in
Appendix
H.

Page
19
Total
Original
Users
Under
the
Baseline
12,151
2,136
14,287
356
891
1,247
Total
Number
of
Actual
Original
User
Generators
Under
the
Baseline
2,066
534
2,600
61
223
284
Total
Number
of
Actual
Original
User
Generators
Under
the
Primary
Alternative
286
SQGs
2,314
Not
Regulated
25
LQGs
259
Not
Regulated
Total
Number
of
Actual
Original
User
Generators
Under
the
CSI
Alternative
390
SQGs
2,452
SQHs
42
LQGs
0
LQHs
3.3.6
Number
of
Original
Users
and
Collectors
that
are
Regulated
Generators
Under
the
CSI
Alternative
Under
the
CSI
alternative,
the
original
user
generators
under
the
baseline
who
send
their
monitors
to
glass
processors
become
handlers.
However,
the
baseline
original
user
generators
that
continue
to
send
monitors
for
disposal
or
to
lead
smelters
will
be
subject
to
full
RCRA
Subtitle
C
regulation
and
will
qualify
as
SQGs
or
LQGs
at
the
RCRA
thresholds
of
100
and
1,000
kilograms
of
CRTs
generated
per
month
respectively.

The
threshold
for
SQGs
under
the
baseline
is
the
same
as
for
small
quantity
handlers
(SQH)
under
the
CSI
alternative.
However,
the
threshold
for
large
quantity
handler
(LQH)
status
is
much
higher.
For
a
handler
to
be
regulated
as
an
LQH
under
the
proposed
rule,
the
handler
must
store
36,287
kilograms
of
computer
monitors
(40
tons)
for
more
than
seven
days.
This
is
equivalent
to
2,281
monitors,
or
an
approximate
total
of
7,984
operating
monitors
on
site.

The
analysis
assumes
that
a
total
of
17
percent
of
generators
(both
SQGs
and
LQGs)
will
send
their
monitors
only
to
glass
processors
under
the
CSI
alternative.
This
assumption
is
based
on
the
fact
that
there
are
currently
only
several
processors
and
thus
transportation
costs
may
be
prohibitive
in
some
areas
of
the
country.
Also
smelters
are
likely
to
compete
on
price
to
obtain
discarded
monitors.
15
Lead
smelters,
in
particular,
value
tipping
fees
from
monitors
as
a
secondary
revenue
source.
The
primary
revenue
source
for
lead
smelters
is
the
sale
of
refined
lead.
These
factors
will
contribute
to
limiting
the
percentage
of
monitors
that
are
sent
for
glass­
to­
glass
recycling.
Under
the
CSI
alternative,
all
of
the
LQGs
sending
their
discarded
CRTs
to
processors
are
reclassified
as
SQHs
because
they
do
not
exceed
the
higher
threshold
for
LQHs.
Under
these
assumptions,
there
are
390
SQGs,
42
LQGs,
2,452
SQHs,
and
no
LQHs
under
the
CSI
alternative.

3.4
Flow
of
CRTs
from
Generators
to
Disposal
Sites
Under
the
Subtitle
C
Baseline
16
National
Safety
Council,
Electronic
Product
Recovery
and
Recycling
Baseline
Report,
Recycling
of
Selected
Electronic
Products
in
the
United
States.
May
1999.

Page
20
The
analysis
considers
the
flow
of
CRTs
from
original
users,
through
collectors,
reusers,
and
glass
processors,
and
on
to
treatment
and
disposal
destinations.
Exhibit
3­
3
presents
a
simplified
diagram
of
this
flow
under
the
Subtitle
C
baseline,
which
shows
how
CRTs
flow
from
original
users
to
the
final
CRT
management
options.
The
exhibit
shows
that
the
CRT
management
options
for
original
users
include
collectors,
establishments
that
reuse
CRTs,
hazardous
waste
treatment
and
disposal
facilities,
reclaimers,
and
glass
processors.
The
CRT
management
options
for
collectors
include
establishments
that
reuse
CRTs,
hazardous
waste
treatment
and
disposal
facilities,
reclaimers,
and
glass
processors.
The
CRT
management
options
for
glass
processors
include
reclaimers
and
CRT
glass
manufacturers.
The
actual
flows
modeled
for
this
baseline
are
presented
in
Exhibit
3­
4.

The
analysis
recognizes
that
either
of
the
two
regulatory
alternatives
will
provide
incentives
for
behavioral
changes
and
will
result
in
altered
flows.
Exhibit
3­
5
shows
the
flows
assumed
to
occur
under
the
primary
alternative.
It
reflects
all
CRTs
that
are
regulated
in
the
baseline,
even
though
many
of
them
will
be
unregulated
post­
rule.
Similarly,
Exhibit
3­
6
shows
the
flows
assumed
to
occur
under
the
CSI
alternative,
including
flows
to
and
from
the
"handlers"
that
will
be
unregulated
under
that
alternative.
These
three
exhibits
show
the
estimated
percentages
for
the
flow
of
CRTs
from
each
type
of
entity
to
each
of
the
various
CRT
management
options,
and
the
total
tons
of
CRTs
sent
from
each
type
of
entity.
Thus,
the
total
tons
of
CRTs
generated
multiplied
by
each
percentage
yields
the
tons
of
CRTs
sent
from
each
type
of
generator
to
each
CRT
management
option.
These
three
exhibits
also
show,
for
reference
purposes,
representative
disposal
costs
for
each
CRT
management
option
to
provide
an
indication
of
the
comparative
economic
advantage
of
sending
CRTs
to
each
CRT
management
option.

Collectors
and
glass
processors
are
only
intermediaries
in
the
flow
of
CRTs
towards
their
ultimate
disposal
endpoint.
Thus
all
of
the
CRTs
that
collectors
and
glass
processors
receive
are
expected
to
be
sent
to
other
entities.
Although
reuse
is
not
the
ultimate
disposal
endpoint
for
CRTs,
within
the
one
year
time
frame
of
this
analysis,
CRTs
that
are
sent
for
reuse
are
not
expected
to
be
discarded
again,
since
the
expected
lifetime
of
a
reused
CRT
is
two
to
four
years.
16
Exhibit
3­
3:
CRT
Life­
Cycle
Flow
Diagram
Page
21
August
24,
2001
­
DRAFT
Page
22
Exhibit
3­
4:
Assumed
Distribution
of
Discarded
Monitors
and
CRT
Glass
Under
the
Subtitle
C
Management
Baseline
Entity
Distributing
CRTs
Reuse
Export
Intermediate
Processors
Disposal
Options
Total
Percent
Total
Tons
Disposed
Collector
Glass
Processor
Hazardous
Waste
Facility
Reclaimer
CRT
Glass
Manufacturer
Disposal
Cost*
$0/
ton
(I)
$100/
ton
(I)
$271/
ton
(I)
$333/
ton
(I)
$0/
ton
(C)
$1,500/
ton
(I)
$160/
ton
(C)
$207/
ton
(I)
$152/
ton
(C)
­
$175/
ton
(C)

Original
User
SQGs
and
LQGs
Due
to
CRTs
Only
2%
(I)
0%
76%
(I)
5%
(I)
2%
(I)
15%
(I)
NA
100%
43,577
Due
to
CRTs
and
Non­
CRT
Hazardous
Waste
0%
(I)
0%
75%
(I)
0%
25%
(I)
0%
NA
100%
2,647
Collectors
SQGs
20%
(I)
30%
(I)
NA
25%
(B)
2%
(B)
23%
(B)
NA
100%
2,925
LQGs
20%
(I)
30%
(I)
NA
30%
(C)
10%
(C)
10%
(C)
NA
100%
32,178
Glass
Processors
0%
0%
NA
NA
0%
2%
(C)
98%
(C)
100%
7,358
Total
Tons
7,892
10,531
35,104
7,538
3,499
9,022
7,387
*
Disposal
costs
shown
are
representative
simplifications
of
the
actual
costs
used
in
the
analysis.
See
Exhibit
3­
10
for
further
details.
(I)
=
Intact
whole
monitors.
(B)
=
Bare
CRTs
without
the
casing.
(C)
=
Crushed
CRT
glass.
NA
=
Not
Applicable.
August
24,
2001
­
DRAFT
Page
23
Exhibit
3­
5:
Assumed
Distribution
of
Discarded
Monitors
Under
the
Primary
Alternative
Entity
Distributing
CRTs
Reuse
Export
Intermediate
Processors
Disposal
Options
Total
Percent
Total
Tons
Disposed
Collector
Glass
Processor
Hazardous
Waste
Facility
Reclaimer
CRT
Glass
Manufacturer
Disposal
Cost*
$0/
ton
(I)
$100/
ton
(I)
$271/
ton
(I)
$333/
ton
(I)
$0/
ton
(C)
$1,500/
ton
(I)
$160/
ton
(C)
$207/
ton
(I)
$152/
ton
(C)
­
$175/
ton
(C)

Original
Users
SQGs
and
LQGs
NA
NA
NA
NA
2%
(I)
NA
NA
100%
46,224
Former
SQGs
and
LQGs
2%
(I)
0%
76%
(I)
5%
(I)
NA
15%
(I)
NA
Collectors
Regulated
Post­
Rule
SQGs
20%
(I)
30%
(I)
NA
25%
(B)
2%
(B)
23%
(B)
NA
100%
59
LQGs
20%
(I)
18%
(I)
NA
45%
(C)
2%
(C)
15%
(C)
NA
100%
648
Unregulated
Post­
Rule
Former
SQGs
20%
(I)
30%
(I)
NA
25%
(B)
NA
25%
(B)
NA
100%
2,886
Former
LQGs
20%
(I)
18%
(I)
NA
45%
(C)
NA
17%
(C)
NA
100%
31,743
Glass
Processors
0%
0%
NA
NA
0%
2%
(C)
98%
(C)
100%
10,546
Total
Tons
7,973
6,714
35,335
10,546
931
10,743
10,335
*
Disposal
costs
shown
are
representative
simplifications
of
the
actual
costs
used
in
the
analysis.
See
Exhibit
3­
10
for
further
details.
(I)
=
Intact
whole
monitors.
(B)
=
Bare
CRTs
without
the
casing.
(C)
=
Crushed
CRT
glass.
NA
=
Not
Applicable.
August
24,
2001
­
DRAFT
Page
24
Exhibit
3­
6:
Assumed
Distribution
of
Discarded
Monitors
Under
the
CSI
Alternative
Entity
Distributing
CRTs
Reuse
Export
Intermediate
Processors
Disposal
Options
Total
Percent
Total
Tons
Disposed
Collector
Glass
Processor
Hazardous
Waste
Facility
Reclaimer
CRT
Glass
Manufacturer
Disposal
Cost*
$0/
ton
(I)
$100/
ton
(I)
$271/
ton
(I)
$333/
ton
(I)
$0/
ton
(C)
$1,500/
ton
(I)
$160/
ton
(C)
$207/
ton
(I)
$152/
ton
(C)
­
$175/
ton
(C)

Original
Users
SQGs
and
LQGs
NA
NA
NA
NA
15%
(I)
85%
(I)
NA
100%
6,926
Former
SQGs
and
LQGs
(SQHs
and
LQHs)
2%
(I)
0%
88%
(I)
10%
(I)
NA
NA
NA
100%
39,298
Collectors
SQGs
20%
(I)
30%
(I)
NA
25%
(B)
2%
(B)
23%
(B)
NA
100%
2,882
LQGs
20%
(I)
20%
(I)
NA
45%
(C)
2%
(C)
13%
(C)
NA
100%
31,701
Glass
Processors
0%
0%
NA
NA
0%
2%
(C)
98%
(C)
100%
11,349
Total
Tons
7,702
7,205
34,582
11,349
1,454
8,984
11,122
*
Disposal
costs
shown
are
representative
simplifications
of
the
actual
costs
used
in
the
analysis.
See
Exhibit
3­
10
for
further
details.
(I)
=
Intact
whole
monitors.
(B)
=
Bare
CRTs
without
the
casing.
(C)
=
Crushed
CRT
glass.
NA
=
Not
Applicable.
August
24,
2001
­
DRAFT
Page
25
Under
the
primary
alternative,
3,008
additional
tons
of
CRTs
are
sent
to
glass
processors
relative
to
the
Subtitle
C
baseline.
These
CRTs
are
re­
directed
primarily
from
hazardous
waste
facilities
(decrease
of
2,568
tons)
and
from
export
(decrease
of
3,817
tons)
under
the
baseline.
The
2,568
tons
of
CRTs
diverted
from
landfills
translates
to
a
volume
of
456,000
cubic
feet.
The
tons
of
CRTs
recycled
under
the
primary
alternative
increases
by
4,669
tons
over
the
baseline.

Under
the
CSI
alternative,
3,811
additional
tons
of
CRTs
are
sent
to
glass
processors
relative
to
the
Subtitle
C
baseline.
These
CRTs
would
go
to
hazardous
waste
facilities
(decrease
of
2,045
tons)
and
for
export
(decrease
of
3,326
tons)
under
the
baseline.
The
2,045
tons
of
CRTs
diverted
from
landfills
translates
to
a
volume
of
351,000
cubic
feet.
The
tons
of
CRTs
recycled
under
the
CSI
alternative
increases
by
3,697
tons
over
the
baseline.

Under
the
Subtitle
C
baseline,
generators
will
send
the
minimum
number
of
shipments
to
stay
in
compliance
with
hazardous
waste
accumulation
limits.
For
small
quantity
generators,
the
storage
limit
is
180
days;
these
establishments
will
make
two
shipments
per
year.
Large
quantity
generators
have
a
storage
limit
of
90
days;
they
will
make
four
shipments
per
year.
Collectors
are
assumed
to
handle
relatively
larger
volumes
of
CRTs
and
thus
are
assumed
to
ship
CRTs
when
they
have
full
loads
or
at
least
four
times
per
year
for
LQGs
and
two
times
a
year
for
SQGs.
On
average,
collectors
ship
CRTs
two
and
four
times
per
year,
respectively
for
SQGs
and
LQGs.
Glass
processors
are
also
assumed
to
handle
relatively
larger
volumes
of
CRTs
and
thus
are
assumed
to
ship
CRTs
when
they
have
full
loads
or
at
least
four
times
per
year.
On
average
glass
processors
ship
CRT
funnel
and
panel
glass
67
and
96
times
per
year
under
the
baseline
and
alternatives,
respectively.
Under
the
primary
and
CSI
alternatives,
each
former
generator
is
assumed
to
send
discarded
CRTs
off­
site
once
a
year
or
more
frequently
if
the
volume
of
CRTs
warrants
increased
shipment
frequency.

3.4.1
Disposal
Option
Assumptions
The
following
assumptions
are
used
to
develop
the
estimates
of
the
volume
of
discarded
monitors
being
sent
to
each
of
the
disposal
alternatives
(collectors,
reuse,
hazardous
waste
facilities,
reclaimers,
and
glass
processors):

Reuse.
The
analysis
assumes
that
two
percent
of
discarded
CRTs
from
original
users
are
sent
for
reuse
in
the
Subtitle
C
baseline,
and
that
this
percentage
remains
constant
under
the
primary
and
CSI
alternatives.
The
percentage
of
CRTs
sent
for
reuse
by
original
users
is
assumed
to
be
low
for
several
reasons.

C
Local
organizations
that
can
use
donated
computers
are
limited
in
number
and
need
for
computers.
Most
donated
computers
are
used
locally,
although
there
is
at
least
one
foundation
that
sends
donated
computers
worldwide
for
reuse.

C
Businesses
donating
computers
are
concerned
about
proprietary
information
that
may
be
left
on
hard
drives.
This
concern
reduces
the
number
of
computers
that
businesses
donate.
17
National
Safety
Council,
Electronic
Product
Recovery
and
Recycling
Baseline
Report,
Recycling
of
Selected
Electronic
Products
in
the
United
States.
May
1999.

August
24,
2001
­
DRAFT
Page
26
The
analysis
assumes
that
20
percent
of
discarded
CRTs
from
collectors
are
sent
for
reuse
under
the
Subtitle
C
baseline,
and
that
this
percentage
remains
constant
under
the
primary
and
CSI
alternative.
Collectors
obtain
a
higher
return
on
reused
monitors
than
they
do
on
disassembled
monitors
whose
parts
are
recycled.
Thus
collectors
have
a
strong
economic
incentive
to
resell
monitors
for
reuse.

Exports.
The
analysis
assumes
that
only
collectors
arrange
for
the
export
of
CRTs
and
that
only
intact
CRTs
are
exported.
Under
the
baseline,
collectors
are
assumed
to
export
30
percent
of
CRTs
they
receive.
The
literature
search
indicated
that
a
large,
but
unknown,
percentage
of
CRTs
are
exported.
17
Under
the
primary
alternative
collectors
who
are
SQGs
are
assumed
to
continue
to
export
30
percent
of
the
CRTs
they
receive,
while
LQGs
are
assumed
to
export
18
percent
of
the
CRTs
they
receive.
Collectors
who
are
LQGs
are
assumed
to
export
fewer
CRTs
under
the
primary
alternative
because
LQGs
have
a
greater
economic
incentive
to
send
CRTs
to
a
glass
processor
than
to
export
them.
Under
the
CSI
alternative
collectors
who
are
SQGs
are
assumed
to
continue
to
export
30
percent
of
the
CRTs
they
receive,
while
LQGs
are
assumed
to
export
20
percent
of
the
CRTs
they
receive.

Collectors.
Under
the
baseline,
the
analysis
assumes
that
76
percent
of
CRTs
from
original
users
are
sent
to
collectors.
CRTs
going
to
collectors
are
consolidated,
reused
when
possible,
demanufactured
and
recycled,
or
refurbished.
Although
collectors
are
not
the
least
expensive
disposal
option
they
become
an
economically
attractive
alternative
when
administrative
and
transportation
costs
are
considered.
Thus,
most
discarded
CRTs
are
assumed
to
be
sent
to
collectors.
There
are
two
factors
that
reduce
the
costs
of
sending
CRTs
to
collectors.
First,
collectors
are
typically
located
near
businesses,
and
thus
the
transportation
costs
are
comparatively
low.
Second,
CRTs
sent
to
collectors
are
considered
a
product
and
not
a
waste
and
thus
do
not
fall
under
RCRA
control.

The
collectors
typically
will
consolidate
the
CRTs
from
various
establishments
and
send
them
to
reclaimers
or
glass
processors.
The
collectors
demanufacture
the
monitors
and
recycle
the
components
that
have
value.
The
analysis
assumes
that
LQG
collectors
have
high
enough
volumes
of
CRTs
to
warrant
purchasing
glass
crushing
equipment.
Thus
all
shipments
of
CRTs
from
LQGs
to
glass
processors,
hazardous
waste
facilities,
and
reclaimers
are
assumed
to
be
crushed
CRT
glass,
which
has
economic
benefit.
The
baseline
assumes
that
30
percent
of
the
CRTs
the
LQG
collectors
receive
are
crushed
and
sent
to
glass
processors,
10
percent
are
crushed
and
sent
to
reclaimers,
and
10
percent
are
crushed
and
sent
to
hazardous
waste
facilities.
Crushing
the
CRTs
significantly
reduces
the
disposal
costs
charged
by
glass
processors,
reclaimers,
and
hazardous
waste
facilities.
More
CRTs
are
assumed
to
be
sent
to
glass
processors
because
the
low
disposal
cost
for
crushed
glass
at
glass
processors
often
18
Envirosafe
Services
of
Ohio
reported
receiving
no
CRTs
last
year
and
approximately
20
to
30
tons
the
previous
year.
Clean
Harbours
in
Massachusetts
reported
that
they
do
receive
CRTs,
however,
all
of
the
CRTs
they
receive
are
processed
in
Clean
Harbours
Bristol
Connecticut
recycling
facility
and
none
are
disposed.

August
24,
2001
­
DRAFT
Page
27
outweighs
the
higher
transportation
costs
due
to
longer
distances.
As
mentioned
above,
20
percent
of
the
regulated
CRTs
that
collectors
receive
are
refurbished
and
sold
for
reuse.
Thirty
percent
of
the
CRTs
received
by
collectors
are
assumed
to
be
exported
for
reuse
or
recycling.
Since
SQG
collectors
do
not
crush
the
CRT
glass
they
are
assumed
to
send
more
CRTs
to
reclaimers
than
to
hazardous
waste
facilities,
because
of
the
lower
tipping
fees
at
reclaimers.
Under
the
regulatory
alternatives
the
analysis
assumes
that
more
crushed
CRTs
are
sent
to
glass
processors
because
of
the
low
tipping
fees
and
absence
of
administrative
costs.
Similarly,
more
crushed
CRTs
are
assumed
to
be
sent
to
reclaimers
and
less
are
sent
to
hazardous
waste
facilities
because
of
the
administrative
burden
on
CRTs
sent
to
hazardous
waste
facilities.

Glass
Processors.
The
analysis
assumes
that
a
relatively
small
percentage
of
CRTs
from
original
users
are
sent
directly
to
glass
processors
because
of
the
higher
disposal
cost
for
intact
CRTs
and
the
relatively
longer
shipping
distances.
The
analysis
assumes
that
only
businesses
located
near
glass
processors
will
send
CRTs
directly
to
them.

Hazardous
Waste
Facilities.
The
analysis
assumes
that
original
users,
who
are
generators
due
to
CRTs
only,
will
send
two
percent
of
discarded
CRTs
to
hazardous
waste
facilities
in
the
Subtitle
C
baseline,
and
that
this
percentage
remains
at
two
percent
under
the
primary
alternative.
Under
the
CSI
alternative,
15
percent
of
CRTs
from
original
users
are
assumed
to
be
sent
to
hazardous
waste
facilities.
Although
the
percent
of
CRTs
sent
to
hazardous
waste
facilities
is
higher
under
the
CSI
alternative
than
the
baseline,
there
is
still
a
60
percent
reduction
in
the
number
of
CRTs
sent
to
hazardous
waste
facilities
due
to
the
smaller
number
of
generators
in
the
CSI
alternative.
Several
contacts
at
one
of
the
largest
Subtitle
C
facilities
in
the
United
States,
Chemical
Waste
Management,
reported
receiving
no
CRTs
during
1998.
Contacts
at
other
commercial
hazardous
waste
disposal
facilities
also
report
receiving
few
CRTs
for
disposal
over
the
last
couple
of
years.
18
However,
a
Tufts
University
study
reports
that
14
percent
of
CRTs
are
sent
to
landfills
or
municipal
waste
combustors.
The
Tufts
data
are
believed
to
include
monitors
from
households.
Households
are
more
likely
to
send
their
CRTs
to
landfills
than
are
RCRA
regulated
establishments
because
households
incur
no
direct
costs
to
send
monitors
to
Subtitle
D
landfills,
but
it
is
expensive
for
regulated
generators
to
send
monitors
for
treatment
and
disposal
in
Subtitle
C
or
D
landfills.
Sending
intact
CRTs
to
a
hazardous
waste
facility
is
more
expensive
than
sending
the
CRTs
to
lead
smelters
or
glass
processors.
Therefore,
most
CRTs
ending
up
at
hazardous
waste
facilities
are
probably
originating
in
areas
of
the
country
without
nearby
lead
smelters,
glass
processors,
or
collectors.

Reclaimers.
The
analysis
assumes
that
under
the
Subtitle
C
baseline,
15
percent
of
CRTs
from
original
users
are
sent
directly
to
reclaimers
and
that
this
percentage
remains
constant
under
the
19
Doe
Run
indicated
that
they
accept
whole
monitors.
The
article
by
Aanstoos,
T.,
Mizuki,
C.,
Nichols,
S.,
and
Pitts,
G.
CRT
Disposition:
An
Assessment
of
Limitations
and
Opportunities
in
Reuses,
Refurbishment,
and
Recycling
in
the
U.
S.
(page
75)
states
that
lead
smelters
accept
whole
monitors.

20
Conversation
with
Greg
Vorhees
of
Envirocycle,
April
25,
2001.

21
Sony
Trinitron
Color
Computer
Display
(manufactured
in
1998)
owners
manual.

22
Based
on
a
conversation
with
Chris
Beyus
of
Clean
Harbor.

August
24,
2001
­
DRAFT
Page
28
primary
alternative.
Lead
smelters
receive
monitors
from
original
users,
collectors,
and
glass
processors.
Most
reclaimed
CRTs
are
sent
to
lead
smelters;
however,
copper
smelters
also
accept
CRT
glass.
The
glass
is
used
as
a
fluxing
agent
in
the
smelting
furnaces.
Two
references
indicated
that
lead
smelters
take
whole
monitors,
crush
them,
and
then
add
the
crushed
monitor
to
the
smelting
furnace.
19
However,
Noranda
indicated
that
the
monitor's
plastic
casing
tends
to
foul
their
sulfuric
acid
plant,
so
they
only
accept
the
glass.
Copper
smelters
put
crushed
or
whole
monitors
into
the
smelting
furnace
to
recover
the
copper
from
the
electronics
and
use
the
glass
as
a
fluxing
agent.
Glass
processors
send
approximately
two
percent
of
the
glass
they
receive
to
reclaimers.
20
This
CRT
glass
is
in
the
form
of
fines
that
cannot
be
sent
to
CRT
glass
manufacturers.

CRT
Glass
Manufacturers.
Only
glass
processors
are
assumed
to
send
recycled
post
consumer
CRT
glass
to
CRT
glass
manufacturers.
Ninety­
eight
percent
of
the
CRT
glass
that
glass
processors
receive
is
sent
to
CRT
glass
manufacturers
because
of
the
quality
requirements
and
technical
specificaitons.

Monitor
Shipping
Size.
A
typical
15
inch
monitor
has
a
volume
of
1.5
cubic
feet.
21
Based
on
the
assumption
that
discarded
CRT
monitors
will
be
shipped
carefully
to
avoid
breakage
of
the
CRT
glass,
the
model
includes
the
assumption
that
the
monitors
will,
on
average,
occupy
3.0
cubic
feet
during
shipment.
22
This
includes
approximately
0.3
cubic
feet
per
monitor
for
the
actual
packing
material,
such
as
a
pallet
or
box.
Whole
monitors
or
whole
CRTs
are
placed
on
a
pallet
and
wrapped
in
plastic,
or
are
placed
in
one
cubic
yard
boxes
(Gaylord
containers)
to
minimize
breakage
and
to
contain
any
broken
glass
during
transport.

Truck
Capacity.
The
maximum
number
of
monitors
that
can
be
shipped
in
a
truck
by
volume
and
weight
is
calculated
to
determine
if
the
largest
individual
shipment
from
a
generator
or
handler
could
be
sent
in
one
truck
or
would
require
two
trucks.
A
truck
volume
of
4,280
cubic
feet
represents
the
volume
of
a
semi­
trailer
measuring
9.5
by
53
by
8.5
feet,
which
is
the
largest
standard
for
trailers.
A
truck
of
this
size
carries
up
to
1,426
monitors
(based
on
the
assumption
that
the
shipping
size
of
a
monitor
is
3.0
cubic
feet).
The
maximum
payload
for
standard
trucks
is
about
23
tons,
which
is
equivalent
to
1,314
thirty­
five
pound
monitors.
Thus
the
truck
weight
limit
is
the
limiting
factor.
The
maximum
number
of
CRTs
that
the
largest
establishments
are
August
24,
2001
­
DRAFT
Page
29
estimated
to
generate
in
one
year
is
2,082
(see
Exhibit
3­
1).
Thus
under
the
alternatives,
where
generators
can
accumulate
CRTs
up
to
one
year,
shipments
from
the
largest
generators
would
require
two
truckloads
per
year.
Under
the
baseline
it
is
assumed
that
all
SQGs
ship
twice
a
year
and
that
all
LQGs
ship
four
times
per
year.
Under
the
primary
alternative,
for
the
generators
that
now
send
CRTs
to
glass
processors
or
reclaimers
and
are
thus
eligible
for
regulatory
relief,
the
model
assumes
that
all
former
SQGs
and
former
LQGs
make
the
number
of
shipments
per
year
that
minimizes
the
total
of
their
administrative,
storage,
and
transportation
costs.
The
analysis
estimates
that
under
the
primary
alternative
former
SQGS
make
one
shipments
and
former
LQGs
make
two
shipments
per
year.

3.5
Estimate
Administrative
Compliance
Costs
This
section
describes
the
administrative
requirements
and
costs
applicable
to
two
groups
of
generators
(i.
e.,
generators
due
solely
to
CRTs
and
generators
due
to
non­
CRT
hazardous
wastes)
under
the
baseline
and
the
primary
and
CSI
alternatives.
Disposal
costs,
transportation
costs,
and
storage
costs
in
the
baseline
and
under
each
alternative
are
addressed
in
Sections
3.6,
3.7,
and
3.8,
respectively.

3.5.1
Baseline
Unit
Costs
for
Original
Users
(Generating
No
Non­
CRT
Hazardous
Waste)

The
analysis
models
the
current
management
of
discarded
CRTs
assuming
100
percent
compliance
with
RCRA
Subtitle
C
requirements
under
the
Subtitle
C
baseline.
Administrative
activities
required
under
Subtitle
C
and
the
associated
unit
costs
are
summarized
in
Exhibit
3­
7.

3.5.2
Baseline
Unit
Costs
for
Original
Users
Also
Generating
Non­
CRT
Hazardous
Waste
The
analysis
models
the
current
management
of
discarded
CRTs
assuming
100
percent
compliance
with
RCRA
Subtitle
C
requirements
under
the
Subtitle
C
baseline.
However,
most
of
the
administrative
costs
(all
but
manifests
for
shipments
of
CRTs
to
smelters
and
glass
processors
that
do
not
refurbish
CRTs)
are
assumed
to
be
due
to
non­
CRT
hazardous
waste
and
thus
are
not
included
in
the
analysis.
The
manifest
costs
that
are
assumed
to
be
due
to
CRTs
are
only
for
shipments
to
smelters
and
glass
processors
that
do
not
refurbish
CRTs
and
have
the
same
cost
as
contained
in
Exhibit
3­
7.

3.5.3
Primary
Alternative
The
full
Subtitle
C
administrative
requirements
are
eliminated
under
the
primary
alternative
for
entities
shipping
CRTs
to
collectors,
glass
processors,
and
lead
smelters.
The
activities
required
for
these
entities
are
only
packaging
and
labeling
requirements
for
CRTs
that
are
broken.
Generators
sending
CRT
waste
for
disposal
are
still
subject
to
full
RCRA
requirements.
August
24,
2001
­
DRAFT
Page
30
Administrative
activities
required
under
the
primary
alternative
and
the
associated
unit
costs
are
summarized
in
Exhibit
3­
8.

3.5.4
CSI
Alternative
Subtitle
C
administrative
requirements
are
significantly
reduced
under
the
CSI
alternative
for
entities
shipping
CRTs
to
glass
processors.
The
activities
required
for
these
handlers
are
the
same
types
of
activities
that
a
facility
incurs
under
the
Universal
Waste
Rule.
Generators
sending
CRT
waste
to
smelters
or
for
disposal
are
still
subject
to
full
RCRA
requirements.

Administrative
activities
required
under
the
CSI
alternative
and
the
associated
unit
costs
are
summarized
in
Exhibit
3­
9.

Exhibit
3­
7:
Generator
Administrative
Requirements
and
Unit
Costs
Under
the
Subtitle
C
Baseline
Required
Activity
Unit
Costs
SQG
LQG
One­
Time
Costs*
Notification
of
Hazardous
Waste
Activity
$218
$218
Rule
Familiarization
$477
$1,373
Emergency
Planning
$533
$787
Total
One­
Time
Costs
per
Facility
$1,228
$2,378
Annual
Costs
Annual
Review
of
Regulations
$91
$91
Recordkeeping
$47
$47
Personnel
Safety
Training
(annualized
cost)
$384
$482
Manifest
Training
$37
$180
Biennial
Reporting
(annualized
cost)
$0
$194
Total
Annual
Costs
per
Facility
$560
$994
Variable
Costs**
Manifest
and
Land
Disposal
Restriction
Notification
(per
shipment)
$44
$54
Exception
Reporting
(per
report)***
$44
$97
Storage
Costs
(per
square
foot
of
storage
area)
$8
$8
*
Each
year
one
percent
of
the
generators
are
assumed
to
be
new
facilities
and
thus
they
incur
additional
costs
as
startup
facilities.

The
entry
rate
is
used
to
determine
the
number
of
establishments
expected
to
incur
initial
costs
in
any
year
(one
percent
of
the
generator
universe).

**
Variable
costs
depend
on
the
number
of
shipments
made
by
a
generator.
The
number
of
shipments
per
year
is
calculated
and
used
to
estimate
the
administrative
costs.

***
The
analysis
uses
an
estimate
of
one
half
of
one
percent
of
manifests
require
an
exception
report.

Sources
of
Cost
Data:
Supporting
Statement
for
EPA
ICR
#
261
"Reporting
and
Recordkeeping
Requirements
for
Generators
of
Mercury­
Containing
Lamps"
June
29,
1994;
Supporting
Statement
for
ICR
#801
"Requirements
for
Generators,
Transporters,
&
August
24,
2001
­
DRAFT
Page
31
Waste
Management
Facilities
Under
the
RCRA
Hazardous
Waste
Manifest
System."
2/
13/
97;
Technical
Background
Document,

Economic
Impact
Analysis
for
the
Proposes
Rule
for
the
Management
of
Spent
Mercury­
Containing
Lamps.
1994;
and
Supporting
Statement
for
EPA
ICR
#
0976,
Amendment
to
OMB
ICR
#
2050­
0024
"Analysis
of
Costs
Under
Draft
Modifications
to
The
Manifest
System,
Final
Report,"
August
1,
1997.

Exhibit
3­
8:
Generator
Administrative
Requirements
and
Unit
Costs
Under
the
Primary
Alternative
Required
Activity
Unit
Costs
SQG
LQG
One­
Time
Costs*
Rule
Familiarization
$477
$477
Total
One­
Time
Costs
per
Facility
$477
$477
Annual
Costs
Total
Annual
Costs
per
Facility
$0
$0
Variable
Costs**
Labeling
and
Packaging
Requirements
for
Shipments
of
Broken
CRTs
$19
$37
Storage
Costs
(per
square
foot
of
storage
area)
$8
$8
*
Each
year
one
percent
of
the
generators
are
assumed
to
be
new
facilities
and
thus
they
incur
additional
costs
as
startup
facilities.

The
entry
rate
is
used
to
determine
the
number
of
establishments
expected
to
incur
initial
costs
in
any
year
(one
percent
of
the
generator
universe).

**
Variable
costs
depend
on
the
number
of
shipments
made
by
a
generator.
The
number
of
shipments
per
year
is
calculated
and
used
to
estimate
the
administrative
costs.

Sources
of
Cost
Data:
Supporting
Statement
for
EPA
ICR
#
261
"Reporting
and
Recordkeeping
Requirements
for
Generators
of
Mercury­
Containing
Lamps"
June
29,
1994;
Supporting
Statement
for
ICR
#801
"Requirements
for
Generators,
Transporters,
&

Waste
Management
Facilities
Under
the
RCRA
Hazardous
Waste
Manifest
System."
2/
13/
97;
Technical
Background
Document,

Economic
Impact
Analysis
for
the
Proposes
Rule
for
the
Management
of
Spent
Mercury­
Containing
Lamps.
1994;
and
Supporting
Statement
for
EPA
ICR
#
0976,
Amendment
to
OMB
ICR
#
2050­
0024
"Analysis
of
Costs
Under
Draft
Modifications
to
The
Manifest
System,
Final
Report,"
August
1,
1997.
Supporting
Statement
for
EPA
Information
Collection
Request
Number[]

"Reporting
and
Recordkeeping
Requirements
for
the
Proposed
Rule
on
Cathode
Ray
Tube
(CRT)
Glass
Reuse."
Working
Draft,

October
9,
1998.
August
24,
2001
­
DRAFT
Page
32
Exhibit
3­
9:
Handler
Administrative
Requirements
and
Unit
Costs
Under
the
CSI
Alternative
Required
Activity
Unit
Costs
SQH
LQH
One­
Time
Costs*
Notification
of
Hazardous
Waste
Activity
$0
$185
Rule
Familiarization
$477
$477
Total
One­
Time
Costs
per
Facility
$477
$662
Annual
Costs
Annual
Review
of
Regulations
$47
$47
Mark
CRT
Materials
or
Storage
Area
$27
$53
Mark
Time/
Date
on
CRT
Material
$27
$53
Total
Annual
Costs
per
Facility
$100
$154
Variable
Costs**
Recordkeeping
of
Outbound
Shipments
(per
shipment)
$0
$4
*
Each
year
one
percent
of
the
handlers
are
assumed
to
be
new
facilities
and
thus
they
incur
additional
costs
as
startup
facilities.
The
entry
rate
is
used
to
determine
the
number
of
establishments
expected
to
incur
initial
costs
in
any
year
(one
percent
of
the
handler
universe).

**
Variable
costs
depend
on
the
number
of
shipments
made
by
a
handler.
The
number
of
shipments
per
year
is
calculated
and
used
to
estimate
the
administrative
costs.

Source
of
Cost
Data:
Supporting
Statement
for
EPA
Information
Collection
Request
"Reporting
and
Recordkeeping
Requirements
for
the
Proposed
Rule
on
Cathode
Ray
Tube
(CRT)
Glass
Reuse,"
October
1998.

3.6
Estimate
Disposal
Costs
The
CRT
management
options
currently
being
used
by
CRT
generators
include
giving
CRTs
to
establishments
that
will
reuse
them,
and
sending
CRTs
to
collectors,
glass
processors,
smelters,
or
treatment
and
disposal
facilities
that
dispose
of
the
treated
CRTs
in
Subtitle
C
or
D
landfills.
The
per
ton
cost
for
each
disposal
option
is
based
on
a
literature
search
and
on
contacts
at
representative
facilities.
The
disposal
costs
obtained
for
each
disposal
option
varied
considerably.
The
maximum
cost
typically
is
two
to
four
times
the
minimum
cost
obtained
for
each
disposal
option.
For
each
disposal
option
the
average
of
the
costs
obtained
is
used
in
the
analysis.
Exhibit
3­
10
summarizes
the
cost
per
ton
for
each
disposal
option.
August
24,
2001
­
DRAFT
Page
33
Exhibit
3­
10:
CRT
Disposal
Costs
(per
ton)

Disposal
Option
Cost
(Price
Paid)
per
Ton
Collectors
$
271
Export
$
107
Reuse
$
0
Treatment
and
Subtitle
C
or
D
Landfill
Disposal
Whole
CRTs
$
1,500
Crushed
CRTs
$
160
Reclaimer
Whole
CRTs
$
295
Whole
bare
CRTs
$
207
Crushed
CRTs
$
152
Glass
Processor
Broken
CRTs
with
no
metal
$
0
Broken
CRTs
with
metal
$
100
Whole
bare
CRTs
$
192
Broken
mixed
color
and
monochrome
CRTs
$
325
Whole
CRTs
$
333
CRT
Glass
Manufacturer
($
175)

Details
of
the
disposal
costs
by
source
are
presented
in
Appendix
C.

3.7
Estimate
Transportation
Costs
Under
the
baseline
and
each
alternative,
either
hazardous
or
non­
hazardous
waste
transportation
costs
are
used
depending
on
the
status
of
the
CRTs
being
shipped.
Different
costs
are
also
used
for
shipments
that
are
assumed
to
be
partial
truckloads
and
full
truckloads.
Shipments
of
CRTs
from
collectors
and
glass
processors
are
assumed
to
be
full
truckloads,
except
for
collector
shipments
sending
CRTs
for
reuse.
Shipment
of
CRTs
for
reuse
are
assumed
to
be
partial
truckloads
for
three
reasons:

C
the
collectors
get
the
highest
benefit
from
returning
the
CRTs
to
the
market
place
as
quickly
as
possible,
and
thus
are
less
likely
to
wait
until
they
have
a
full
truckload.
August
24,
2001
­
DRAFT
Page
34
C
the
shipping
distances
for
reuse
are
likely
to
be
relatively
short,
because
most
CRTs
are
reused
locally,
thus
the
expense
of
sending
partial
loads
is
roughly
equivalent
to
sending
full
shipments.

C
collectors
who
primarily
refurbish
CRTs
for
reuse
tend
to
be
smaller
and
handle
smaller
volumes
and
thus
may
take
a
long
time
to
generate
a
full
truckload
of
CRTs
for
reuse.

Exhibit
3­
12
provides
a
summary
of
the
two
factors
(i.
e.,
hazardous
or
non­
hazardous
transport
and
partial
or
full
truckload)
that
drive
the
transportation
costs
for
each
of
the
disposal
options.
The
analysis
assumes
that
shipments
of
less
than
one
truckload
are
consolidated
by
the
shipping
company
prior
to
trucking
the
waste
CRTs
to
a
disposal
facility,
and
that
consolidated
rates
are
passed
on
to
generators.
The
analysis
assumes
consolidated
shipments
because
of
the
low
volumes
of
waste
(0.5
to
6
tons
for
original
users
and
9
to
16
tons
for
collectors
under
the
baseline)
and
because
generators
are
clustered
around
urban
and
suburban
areas.
As
discussed
in
Section
3.4,
regulated
generators
are
found
in
66
different
two­
digit
SIC
codes.
For
any
individual
generator
the
assumption
made
in
this
analysis
will
not
be
accurate.
However,
in
the
aggregate
the
assumptions
used
in
the
analysis
reasonably
estimate
the
actual
transportation
costs
incurred.

Exhibit
3­
12:
Transportation
Cost
Driver
Assumptions
CRT
Management
Options
Collectors
Reuse
Treatment
&

Disposal
Reclaimer
Glass
Processor
CRT
Glass
Manufacturer
Baseline
Original
Users
NH
­
LTT
NH
­
LTT
H
­
LTT
H
­
LTT
NH
­
LTT
NA
Collectors
NA
NH
­
LTT
H
­
TL
H
­
TL
H
­
TL
NA
Glass
Processors
NA
NA
NA
H
­
TL
NA
H
­
TL
Primary
Alternative
Original
Users
NH
­
LTT
NH
­
LTT
H
­
LTT
NH
­
LTT
NH
­
LTT
NA
Collectors
NA
NH
­
LTT
H
­
TL
NH
­
TL
NH
­
TL
NA
Glass
Processors
NA
NA
NA
NH
­
TL
NA
NH
­
TL
CSI
Alternative
Original
Users
NH
­
LTT
NH
­
LTT
H
­
LTT
H
­
LTT
NH
­
LTT
NA
Collectors
NA
NH
­
LTT
H
­
TL
H
­
TL
NH
­
TL
NA
Glass
Processors
NA
NA
NA
H
­
TL
NA
NH
­
TL
NH
=
Non­
hazardous
transport.

H
=
Hazardous
material
transport.

LTT
=
Less
than
truck
load
shipments.

TL
=
Full
truck
load
shipments.
23
The
cost
to
transport
CRTs
for
generators
due
to
non­
CRT
waste
is
estimated
to
be
less
than
$20
per
shipment.
This
estimate
is
based
on
the
per
ton­
mile
rate
of
$0.16,
250
miles
to
a
treatment
and
disposal
facility,
and
0.5
tons
of
CRTs
per
shipment.
The
actual
tons
shipped
by
these
generators
is
typically
less
than
0.5
tons.
There
are
approximately
800
establishments
in
this
category.
Thus
the
total
shipping
cost
is
approximately
$16,000,
or
less
than
one
half
of
one
percent
of
the
savings
under
the
primary
alternative.

August
24,
2001
­
DRAFT
Page
35
NA
=
Not
applicable.

The
transportation
costs
for
less
than
truck
load
shipments
consist
of
two
parts,
a
fixed
fee
and
a
variable
fee
based
on
tons
shipped
and
miles
driven.
The
variable
portion
of
the
per
shipment
transportation
cost
is
based
on
an
average
shipment
size
and
the
assumed
miles
that
the
CRTs
are
shipped
to
each
disposal
option.
For
SQGs
the
average
shipment
size
is
calculated
by
dividing
the
total
tons
of
CRTs
shipped
by
the
total
number
of
shipments.
The
total
number
of
shipments
is
calculated
by
assuming
that
each
SQG
ships
twice
a
year
and
multiplying
by
the
number
of
SQGs.
The
same
methodology
is
used
for
calculating
the
average
shipment
size
for
LQGs,
except
LQGs
ship
CRTs
four
times
per
year.
Under
the
regulatory
alternatives,
unregulated
establishments
are
assumed
to
ship
CRTs
once
per
year,
unless
they
generate
enough
CRTs
to
need
two
shipments.
Only
formerly
regulated
collectors
generate
enough
CRTs
to
need
two
shipments
per
year.
Glass
processors
are
estimated
to
make
23
shipments
of
funnel
glass
under
the
baseline,
32
shipments
under
the
primary
alternative,
and
34
shipments
under
the
CSI
alternative.
The
glass
processor
shipments
only
include
shipments
of
funnel
glass,
because
panel
glass
does
not
contain
enough
lead
to
render
it
hazardous
waste
when
discarded.
The
transportation
costs
for
full
truck
load
shipments
consists
of
a
variable
fee
based
on
the
miles
the
load
must
be
shipped.
Appendix
E
contains
the
average
shipment
sizes
for
each
type
of
entity
distributing
CRTs
to
each
of
the
management
options.
Exhibit
3­
13
presents
the
cost
functions
for
hazardous
waste
and
non­
hazardous
materials
for
both
less
than
truckload
and
full
truck
loads.
These
cost
functions
include
the
pre­
shipment
handling
and
administrative
costs
associated
with
each
shipment.
Exhibit
3­
14
presents
the
estimated
or
assumed
mileage
between
each
type
of
establishment
distributing
CRTs
and
the
CRT
management
options.

The
transportation
costs
to
collectors
and
disposal
facilities
for
generators
due
to
non­
CRT
hazardous
waste
are
zero
because
the
CRTs
are
assumed
to
be
shipped
with
the
generator's
other
hazardous
waste.
The
actual
cost
is
greater
than
zero
but
is
not
significant
to
the
analysis.
23
24
Conversation
with
Hagerstown
Transload
Services
on
February
9,
1999.

25
Conversation
with
American
Moving
and
Storage
on
February
9,
1999.

August
24,
2001
­
DRAFT
Page
36
Exhibit
3­
13:
Transportation
Cost
Functions
<
50
miles
50
to
400
miles
Hazardous
Non­
Hazardous
Hazardous
Non­
Hazardous
Full
Truck
Loads
NA
$3.41/
mile
$2.98/
mile
$2.25/
mile
Less
Than
Truck
Load
NA
$108
+
$0.18/
ton­
mile
$162
+
$0.16/
ton­
mile
$108
+
$0.12/
ton­
mile
Source:
ICF
Memorandum
to
Allen
Maples,
EPA,
August
31,
1998.

NA
=
Not
applicable.

Exhibit
3­
14:
Transportation
Distances
for
Each
CRT
Management
Option
(Miles)

CRT
Management
Options
Collectors
Reuse
Treatment
&
Disposal
Reclaimer
Glass
Processor
CRT
Glass
Manufacturer
Original
Users
20
20
250
300
200
NA
Collectors
NA
20
250
300
200
NA
Glass
Processors
NA
NA
NA
350
NA
100
NA
=
Not
applicable.

3.8
Estimate
Storage
Costs
Storage
costs
may
increase
for
former
generators
under
the
regulatory
alternatives
because
the
frequency
of
shipments
decreases
relative
to
shipments
by
generators.
This
section
contains
the
storage
costs
applicable
to
generators
and
former
generators.

Storage
costs
depend
on
several
assumptions
about
the
type
of
storage
facility
that
is
used
by
the
generator.
Some
generators
may
use
offsite
commercial
warehouse
space
which
generally
cost
three
to
four
dollars
per
square
foot
for
an
annual
rental,
plus
handling
fees
for
each
shipment
in
or
out
of
the
warehouse.
24
Other
generators
may
store
materials
in
self
storage
facilities
that
generally
cost
$12
to
$15
per
square
foot
per
year.
25
Finally
other
generators
may
have
on
site
storage
that
they
use.
The
on
site
storage
cost
can
be
considered
to
be
zero
if
space
is
available
and
the
building
space
is
considered
a
sunk
cost.
However,
for
some
generators
there
will
be
an
opportunity
cost
of
storing
the
26
The
storage
cost
of
eight
dollars
per
square
foot
is
an
assumed
average
cost
based
on
the
information
from
the
two
storage
companies
contacted,
Hagerstown
Transload
Services
and
American
Moving
and
Storage.

August
24,
2001
­
DRAFT
Page
37
CRTs.
In
this
case
the
storage
cost
is
the
cost
of
the
lease
or
rent
per
square
foot.
The
analysis
assumes
an
average
cost
of
eight
dollars
per
square
foot
per
year
for
storage.
26
The
model
assumes
that
each
CRT
will
occupy
three
cubic
feet
and
that
the
CRTs
will
be
stacked
up
to
eight
feet
high.
Exhibit
3­
15
summarizes
the
number
of
CRTs
stored
and
the
annual
storage
costs
for
each
type
of
generator.
August
24,
2001
­
DRAFT
Page
38
Exhibit
3­
15:
Storage
Costs
for
Monitors
Number
of
CRTs
Stored
Storage
Area
Required
(ft
2
)
Cost
per
Square
Foot
Annual
Storage
Cost
Generators
Due
to
CRTs
Alone
Baseline
SQG
84
31
$8.30
$261
LQG
319
119
$8.30
$991
Primary
Alternative
SQG
84
31
$8.30
$261
LQG
319
119
$8.30
$991
Former
SQG
168
63
$8.30
$522
Former
LQG
637
239
$8.30
$1,983
CSI
Alternative
SQG
84
31
$8.30
$261
LQG
319
119
$8.30
$991
SQH
170
64
$8.30
$529
LQH
NA
NA
NA
NA
Generators
Due
to
CRTs
and
Non­
CRT
Hazardous
Waste
Baseline
SQG
25
9
$8.30
$78
LQG
13
5
$8.30
$40
Primary
Alternative
SQG
25
9
$8.30
$78
LQG
13
5
$8.30
$40
Former
SQG
50
19
$8.30
$154
Former
LQG
51
19
$8.30
$159
CSI
Alternative
SQG
25
9
$8.30
$78
LQG
13
5
$8.30
$40
SQH
NA
NA
NA
NA
LQH
NA
NA
NA
NA
NA
=
Not
Applicable
27
ICF
Incorporated,
Economic
Impact
Analysis
for
the
Military
Munitions
Final
Rule,
June
1996.

August
24,
2001
­
DRAFT
Page
39
3.9
Estimate
Costs
for
Glass
Processors
and
Transporters
3.9.1
Costs
to
Glass
Processors
Only
a
small
number
of
dedicated
processors
exists
at
present.
The
analysis
estimates
there
are
five
glass
processors.
The
glass
reclamation
process
is
exempt
from
RCRA
Subtitle
C
regulation
(40
CFR
261.6(
c)(
1)).
However,
under
the
baseline
the
storage
of
CRTs
prior
to
reclamation
requires
a
RCRA
Part
B
Permit.
The
estimated
cost
for
obtaining
a
storage
permit
is
$13,300.
27
If
a
glass
processor
refurbishes
some
of
the
CRTs,
then
any
CRTs
sent
to
the
glass
processor
that
possibly
will
be
refurbished
are
not
a
solid
waste.
Exhibit
3­
16
shows
the
glass
processor
activities
required
under
the
baseline
and
regulatory
alternatives
and
the
associated
unit
costs.

3.9.2
Costs
to
CRT
Glass
Transporters
Current
CRT
transporters
are
assumed
to
transport
other
hazardous
wastes
and
other
nonhazardous
materials
and,
consequently,
do
not
incur
savings
under
the
proposed
rule.
To
the
extent
that
new
transporters
enter
the
CRT
market
that
do
not
transport
other
hazardous
wastes,
these
new
transporters
will
incur
minor
compliance
costs
attributable
to
reviewing
regulations.
The
analysis
does
not
attempt
to
quantify
the
costs
associated
with
new
transporters
shipping
CRTs
due
to
the
uncertainty
in
the
number
of
new
transporters
likely
to
enter
this
market
and
the
estimated
small
impact
on
the
overall
analytical
results.
August
24,
2001
­
DRAFT
Page
40
Exhibit
3­
16:
Glass
Processor
Compliance
Requirements
and
Unit
Costs
Required
Activity
Unit
Costs
Baseline
Primary
Alternative
CSI
Alternative
Initial
Fixed
Costs
Notification
of
Hazardous
Waste
Activity
$218
$218
$218
Rule
Familiarization
$1,373
$1,373
$1,373
Emergency
Planning
$787
$787
$787
Environmental
Justice
Requirements
$0
$0
$159
Total
Initial
Fixed
Costs
per
Facility
$2,378
$2,378
$2,537
Annual
Costs
Annual
Review
of
Regulations
$91
$91
$91
Recordkeeping
$47
$47
$47
Personnel
Safety
Training
(annualized
cost)
$482
$482
$482
Manifest
Training
$180
$180
$180
Biennial
Reporting
$194
$194
$194
Total
Annual
Costs
per
Facility
$994
$994
$994
Variable
Costs
Manifest
and
Land
Disposal
Restriction
Notification
(per
shipment)
$54
$0
$0
Recordkeeping
of
Incoming
Shipments
(per
shipment)
$0
$0
$4
Recordkeeping
of
Outbound
Shipments
(per
shipment)
$0
$0
$9
Source
of
Cost
Data:
Supporting
Statement
for
EPA
Information
Collection
Request
Number
[
]
"Reporting
and
Recordkeeping
Requirements
for
the
Proposed
Rule
on
Cathode
Ray
Tube
(CRT)
Glass
Reuse,"
October
1998;
and
Supporting
Statement
for
EPA
ICR
#
261
"Reporting
and
Recordkeeping
Requirements
for
Generators
of
Mercury­
Containing
Lamps"
June
29,
1994.

3.10
Estimate
the
Impact
of
Compliance
Costs
on
Affected
Entities
The
analysis
estimates
first­
order
economic
impacts
of
incremental
costs
by
calculating
the
cost­
to­
sales
ratio
for
each
type
of
original
user
in
each
two­
digit
SIC
code.
Census
data
for
the
year
1994
served
as
the
source
of
average
sales
data
for
establishments
in
each
two­
digit
SIC
code.
(Appendix
F
presents
the
average
sales
per
establishment
for
all
SIC
codes
used
in
the
calculations
for
this
report.)
Incremental
compliance
costs
or
cost
savings
for
representative
establishments
are
developed
by
adding
the
costs
as
described
previously.
For
purposes
of
this
analysis,
economic
impacts
are
considered
significant
if
costs
exceed
three
percent
of
sales.

The
impacts
analysis
is
likely
to
overstate
economic
impacts
(whether
costs
or
savings)
because
the
sales
data
used
in
the
analysis
represent
average
values
for
each
SIC
code
as
a
whole,
whereas
the
estimated
compliance
costs
arise
only
for
the
entities
that
are
large
enough
to
be
considered
an
SQG
or
August
24,
2001
­
DRAFT
Page
41
LQG
in
the
baseline.
Such
entities
are
likely
to
have
an
average
sales
value
higher
than
the
average
for
the
industry
as
a
whole.

3.11
Methodology
for
Subtitle
D
Management
Baseline
This
analysis
includes
a
Subtitle
D
management
baseline
because
it
may
more
accurately
represent
current
CRT
management
practices.
This
baseline
uses
the
same
methodology
and
assumptions
as
the
RCRA
Subtitle
C
baseline
except
for
three
changes
in
assumptions.
The
first
change
is
the
percentage
of
facilities
assumed
to
manage
CRTs
using
Subtitle
D
landfills.
The
second
change
is
the
assumed
flow
of
CRTs
to
each
of
the
disposal
options,
including
Subtitle
D
landfills.
The
third
change
is
that
estimated
costs
are
different
under
this
baseline.
One
similarity
between
the
baselines
is
the
percent
of
CRTs
recycled.
Although
the
number
of
tons
of
CRTs
sent
for
recycling
under
the
two
baselines
differs
by
about
a
factor
of
five,
the
percent
of
CRTs
sent
for
recycling
is
approximately
the
same
at
about
45
percent.

The
Subtitle
D
management
baseline
assumes
that
20
percent
of
facilities
are
managing
their
CRTs
as
Subtitle
C
waste
and
80
percent
of
facilities
are
managing
their
CRTs
as
Subtitle
D
waste.
The
20
percent
of
facilities
that
are
managing
their
CRTs
under
Subtitle
C
incur
all
of
the
administrative,
disposal,
transportation,
and
storage
costs
as
discussed
in
Sections
3.5
through
3.8.
Under
these
assumptions
in
the
baseline,
there
are
213
SQGs,
23
LQGs,
and
2,648
establishments
sending
CRTs
to
Subtitle
D
landfills
without
treatment.
The
primary
alternative
is
assumed
to
induce
some
establishments
sending
CRTs
to
Subtitle
D
landfills
to
send
their
CRTs
to
glass
processors
or
reclaimers.
Thus
under
the
primary
alternative,
there
are
58
SQGs,
5
LQGs,
155
former
SQGs,
18
former
LQGs,
and
2,648
establishments
sending
CRTs
to
Subtitle
D
landfills.
The
CSI
alternative
is
assumed
to
induce
some
establishments
sending
CRTs
to
Subtitle
D
landfills
to
send
their
CRTs
to
glass
processors.
Thus
under
the
CSI
alternative,
there
are
32
SQGs,
4
LQGs,
200
small
quantity
handlers
(CSI
SQHs),
and
2,648
establishments
sending
CRTs
to
Subtitle
D
landfills.
Exhibit
3­
17
contains
the
flow
assumptions
for
CRTs
under
the
Subtitle
D
management
baseline.
Exhibits
3­
18
and
3­
19
contain
the
flow
assumption
for
CRTs
under
the
primary
and
CSI
alternatives,
respectively.

The
cost
for
managing
CRTs
under
the
Subtitle
D
baseline
are
assumed
to
include
only
disposal
costs
of
$41
per
ton.
Thus,
facilities
managing
CRTs
under
the
Subtitle
D
baseline
have
no
administrative
costs,
no
storage
costs,
and
no
transportation
costs.
There
are
no
administrative
costs
because
these
facilities
will
not
prepare
manifests,
review
regulations
on
an
annual
basis,
or
conduct
any
of
the
other
activities
required
under
Subtitle
C
management.
The
storage
costs
are
assumed
to
be
zero
because
facilities
will
not
store
the
CRTs,
but
will
place
them
with
their
other
trash
as
soon
as
they
discard
the
CRTs.
The
transportation
costs
are
approximately
zero
because
facilities
will
place
the
CRTs
in
with
their
other
trash
and
not
ship
the
CRTs
separately.
An
incremental
transportation
cost
could
be
attributed
to
the
CRTs
based
on
the
weight
of
the
CRTs
and
the
hauling
charges
companies
pay
for
their
trash;
however,
the
analysis
assumes
that
any
incremental
transportation
cost
is
immaterial
to
the
results.
August
24,
2001
­
DRAFT
Page
42
Exhibit
3­
17:
Assumed
Distribution
of
Discarded
Monitors
and
CRT
Glass
Under
the
Subtitle
D
Management
Baseline
Entity
Distributing
CRTs
Reuse
Export
Intermediate
Processors
Disposal
Options
Total
Percent
Total
Tons
Disposed
Collector
Glass
Processor
Municipal
Solid
Waste
Landfill
Hazardous
Waste
Facility
Reclaimer
CRT
Glass
Manufacturer
Disposal
Cost
$0/
ton
(I)
$100/
ton
(I)
$271/
ton
(I)
$333/
ton
(I)
$0/
ton
(C)
$41/
ton
$1,500/
ton
(I)
$160/
ton
(C)
$207/
ton
(I)
$152/
ton
(C)
­
$175/
ton
(C)

Original
User
SQGs
and
LQGs*

Due
to
CRTs
Only
2%
(I)
0%
6%
(I)
5%
(I)
80%
(I)
2%
(I)
5%
(I)
NA
100%
43,577
Due
to
CRTs
and
Non­
CRT
Hazardous
Waste
0%
(I)
0%
10%
(I)
0%
80%
(I)
10%
(I)
0%
NA
100%
2,647
Collectors
SQGs
20%
(I)
20%
(I)
NA
5%
(I)
50%
(B)
0%
(B)
5%
(B)
NA
100%
240
LQGs
20%
(I)
20%
(I)
NA
10%
(C)
43%
(B)
2%
(C)
5%
(C)
NA
100%
2,639
Glass
Processors
0%
0%
NA
NA
0%
0%
2%
(C)
98%
(C)
100%
1,473
Total
Tons
1,447
576
2,879
1,473
38,234
1,168
2,295
1,443
*
Disposal
costs
shown
are
representative
simplifications
of
the
actual
costs
used
in
the
analysis.
See
3­
10
for
further
details.
(I)
=
Intact
whole
monitors.
(B)
=
Bare
CRTs
without
the
casing.
(C)
=
Crushed
CRT
glass.
NA
=
Not
Applicable.
August
24,
2001
­
DRAFT
Page
43
Exhibit
3­
18:
Assumed
Distribution
of
Discarded
Monitors
Under
the
Primary
Alternative
and
the
Subtitle
D
Baseline
Entity
Distributing
CRTs
Reuse
Export
Intermediate
Processors
Disposal
Options
Total
Percent
Total
Tons
Disposed
Collector
Glass
Processor
Municipal
Solid
Waste
Landfill
Hazardous
Waste
Facility
Reclaimer
CRT
Glass
Manufacturer
Disposal
Cost*
$0/
ton
(I)
$100/
ton
(I)
$271/
ton
(I)
$333/
ton
(I)
$0/
ton
(C)
$41/
ton
$1,500/
ton
(I)
$160/
ton
(C)
$207/
ton
(I)
$152/
ton
(C)
­
$175/
ton
(C)

Original
Users
SQGs
and
LQGs
NA
NA
NA
NA
NA
2%
(I)
NA
NA
100%
46,224
Former
SQGs
and
LQGs
2%
(I)
0%
10%
(I)
6%
(I)
NA
NA
7%
(I)
NA
Out
of
Compliance
SQGs
and
LQGs
NA
NA
NA
NA
75%
(I)
NA
NA
NA
Collectors
Regulated
Post­
Rule
SQGs
20%
(I)
30%
(I)
NA
10%
(B)
40%
(B)
2%
(B)
13%
(B)
NA
100%
8
LQGs
20%
(I)
18%
(I)
NA
15%
(C)
40%
(B)
2%
(C)
8%
(C)
NA
100%
83
Unregulated
Post­
Rule
Former
SQGs
20%
(I)
15%
(I)
NA
10%
(B)
40%
(B)
NA
15%
(B)
NA
100%
370
Former
LQGs
20%
(I)
15%
(I)
NA
15%
(C)
40%
(B)
NA
10%
(C)
NA
100%
4,070
Glass
Processors
0%
0%
NA
NA
0%
0%
2%
(C)
98%
(C)
100%
2,027
Total
Tons
1,812
680
4,530
2,027
35,788
923
3,494
1,987
*
Disposal
costs
shown
are
representative
simplifications
of
the
actual
costs
used
in
the
analysis.
See
3­
10
for
further
details.
(I)
=
Intact
whole
monitors.
(B)
=
Bare
CRTs
without
the
casing.
(C)
=
Crushed
CRT
glass.
NA
=
Not
Applicable.
August
24,
2001
­
DRAFT
Page
44
Exhibit
3­
19:
Assumed
Distribution
of
Discarded
Monitors
Under
the
CSI
Alternative
and
the
Subtitle
D
Baseline
Entity
Distributing
CRTs
Reuse
Export
Intermediate
Processors
Disposal
Options
Total
Percent
Total
Tons
Disposed
Collector
Glass
Processor
Municipal
Solid
Waste
Landfill
Hazardous
Waste
Facility
Reclaimer
CRT
Glass
Manufacturer
Disposal
Cost*
$0/
ton
(I)
$100/
ton
(I)
$271/
ton
(I)
$333/
ton
(I)
$0/
ton
(C)
$41/
ton
$1,500/
ton
(I)
$160/
ton
(C)
$207/
ton
(I)
$152/
ton
(C)
­
$175/
ton
(C)

Original
Users
SQGs
and
LQGs
NA
NA
NA
NA
60%
(I)
15%
(I)
25%
(I)
NA
100%
6,926
Former
SQGs
and
LQGs
(SQHs
and
LQHs)
2%
(I)
0%
(I)
10%
(I)
10%
(I)
NA
NA
NA
NA
22%
8,646
Out
of
Compliance
SQGs
and
LQGs
NA
NA
NA
NA
78%
NA
NA
NA
78%
30,652
Collectors
SQGs
20%
(I)
20%
(I)
NA
10%
(B)
38%
(B)
2%
(B)
10%
(B)
NA
100%
327
LQGs
20%
(I)
20%
(I)
NA
15%
(C)
38%
(B)
2%
(C)
5%
(C)
NA
100%
3,602
Glass
Processors
0%
0%
NA
NA
0%
0%
2%
(C)
98%
(C)
100%
2,702
Total
Tons
1,572
786
3,930
2,702
36,301
1,086
1,913
2,648
*
Disposal
costs
shown
are
representative
simplifications
of
the
actual
costs
used
in
the
analysis.
See
Exhibit
3­
10
for
further
details.
(I)
=
Intact
whole
monitors.
(B)
=
Bare
CRTs
without
the
casing.
(C)
=
Crushed
CRT
glass.
NA
=
Not
Applicable.
28
One
of
the
most
likely
industries
to
discard
a
significant
quantity
of
televisions
is
the
hotel
industry,
which
is
exempt
from
the
RCRA
hazardous
waste
requirements
(40
CFR
§261.4(
b)(
1)).

August
24,
2001
­
DRAFT
Page
45
3.12
Limitations
of
the
Methodology
and
Data
The
accuracy
of
the
analysis
depends
on
a
wide
variety
of
data
and
assumptions.
The
following
is
a
list
of
assumptions,
limitations,
and
other
factors
affecting
the
accuracy
of
the
analysis.
Some
assumptions
tend
to
increase
or
decrease
the
savings
of
the
alternatives,
as
noted
in
the
discussion
of
the
individual
assumptions.
Except
where
noted,
assumptions
are
best
estimates
and
are
not
believed
to
introduce
systematic
bias
into
the
results.

3.12.1
Assumptions
Life
Cycle
Flow
of
CRTs
C
The
assumed
percentages
of
CRTs
sent
from
generators
to
Subtitle
C
or
D
landfills,
smelters,
glass
processors,
collectors,
and
for
reuse
or
export.
Information
on
the
flow
of
CRTs
is
mostly
anecdotal.
See
Exhibits
3­
3,
3­
4,
3­
5,
3­
17,
3­
18,
and
3­
19
for
the
percentages
used
in
the
analysis.
In
developing
the
flow
percentages,
the
analysis
takes
into
consideration
the
stigma
of
hazardous
waste.

C
The
assumed
percentage
of
generators
that
are
no
longer
regulated
under
the
primary
or
CSI
alternatives.
Under
the
primary
alternative
98
percent
of
baseline
generators
are
assumed
to
no
longer
be
regulated.
Under
the
CSI
alternative
85
percent
of
generators,
who
are
original
users,
are
assumed
to
no
longer
be
regulated.
More
generators
become
unregulated
under
the
primary
alternative
because
CRTs
going
to
reclaimers
are
not
regulated.

C
The
number
of
CRTs
from
televisions
discarded
by
businesses
is
insignificant
compared
to
the
number
of
CRTs
from
monitors.
Available
data
on
television
use
in
businesses
are
not
adequate
to
incorporate
into
the
analysis.
The
number
of
televisions
used
in
businesses
is
believed
to
be
relatively
insignificant
compared
with
the
number
of
computer
monitors.
28
Eliminating
televisions
from
the
analysis
is
not
believed
to
significantly
affect
the
analysis,
although
this
assumption
could
change
if
business
use
of
televisions
increases
(e.
g.,
due
to
increases
in
televideo
conferencing).
This
assumption
may
result
in
the
reported
savings
of
the
alternatives
being
understated
because
the
total
number
of
CRTs
generated
is
underestimated.

C
Original
users
do
not
export
CRTs
directly.
Only
collectors
export
CRTs.

C
All
exports
of
CRTs
are
of
intact
CRTs
for
refurbishment
and
reuse.
August
24,
2001
­
DRAFT
Page
46
Monitor
Characteristics
C
The
lifetime
of
a
computer
monitor
in
businesses
is
assumed
to
be
3.5
years.

C
The
estimated
percentage
of
color
monitors
in
use
in
businesses
3.5
years
prior
to
the
modeled
year
is
90
percent.

C
The
assumed
percentage
of
laptop
computers
in
use
3.5
years
prior
to
the
modeled
year
is
18
percent.

C
The
estimated
average
weight
of
computer
monitors
being
discarded
in
the
modeled
year
is
35
pounds.

Transportation
C
The
assumed
transportation
costs
for
hazardous
waste
generators
that
are
generators
due
to
non­
CRT
hazardous
wastes.
These
generators
are
assumed
to
include
their
CRTs
in
regular
shipments
of
other
hazardous
waste
when
the
CRTs
are
sent
for
treatment
and
disposal
in
Subtitle
C
or
D
landfills.
Thus
the
cost
of
shipping
the
CRTs
to
these
disposal
options
is
only
an
incremental
cost
and
is
assumed
to
be
zero
in
the
analysis
for
both
the
baseline
and
regulatory
alternatives.
When
these
generators
send
CRTs
to
collectors,
smelters,
or
glass
processors
the
analysis
assumes
that
these
are
dedicated
shipments
and
the
generator
incurs
transportation
costs
under
both
the
baseline
and
regulatory
alternatives.
This
assumption
may
result
in
the
reported
savings
of
the
alternatives
being
underestimated
because
the
costs
of
shipping
CRTs
is
underestimated.

C
Under
the
baseline,
shipments
of
CRTs
are
transported
as
hazardous
waste
if
the
shipments
are
going
for
disposal,
to
lead
smelters,
or
to
glass
processors.
Under
the
primary
alternative,
shipments
of
CRTs
are
transported
as
hazardous
waste
only
if
the
shipments
are
going
for
disposal.
Under
the
CSI
alternative,
shipments
of
CRTs
are
transported
as
hazardous
waste
if
the
shipments
are
going
for
disposal
or
to
lead
smelters.

C
The
distances
to
each
of
the
CRT
management
options.
See
Exhibit
3­
14
for
the
transportation
distances
used
in
the
analysis.

Generators
C
The
assumed
distribution
of
SQGs
across
all
two­
digit
SIC
codes.
Existing
databases
do
not
track
the
SIC
codes
of
all
SQG
generators.
The
analysis
assumes
that
the
distribution
of
SQGs
across
SIC
codes
is
the
same
as
it
is
for
SQGs
that
are
August
24,
2001
­
DRAFT
Page
47
reported
in
the
Resource
Conservation
and
Recovery
Information
System
(RCRIS)
database.

C
The
assumed
distribution
of
SQGs
and
LQGs
across
establishment
size
ranges
within
a
two­
digit
SIC
code.
The
analysis
assumes
that
SQGs
are
1.5
times
and
LQGs
are
2
times
more
likely
to
have
250
or
more
employees
than
non­
generator
establishments.
This
is
based
on
the
presumption
that
larger
facilities
with
more
employees
are
more
likely
to
meet
the
thresholds
for
establishments
becoming
SQGs
or
LQGs.

C
The
assumed
cost
savings
for
generators
that
are
generators
due
solely
to
the
disposal
of
CRTs.
The
analysis
assumes
that
establishments
qualifying
as
generators
solely
due
to
CRTs
do
not
generate
any
other
hazardous
waste
and
thus
can
achieve
the
maximum
savings
possible
under
the
proposed
rule.
This
assumption
results
in
the
reported
savings
of
the
alternatives
being
overstated
because
the
total
number
of
these
generators
is
likely
to
be
overestimated.

C
Under
the
CSI
alternative,
all
collectors
will
send
some
CRTs
for
disposal
or
to
lead
smelters.
Therefore,
all
collectors
continue
to
be
fully
regulated
under
the
CSI
alternative.
This
assumption
results
in
the
reported
savings
of
the
CSI
alternative
being
understated
because
it
is
unlikely
that
all
collectors
will
continue
to
send
some
CRTs
for
disposal
or
to
a
lead
smelter.

C
Original
users
only
send
intact
CRTs.
This
assumption
results
in
the
reported
savings
of
the
alternatives
being
overstated
because
some
administrative
costs
are
avoided
by
generators
in
the
analysis.

C
Collectors
who
are
SQGs
send
bare
CRTs
that
have
had
the
casing
and
electronics
removed.

C
Collectors
who
are
LQGs
are
the
only
entities
sending
any
broken
CRTs
to
reclaimers,
hazardous
waste
facilities,
and
glass
processors.
This
assumption
results
in
the
reported
savings
of
the
alternatives
being
overstated
because
some
administrative
costs
are
avoided
by
SQGs
in
the
analysis.

C
One
half
of
all
collectors
are
assumed
to
send
CRTs
for
disposal
or
reclamation
and
thus
are
regulated
under
the
baseline.
The
other
half
of
the
collectors
are
assumed
to
send
CRTs
for
reuse,
export,
or
to
glass
processors
who
refurbish
CRTs.

C
The
number
of
CRTs
that
glass
processors
send
for
reuse
is
insignificant
compared
to
the
number
of
CRTs
that
are
processed
for
new
CRT
glass.
This
assumption
results
in
the
reported
savings
of
the
alternatives
being
understated
because
potential
savings
are
not
captured.
August
24,
2001
­
DRAFT
Page
48
C
Seventeen
percent
of
collectors
are
assumed
to
be
SQGs.
Collectors
who
are
SQGs
are
assumed
to
be
primarily
refurbishers
who
are
able
to
resell
most
CRTs
with
only
small
volumes
that
they
discard.
Collectors
who
are
LQGs
are
assumed
to
be
primarily
recyclers
who
need
to
recycle
large
volumes
of
CRTs
to
make
their
business
profitable.

C
Eight
percent
of
all
CRTs
are
received
by
collectors
who
are
SQGs.

C
The
analysis
models
the
flow
of
all
CRTs
discarded
by
original
users
in
amounts
exceeding
the
threshold
for
conditionally
exempt
small
quantity
generators
(more
than
100
kg
per
month),
even
though
many
of
these
original
users
are
not
regulated
(because
they
send
their
CRTs
to
collectors,
for
reuse,
or
to
glass
processors
that
refurbish
CRTs),
and
do
not
accrue
incremental
costs.
The
flow
of
CRTs
from
these
entities
is
modeled
in
order
to
calculate
incremental
costs
on
other
regulated
entities
(e.
g.,
collectors).

Disposal
Options
C
The
assumed
available
capacity
of
U.
S.
lead
smelters
to
take
discarded
CRTs.
The
analysis
assumes
that
all
U.
S.
lead
smelters
are
available
to
accept
discarded
CRTs,
storing
them
as
necessary.
The
actual
availability
of
smelters
might
be
less,
because
CRTs
are
shipped
as
a
hazardous
waste
and
smelters
who
store
CRTs
must
obtain
a
RCRA
Part
B
permit.
The
resources
needed
and
potential
compliance
consequences
of
obtaining
a
Part
B
permit
discourage
most
if
not
all
smelters
from
obtaining
the
permit,
thus
disqualifying
them
for
storing
CRTs.

C
The
analysis
assumes
that
lead
smelters
do
not
refurbish
CRTs
for
reuse.
Thus
under
the
baseline
all
shipments
of
CRTs
to
lead
smelters
are
regulated
shipments.
This
assumption
results
in
the
reported
savings
of
the
alternatives
being
overstated
because
it
tends
to
increase
the
difference
between
the
baseline
and
alternatives.

Storage
C
The
analysis
assumes
a
single
storage
cost
rate
($
8/
ft
2
)
for
all
facilities,
regardless
of
potentially
available
storage
alternatives.

C
Collectors
and
processors
are
not
allocated
storage
costs.
These
entities
are
not
allocated
storage
costs
because
their
storage
of
CRTs
is
not
driven
by
the
regulations
and
is
an
integral
part
of
their
primary
business.

3.12.2
Limitations
29
Monchamp,
A.,
Evans,
H.,
Nardone,
J.,
Wood,
S.,
Proch,
E.,
and
Wagner,
T.,
Cathode
Ray
Tube
Manufacturing
and
Recycling:
Analysis
of
Industry
Survey.
Electronics
Industries
Alliance,
May
2001.

August
24,
2001
­
DRAFT
Page
49
C
State
and
local
governments
and
their
discarded
CRTs
are
not
included
in
the
model.
This
assumption
results
in
the
reported
savings
of
the
alternatives
being
understated
because
the
total
number
of
generators
is
underestimated.

C
The
analysis
does
not
model
CRTs
coming
out
of
or
going
into
long­
term
storage.
Long­
term
storage
is
defined
as
more
than
one
year.

C
The
impacts
analysis
is
likely
to
overstate
economic
impacts
(whether
costs
or
savings)
because
the
sales
data
used
in
the
analysis
represent
average
values
for
each
SIC
code
as
a
whole,
whereas
the
estimated
compliance
costs
arise
only
for
the
entities
that
are
large
enough
to
be
considered
an
SQG
or
LQG
in
the
baseline.
Such
entities
are
likely
to
have
an
average
sales
value
higher
than
the
average
for
the
industry
as
a
whole.

3.12.3
Other
Factors
C
Consistent
with
least­
cost
behavior,
the
analysis
reflects
generators
of
non­
CRT
hazardous
wastes
only
to
the
extent
that
these
entities
generate
30
or
more
CRTs
per
year.
Generators
discarding
less
than
30
CRTs
per
year
are
assumed
in
the
baseline
to
consolidate
their
CRTs
shipments
with
shipments
of
other
hazardous
waste;
in
this
case,
the
transportation
cost
for
shipping
the
CRTs
is
only
an
incremental
cost
(i.
e.,
relative
to
the
cost
of
shipping
the
other
hazardous
wastes).
The
incremental
cost
for
shipping
less
than
30
CRTs
is
less
than
$18
per
shipment.
Under
the
two
regulatory
alternatives,
if
these
generators
were
to
ship
CRTs
to
glass
processors
or
reclaimers,
they
would
be
assumed
to
ship
the
CRTs
on
a
separate
truck,
thereby
incurring
a
significant
increase
in
transportation
costs
of
more
than
$100
per
shipment.
Given
the
increase
in
transportation
cost
and
the
low
volume
of
CRTs
(i.
e.,
less
than
30),
the
least
cost
behavior
for
these
hazardous
waste
generators
is
to
continue
consolidating
CRTs
with
other
hazardous
waste
shipments.
The
model
does
not
include
such
generators
whose
behavior
will
not
be
affected
by
the
alternatives.
The
sensitivity
analysis
in
Sections
4.2.4,
4.3.4,
5.2.4,
and
5.3.4
includes
the
CRTs
from
these
entities
as
well
as
from
CESQGs.

C
The
amount
of
CRT
glass
that
CRT
glass
manufacturers
can
recycle
is
a
potentially
limiting
factor
in
the
amount
of
CRTs
that
can
be
economically
recycled.
A
recent
study
estimates
that
CRT
glass
manufacturers
could
use
125,100
tons
of
postconsumer
cullet
using
the
current
sorting
technology.
29
If
better
sorting
technology
is
developed,
then
the
amount
the
CRT
glass
manufacturers
could
use
will
increase
to
at
30
The
Microelectronics
and
Computer
Technology
Corporation
(MCC),
page
231.

31
ICF
communication
with
Greg
Voorhees
of
Envirocycle,
2001.

32
ICF
communication
with
Greg
Voorhees
of
Envirocycle,
1996
and
2001,
and
Envirocycle
web
page.

August
24,
2001
­
DRAFT
Page
50
least
161,600
tons
per
year.
The
model
estimates
that
12
million
color
CRT
monitors
enter
the
waste
stream
each
year
from
all
businesses
(regulated
and
unregulated).
At
an
average
weight
of
35
pounds
per
CRT,
the
total
weight
of
color
CRT
monitors
entering
the
waste
stream
is
210,000
tons.
The
CRT
glass
constitutes
approximately
60
percent
of
the
CRT
weight;
so
the
total
amount
of
CRT
glass
entering
the
waste
stream
per
year
from
businesses
is
126,000
tons.
30
Thus,
all
post
consumer
CRT
glass
that
is
estimated
to
be
generated
by
all
businesses,
not
just
those
entities
considered
in
this
analysis,
could
be
used
by
CRT
glass
manufacturers.
The
amount
of
CRT
glass
currently
entering
the
waste
stream
from
regulated
establishments
is
estimated
at
below
44,000
tons.
Therefore,
it
does
not
appear
that
the
amount
of
glass
that
CRT
glass
manufacturers
can
accept
should
be
a
limiting
factor
in
CRT
glass­
to­
glass
recycling.

C
The
production
capacity
of
glass
processors
is
a
potentially
limiting
factor
in
the
amount
of
discarded
CRTs
that
can
be
recycled
each
year,
and
thus
is
a
limiting
factor
for
the
success
of
the
proposed
rule.
Currently
there
are
only
a
few
glass
processors.
The
largest
processor
is
Envirocycle,
with
an
estimated
production
capacity
of
45,000
tons
of
CRTs
per
year.
31
However,
the
estimated
total
amount
of
CRTs
generated
by
regulated
generators
is
43,750
tons
per
year.
Envirocycle
obtains
about
10,000
tons
of
CRTs
from
computer
monitor
and
television
manufacturers.
32
Thus,
Envirocycle
seems
unlikely
to
have
enough
current
capacity
to
process
all
CRTs
generated
by
regulated
entities.
Envirocycle
plans
to
open
two
new
processing
facilities
by
the
end
of
2001
that
will
add
additional
capacity.
Also,
the
capacity
of
the
second
glass
processor
is
likely
to
be
greater
than
8,750
tons
per
year.
Therefore,
the
production
capacity
of
glass
processors
is
not
likely
to
be
an
active
constraint
on
the
number
of
regulated
CRTs
that
could
be
recycled
each
year.

C
The
real­
world
conditions
that
are
approximated
in
the
analysis
are
likely
to
change
significantly
over
the
next
several
years.
For
example,
both
the
number
of
computers
used
in
businesses
and
the
percent
of
color
monitors
in
use
are
expected
to
increase
over
time,
which
would
increase
the
savings
under
the
proposed
rule.
On
the
other
hand,
trends
towards
greater
use
of
laptop
computers
and
other
flat
screen
monitors
may
eventually
lead
to
reduced
savings.

C
The
analysis
does
not
take
into
consideration
State
and
local
laws
that
prohibit
CRTs
from
being
disposed
in
municipal
solid
waste
landfills
and
incinerators
or
the
inclusion
of
August
24,
2001
­
DRAFT
Page
51
CRTs
in
various
State's
Part
273
regulations.
By
not
considering
such
information,
the
analysis
tends
to
overestimate
the
savings
accruing
to
each
regulatory
alternative.

4.0
Cost
Results
and
Sensitivity
Analysis
for
Subtitle
C
Management
Baseline
The
incremental
annual
savings
attributable
to
both
the
primary
alternative
and
the
CSI
alternative
are
calculated
by
subtracting
the
estimated
costs
under
each
alternative
from
the
estimated
costs
under
the
Subtitle
C
baseline.

4.1
Costs
Under
the
Subtitle
C
Baseline
The
total
applicable
cost
of
compliance
in
the
Subtitle
C
baseline
is
calculated
for
several
groups
of
affected
entities.
As
shown
in
Exhibit
4­
1,
the
analysis
categorizes
affected
entities
based
on
whether
they
are
original
users
or
collectors,
the
amount
of
waste
they
generate
(SQGs
or
LQGs),
and,
for
original
users,
whether
they
are
regulated
solely
because
of
CRT
generation
or
because
of
a
combination
of
CRT
and
non­
CRT
hazardous
waste
generation.
Collectors
are
all
assumed
to
be
regulated
solely
because
of
CRT
generation.
Compliance
costs
also
are
calculated
for
glass
processors.
Exhibit
4­
1
presents
the
cost
per
establishment
for
administrative,
storage,
transportation,
and
disposal
costs,
and
for
the
total
cost
of
compliance
under
the
baseline.
Administrative
costs
are
assumed
to
be
the
same
for
all
generators
in
each
size
category
(small
or
large).
The
other
costs
vary
across
the
categories
(based
on
RCRA
requirements
for
different
types
of
generators,
on
the
average
number
of
CRTs
discarded,
and
on
the
disposal
method
used
by
that
generator).
So
Exhibit
4­
1
presents
the
average
cost
for
each
group
of
generators.
August
24,
2001
­
DRAFT
Page
52
Exhibit
4­
1:
Subtitle
C
Baseline
Compliance
Costs
Average
Costs
per
Generator
Number
of
Regulated
Generators
Average
Costs
per
Potentially
Regulated
Generator
Number
of
Potentially
Regulated
Generators
Total
Cost
Admin.
Storage
Transp.
Disposal
Transp.
Disposal
Original
Users
(Generating
No
Non­
CRT
Hazardous
Waste)

SQG
$
660
$
261
$
270
$
870
2,066
$
270
$
870
10,085
$
15,763,000
LQG
$
1,234
$
991
$
739
$
6,616
61
$
739
$
6,616
295
$
2,754,000
Subtotal
$
18,517,000
Original
Users
Also
Generating
Non­
CRT
Hazardous
Waste
SQG
$
88
$
78
$
255
$
501
534
$
255
$
501
1,602
$
1,703,000
LQG
$
217
$
40
$
499
$
517
223
$
499
$
517
668
$
962,000
Subtotal
$
2,665,000
Collectors
SQG
$
668
$
0
$
828
$
3,370
50
$
828
$
3,370
50
$
453,000
LQG
$
1,232
$
0
$
1,554
$
3,989
250
$
1,554
$
3,989
250
$
3,080,000
Subtotal
$
3,533,000
Glass
Processors
$
2,316
$
0
$
6,754
$
(83,960)
5
N/
A
N/
A
N/
A
$
(374,000)

Total
Baseline
Compliance
Costs
$
24,342,000
Note:
Total
cost
numbers
rounded
to
nearest
thousand.
Costs
may
not
add
due
to
rounding.

4.2
Primary
Alternative
4.2.1
Costs
Under
the
Primary
Alternative
The
total
applicable
cost
of
compliance
under
the
primary
alternative
is
calculated
for
all
of
the
generators
described
in
Section
4.1,
and
for
all
of
the
entities
that
were
formerly
generators
but
that
no
longer
are
required
to
comply
with
the
hazardous
waste
regulations.
These
are
called
"former
generators."
Exhibit
4­
2
presents
the
cost
per
establishment
for
administrative,
storage,
transportation,
and
disposal
costs,
and
for
the
total
cost
of
compliance
under
the
primary
alternative.
Administrative
costs
are
assumed
to
be
the
same
for
all
generators
in
each
size
category
(small
or
large).
The
other
costs
vary
across
the
categories
(based
on
RCRA
requirements
for
different
types
of
generators,
on
the
average
number
of
CRTs
discarded,
and
on
the
CRT
management
method
used
by
that
generator).
So
Exhibit
4­
2
presents
the
average
cost
for
each
group
of
generators.

The
average
transportation
and
disposal
cost
for
SQGs
and
LQGs
changes
between
the
baseline
and
the
primary
alternative
because,
in
the
baseline,
five
CRT
management
options
(collector,
reuse,
processor,
smelter,
and
hazardous
waste
landfill)
are
available
while
in
the
primary
alternative
only
one
disposal
option
(hazardous
waste
landfill)
is
considered
for
regulated
generators
and
four
of
33
Assumes
a
six
year
monitor
life,
an
average
monitor
weight
of
30
pounds,
and
75
percent
of
discarded
monitors
are
color.

34
Assumes
a
two
year
monitor
life,
an
average
monitor
weight
of
41
pounds,
and
90
percent
of
discarded
monitors
are
color.

August
24,
2001
­
DRAFT
Page
53
the
CRT
management
options
are
available
(collector,
reuse,
processor,
and
smelter)
for
"former"
generators.
The
reason
for
the
changes
in
average
collector
costs
is
similar.
Under
the
baseline,
five
CRT
management
options
are
available
(reuse,
processor,
smelter,
hazardous
waste
landfill,
and
export).
Under
the
primary
alternative,
the
same
five
CRT
management
options
are
averaged
for
regulated
collectors,
while
"former"
collectors
have
only
four
CRT
management
options
(reuse,
processor,
smelter,
and
export).

Exhibit
4­
2:
Primary
Alternative
Compliance
Costs
Under
the
Subtitle
C
Baseline
Average
Costs
per
Generator
Number
of
Regulated
Generators
Average
Costs
per
Potentially
Regulated
Generator
Number
of
Potentially
Regulated
Generators
Total
Cost
Admin.
Storage
Transp.
Disposal
Transp.
Disposal
Original
Users
(Generating
No
Non­
CRT
Hazardous
Waste)

Former
SQG
$
0
$
522
$
136
$
798
1,823
$
136
$
798
10,085
$
12,078,000
Former
LQG
$
0
$
1,983
$
428
$
6,068
54
$
428
$
6,068
295
$
2,374,000
Subtotal
$
14,452,000
Original
Users
Also
Generating
Non­
CRT
Hazardous
Waste
Former
SQG
$
0
$
154
$
117
$
236
491
$
117
$
236
1,602
$
813,000
Former
LQG
$
0
$
159
$
117
$
243
205
$
117
$
243
668
$
347,000
Subtotal
$
1,160,000
Collectors
Former
SQG
$
0
$
0
$
558
$
3,436
48
$
558
$
3,436
50
$
391,000
Former
LQG
$
0
$
0
$
1,135
$
3,319
240
$
1,135
$
3,319
250
$
2,182,000
Subtotal
$
2,573,000
Total
Cost
to
Regulated
Generators
$
1,315,000
Total
Compliance
Costs
under
the
Primary
Alternative
$
19,502,000
Note:
Total
cost
numbers
rounded
to
nearest
thousand.
Costs
may
not
add
due
to
rounding.

4.2.2
Incremental
Cost
Difference
Between
the
Subtitle
C
Baseline
and
the
Primary
Alternative
The
primary
alternative
generates
a
net
savings
relative
to
the
baseline,
due
primarily
to
reduced
administrative
requirements
and
savings
from
reduced
transportation
and
disposal
costs.
Savings
from
the
primary
alternative
accrue
to
former
generators
that
would
no
longer
be
regulated.
The
range
of
potential
savings
under
the
primary
alternative
is
estimated
to
be
from
$2,401,000
33
to
$5,071,000,
34
35
Assumes
a
3.5
year
monitor
life,
an
average
monitor
weight
of
35
pounds,
and
90
percent
of
discarded
monitors
are
color.

August
24,
2001
­
DRAFT
Page
54
with
a
best
estimate
of
$4,840,000.
35
Exhibit
4­
3
summarizes
the
costs
under
the
baseline
and
the
primary
alternative
by
cost
category.

Exhibit
4­
3:
Costs
of
Primary
Alternative
Relative
to
Subtitle
C
Baseline
Cost
Category
Baseline
Primary
Alternative
Saving
(Cost)

Administrative
$
1,888,000
$
197,000
$
1,691,000
Disposal
$
16,373,000
$
15,128,000
$
1,245,000
Transportation
$
5,431,000
$
2,936,000
$
2,495,000
Storage
$
650,000
$
1,241,000
$
(591,000)

Total
$
24,342,000
$
19,502,000
$
4,840,000
Note:
Cost
numbers
rounded
to
nearest
thousand.
Costs
may
not
add
due
to
rounding.

4.2.3
Sensitivity
Analysis
for
the
Primary
Alternative
Individual
sensitivity
and
bounding
analysis
is
conducted
on
the
difference
between
the
Subtitle
C
baseline
and
the
primary
alternative
for
the
following
four
parameters:
monitor
weight,
monitor
lifetime,
storage
costs,
and
percent
of
monitors
that
are
color.
Appendix
G
lists
the
parameters
to
which
the
analysis
results
are
relatively
insensitive.
The
individual
sensitivity
analysis
is
conducted
by
changing
one
parameter
at
a
time
while
holding
all
other
parameters
at
their
best
estimate
value.
Exhibit
4­
4
contains
the
upper
and
lower
bounds
and
the
best
estimate
values
for
the
four
parameters
as
well
as
the
percent
change
of
the
lower
and
upper
bounds
from
the
best
estimate.
The
upper
and
lower
bounds
were
selected
because
they
represent
probable
limits
on
the
selected
parameters.
Exhibit
4­
5
contains
the
model
results
for
each
individual
change.
Exhibit
4­
6
plots
the
data
in
Exhibit
4­
5
from
the
individual
sensitivity
analysis
for
the
four
parameters.
The
graph
illustrates
that
the
analysis
is
most
sensitive
to
the
monitor
weight,
monitor
lifetime,
and
the
percent
of
color
monitors
discarded.
The
graph
also
indicates
that
the
model
results
are
not
linearly
related
with
respect
to
percent
color,
monitor
weight,
and
monitor
life,
since
the
lines
for
these
parameters
are
not
straight.
To
determine
a
potential
maximum
upper
bound
on
the
savings,
a
combined
sensitivity
analysis
is
conducted
using
a
monitor
weight
of
41
pounds,
a
monitor
lifetime
of
3.5
years,
the
percent
of
color
monitors
discarded
of
90
percent,
and
storage
cost
of
zero
dollars
per
square
foot.
The
savings
under
the
combined
sensitivity
analysis
is
$5,723,000.
August
24,
2001
­
DRAFT
Page
55
Exhibit
4­
4:
Parameter
Values
for
Individual
Sensitivity
Analysis
Lower
Bound
%
Change
from
Best
Estimate
Best
Estimate
Upper
Bound
%
Change
from
Best
Estimate
Monitor
Weight
30
lbs.
­14
%
35
lbs.
40
lbs.
14
%

Monitor
Life
2
years
­43
%
3.5
years
5
years
43
%

Storage
Cost
$
0
­100
%
$
8.30
$
15
81
%

Percent
Color
60
%
­33
%
90
%
99
%
10
%

Exhibit
4­
5:
Individual
Sensitivity
Analysis
Results
Lower
Bound
Best
Estimate
Upper
Bound
Monitor
Weight
$
4,326,000
$
4,840,000
$
5,091,000
Monitor
Life
$
4,753,000
$
4,840,000
$
3,934,000
Storage
Cost
$
5,431,000
$
4,840,000
$
4,364,000
Percent
Color
$
3,861,000
$
4,840,000
$
4,871,000
Numbers
rounded
to
nearest
thousand.

Sensitivity
analysis
is
also
conducted
for
disposal
costs
above
and
below
the
best
estimate
values.
By
changing
the
cost
for
disposal
to
a
hazardous
waste
landfill
to
$800
and
$1700
per
ton
for
whole
CRTs
(from
a
best
estimate
of
$1,500),
and
to
$50
and
$250
per
ton
for
crushed
CRTs
(from
a
best
estimate
of
$160),
the
savings
ranged
from
$5,141,000
to
$4,175,000.
By
changing
the
cost
for
disposal
to
a
reclaimer
to
$150
and
$500
per
ton
for
whole
CRTs
(from
a
best
estimate
of
$295),
to
$100
and
$300
per
ton
for
bare
CRTs
(from
a
best
estimate
of
$207),
and
to
$75
and
$250
per
ton
for
crushed
CRTs
(from
a
best
estimate
of
$152),
the
savings
ranged
from
$4,642,000
to
$4,990,000.
By
changing
the
cost
for
disposal
to
a
collector
to
$100
and
$350
per
ton
(from
a
best
estimate
of
$271),
the
savings
ranged
from
$4,821,000
to
$4,879,000.
The
sensitivity
analysis
on
disposal
costs
shows
that
the
model
is
moderately
sensitive
to
hazardous
waste
disposal
costs
and
only
slightly
sensitive
to
the
reclaimer
and
collector
disposal
costs.
36
The
number
of
televisions
disposed
of
is
based
on
the
assumption
that
there
are
100
million
households
each
with
two
televisions
and
that
the
TVs
are
discarded
after
ten
years.
The
20
million
TVs
discarded
is
also
consistent
with
the
number
of
televisions
sold
in
1991,
which
was
19.5
million.
The
number
of
computer
monitor
CRTs
disposed
of
is
based
on
data
from
the
August
24,
2001
­
DRAFT
Page
56
$3,500,000
$3,750,000
$4,000,000
$4,250,000
$4,500,000
$4,750,000
$5,000,000
$5,250,000
$5,500,000
­150%
­100%
­50%
0%
50%
100%

Percent
Change
from
Best
Estimate
Total
Cost
Savings
from
Baseline
($)

Monitor
Weight
Monitor
Life
Storage
Cost
Percent
Color
Exhibit
4­
6:
Plot
of
Individual
Sensitivity
Analysis
Results
for
the
Primary
Alternative
Note:
Lines
with
relatively
steeper
slopes
indicate
greater
sensitivity
of
the
results
to
changes
(or
uncertainty)
in
the
given
parameters.

4.2.4
Incremental
Cost
Difference
Between
the
Subtitle
C
Baseline
and
the
Primary
Alternative,
Including
Currently
Unregulated
Monitors
and
Televisions
To
help
understand
how
the
two
regulatory
alternatives
might
be
affected
by
capacity
issues,
the
total
cost
of
compliance
under
the
Subtitle
C
baseline
and
the
primary
alternative
is
calculated
including
CRTs
from
conditionally
exempt
small
quantity
generators
(CESQG)
and
households.
It
is
assumed
that
20
million
unregulated
television
CRTs
are
disposed
and
16.7
million
unregulated
computer
monitor
CRTs
are
disposed
from
households
and
CESQGs.
36
Exhibit
4­
7
contains
a
US
Census,
Survey
of
Computer
Use,
1997,
which
estimates
that
52
percent
of
households
have
computers.

August
24,
2001
­
DRAFT
Page
57
summary
of
the
costs
under
the
baseline
and
the
primary
alternative
by
cost
category.
Disposal
costs
are
higher
under
the
primary
alternative
than
the
baseline
because
it
is
assumed
that
a
greater
percentage
of
unregulated
CRTs
are
sent
to
collectors,
which
increases
the
number
of
CRTs
that
have
a
non­
zero
disposal
cost
under
the
primary
alternative.

Exhibit
4­
7:
Costs
of
Primary
Alternative
Relative
to
Subtitle
C
Baseline,
Including
Unregulated
Monitors
and
Televisions
Cost
Category
Baseline
Primary
Alternative
Saving
(Cost)

Administrative
$
1,984,000
$
197,000
$
1,787,000
Disposal
$
20,854,000
$
21,824,000
$
(970,000)

Transportation
$
6,790,000
$
5,893,000
$
897,000
Storage
$
650,000
$
1,241,000
$
(591,000)

Total
$
30,278,000
$
29,155,000
$
1,123,000
Note:
Cost
numbers
rounded
to
nearest
thousand.
Costs
may
not
add
due
to
rounding.

The
analysis
estimates
that
51,800
tons
of
CRT
glass
are
sent
to
glass
processors
and
that,
of
this,
50,700
tons
of
CRT
glass
are
sent
to
CRT
glass
manufacturers.
The
quantity
of
CRTs
sent
to
glass
processors
may
be
above
the
capacity
limit
for
glass
processors,
since
the
capacity
of
one
of
the
processors
is
not
precisely
known.
The
quantity
sent
to
CRT
glass
manufacturers
is
below
the
capacity
limits
for
CRT
glass
manufacturers.
As
the
CRT
recycling
infrastructure
grows
and
additional
unregulated
CRTs
are
recycled,
the
capacities
of
both
glass
processors
and
glass
manufacturers
will
be
exceeded.
This
analysis
does
not
attempt
to
predict
when
this
might
occur.

4.3
CSI
Alternative
4.3.1
Costs
Under
the
CSI
Alternative
The
total
applicable
cost
of
compliance
under
the
CSI
alternative
is
calculated
for
all
of
the
entities
described
in
Section
4.1,
and
for
all
of
the
entities
that
were
formerly
generators
but
that
no
longer
are
required
to
comply
with
the
hazardous
waste
regulations.
These
are
called
CSI
handlers.
Exhibit
4­
8
presents
the
cost
per
CSI
handler
for
administrative,
storage,
transportation,
and
disposal,
and
for
the
total
cost
of
compliance
under
the
CSI
alternative.
Administrative
costs
are
assumed
to
be
the
same
for
all
CSI
handlers
in
each
size
category
(small
or
large).
The
other
costs
vary
across
the
categories
(based
on
RCRA
requirements
for
different
types
of
generators,
on
the
average
number
of
37
Assumes
a
six
year
monitor
life,
an
average
monitor
weight
of
35
pounds,
and
75
percent
of
discarded
monitors
are
color.

38
Assumes
a
3.5
year
monitor
life,
an
average
monitor
weight
of
41
pounds,
and
89
percent
of
discarded
monitors
are
color.

August
24,
2001
­
DRAFT
Page
58
CRTs
discarded,
and
on
the
CRT
management
method
used
by
that
generator).
So
Exhibit
4­
8
presents
the
average
cost
for
CSI
handlers.

The
average
transportation
and
disposal
cost
for
SQGs
and
LQGs
changes
between
the
baseline
and
the
CSI
alternative
because,
in
the
baseline,
five
CRT
management
options
(collector,
reuse,
processor,
smelter,
and
hazardous
waste
landfill)
are
available
while
in
the
CSI
alternative
only
two
CRT
management
options
(lead
smelter
and
hazardous
waste
landfill)
are
available
for
regulated
generators,
and
only
three
of
the
CRT
management
options
are
available
(collector,
reuse,
and
processor)
for
CSI
handlers.

Exhibit
4­
8:
CSI
Alternative
Compliance
Costs
Under
the
Subtitle
C
Baseline
Average
Costs
per
Generator
Number
of
Regulated
Generators
Average
Costs
per
Potentially
Regulated
Generator
Number
of
Potentially
Regulated
Generators
Total
Cost
Admin.
Storage
Transp.
Disposal
Transp.
Disposal
CSI
Handlers
SQH
$
100
$
529
$
125
$
809
2,452
$
125
$
809
10,752
$
13,874,000
LQH
$
0
$
0
$
0
$
0
0
$
0
$
0
0
$
0
Subtota
l
$
13,874,000
Total
Cost
to
Regulated
Generators
7,371,000
Total
Compliance
Costs
under
the
CSI
Alternative
$
21,244,000
Note:
Total
cost
numbers
rounded
to
nearest
thousand.
Costs
may
not
add
due
to
rounding.

4.3.2
Incremental
Cost
Difference
Between
the
Subtitle
C
Baseline
and
the
CSI
Alternative
The
CSI
alternative
generates
a
net
savings
relative
to
the
baseline,
due
primarily
to
reduced
administrative
requirements
and
savings
from
reduced
transportation
and
disposal
costs.
Savings
from
the
CSI
alternative
accrue
to
CSI
handlers
that
would
no
longer
be
regulated.
The
range
of
potential
savings
under
the
CSI
alternative
is
estimated
to
be
from
$1,504,000
37
to
$3,402,000,
38
with
a
best
39
Assumes
a
3.5
year
monitor
life,
an
average
monitor
weight
of
35
pounds,
and
90
percent
of
discarded
monitors
are
color.

August
24,
2001
­
DRAFT
Page
59
estimate
of
$3,098,000.
39
Exhibit
4­
9
summarizes
the
costs
under
the
baseline
and
the
CSI
alternative
by
cost
category.

Exhibit
4­
9:
Costs
of
CSI
Alternative
Relative
to
Subtitle
C
Baseline
Cost
Category
Baseline
Primary
Alternative
Saving
(Cost)

Administrative
$
1,888,000
$
826,000
$
1,062,000
Disposal
$
16,373,000
$
15,356,000
$
1,017,000
Transportation
$
5,431,000
$
3,667,000
$
1,764,000
Storage
$
650,000
$
1,395,000
$
(745,000)

Total
$
24,342,000
$
21,244,000
$
3,098,000
Note:
Cost
numbers
rounded
to
nearest
thousand.
Costs
may
not
add
due
to
rounding.

4.3.3
Sensitivity
Analysis
for
the
CSI
Alternative
Individual
sensitivity
and
bounding
analysis
is
conducted
on
the
difference
between
the
Subtitle
C
baseline
and
the
CSI
alternative
for
the
following
four
parameters:
monitor
weight,
monitor
lifetime,
storage
costs,
and
percent
of
monitors
that
are
color.
Appendix
G
lists
the
parameters
to
which
the
analysis
results
are
relatively
insensitive.
The
individual
sensitivity
analysis
is
conducted
by
changing
one
parameter
at
a
time
while
holding
all
other
parameters
at
their
best
estimate
value.
Exhibit
4­
10
contains
the
upper
and
lower
bounds
and
the
best
estimate
values
for
the
four
parameters
as
well
as
the
percent
change
of
the
lower
and
upper
bounds
from
the
best
estimate.
The
upper
and
lower
bounds
were
selected
because
they
represent
probable
limits
on
the
selected
parameters.
Exhibit
4­
11
contains
the
model
results
for
each
individual
change.
Exhibit
4­
12
plots
the
data
in
Exhibit
4­
11
from
the
individual
sensitivity
analysis
for
the
four
parameters.
The
graph
illustrates
that
the
analysis
is
most
sensitive
to
the
monitor
weight,
monitor
lifetime,
and
the
percent
of
color
monitors
discarded.
The
graph
also
indicates
that
the
model
results
are
not
linearly
related
with
respect
to
percent
color,
monitor
weight,
and
monitor
life,
since
the
lines
for
these
parameters
are
not
straight.
To
determine
a
potential
maximum
upper
bound
on
the
savings,
a
combined
sensitivity
analysis
is
conducted
using
a
monitor
weight
of
35
pounds,
a
monitor
lifetime
of
2
years,
the
percent
of
color
monitors
discarded
of
99
percent,
and
storage
cost
of
zero
per
square
foot.
The
savings
under
the
combined
sensitivity
analysis
is
$4,221,000.
August
24,
2001
­
DRAFT
Page
60
Exhibit
4­
10:
Parameter
Values
for
Individual
Sensitivity
Analysis
Lower
Bound
%
Change
from
Best
Estimate
Best
Estimate
Upper
Bound
%
Change
from
Best
Estimate
Monitor
Weight
30
lbs.
­14
%
35
lbs.
40
lbs.
14
%

Monitor
Life
2
years
­43
%
3.5
years
5
years
43
%

Storage
Cost
$
0
­100
%
$
8.30
$
15
81
%

Percent
Color
60
%
­33
%
90
%
99
%
10
%

Exhibit
4­
11:
Individual
Sensitivity
Analysis
Results
Lower
Bound
Best
Estimate
Upper
Bound
Monitor
Weight
$
2,677,000
$
3,098,000
$
3,365,000
Monitor
Life
$
2,735,000
$
3,098,000
$
2,386,000
Storage
Cost
$
3,843,000
$
3,098,000
$2,496,000
Percent
Color
$
2,343,000
$
3,098,000
$3,157,000
Numbers
rounded
to
nearest
thousand.

Sensitivity
analysis
is
also
conducted
for
disposal
costs
above
and
below
the
best
estimate
values.
By
changing
the
cost
for
disposal
to
a
hazardous
waste
landfill
to
$800
and
$1700
per
ton
for
whole
CRTs
(from
a
best
estimate
of
$1,500),
and
to
$50
and
$250
per
ton
for
crushed
CRTs
(from
a
best
estimate
of
$160),
the
savings
ranged
from
$3,336,000
to
$2,580,000.
By
changing
the
cost
for
disposal
to
a
reclaimer
to
$150
and
$500
per
ton
for
whole
CRTs
(from
a
best
estimate
of
$295),
to
$100
and
$300
per
ton
for
bare
CRTs
(from
a
best
estimate
of
$207),
and
to
$75
and
$250
per
ton
for
crushed
CRTs
(from
a
best
estimate
of
$152),
the
savings
ranged
from
$3,171,000
to
$3,050,000.
By
changing
the
cost
for
disposal
to
a
collector
to
$100
and
$350
per
ton
(from
a
best
estimate
of
$271),
the
savings
ranged
from
$3,139,000
to
$3,008,000.
The
sensitivity
analysis
on
disposal
costs
shows
that
the
model
is
moderately
sensitive
to
hazardous
waste
disposal
costs
and
only
slightly
sensitive
to
the
reclaimer
and
collector
disposal
costs.
August
24,
2001
­
DRAFT
Page
61
$2,200,000
$2,400,000
$2,600,000
$2,800,000
$3,000,000
$3,200,000
$3,400,000
$3,600,000
$3,800,000
$4,000,000
­150%
­100%
­50%
0%
50%
100%

Percent
Change
from
Best
Estimate
Total
Cost
Savings
from
Baseline
($)

Monitor
Weight
Monitor
Life
Storage
Cost
Percent
Color
Exhibit
4­
12:
Plot
of
Individual
Sensitivity
Analysis
Results
for
the
CSI
Alternative
Note:
Lines
with
relatively
steeper
slopes
indicate
greater
sensitivity
of
the
results
to
changes
(or
uncertainty)
in
the
given
parameters.

4.3.4
Incremental
Cost
Difference
Between
the
Subtitle
C
Baseline
and
the
CSI
Alternative,
Including
Currently
Unregulated
Monitors
and
Televisions
To
help
understand
how
the
two
regulatory
alternatives
might
be
affected
by
capacity
issues,
the
total
cost
of
compliance
under
the
Subtitle
C
baseline
and
the
CSI
alternative
is
also
calculated
including
CRTs
from
households
and
CESQGs.
It
is
assumed
that
20
million
unregulated
television
CRTs
are
disposed
and
16.7
million
unregulated
computer
monitor
CRTs
are
disposed
from
40
The
number
of
televisions
disposed
of
is
based
on
the
assumption
that
there
are
100
million
households
each
with
two
televisions
and
that
the
TVs
are
discarded
after
ten
years.
The
20
million
TVs
discarded
is
also
consistent
with
the
number
of
televisions
sold
in
1991,
which
was
19.5
million.
The
number
of
computer
monitor
CRTs
disposed
of
is
based
on
data
from
the
US
Census,
Survey
of
Computer
Use,
1997,
which
estimates
that
52
percent
of
households
have
computers.

August
24,
2001
­
DRAFT
Page
62
households
and
CESQGs.
40
Exhibit
4­
13
contains
a
summary
of
the
costs
under
the
baseline
and
the
CSI
alternative
by
cost
category.

Exhibit
4­
13:
Costs
of
CSI
Alternative
Relative
to
Subtitle
C
Baseline,
Including
Unregulated
Monitors
and
Televisions
Cost
Category
Baseline
CSI
Alternative
Saving
(Cost)

Administrative
$
1,984,000
$
855,000
$
1,129,000
Disposal
$
20,854,000
$
18,834,000
$
2,020,000
Transportation
$
6,790,000
$
4,988,000
$
1,802,000
Storage
$
650,000
$
1,395,000
$
(745,000)

Total
$
30,278,000
$
26,072,000
$
4,206,000
The
analysis
estimates
that
32,000
tons
of
CRT
glass
is
sent
to
glass
processors
and
that,
of
this,
31,300
tons
of
CRT
glass
is
sent
to
CRT
glass
manufacturers.
These
quantities
are
below
the
capacity
limits
for
glass
processors
and
CRT
glass
manufacturers.
As
the
CRT
recycling
infrastructure
grows
and
additional
unregulated
CRTs
are
recycled,
the
capacities
of
both
glass
processors
and
glass
manufacturers
will
be
exceeded.
This
analysis
does
not
attempt
to
predict
when
this
might
occur.

5.0
Cost
Results
and
Sensitivity
Analysis
for
Subtitle
D
Management
Baseline
The
incremental
annual
savings
attributable
to
both
the
primary
alternative
and
the
CSI
alternative
are
calculated
by
subtracting
the
estimated
costs
under
each
alternative
from
the
estimated
costs
under
the
Subtitle
D
baseline.

5.1
Costs
Under
the
Subtitle
D
Baseline
The
total
applicable
cost
of
the
Subtitle
D
management
baseline
is
calculated
for
several
groups
of
entities.
As
shown
in
Exhibit
5­
1,
the
analysis
groups
affected
entities
based
on
whether
they
are
original
users
or
collectors,
the
amount
of
waste
they
generate
(SQGs
or
LQGs),
and,
for
original
users,
whether
they
are
regulated
solely
because
of
CRT
generation
or
because
of
a
combination
of
CRT
and
non­
CRT
hazardous
waste
generation.
Collectors
are
all
assumed
to
be
regulated
solely
August
24,
2001
­
DRAFT
Page
63
because
of
CRT
generation.
Compliance
costs
also
are
calculated
for
glass
processors.
Exhibit
5­
1
presents
the
cost
per
establishment
for
administrative,
storage,
transportation,
and
disposal,
and
for
the
total
cost
of
compliance
under
the
baseline.
Administrative
costs
are
assumed
to
be
the
same
for
all
generators
in
each
size
category
(small
or
large).
The
other
costs
vary
across
the
categories
(based
on
RCRA
requirements
for
different
types
of
generators,
on
the
average
number
of
CRTs
discarded,
and
on
the
disposal
method
used
by
that
generator).
So
Exhibit
5­
1
presents
the
average
cost
for
each
group
of
generators.
As
discussed
in
Section
3.11,
generators
sending
CRTs
to
Subtitle
D
landfills
only
incur
a
disposal
cost.

Exhibit
5­
1:
Subtitle
D
Baseline
Compliance
Costs
Average
Costs
per
Generator
Number
of
Regulate
d
Generator
s
Average
Costs
per
Potentially
Regulated
Generator
Number
of
Potentiall
y
Regulate
d
Generator
s
Total
Cost
Admin.
Storag
e
Transp
.
Disposal
Except
Subtitle
D
Subtitle
D
Disposal
Transp.
Disposal
Except
Subtitle
D
Subtitle
D
Disposal
Original
Users
(Generating
No
Non­
CRT
Hazardous
Waste)

SQG
$
663
$
1,304
$
120
$
1,139
$
485
170
$
120
$
1,139
$
485
2,260
$
4,571,000
LQG
$
1,327
$
3,314
$
682
$
8,681
$
3,696
5
$
682
$
8,681
$
3,696
66
$
950,000
Subtota
l
$
5,521,000
Original
Users
Also
Generating
Non­
CRT
Hazardous
Waste
SQG
$
87
$
386
$
73
$
768
$
143
43
$
73
$
768
$
143
384
$
441,000
LQG
$
325
$
134
$
182
$
792
$
148
18
$
182
$
792
$
148
160
$
208,000
Subtota
l
$
649,000
Collectors
SQG
$
647
$
0
$
234
$
95
$
50
10
$
234
$
95
$
50
90
$
44,000
LQG
$
1,290
$
0
$
630
$
166
$
94
85
$
630
$
166
$
94
415
$
554,000
Subtota
l
$
598,000
Glass
Processors
$
1,284
$
0
$
1,542
$
(16,405)
N/
A
5
N/
A
N/
A
N/
A
N/
A
$
(68,000)

Total
Baseline
Compliance
Costs
$
6,700,000
Note:
Total
cost
numbers
rounded
to
nearest
thousand.
Costs
may
not
add
due
to
rounding.

5.2
Primary
Alternative
5.2.1
Costs
Under
the
Primary
Alternative
August
24,
2001
­
DRAFT
Page
64
The
total
applicable
cost
of
compliance
under
the
primary
alternative
is
calculated
for
all
of
the
entities
described
in
Section
5.1,
and
for
all
of
the
entities
that
were
formerly
generators
but
that
no
longer
are
required
to
comply
with
the
hazardous
waste
regulations.
These
are
called
"former
generators."
Exhibit
5­
2
presents
the
cost
per
establishment
for
administrative,
storage,
transportation,
and
disposal,
and
for
the
total
cost
of
compliance
under
the
primary
alternative.
Administrative
costs
are
assumed
to
be
the
same
for
all
generators
in
each
size
category
(small
or
large).
The
other
costs
vary
across
the
categories
(based
on
RCRA
requirements
for
different
types
of
generators,
on
the
average
number
of
CRTs
discarded,
and
on
the
disposal
method
used
by
that
generator).
So
Exhibit
5­
2
presents
the
average
cost
for
each
group
of
generators.
As
discussed
in
section
3.11,
generators
sending
CRTs
to
Subtitle
D
landfills
only
incur
a
disposal
cost.

The
average
transportation
and
disposal
cost
for
SQGs
and
LQGs
changes
between
the
baseline
and
the
primary
alternative
because,
in
the
baseline,
six
CRT
management
options
(collector,
reuse,
processor,
smelter,
hazardous
waste
landfill,
and
municipal
landfill)
are
available
while
in
the
primary
alternative
only
one
disposal
option
(hazardous
waste
landfill)
is
available
for
regulated
generators
and
five
of
the
CRT
management
options
are
available
(collector,
reuse,
processor,
smelter,
hazardous
waste
landfill,
and
municipal
landfill)
for
former
generators.
The
reason
for
the
changes
in
average
collector
costs
is
similar.
Under
the
baseline,
six
CRT
management
options
are
available
(reuse,
processor,
smelter,
hazardous
waste
landfill,
municipal
landfill,
and
export).
Under
the
primary
alternative,
the
same
six
CRT
management
options
are
available
for
regulated
collectors,
while
former
generators
have
five
CRT
management
options
(reuse,
municipal
landfill,
processor,
smelter,
and
export).
41
Assumes
a
two
year
monitor
life,
an
average
monitor
weight
of
40
pounds,
and
95
percent
of
discarded
monitors
are
color.

August
24,
2001
­
DRAFT
Page
65
Exhibit
5­
2:
Primary
Alternative
Compliance
Costs
Under
the
Subtitle
D
Baseline
Average
Costs
per
Generator
Number
of
Regulate
d
Generator
s
Average
Costs
per
Potentially
Regulated
Generator
Number
of
Potentiall
y
Regulate
d
Generator
s
Total
Cost
Admin.
Storag
e
Trans
p.
Disposal
Except
Subtitle
D
Subtitle
D
Dispos
al
Transp
.
Disposal
Except
Subtitle
D
Subtitle
D
Disposal
Original
Users
(Generating
No
Non­
CRT
Hazardous
Waste)

Former
SQG
$
0
$
1,304
$
119
$
993
$
455
121
$
119
$
993
$
455
2,260
$
3,888,000
Former
LQG
$
0
$
3,295
$
654
$
7,527
$
3,445
4
$
654
$
7,527
$
3,445
66
$
827,000
Subtotal
$
4,715,000
Original
Users
Also
Generating
Non­
CRT
Hazardous
Waste
Former
SQG
$
0
$
772
$
47
$
294
$
134
34
$
47
$
294
$
134
384
$
225,000
Former
LQG
$
0
$
798
$
48
$
304
$
139
14
$
48
$
304
$
139
160
$
97,000
Subtotal
$
322,000
Collectors
Former
SQG
$
0
$
0
$
94
$
199
$
62
8
$
94
$
199
$
62
90
$
35,000
Former
LQG
$
0
$
0
$
120
$
255
$
137
75
$
120
$
255
$
137
415
$
251,000
Subtotal
$
286,000
Total
Cost
to
Regulated
Generators
$
1,484,000
Total
Compliance
Costs
under
the
Primary
Alternative
$
6,806,000
Note:
Total
cost
numbers
rounded
to
nearest
thousand.
Costs
may
not
add
due
to
rounding.

5.2.2
Incremental
Cost
Difference
Between
the
Subtitle
D
Baseline
and
the
Primary
Alternative
The
primary
alternative
generates
a
net
savings
relative
to
the
baseline,
due
primarily
to
reduced
administrative
requirements
and
savings
from
reduced
transportation
and
disposal
costs.
Savings
from
the
primary
alternative
accrue
to
former
generators
that
would
no
longer
be
regulated.
The
range
of
potential
savings
under
the
primary
alternative
is
estimated
to
be
from
a
net
cost
of
1,301,000
41
to
a
net
42
Assumes
a
six
year
monitor
life,
an
average
monitor
weight
of
30
pounds,
and
75
percent
of
discarded
monitors
are
color.

43
Assumes
a
three
and
one
half
year
monitor
life,
an
average
monitor
weight
of
35
pounds,
and
90
percent
of
discarded
monitors
are
color.

August
24,
2001
­
DRAFT
Page
66
savings
of
$291,000,
42
with
a
best
estimate
of
a
cost
of
$106,000.
43
Exhibit
5­
3
summarizes
the
costs
under
the
baseline
and
the
primary
alternative
by
cost
category.

Exhibit
5­
3:
Costs
of
Primary
Alternative
Relative
to
Subtitle
D
Baseline
Cost
Category
Baseline
Primary
Alternative
Saving
(Cost)

Administrative
$
251,000
$
56,000
$
195,000
Disposal
Except
Subtitle
D
$
3,863,000
$
4,485,000
$
(622,000)

Subtitle
D
Disposal
$
1,580,000
$
1,479,000
$
101,000
Transportation
$
749,000
$
507,000
$
(242,000)

Storage
$
257,000
$
279,000
$
22,000
Total
$
6,700,000
$
6,806,000
$
106,000
Note:
Cost
numbers
rounded
to
nearest
thousand.
Costs
may
not
add
due
to
rounding.

5.2.3
Sensitivity
Analysis
for
the
Primary
Alternative
Individual
sensitivity
and
bounding
analysis
is
conducted
on
the
difference
between
the
Subtitle
D
baseline
and
the
primary
alternative
for
the
following
four
parameters:
monitor
weight,
monitor
lifetime,
storage
costs,
and
percent
of
monitors
that
are
color.
The
individual
sensitivity
analysis
is
conducted
by
changing
one
parameter
at
a
time
while
holding
all
other
parameters
at
their
best
estimate
value.
Exhibit
5­
4
contains
the
upper
and
lower
bounds
and
the
best
estimate
values
for
the
four
parameters
as
well
as
the
percent
change
of
the
lower
and
upper
bounds
from
the
best
estimate.
The
upper
and
lower
bounds
were
selected
because
they
represent
probable
limits
on
the
selected
parameters.
Exhibit
5­
5
contains
the
model
results
for
each
individual
change.
Exhibit
5­
6
plots
the
data
in
Exhibit
5­
5
from
the
individual
sensitivity
analysis
for
the
four
parameters.
The
graph
illustrates
that
the
analysis
is
most
sensitive
to
the
monitor
weight,
monitor
lifetime,
and
the
percent
of
color
monitors
discarded.
To
determine
a
potential
maximum
upper
bound
on
the
savings,
a
combined
sensitivity
analysis
is
conducted
using
a
monitor
weight
of
30
pounds,
a
monitor
lifetime
of
6
years,
the
percent
of
color
monitors
discarded
of
85
percent,
and
storage
cost
of
zero
dollars
per
square
foot.
The
savings
under
the
combined
sensitivity
analysis
is
$349,000.
August
24,
2001
­
DRAFT
Page
67
Exhibit
5­
4:
Parameter
Values
for
Individual
Sensitivity
Analysis
Lower
Bound
%
Change
from
Best
Estimate
Best
Estimate
Upper
Bound
%
Change
from
Best
Estimate
Monitor
Weight
30
lbs.
­14
%
35
lbs.
40
lbs.
14
%

Monitor
Life
2
years
­43
%
3.5
years
5
years
43
%

Storage
Cost
$
0
­100
%
$
8.30
$
15
81
%

Percent
Color
60
%
­33
%
90
%
99
%
10
%

Exhibit
5­
5:
Individual
Sensitivity
Analysis
Results
Lower
Bound
Best
Estimate
Upper
Bound
Monitor
Weight
$
17,000
$
(106,000)
$
(247,000)

Monitor
Life
$
(916,000)
$
(106,000)
$
93,000
Storage
Cost
$
(84,000)
$
(106,000)
$
(123,000)

Percent
Color
$
120,000
$
(106,000)
$
(191,000)

Note:
Cost
numbers
rounded
to
nearest
thousand.

Sensitivity
analysis
is
also
conducted
for
disposal
costs
above
and
below
the
best
estimate
values.
By
changing
the
cost
for
disposal
to
a
hazardous
waste
landfill
to
$800
and
$1700
per
ton
for
whole
CRTs
(from
a
best
estimate
of
$1,500),
and
to
$50
and
$250
per
ton
for
crushed
CRTs
(from
a
best
estimate
of
$160),
the
savings
ranged
from
$
(61,000)
to
$(
259,000).
By
changing
the
cost
for
disposal
to
a
reclaimer
to
$150
and
$500
per
ton
for
whole
CRTs
(from
a
best
estimate
of
$295),
to
$100
and
$300
per
ton
for
bare
CRTs
(from
a
best
estimate
of
$207),
and
to
$75
and
$250
per
ton
for
crushed
CRTs
(from
a
best
estimate
of
$152),
the
savings
ranged
from
$(
330,000)
to
$54,000.
By
changing
the
cost
for
disposal
to
a
collector
to
$100
and
$350
per
ton
(from
a
best
estimate
of
$271),
the
savings
ranged
from
$(
236,000)
to
$176,000.
The
sensitivity
analysis
on
disposal
costs
shows
that
the
model
is
moderately
sensitive
to
hazardous
waste,
reclaimer,
and
collector
disposal
costs.
44
The
number
of
televisions
disposed
of
is
based
on
the
assumption
that
there
are
100
million
households
each
with
two
televisions
and
that
the
TVs
are
discarded
after
ten
years.
The
20
August
24,
2001
­
DRAFT
Page
68
($
950,000)
($
700,000)
($
450,000)
($
200,000)
$50,000
­150%
­100%
­50%
0%
50%
100%

Percent
Change
from
Best
Estimate
Total
Cost
Savings
from
Baseline
($)

Monitor
Weight
Monitor
Life
Storage
Cost
Percent
Color
Exhibit
5­
6:
Plot
of
Individual
Sensitivity
Analysis
Results
for
the
Primary
Alternative
Note:
Lines
with
relatively
steeper
slopes
indicate
greater
sensitivity
of
the
results
to
changes
(or
uncertainty)
in
the
given
parameters.

5.2.4
Incremental
Cost
Difference
Between
the
Subtitle
D
Baseline
and
the
Primary
Alternative,
Including
Currently
Unregulated
Monitors
and
Televisions
To
help
understand
how
the
two
regulatory
alternatives
might
be
affected
by
capacity
issues,
the
total
cost
of
compliance
under
the
Subtitle
D
baseline
and
the
primary
alternative
is
also
calculated
including
CRTs
from
households
and
CESQGs.
It
is
assumed
that
20
million
unregulated
television
CRTs
are
disposed
and
16.7
million
unregulated
computer
monitor
CRTs
are
disposed
from
households
and
CESQGs.
44
Exhibit
5­
7
contains
a
summary
of
the
costs
under
the
baseline
and
the
million
TVs
discarded
is
also
consistent
with
the
number
of
televisions
sold
in
1991,
which
was
19.5
million.
The
number
of
computer
monitor
CRTs
disposed
of
is
based
on
data
from
the
US
Census,
Survey
of
Computer
Use,
1997,
which
estimates
that
52
percent
of
households
have
computers.

August
24,
2001
­
DRAFT
Page
69
primary
alternative
by
cost
category.
Transportation
and
disposal
costs
are
higher
under
the
primary
alternative
than
the
baseline
because
it
is
assumed
that
a
greater
percentage
of
unregulated
CRTs
are
sent
to
collectors,
which
increases
the
number
of
CRTs
that
have
a
non­
zero
disposal
cost
under
the
primary
alternative.

Exhibit
5­
7:
Costs
of
Primary
Alternative
Relative
to
Subtitle
D
Baseline
Including
Unregulated
Monitors
and
Televisions
Cost
Category
Baseline
Primary
Alternative
Saving
(Cost)

Administrative
$
269,000
$
56,000
$
213,000
Disposal
Except
Subtitle
D
$
6,155,000
$
6,677,000
$
(522,000)

Subtitle
D
Disposal
$
3,007,000
$
2,789,000
$
218,000
Transportation
$
1,063,000
$
1,213,000
$
(150,000)

Storage
$
257,000
$
279,000
$
(22,000)

Total
$
10,751,000
$
11,014,000
$
(263,000)

Note:
Cost
numbers
rounded
to
nearest
thousand.
Costs
may
not
add
due
to
rounding.

The
analysis
estimates
that
9,600
tons
of
CRT
glass
is
sent
to
glass
processors
and
that,
of
this,
8,800
tons
of
CRT
glass
is
sent
to
CRT
glass
manufacturers.
These
quantities
are
below
the
capacity
limits
for
glass
processors
and
CRT
glass
manufacturers.
As
the
CRT
recycling
infrastructure
grows
and
additional
unregulated
CRTs
are
recycled,
the
capacities
of
both
glass
processors
and
glass
manufacturers
will
be
exceeded.
This
analysis
does
not
attempt
to
predict
when
this
might
occur.

5.3
CSI
Alternative
5.3.1
Costs
Under
the
CSI
Alternative
The
total
applicable
cost
of
compliance
under
the
CSI
alternative
is
calculated
for
all
of
the
entities
described
in
Section
5.1,
and
for
all
of
the
entities
that
were
formerly
generators
but
that
no
longer
are
required
to
comply
with
the
hazardous
waste
regulations.
These
are
called
CSI
handlers.
Exhibit
5­
8
presents
the
cost
per
establishment
for
administrative,
storage,
transportation,
and
disposal,
and
for
the
total
cost
of
compliance
under
the
CSI
alternative.
Administrative
costs
are
assumed
to
be
the
same
for
all
CSI
handlers
in
each
size
category
(small
or
large).
The
other
costs
vary
across
the
45
Assumes
a
two
year
monitor
life,
an
average
monitor
weight
of
40
pounds,
and
95
percent
of
discarded
monitors
are
color.

August
24,
2001
­
DRAFT
Page
70
categories
(based
on
RCRA
requirements
for
different
types
of
generators,
on
the
average
number
of
CRTs
discarded,
and
on
the
CRT
management
method
used
by
that
generator).
So
Exhibit
5­
8
presents
the
average
cost
for
CSI
handlers.
As
discussed
in
section
3.11,
generators
sending
CRTs
to
Subtitle
D
landfills
only
incur
a
disposal
cost.

The
average
transportation
and
disposal
cost
for
SQGs
and
LQGs
changes
between
the
baseline
and
the
CSI
alternative
because,
in
the
baseline,
six
CRT
management
options
(collector,
reuse,
processor,
smelter,
hazardous
waste
landfill,
and
municipal
landfill)
are
available
while
in
the
CSI
alternative
only
three
CRT
management
options
(lead
smelter,
hazardous
waste
landfill,
and
municipal
landfill)
are
available
for
regulated
generators,
and
four
of
the
CRT
management
options
are
available
(collector,
reuse,
processor,
and
municipal
landfill)
for
CSI
handlers.

Exhibit
5­
8:
CSI
Alternative
Compliance
Costs
Under
the
Subtitle
D
Baseline
Average
Costs
per
Generator
Number
of
Regulated
Generator
s
Average
Costs
per
Potentially
Regulated
Generator
Number
of
Potentially
Regulated
Generators
Total
Cost
Admin
.
Storage
Transp.
Disposal
Except
Subtitle
D
Subtitle
D
Disposal
Transp.
Disposal
Except
Subtitle
D
Subtitle
D
Disposal
CSI
Handlers
SQH
$
100
$
883
$
114
$
900
$
480
200
$
114
$
900
$
480
2,439
$
4,138,000
LQH
$
0
$
0
$
0
$
0
$
0
0
$
0
$
0
$
0
0
$
0
Subtotal
$
4,138,000
Total
Cost
to
Regulated
Generators
$
2,996,000
Total
Compliance
Costs
under
the
CSI
Alternative
$
7,134,000
Note:
Total
cost
numbers
rounded
to
nearest
thousand.
Costs
may
not
add
due
to
rounding.

5.3.2
Incremental
Cost
Difference
Between
the
Subtitle
D
Baseline
and
the
CSI
Alternative
The
CSI
alternative
generates
a
net
savings
relative
to
the
baseline,
due
primarily
to
reduced
administrative
requirements
and
savings
from
reduced
transportation
and
disposal
costs.
Savings
from
the
CSI
alternative
accrue
to
CSI
handlers
that
would
no
longer
be
regulated.
The
range
of
potential
savings
under
the
CSI
alternative
is
estimated
to
be
from
a
net
cost
of
$1,521,000
45
to
a
net
cost
of
46
Assumes
a
six
year
monitor
life,
an
average
monitor
weight
of
30
pounds,
and
86
percent
of
discarded
monitors
are
color.

47
Assumes
a
three
and
one
half
year
monitor
life,
an
average
monitor
weight
of
35
pounds,
and
90
percent
of
discarded
monitors
are
color.

August
24,
2001
­
DRAFT
Page
71
$33,000,
46
with
a
best
estimate
of
a
net
cost
of
$434,000.
47
Exhibit
5­
9
summarizes
the
costs
under
the
baseline
and
the
CSI
alternative
by
cost
category.

Exhibit
5­
9:
Costs
of
CSI
Alternative
Relative
to
Subtitle
D
Baseline
Cost
Category
Baseline
Primary
Alternative
Saving
(Cost)

Administrative
$
251,000
$
129,000
$
122,000
Disposal
Except
Subtitle
D
$
3,863,000
$
4,435,000
$
(572,000)

Subtitle
D
Disposal
$
1,580,000
$
1,500,000
$
80,000
Transportation
$
749,000
$
875,000
$
(126,000)

Storage
$
257,000
$
195,000
$
62,000
Total
$
6,700,000
$
7,134,000
$
(434,000)

Note:
Cost
numbers
rounded
to
nearest
thousand.
Costs
may
not
add
due
to
rounding.

5.3.3
Sensitivity
Analysis
for
the
CSI
Alternative
Individual
sensitivity
and
bounding
analysis
is
conducted
on
the
difference
between
the
Subtitle
D
baseline
and
the
CSI
alternative
for
the
following
four
parameters:
monitor
weight,
monitor
lifetime,
storage
costs,
and
percent
of
monitors
that
are
color.
The
individual
sensitivity
analysis
is
conducted
by
changing
one
parameter
at
a
time
while
holding
all
other
parameters
at
their
best
estimate
value.
Exhibit
5­
10
contains
the
upper
and
lower
bounds
and
the
best
estimate
values
for
the
four
parameters
as
well
as
the
percent
change
of
the
lower
and
upper
bounds
from
the
best
estimate.
The
upper
and
lower
bounds
were
selected
because
they
represent
probable
limits
on
the
selected
parameters.
Exhibit
5­
11
contains
the
model
results
for
each
individual
change.
Exhibit
5­
12
plots
the
data
in
Exhibit
5­
11
from
the
individual
sensitivity
analysis
for
the
four
parameters.
The
graph
illustrates
that
the
analysis
is
most
sensitive
to
the
monitor
weight,
monitor
lifetime,
and
the
percent
of
color
monitors
discarded.
To
determine
a
potential
maximum
upper
bound
on
the
savings,
a
combined
sensitivity
analysis
is
conducted
using
a
monitor
weight
of
26
pounds,
a
monitor
lifetime
of
5.5
years,
the
percent
of
color
monitors
discarded
of
75
percent,
and
storage
cost
of
$15
per
square
foot.
The
savings
under
the
combined
sensitivity
analysis
is
$5,000.
August
24,
2001
­
DRAFT
Page
72
Exhibit
5­
10:
Parameter
Values
for
Individual
Sensitivity
Analysis
Lower
Bound
%
Change
from
Best
Estimate
Best
Estimate
Upper
Bound
%
Change
from
Best
Estimate
Monitor
Weight
30
lbs.
­14
%
35
lbs.
40
lbs.
14
%

Monitor
Life
2
years
­43
%
3.5
years
5
years
43
%

Storage
Cost
$
0
­100
%
$
8.30
$
15
81
%

Percent
Color
60
%
­33
%
90
%
99
%
10
%

Exhibit
5­
11:
Individual
Sensitivity
Analysis
Results
Lower
Bound
Best
Estimate
Upper
Bound
Monitor
Weight
$
(315,000)
$
(434,000)
$
(568,000)

Monitor
Life
$
(1,153,000)
$
(434,000)
$
(259,000)

Storage
Cost
$
(496,000)
$
(434,000)
$
(383,000)

Percent
Color
$
(223,000)
$
(434,000)
$
(509,000)

Numbers
rounded
to
nearest
thousand.

Sensitivity
analysis
is
also
conducted
for
disposal
costs
above
and
below
the
best
estimate
values.
By
changing
the
cost
for
disposal
to
a
hazardous
waste
landfill
to
$800
and
$1700
per
ton
for
whole
CRTs
(from
a
best
estimate
of
$1,500),
and
to
$50
and
$250
per
ton
for
crushed
CRTs
(from
a
best
estimate
of
$160),
the
savings
ranged
from
$(
417,000)
to
$(
499,000).
By
changing
the
cost
for
disposal
to
a
reclaimer
to
$150
and
$500
per
ton
for
whole
CRTs
(from
a
best
estimate
of
$295),
to
$100
and
$300
per
ton
for
bare
CRTs
(from
a
best
estimate
of
$207),
and
to
$75
and
$250
per
ton
for
crushed
CRTs
(from
a
best
estimate
of
$152),
the
savings
ranged
from
$(
349,000)
to
$(
493,000).
By
changing
the
cost
for
disposal
to
a
collector
to
$100
and
$350
per
ton
(from
a
best
estimate
of
$271),
the
savings
ranged
from
$(
577,000)
to
$(
255,000).
August
24,
2001
­
DRAFT
Page
73
($
1,200,000)
($
1,100,000)
($
1,000,000)
($
900,000)
($
800,000)
($
700,000)
($
600,000)
($
500,000)
($
400,000)
($
300,000)
($
200,000)

­150%
­100%
­50%
0%
50%
100%
Percent
Change
from
Best
Estimate
Total
Cost
Savings
from
Baseline
($)

Monitor
Weight
Monitor
Life
Storage
Cost
Percent
Color
Exhibit
5­
12:
Plot
of
Individual
Sensitivity
Analysis
Results
for
the
CSI
Alternative
Note:
Lines
with
relatively
steeper
slopes
indicate
greater
sensitivity
of
the
results
to
changes
(or
uncertainty)
in
the
given
parameters.

5.3.4
Incremental
Cost
Difference
Between
the
Subtitle
D
Baseline
and
the
CSI
Alternative,
Including
Currently
Unregulated
Monitors
and
Televisions
To
help
understand
how
the
two
regulatory
alternatives
might
be
affected
by
capacity
issues,
the
total
cost
of
compliance
under
the
Subtitle
D
baseline
and
the
CSI
alternative
is
also
calculated
including
CRTs
from
households
and
CESQGs.
It
is
assumed
that
20
million
unregulated
television
CRTs
are
disposed
and
16.7
million
unregulated
computer
monitor
CRTs
are
disposed
from
48
The
number
of
televisions
disposed
of
is
based
on
the
assumption
that
there
are
100
million
households
each
with
two
televisions
and
that
the
TVs
are
discarded
after
ten
years.
The
20
million
TVs
discarded
is
also
consistent
with
the
number
of
televisions
sold
in
1991,
which
was
19.5
million.
The
number
of
computer
monitor
CRTs
disposed
of
is
based
on
data
from
the
US
Census,
Survey
of
Computer
Use,
1997,
which
estimates
that
52
percent
of
households
have
computers.

August
24,
2001
­
DRAFT
Page
74
households
and
CESQGs.
48
Exhibit
5­
13
summarizes
the
costs
under
the
baseline
and
the
CSI
alternative
by
cost
category.

Exhibit
5­
13:
Costs
of
CSI
Alternative
Relative
to
Subtitle
D
Baseline,
Including
Unregulated
Monitors
and
Televisions
Cost
Category
Baseline
Primary
Alternative
Saving
(Cost)

Administrative
$
269,000
$
136,000
$
133,000
Disposal
Except
Subtitle
D
$
6,155,000
$
6,934,000
$
(779,000)

Subtitle
D
Disposal
$
3,007,000
$
2,745,000
$
262,000
Transportation
$
1,063,000
$
1,224,000
$
(161,000)

Storage
$
257,000
$
195,000
$
62,000
Total
$
10,751,000
$
11,234,000
$
(483,000)

The
analysis
estimates
that
9,600
tons
of
CRT
glass
is
sent
to
glass
processors
and
that,
of
this,
9,400
tons
of
CRT
glass
is
sent
to
CRT
glass
manufacturers.
These
quantities
are
below
the
capacity
limits
for
glass
processors
and
CRT
glass
manufacturers.
As
the
CRT
recycling
infrastructure
grows
and
additional
unregulated
CRTs
are
recycled,
the
capacities
of
both
glass
processors
and
glass
manufacturers
will
be
exceeded.
This
analysis
does
not
attempt
to
predict
when
this
might
occur.

6.0
Economic
Impacts
This
section
presents
the
estimated
first­
order
economic
impacts
associated
with
the
incremental
cost
savings
from
the
primary
and
CSI
alternatives
over
the
Subtitle
C
management
baseline
using
the
cost
to
sales
ratio.
As
noted
in
Section
3.10,
the
impacts
analysis
is
likely
to
overstate
economic
impacts
(whether
costs
or
savings)
because
the
sales
data
used
in
the
analysis
represent
average
values
for
each
SIC
code
as
a
whole,
whereas
the
estimated
compliance
costs
arise
only
for
the
entities
that
are
large
enough
to
be
considered
an
SQG
or
LQG
in
the
baseline.
Such
entities
are
likely
to
have
an
average
sales
value
higher
than
the
average
for
the
industry
as
a
whole.
August
24,
2001
­
DRAFT
Page
75
Primary
Alternative
Exhibit
6­
1
shows
the
impacts
of
the
cost
savings
for
original
users
that
were
baseline
small
quantity
generators
(SQGs).
Their
average
savings
is
$606
per
year,
due
primarily
to
reduced
administrative
requirements
and
transportation
savings.
The
highest
impact
on
SQGs
is
on
the
"Personal
Services"
sector
(SIC
code
72).
Establishments
in
SIC
code
72
have
average
annual
sales
of
$219,582.
The
incremental
cost
savings
represents
0.28
percent
of
the
average
annual
sales.
Establishments
in
all
but
one
other
SIC
code
have
impacts
of
less
than
0.17
percent
of
the
average
annual
sales.

Exhibit
6­
2
presents
the
results
for
original
users
that
were
baseline
large
quantity
generators
(LQGs).
Their
average
savings
is
$1,101
per
year,
due
to
reduced
administrative
requirements,
and
transportation
and
disposal
costs.
The
LQGs
under
the
baseline
are
in
25
SIC
codes.
The
highest
impact
for
LQHs
is
on
the
Retail
Trade
Administrative
and
Auxiliary
category.
The
maximum
incremental
cost
savings
represents
0.30
percent
of
the
average
annual
sales.
Establishments
in
all
other
SIC
codes
have
impacts
of
less
than
0.23
percent
of
the
average
annual
sales.

Exhibit
6­
1:
Estimated
Impact
of
Savings
Under
the
Primary
Alternative
on
Former
SQGs
that
were
Baseline
SQGs
Industry
SIC
Code
Average
Sales
per
Establishment
Number
of
Baseline
Potential
SQGs
Savings
(Cost)
Impact
of
Primary
Alternative
MINING
Metal
Mining
10
$9,642,717
24
0.01%

Coal
Mining
12
$8,841,349
21
0.01%

Oil
&
Gas
Extraction
13
$5,338,313
52
0.01%

Non­
metallic
minerals,
except
fuels
14
$2,338,749
5
0.03%

Administrative
&
Auxiliary
1
$1,545,768
37
0.04%

CONSTRUCTION
General
contractors
15
$1,280,404
8
0.05%

Heavy
construction
16
$2,570,507
24
0.02%

Special
trade
contractors
17
$590,600
5
0.10%

MANUFACTURING
Food
&
kindred
products
20
$19,567,362
178
0.00%

Tobacco
products
21
$308,752,632
10
0.00%

Textile
mill
products
22
$12,020,557
56
0.01%

Apparel
&
other
textile
products
23
$3,103,014
9
0.02%

Lumber
&
wood
products
24
$2,277,901
3
0.03%

Furniture
&
Fixtures
25
$3,759,298
30
0.02%

Paper
&
allied
products
26
$20,760,708
208
0.00%
Industry
SIC
Code
Average
Sales
per
Establishment
Number
of
Baseline
Potential
SQGs
Savings
(Cost)
Impact
of
Primary
Alternative
August
24,
2001
­
DRAFT
Page
76
Printing
&
publishing
27
$2,540,878
328
0.02%

Chemicals
&
allied
products
28
$25,443,194
297
0.00%

Petroleum
and
Coal
Products
29
$70,728,296
44
0.00%

Rubber
&
miscellaneous
plastics
products
30
$7,170,357
225
0.01%

Leather
&
leather
products
31
$4,751,863
5
0.01%

Stone,
clay,
and
glass
products
32
$3,846,475
22
0.02%

Primary
metal
industries
33
$21,271,651
72
0.00%

Fabricated
metal
products
34
$4,571,413
62
0.01%

Industrial
machinery
&
equipment
35
$4,793,932
483
0.01%

Electronic
&
other
electronic
equipment
36
$12,809,615
578
0.00%

Transportation
equipment
37
$35,374,262
459
0.00%

Instrument
&
related
products
38
$11,884,834
121
0.01%

Miscellaneous
manufacturing
39
$2,318,656
19
0.03%

Administrative
&
Auxiliary
1
$3,156,356
212
0.02%

TRANSPORTATION
Local
&
Interurban
passenger
transit
41
$
710,436
7
0.09%

Trucking
&
Warehousing
42
$1,296,519
98
0.05%

Water
transportation
44
$3,585,027
16
0.02%

Transportation
by
Air
45
$2,338,134
78
0.03%

Pipelines,
except
natural
gases
46
$8,368,550
1
0.01%

Communication
48
$5,877,769
303
0.01%

Electronic,
gas,
&
sanitary
services
49
$15,510,062
255
0.00%

Administrative
&
Auxiliary
1
$1,766,775
43
0.03%

WHOLESALE
Wholesale
trade­
durable
goods
50
$5,084,711
168
0.01%

Wholesale
trade­
nondurable
goods
51
$9,036,867
213
0.01%

Bldg.
Materials
&
garden
supplies
52
$1,422,393
1
0.04%

Administrative
&
Auxiliary
1
$781,548
98
0.08%

RETAIL
TRADE
General
merchandise
store
53
$7,089,224
28
0.01%

Food
stores
54
$2,044,651
2
0.03%

Auto
dealers
&
service
station
55
$4,100,193
1
0.01%

Apparel
&
accessory
stores
56
$699,117
4
0.09%

Furniture
&
home
furnishing
stores
57
$846,766
2
0.07%

Eating
&
drinking
places
58
$450,446
6
0.13%

Miscellaneous
retail
59
$607,995
31
0.10%

Administrative
&
Auxiliary
1
$370,918
96
0.16%
Industry
SIC
Code
Average
Sales
per
Establishment
Number
of
Baseline
Potential
SQGs
Savings
(Cost)
Impact
of
Primary
Alternative
August
24,
2001
­
DRAFT
Page
77
FINANCE,
INSURANCE,
AND
REAL
ESTATE
Depository
Institution
60
$5,091,211
339
0.01%

Nondepository
Institution
61
$3,432,819
87
0.02%

Security
&
commodity
brokers
62
$3,491,738
86
0.02%

Insurance
carriers
63
$20,422,940
482
0.00%

Insurance
agents,
brokers,
&
servicers
64
$424,989
27
0.14%

Real
Estate
65
$617,331
74
0.10%

Holding
&
other
investment
offices
67
$3,237,932
37
0.02%

Administrative
&
Auxiliary
1
$1,054,687
23
0.06%

SERVICES
Personal
services
72
$219,582
6
0.28%

Business
services
73
$896,726
1,432
0.07%

Auto
repair,
services,
and
parking
75
$407,237
1
0.15%

Misc.
repair
services
76
$429,359
2
0.14%

Motion
picture
78
$1,040,439
15
0.06%

Amusement
&
recreation
services
79
$793,715
69
0.08%

Health
services
80
$677,073
3,177
0.09%

Legal
services
81
$641,030
52
0.09%

Educational
services
82
$491,509
580
0.12%

Social
services
83
$225,786
18
0.27%

Museums,
botanical,
zoological
gardens
84
$611,305
3
0.10%

Membership
organization
86
$500,857
83
0.12%

Engineering
&
management
service
87
$827,956
365
0.07%

Services,
n.
e.
c
89
$546,119
8
0.11%

Administrative
&
Auxiliary
1
$1,053,680
134
0.06%

Exhibit
6­
2:
Estimated
Impact
of
Savings
Under
the
Primary
Alternative
on
Former
LQGs
that
were
Baseline
LQGs
Industry
SIC
Code
Average
Sales
per
Establishment
Number
of
Baseline
Potential
LQGs
Savings
(Cost)
Impact
of
Primary
Alternative
MANUFACTURING
Food
and
kindred
products
20
$19,567,362
3
0.01%

Tobacco
products
21
$308,752,632
1
0.00%

Chemicals
&
allied
products
28
$25,443,194
4
0.01%

Primary
metal
industries
33
$21,271,651
5
0.01%
Industry
SIC
Code
Average
Sales
per
Establishment
Number
of
Baseline
Potential
LQGs
Savings
(Cost)
Impact
of
Primary
Alternative
August
24,
2001
­
DRAFT
Page
78
Industrial
machinery
&
equipment
35
$4,793,932
7
0.02%

Electronic
&
other
electronic
equipment
36
$12,809,615
12
0.01%

Transportation
equipment
37
$35,374,262
51
0.00%

TRANSPORTATION
Local
&
Interurban
passenger
transit
41
$710,436
1
0.16%

Trucking
&
Warehousing
42
$1,296,519
12
0.08%

Transportation
by
Air
45
$2,338,134
20
0.05%

Communication
48
$5,877,769
11
0.02%

Electronic,
gas,
&
sanitary
services
49
$15,510,062
4
0.01%

Administrative
&
Auxiliary
1
$1,766,775
5
0.06%

WHOLESALE
Administrative
&
Auxiliary
1
$781,548
1
0.14%

RETAIL
TRADE
Food
stores
54
$2,044,651
1
0.05%

Administrative
&
Auxiliary
1
$370,918
1
0.30%

FINANCE,
INSURANCE,
AND
REAL
ESTATE
Depository
Institution
60
$5,091,211
18
0.02%

Nondepository
institution
61
$3,432,819
5
0.03%

Security
and
commodity
brokers
62
$3,491,738
5
0.03%

Insurance
carriers
63
$20,422,940
14
0.01%

Holding
and
other
investment
offices
67
$3,237,932
3
0.03%

SERVICES
Business
services
73
$896,726
22
0.12%

Motion
picture
78
$1,040,439
5
0.11%

Amusement
&
recreation
services
79
$793,715
3
0.14%

Health
services
80
$677,073
65
0.16%

Educational
services
82
$491,509
33
0.22%

Membership
organization
86
$500,857
6
0.22%

Engineering
&
management
service
87
$827,956
31
0.13%

Administrative
&
Auxiliary
1
$1,053,680
7
0.10%

CSI
Alternative
Exhibit
6­
3
shows
the
impacts
of
the
cost
savings
for
small
quantity
handlers
(SQHs)
that
were
baseline
small
quantity
generators
(SQGs).
Their
average
savings
is
$498
per
year,
due
primarily
to
reduced
administrative
requirements
and
transportation
savings.
The
highest
impact
on
SQGs
is
on
the
August
24,
2001
­
DRAFT
Page
79
"Personal
Services"
sector
(SIC
code
72).
Establishments
in
SIC
code
72
have
average
annual
sales
of
$219,582.
The
incremental
cost
savings
represents
0.23
percent
of
the
average
annual
sales.
Establishments
in
all
but
one
other
SIC
codes
have
impacts
of
less
than
0.14
percent
of
the
average
annual
sales.

Exhibit
6­
4
presents
the
results
for
the
small
quantity
handlers
(SQHs)
that
were
baseline
large
quantity
generators
(LQGs).
Their
average
savings
is
$8,017
per
year,
due
primarily
to
reduced
administrative
requirements
and
disposal
costs.
Fifteen
percent
of
the
LQGs
under
the
baseline
are
assumed
to
continue
following
RCRA
regulations
because
they
send
their
waste
to
destinations
other
than
glass
processors.
These
establishments
realize
no
cost
savings
under
the
CSI
alternative.
The
former
LQGs
are
regulated
as
SQHs
under
the
CSI
alternative,
and
are
the
main
beneficiaries
of
the
regulatory
burden
reduction.

The
model
estimates
that
no
large
quantity
handlers
will
exist
under
the
CSI
alternative.
Thus,
the
baseline
large
quantity
generators
that
become
SQHs
by
sending
discarded
CRTs
to
processors
under
the
CSI
alternative
realize
the
most
cost
savings.
The
LQGs
under
the
baseline
are
in
25
SIC
codes.
The
highest
impact
for
LQHs
is
on
the
Retail
Trade
Administrative
and
Auxiliary
category.
The
maximum
incremental
cost
savings
represents
2.16
percent
of
the
average
annual
sales.
Establishments
in
all
other
SIC
codes
have
impacts
of
less
than
1.64
percent
of
the
average
annual
sales.

Exhibit
6­
3:
Estimated
Impact
of
Savings
Under
the
CSI
Alternative
on
Small
Quantity
Handlers
that
were
Baseline
SQGs
Industry
SIC
Code
Average
Sales
per
Establishment
Number
of
Baseline
Potential
SQGs
Savings
(Cost)
Impact
of
Primary
Alternative
MINING
Metal
Mining
10
$9,642,717
24
0.01%

Coal
Mining
12
$8,841,349
21
0.01%

Oil
&
Gas
Extraction
13
$5,338,313
52
0.01%

Non­
metallic
minerals,
except
fuels
14
$2,338,749
5
0.02%

Administrative
&
Auxiliary
1
$1,545,768
37
0.03%

CONSTRUCTION
General
contractors
15
$1,280,404
8
0.04%

Heavy
construction
16
$2,570,507
24
0.02%

Special
trade
contractors
17
$590,600
5
0.08%

MANUFACTURING
Food
&
kindred
products
20
$19,567,362
178
0.00%

Tobacco
products
21
$308,752,632
10
0.00%

Textile
mill
products
22
$12,020,557
56
0.00%

Apparel
&
other
textile
products
23
$3,103,014
9
0.02%

Lumber
&
wood
products
24
$2,277,901
3
0.02%
Industry
SIC
Code
Average
Sales
per
Establishment
Number
of
Baseline
Potential
SQGs
Savings
(Cost)
Impact
of
Primary
Alternative
August
24,
2001
­
DRAFT
Page
80
Furniture
&
Fixtures
25
$3,759,298
30
0.01%

Paper
&
allied
products
26
$20,760,708
208
0.00%

Printing
&
publishing
27
$2,540,878
328
0.02%

Chemicals
&
allied
products
28
$25,443,194
297
0.00%

Petroleum
and
Coal
Products
29
$70,728,296
44
0.00%

Rubber
&
miscellaneous
plastics
products
30
$7,170,357
225
0.01%

Leather
&
leather
products
31
$4,751,863
5
0.01%

Stone,
clay,
and
glass
products
32
$3,846,475
22
0.01%

Primary
metal
industries
33
$21,271,651
72
0.00%

Fabricated
metal
products
34
$4,571,413
62
0.01%

Industrial
machinery
&
equipment
35
$4,793,932
483
0.01%

Electronic
&
other
electronic
equipment
36
$12,809,615
578
0.00%

Transportation
equipment
37
$35,374,262
459
0.00%

Instrument
&
related
products
38
$11,884,834
121
0.00%

Miscellaneous
manufacturing
39
$2,318,656
19
0.02%

Administrative
&
Auxiliary
1
$3,156,356
212
0.02%

TRANSPORTATION
Local
&
Interurban
passenger
transit
41
$
710,436
7
0.07%

Trucking
&
Warehousing
42
$1,296,519
98
0.04%

Water
transportation
44
$3,585,027
16
0.01%

Transportation
by
Air
45
$2,338,134
78
0.02%

Pipelines,
except
natural
gases
46
$8,368,550
1
0.01%

Communication
48
$5,877,769
303
0.01%

Electronic,
gas,
&
sanitary
services
49
$15,510,062
255
0.00%

Administrative
&
Auxiliary
1
$1,766,775
43
0.03%

WHOLESALE
Wholesale
trade­
durable
goods
50
$5,084,711
168
0.01%

Wholesale
trade­
nondurable
goods
51
$9,036,867
213
0.01%

Bldg.
Materials
&
garden
supplies
52
$1,422,393
1
0.04%

Administrative
&
Auxiliary
1
$781,548
98
0.06%

RETAIL
TRADE
General
merchandise
store
53
$7,089,224
28
0.01%

Food
stores
54
$2,044,651
2
0.02%

Auto
dealers
&
service
station
55
$4,100,193
1
0.01%

Apparel
&
accessory
stores
56
$699,117
4
0.07%

Furniture
&
home
furnishing
stores
57
$846,766
2
0.06%

Eating
&
drinking
places
58
$450,446
6
0.11%
Industry
SIC
Code
Average
Sales
per
Establishment
Number
of
Baseline
Potential
SQGs
Savings
(Cost)
Impact
of
Primary
Alternative
August
24,
2001
­
DRAFT
Page
81
Miscellaneous
retail
59
$607,995
31
0.08%

Administrative
&
Auxiliary
1
$370,918
96
0.13%

FINANCE,
INSURANCE,
AND
REAL
ESTATE
Depository
Institution
60
$5,091,211
339
0.01%

Nondepository
Institution
61
$3,432,819
87
0.01%

Security
&
commodity
brokers
62
$3,491,738
86
0.01%

Insurance
carriers
63
$20,422,940
482
0.00%

Insurance
agents,
brokers,
&
servicers
64
$424,989
27
0.12%

Real
Estate
65
$617,331
74
0.08%

Holding
&
other
investment
offices
67
$3,237,932
37
0.02%

Administrative
&
Auxiliary
1
$1,054,687
23
0.05%

SERVICES
Personal
services
72
$219,582
6
0.23%

Business
services
73
$896,726
1,432
0.06%

Auto
repair,
services,
and
parking
75
$407,237
1
0.12%

Misc.
repair
services
76
$429,359
2
0.12%

Motion
picture
78
$1,040,439
15
0.05%

Amusement
&
recreation
services
79
$793,715
69
0.06%

Health
services
80
$677,073
3,177
0.07%

Legal
services
81
$641,030
52
0.08%

Educational
services
82
$491,509
580
0.10%

Social
services
83
$225,786
18
0.22%

Museums,
botanical,
zoological
gardens
84
$611,305
3
0.08%

Membership
organization
86
$500,857
83
0.10%

Engineering
&
management
service
87
$827,956
365
0.06%

Services,
n.
e.
c
89
$546,119
8
0.09%

Administrative
&
Auxiliary
1
$1,053,680
134
0.05%

Exhibit
6­
4:
Estimated
Impact
of
Savings
Under
the
CSI
Alternative
on
Small
Quantity
Handlers
that
were
Baseline
LQGs
Industry
SIC
Code
Average
Sales
per
Establishment
Number
of
Baseline
Potential
LQGs
Savings
(Cost)
Impact
of
Primary
Alternative
MANUFACTURING
Food
and
kindred
products
20
$19,567,362
3
0.04%

Tobacco
products
21
$308,752,632
1
0.00%
Industry
SIC
Code
Average
Sales
per
Establishment
Number
of
Baseline
Potential
LQGs
Savings
(Cost)
Impact
of
Primary
Alternative
August
24,
2001
­
DRAFT
Page
82
Chemicals
&
allied
products
28
$25,443,194
4
0.03%

Primary
metal
industries
33
$21,271,651
5
0.04%

Industrial
machinery
&
equipment
35
$4,793,932
7
0.17%

Electronic
&
other
electronic
equipment
36
$12,809,615
12
0.06%

Transportation
equipment
37
$35,374,262
51
0.02%

TRANSPORTATION
Local
&
Interurban
passenger
transit
41
$710,436
1
1.13%

Trucking
&
Warehousing
42
$1,296,519
12
0.62%

Transportation
by
Air
45
$2,338,134
20
0.34%

Communication
48
$5,877,769
11
0.14%

Electronic,
gas,
&
sanitary
services
49
$15,510,062
4
0.05%

Administrative
&
Auxiliary
1
$1,766,775
5
0.45%

WHOLESALE
Administrative
&
Auxiliary
1
$781,548
1
1.03%

RETAIL
TRADE
Food
stores
54
$2,044,651
1
0.39%

Administrative
&
Auxiliary
1
$370,918
1
2.16%

FINANCE,
INSURANCE,
AND
REAL
ESTATE
Depository
Institution
60
$5,091,211
18
0.16%

Nondepository
institution
61
$3,432,819
5
0.23%

Security
and
commodity
brokers
62
$3,491,738
5
0.23%

Insurance
carriers
63
$20,422,940
14
0.04%

Holding
and
other
investment
offices
67
$3,237,932
3
0.25%

SERVICES
Business
services
73
$896,726
22
0.89%

Motion
picture
78
$1,040,439
5
0.77%

Amusement
&
recreation
services
79
$793,715
3
1.01%

Health
services
80
$677,073
65
1.18%

Educational
services
82
$491,509
33
1.63%

Membership
organization
86
$500,857
6
1.60%

Engineering
&
management
service
87
$827,956
31
0.97%

Administrative
&
Auxiliary
1
$1,053,680
7
0.76%

*
The
only
LQGs
under
the
CSI
Alternative
are
those
required
to
follow
RCRA
regulations
because
they
send
their
waste
to
destinations
other
than
Glass­
to­
Glass
recyclers.
Eighty­
five
percent
of
the
Baseline
LQGs
are
regulated
as
SQHs
under
the
proposed
rule,
the
others
remain
RCRA
LQGs
and
therefore
realize
no
cost
savings.

7.0
Qualitative
Environmental
Benefits
August
24,
2001
­
DRAFT
Page
83
The
shift
of
waste
CRTs
from
landfills
and
incinerators
to
glass
processors,
and
thus
to
CRT
glass
manufacturers,
has
four
major
potential
qualitative
environmental
benefits.
The
four
potential
qualitative
benefits
are
(1)
increase
in
the
availability
of
landfill
space;
(2)
increase
in
resource
efficiency;
(3)
increase
in
recycling
by
non­
regulated
entities;
and
(4)
reduction
of
lead
emissions
from
incinerators.
This
section
discusses
these
four
qualitative
environmental
benefits.

Landfill
Capacity
A
qualitative
benefit
of
both
alternatives
is
the
shift
of
CRTs
from
Subtitle
C
and
D
landfills
to
CRT
glass
processors.
The
analysis
estimates
that
approximately
2,600
tons
or
456,000
cubic
feet
of
CRTs
will
be
redirected
away
from
landfills
each
year
under
the
primary
alternative.
This
additional
space
can
be
used
for
other
waste.
By
not
disposing
of
CRTs
in
Subtitle
C
and
D
landfills,
the
landfill
capacity
will
not
be
reached
as
quickly
and
new
landfills
will
not
be
needed
as
soon.
This
unused
Subtitle
C
and
D
landfill
capacity
is
seen
as
a
minor
qualitative
benefit,
because
so
few
regulated
CRTs
currently
are
being
sent
to
these
landfills.

Increase
in
Resource
Efficiency
The
resources
that
could
be
used
more
efficiently
under
the
two
regulatory
alternatives
include
energy,
CRT
glass,
raw
materials
for
glass
manufacturing,
and
landfill
space.
The
amount
of
energy
required
to
turn
discarded
televisions
and
computer
monitors
into
an
input
for
CRT
glass
manufacturers
may
be
less
than
the
energy
required
to
mine,
process,
and
transport
the
raw
materials
for
glass
making.
Discarded
CRTs
are
a
direct
replacement
for
raw
materials
to
glass
manufacturing,
thus
reserving
those
raw
materials
for
future
use.

Recycling
by
Non­
Regulated
Entities
The
alternatives
are
designed
to
stimulate
an
increase
in
glass­
to­
glass
CRT
recycling
in
certain
effected
entities
(i.
e.,
firms
that
disposition
a
sufficient
number
of
CRTs
that
they
could
potentially
qualify
as
SQGs
or
LQGs).
If
the
initiative
is
successful,
the
glass­
to­
glass
recycling
industry
may
develop
and
expand
its
operations.
As
CRT
recycling
infrastructure
develops,
it
will
become
a
more
attractive
option
for
smaller
entities
and
for
the
general
public.
Thus,
some
additional
entities
may
shift
the
management
of
their
waste
from
Subtitle
D
landfills
to
glass
recycling.
This
shift
has
the
benefit
of
saving
additional
landfill
space,
and
provides
for
more
environmentally
sound
disposal
of
unregulated
CRTs.
The
increased
recycling
infrastructure
is
already
proving
itself
to
be
a
valuable
incentive
for
increased
non­
regulated
CRT
recycling
in
states
such
as
Massachusetts
and
Minnesota.

Reduction
of
Lead
Emissions
Exposure
to
lead
may
result
in
health
problems
to
adults
and
children.
These
effects
include
hypertension,
stroke,
cancer
in
adults
and
decreased
IQ
and
gestational
age,
reduced
birth
weight,
and
other
neurological
effects
in
infants
and
children.
By
shifting
disposal
of
CRTs
from
municipal
waste
incinerators,
the
total
lead
emitted
from
CRT
incineration
can
be
reduced.
However,
the
benefits
of
49
Macauley
et
al.,
2001,
page
51.

50
Macauley
et
al.,
2001,
page
45.

August
24,
2001
­
DRAFT
Page
84
reducing
lead
emissions
from
CRT
incineration
are
reported
to
be
small.
49
One
report
estimates
that
the
value
of
the
health
effects
due
to
a
complete
ban
on
incineration
of
any
CRTs
is
on
the
order
of
$5
million.
50
8.0
Other
Administrative
Requirements
This
section
describes
the
Agency's
response
to
other
rulemaking
requirements
established
by
statute
and
executive
order,
within
the
context
of
the
proposed
rule
for
CRTs.

8.1
Environmental
Justice
The
EPA
is
committed
to
addressing
environmental
justice
concerns
and
is
assuming
a
leadership
role
in
environmental
justice
initiatives
to
enhance
environmental
quality
for
all
residents
of
the
United
States.
The
Agency's
goals
are
to
ensure
that
no
segment
of
the
population,
regardless
of
race,
color,
national
origin,
or
income
bears
disproportionately
high
and
adverse
human
health
and
environmental
impacts
as
a
result
of
the
EPA's
policies,
programs,
and
activities,
and
that
all
people
live
in
clean
and
sustainable
communities.
In
response
to
Executive
Order
12898
and
to
concerns
voiced
by
many
groups
outside
the
Agency,
the
EPA's
Office
of
Solid
Waste
and
Emergency
Response
formed
an
Environmental
Justice
Task
Force
to
analyze
the
array
of
environmental
justice
issues
specific
to
waste
programs
and
to
develop
an
overall
strategy
to
identify
and
address
these
issues
(OSWER
Directive
No.
9200.3­
17).

Because
CRTs
are
ubiquitous,
it
is
not
certain
whether
the
environmental
problems
addressed
by
the
proposed
rule
could
disproportionately
affect
minority
or
low
income
communities.
CRTs
are
used
throughout
the
country
and
many
are
located
within
highly
populated
areas.
Because
the
proposed
rule
establishes
general
environmental
performance
requirements
to
minimizes
breakage,
and
helps
prevent
the
release
of
glass
particulates,
the
Agency
does
not
believe
that
this
rule
will
increase
risks
from
CRT
wastes.
Moreover,
the
CSI
alternative
establishes
an
environmental
justice
procedure
for
new
CRT
processors.
The
procedure
calls
for
new
processors
to
advise
the
local
community
through
notice
and
possibly
public
meeting
regarding
the
nature
of
the
activities
conducted,
including
the
potential
for
residential
or
worker
exposure
to
lead
or
chemical
coatings.
It
is,
therefore,
not
expected
to
result
in
any
disproportionately
negative
impacts
on
minority
or
low
income
communities
relative
to
affluent
or
non­
minority
communities.
51
An
economically
significant
rule
is
defined
by
Executive
Order
12866
as
any
rulemaking
that
has
an
annual
effect
on
the
economy
of
$100
million
or
more,
or
adversely
affects
in
a
material
way
the
economy,
a
sector
of
the
economy,
productivity,
competition,
jobs,
the
environment,
public
health,
or
safety,
or
State,
local,
or
tribal
governments
or
communities.

August
24,
2001
­
DRAFT
Page
85
8.2
Unfunded
Mandates
Reform
Act
Under
Section
202
of
the
Unfunded
Mandates
Reform
Act
of
1995,
signed
into
law
on
March
22,
1995,
the
EPA
must
prepare
a
statement
to
accompany
any
rule
for
which
the
estimated
costs
to
state,
local,
or
tribal
governments
in
the
aggregate,
or
to
the
private
sector,
will
be
$100
million
or
more
in
any
one
year.
Under
Section
205,
the
EPA
must
select
the
most
cost­
effective
and
least
burdensome
alternative
that
achieves
the
objective
of
the
rule
and
is
consistent
with
statutory
requirements.
Section
203
requires
the
EPA
to
establish
a
plan
for
informing
and
advising
any
small
governments
that
may
be
significantly
affected
by
the
rule.

An
analysis
of
the
costs
and
benefits
of
the
proposed
rule
was
conducted
and
it
was
determined
that
this
rule
does
not
include
a
federal
mandate
that
may
result
in
estimated
costs
of
$100
million
or
more
to
either
state,
local,
or
tribal
governments
in
the
aggregate.
The
private
sector
also
is
not
expected
to
incur
costs
exceeding
$100
million
per
year
in
this
EA.

8.3
Protection
of
Children
from
Environmental
Health
Risks
and
Safety
Risks
Executive
Order
13045,
entitled
"Protection
of
Children
from
Environmental
Health
Risks
and
Safety
Risks"
requires
all
economically
significant
rules
51
that
concern
an
environmental
health
risk
or
safety
risk
that
may
disproportionately
affect
children
to
comply
with
requirements
of
the
Executive
Order.
Because
the
EPA
does
not
consider
the
proposed
rule
to
be
economically
significant,
it
is
not
subject
to
Executive
Order
13045.
Because
this
rulemaking
establishes
general
environmental
performance
requirements,
minimizes
breakage,
and
prevents
of
release
of
glass
particulates,
the
EPA
believes
that
the
proposed
rule
will
not
result
in
increased
exposures
to
children.
For
these
reasons,
the
environmental
health
risks
or
safety
risks
addressed
by
this
action
do
not
have
a
disproportionate
effect
on
children.

8.4
Regulatory
Flexibility
The
Regulatory
Flexibility
Act
(RFA),
as
amended
by
the
Small
Business
Regulatory
Enforcement
and
Fairness
Act,
5
U.
S.
C.
§§
601­
612,
generally
requires
an
agency
to
conduct
a
regulatory
flexibility
analysis
of
any
rule
subject
to
notice
and
comment
rulemaking
requirements
unless
the
agency
certifies
that
the
rule
will
not
have
a
significant
economic
impact
on
a
substantial
number
of
small
entities.
Small
entities
include
small
businesses,
small
not­
for­
profit
enterprises,
and
small
governmental
jurisdictions.
This
proposed
rule
does
not
have
a
significant
impact
on
a
substantial
number
of
small
entities
because
today's
proposed
rule
relieves
regulatory
burden
for
CRT
handlers
through
reduced
regulatory
requirements.
In
addition,
the
Agency
estimates
that
this
proposed
rule
August
24,
2001
­
DRAFT
Page
86
leads
to
an
overall
cost
savings
in
the
range
of
$4
to
5
million
annually.
Accordingly,
EPA
believes
that
the
rule
will
not
have
a
significant
economic
impact
on
a
substantial
number
of
small
entities.

9.0
Discussion
of
Findings
and
Summary
The
main
conclusion
of
this
analysis
is
that
both
the
overall
savings
and
the
savings
for
individual
establishments
are
small,
and
that
the
results
are
sensitive
to
a
few
key
parameters
(CRT
life
in
businesses,
the
average
weight
of
CRTs,
storage
costs,
and
the
percent
of
color
monitors
discarded).
A
second
conclusion
is
that
both
the
glass
processing
and
CRT
glass
manufacturer
capacities
are
adequate
to
handle
all
regulated
CRTs.
However,
if
a
new
rule
induces
significantly
more
unregulated
CRTs
to
be
recycled
than
is
modeled
in
this
analysis,
then
both
the
glass
processing
and
CRT
glass
manufacturer
capacities
may
become
inadequate
to
handle
this
larger
volume
of
CRT
glass.

The
primary
alternative,
as
modeled
in
this
analysis,
is
expected
to
impact
approximately
2,900
establishments
in
66
different
two­
digit
SIC
codes.
Under
the
Subtitle
C
baseline
the
proposed
rule
will
lead
to
total
savings
of
approximately
$4,840,000
for
current
generators
that
elect
not
to
send
their
discarded
CRTs
for
disposal.
These
savings
are
due
primarily
to
reduced
administrative,
disposal,
and
transportation
costs.
Under
the
Subtitle
D
baseline
the
proposed
rule
will
lead
to
a
total
savings
of
approximately
$106,000,
due
to
reduced
administrative
and
transportation
costs.

The
CSI
alternative,
as
modeled
in
this
analysis,
is
expected
to
impact
approximately
2,500
establishments
in
66
different
two­
digit
SIC
codes.
Under
the
Subtitle
C
baseline
the
proposed
rule
will
lead
to
total
savings
of
approximately
$3,098,000
for
current
generators
that
elect
not
to
send
their
discarded
CRTs
for
disposal.
These
savings
are
due
primarily
to
reduced
administrative,
disposal,
and
transportation
costs.
Under
the
Subtitle
D
baseline
the
proposed
rule
will
lead
to
a
total
savings
of
approximately
$434,000,
due
to
reduced
administrative
and
transportation
costs.

Relative
to
the
Subtitle
C
baseline,
the
economic
impacts
on
the
entities
in
the
regulated
community
are
expected
to
be
negligible
because
the
rule
provides
savings
for
all
entities
managing
CRTs.
A
significant
benefit
of
the
proposed
rule
is
the
possible
increase
in
glass­
to­
glass
recycling
by
the
non­
regulated
community.
August
24,
2001
­
DRAFT
Page
87
Appendices
Appendix
A:
Number
of
Establishments
and
the
Number
of
Employees
for
all
Two­
Digit
SIC
Codes
Appendix
B:
Ratios
of
Computers
per
Employee
Calculated
for
Each
SIC
Code
Appendix
C:
Disposal
Cost
Source
Details
Appendix
D:
Flow
of
CRTs
in
Both
Number
and
Tons
Appendix
E:
Average
Shipment
Sizes
for
Each
Type
of
Establishment
Distributing
CRTs
to
Each
CRT
Management
Option
Appendix
F:
Revenues
per
Establishment
for
All
Two­
Digit
SIC
Codes
Appendix
G:
List
of
Parameters
to
Which
the
Analysis
Results
are
Relatively
Insensitive
Appendix
H:
Telephone
Contacts
Appendix
I:
Bibliography
August
24,
2001
­
DRAFT
Page
A­
1
Appendix
A
Total
Employees,
Establishments,
and
Number
of
Establishments
by
Number
of
Employees,
and
by
2­
Digit
SIC
Code
Industry
SIC
code
Total
Employees
Total
Est.
Number
of
Establishments
per
Employee
Size
Range
250
to
499
500
to
999
1,000
to
1,499
1,500
to
2,499
2,500
to
4,999
5,000
or
more
AGRICULTURE
Agricultural
services
7
595,842
103,543
51
18
4
1
Forestry
8
20,488
2,512
4
1
1
Fishing,
hunting,
trapping
9
11,871
2,236
5
0
1
Administrative
&
Auxiliary
­
0
62
2
0
MINING
Metal
Mining
10
48,105
921
20
16
5
3
Coal
Mining
12
104,204
2,294
82
21
Oil
&
Gas
Extraction
13
295,990
17,513
87
37
10
5
Non­
metallic
minerals,

except
fuels
14
99,182
5,572
18
3
2
Administrative
&
Auxiliary
­
80,002
1,056
48
29
6
1
1
CONSTRUCTION
General
contractors
15
1,222,061
190,316
141
49
10
5
2
1
Heavy
construction
16
707,811
34,168
174
60
13
11
8
5
Special
trade
contractors
17
3,091,307
409,114
325
66
9
5
Administrative
&
Auxiliary
­
17,660
402
11
3
MANUFACTURING
Food
&
kindred
products
20
1,525,070
21,285
872
408
118
50
10
3
Tobacco
products
21
30,411
112
16
4
1
5
1
Textile
mill
products
22
624,005
6,452
492
200
38
11
7
Apparel
&
other
textile
products
23
910,919
24,216
513
186
19
7
2
Lumber
&
wood
products
24
730,144
37,601
254
50
9
1
3
Furniture
&
Fixtures
25
505,956
11,611
291
113
16
9
4
1
Paper
&
allied
products
26
634,737
6,552
305
153
40
15
Printing
&
publishing
27
1,505,794
64,690
531
200
78
37
13
Chemicals
&
allied
products
28
826,839
12,328
352
190
58
35
14
4
Petroleum
and
coal
products
29
111,369
2,042
53
26
12
6
Rubber
&
miscellaneous
plastics
products
30
1,001,010
16,611
526
169
26
26
4
Leather
&
leather
products
31
95,151
1,957
68
23
3
2
Stone,
clay,
and
glass
products
32
491,795
16,214
190
75
16
6
Primary
metal
industries
33
684,703
6,768
365
165
34
21
17
5
Fabricated
metal
products
34
1,450,089
36,314
606
192
34
18
10
Industry
SIC
code
Total
Employees
Total
Est.
Number
of
Establishments
per
Employee
Size
Range
250
to
499
500
to
999
1,000
to
1,499
1,500
to
2,499
2,500
to
4,999
5,000
or
more
August
24,
2001
­
DRAFT
Page
A­
2
Industrial
machinery
&
equipment
35
1,883,431
55,476
686
338
74
46
25
7
Electronic
&
other
electronic
equipment
36
1,503,923
17,058
775
373
101
67
37
12
Transportation
equipment
37
1,543,731
11,256
463
255
75
62
67
51
Instrument
&
related
products
38
832,706
11,378
361
177
55
33
23
10
Miscellaneous
manufacturing
39
394,287
17,899
153
57
11
7
1
Administrative
&
Auxiliary
­
1,326,527
12,105
560
315
104
64
32
12
TRANSPORTATION
&
PUBLIC
UTILITIES
Local
&
Interurban
passenger
transit
41
403,025
18,900
101
22
4
2
1
1
Trucking
&
Warehousing
42
1,808,949
124,190
306
150
30
12
56
12
Water
transportation
44
164,920
8,707
45
31
13
2
1
Transportation
by
Air
45
715,137
12,076
150
78
32
27
19
20
Pipelines,
except
natural
gases
46
16,395
1,091
4
0
1
Transportation
services
47
391,340
50,172
50
17
Communication
48
1,340,061
44,713
563
224
51
28
7
4
Electronic,
gas,
&
sanitary
services
49
908,820
22,455
340
152
57
35
11
4
Administrative
&
Auxiliary
­
175,605
2,682
57
30
6
3
4
5
WHOLESALE
Wholesale
trade­
durable
goods
50
3,683,301
327,640
488
135
19
13
1
Wholesale
tradenondurable
goods
51
2,582,397
184,384
550
146
39
15
13
Administrative
&
Auxiliary
­
340,488
5,713
177
69
15
11
3
1
RETAIL
TRADE
Bldg.
Materials
&
garden
supplies
52
739,615
64,436
35
1
General
merchandise
store
53
2,290,572
36,216
1,541
217
14
13
1
Food
stores
54
3,188,462
181,870
452
51
2
1
Auto
dealers
&
service
station
55
2,189,767
199,791
79
5
1
Apparel
&
accessory
stores
56
1,147,856
135,270
37
44
4
Furniture
&
home
furnishing
stores
57
859,460
116,727
36
5
2
Eating
&
drinking
places
58
7,208,158
456,732
209
46
4
2
Miscellaneous
retail
59
2,610,918
360,787
110
53
16
8
7
Administrative
&
Auxiliary
­
849,766
16,055
433
254
65
19
12
1
Industry
SIC
code
Total
Employees
Total
Est.
Number
of
Establishments
per
Employee
Size
Range
250
to
499
500
to
999
1,000
to
1,499
1,500
to
2,499
2,500
to
4,999
5,000
or
more
August
24,
2001
­
DRAFT
Page
A­
3
FINANCE,
INSURANCE,
AND
REAL
ESTATE
Depository
Institution
60
2,079,264
104,666
491
223
68
48
13
5
Nondepository
Institution
61
489,804
45,408
136
62
15
10
5
Security
&
commodity
brokers
62
522,895
40,961
115
63
14
9
5
Insurance
carriers
63
1,502,920
41,330
594
287
93
80
22
14
Insurance
agents,
brokers,
&
servicers
64
676,602
125,361
70
20
2
5
Real
Estate
65
1,402,828
246,119
212
64
8
1
1
Holding
&
other
investment
offices
67
255,044
23,202
71
27
5
5
3
Administrative
&
Auxiliary
­
68,799
1,452
50
18
3
2
SERVICES
Hotels
&
other
lodging
places
70
1,575,077
54,130
669
261
66
35
30
4
Personal
services
72
1,281,898
202,349
156
12
3
2
1
Business
services
73
6,824,962
352,658
2,651
1,031
217
123
61
22
Auto
repair,
services,
&
parking
75
990,658
181,336
62
18
1
Misc.
repair
services
76
456,425
73,562
33
5
2
Motion
picture
78
511,651
42,946
40
17
5
5
5
5
Amusement
&
recreation
services
79
1,324,194
93,500
242
107
42
19
8
3
Health
services
80
10,851,331
478,286
2,528
1,525
731
611
310
65
Legal
services
81
960,693
163,554
167
49
2
1
Educational
services
82
2,066,531
46,224
521
323
140
80
37
33
Social
services
83
2,263,314
155,846
475
97
12
6
Museums,
botanical,
zoological
gardens
84
76,079
3,790
40
7
1
1
1
Membership
organization
86
2,151,350
243,592
274
61
15
7
3
3
Engineering
&
management
service
87
2,795,304
269,243
673
255
50
60
21
10
Service
89
100,472
14,877
14
6
1
1
Administrative
&
Auxiliary
­
477,226
9,639
221
92
31
11
4
3
Unclassified
­
105,336
68,916
1
Note:
(D)
Data
withheld
to
avoid
disclosing
data
for
individual
companies:
data
included
in
broader
industry
totals.

Source:
US
Bureau
of
Census,
County
Business
Patterns
1995.
August
24,
2001
­
DRAFT
Page
B­
1
Appendix
B
Computer
Use
By
Employees
SIC
Category
Number
of
Survey
Respondents
Employed
Respondents
Using
a
Computer
at
Work
Computer
Use
per
Employee
in
1993
Estimated
Computer
Use
per
Employee
in
2001
All
industries
118,400
51,106
0.43
0.56
Agriculture
services
968
160
0.17
0.24
Other
agriculture
2006
219
0.11
0.16
Mining
689
307
0.45
0.46
Construction
7,567
1,182
0.16
0.25
Lumber
and
wood
841
114
0.14
0.17
Furniture
665
161
0.24
0.30
Stone,
clay
568
165
0.29
0.36
Primary
metals
653
217
0.33
0.42
Fabricated
metals
1,290
442
0.34
0.43
Machinery,
excluding
electric
2,238
1,233
0.55
0.69
Electrical
machinery
1,689
950
0.56
0.70
Motor
vehicles
1,120
428
0.38
0.48
Aircraft
and
parts
502
335
0.67
0.84
Other
transportation
624
376
0.60
0.75
Professional
photo
equipment
680
406
0.60
0.75
Toys,
sporting
goods
128
44
0.34
0.43
Miscellaneous
manufacturing
437
100
0.23
0.29
Food
and
kindred
products
1,776
532
0.30
0.37
Tobacco
manufacturing
52
25
0.48
0.60
Textile
mill
products
664
177
0.27
0.33
Apparel
&
other
finished
goods
970
143
0.15
0.18
Paper
and
allied
products
740
339
0.46
0.57
Printing,
publishing
1,705
857
0.50
0.63
Chemicals
and
allied
products
1,220
729
0.60
0.75
Petroleum,
coal
145
88
0.61
0.76
Rubber
and
plastics
791
293
0.37
0.46
Leather
and
leather
products
107
24
0.22
0.28
Transportation
5,410
1,866
0.34
0.42
Communications
1,637
1,283
0.78
0.96
Utilities
&
sanitary
1,501
807
0.54
0.66
Wholesale
trade
4,531
2,226
0.49
0.66
Retail
trade
18,706
5,837
0.31
0.42
Banking
and
finance
3,417
2,888
0.85
0.99
Insurance
&
real
estate
4,561
3,094
0.68
0.79
Private
household
services
1,099
16
0.01
0.02
Business
services
5,038
2,646
0.53
0.75
SIC
Category
Number
of
Survey
Respondents
Employed
Respondents
Using
a
Computer
at
Work
Computer
Use
per
Employee
in
1993
Estimated
Computer
Use
per
Employee
in
2001
August
24,
2001
­
DRAFT
Page
B­
2
Repair
services
1,915
382
0.20
0.28
Personal
services
3,220
662
0.21
0.29
Entertainment,
recreation
1,735
538
0.31
0.44
Hospitals
5,182
3,105
0.60
0.85
Health
services,
excluding
hospitals
5,377
1,963
0.37
0.52
Education
services
9,845
5,066
0.51
0.73
Social
services
2,721
753
0.28
0.39
Other
professional
5,578
3,735
0.67
0.95
Forestry,
fisheries
166
56
0.34
0.48
Justice,
public
order
2,179
1,324
0.61
0.69
Administration
human
resource
834
632
0.76
0.86
National
security
802
597
0.74
0.85
Other
public
administration
2,112
1,584
0.75
0.85
Sources:
1993
Census
Data,
Table
7WK
Uses
of
Computers
at
work,
by
Sex
and
Intermediate
Industry,
in
"Computer
Use
in
the
United
States:
October
1993."
and
Table
D
Use
of
Computers
at
Work
by
People
18
Years
and
Older
by
Gender:
October
1997,
"Computer
Use
in
the
United
States:
October
1997."
August
24,
2001
­
DRAFT
Page
C­
1
Appendix
C
Disposal
Cost
Source
Details
Disposal
Option
Source
Source
Cost
per
Ton
Year
of
cost
estimate
Cost
(Price
Paid)
per
Ton
(2001$)

Collectors
1
$
240
1998
2
$
400
2001
3
$
0
2001
4
$
383
1997
Average
$
250
1998
$
271
Export
4
$
100
1999
$
107
Reuse
None
$
0
2001
$
0
Treatment
and
Subtitle
C
or
D
Landfill
Disposal
Whole
CRTs
5
$
1,196
1998
6
$1,300
2001
7
$
1,500
2001
Value
used
in
analysis
$
1,500
2001
$
1,500
Crushed
CRTs
7
$
160
2001
8
$
100
2000
9
$
125
2000
Value
used
in
analysis
$
160
2001
$
160
Subtitle
D
Landfill
Disposal
8
$
40
2000
$
41
Reclaimer
4
$
667
1997
8
$
200
2000
8
$
420
2000
10
$
200
1998
Disposal
Option
Source
Source
Cost
per
Ton
Year
of
cost
estimate
Cost
(Price
Paid)
per
Ton
(2001$)

August
24,
2001
­
DRAFT
Page
C­
2
10
$
350
1998
11
$
140
1998
12
$
200
1997
12
$
500
1997
13
$
200
1997
13
$
300
1997
14
$
200
1998
Whole
CRTs
­
Average
$
284
2000
$
295
Whole
bare
CRTs
­
Average
$
200
2000
$
207
Crushed
CRTs
­
Average
$
140
1998
$
152
Glass
Processor
Broken
CRTs
with
no
metal
15,16
$
0
2001
$
0
Broken
CRTs
with
metal
$
100
2001
$
100
Whole
bare
CRTs
$
192
2001
$
192
Broken
mixed
color
and
monochrome
CRTs
$
325
2001
$
325
Whole
CRTs
$
333
2001
$
333
CRT
Glass
Manufacturer
15
($
175)
2001
($
175)
August
24,
2001
­
DRAFT
Page
C­
3
Source
Number
Source
Title
1
DMC
Recycling
Inc,
1998.

2
F&
M
Bay
Electronics
Co.
Inc./
SEER
Inc.,
2001.

3
WasteNot
Recycling,
2001.

4
U.
S.
Environmental
Protection
Agency,
Region
1.
Analysis
of
Five
Community
Consumer/
Residential
Collections,
End­
of­
Life
Electronic
and
Electrical
Equipment.
EPA­
901­
R­
98­
003,
April
1999.

5
Personal
communications
with
Chem
Waste
Management,
1998.

6
Personal
communications
with
Clean
Harbors
of
Braintree,
2001.

7
Personal
communications
with
Envirosafe
Services
of
Ohio,
2001.

8
U.
S.
Environmental
Protection
Agency,
Office
of
Solid
Waste,
Economics,
Methods
and
Risk
Analysis
Division.
Unit
Cost
Compendium.
September
30,
2000.

9
ETC's
landfill
cost
survey,
2000.

10
Personal
communications
with
Noranda,
1998.

11
Personal
communications
with
Doe
Run,
1998.

12
Aanstoos,
T.,
Mizuki,
C.,
Nichols,
S.,
and
Pitts,
G.
CRT
Disposition:
An
Assessment
of
Limitations
and
Opportunities
in
Reuses,
Refurbishment,
and
Recycling
in
the
U.
S.,
IEEE
International
Symposium
on
Electronics
&
the
Environment,
1997.

13
Cutter
Information
Corp.
's
"Product
Stewardship
Advisor"
Vol.
I,
No.
4,
1997.

14
National
Safety
Council,
Electronic
Product
Recovery
and
Recycling
Baseline
Report,
Recycling
of
Selected
Electronic
Products
in
the
United
States.
May
1999.

15
Personal
communications
with
Greg
Voorhees
of
Envirocycle,
2001.

16
Price
list
from
Envirocycle,
2001.
August
24,
2001
­
DRAFT
Page
D­
1
Appendix
D
Flow
of
CRTs
under
Subtitle
C
(Number)

Total
Number
of
CRTs
To
Collector
To
Reuse
To
MSW
Landfill
(Subtitle
D)
To
HW
Landfill
(Subtitle
C)
To
Reclaimer
To
Glass
Processor
To
Exporter
To
CRT
Manufacturer
Baseline
Original
Users
SQGs
CRT
only
2,036,512
1,547,749
40,730
40,730
305,477
101,826
SQGs
all
HW
105,753
79,315
26,438
LQGs
CRT
only
453,584
344,724
9,072
9,072
68,038
22,679
LQGs
all
HW
45,517
34,138
11,379
Collectors
SQGs
167,160
33,432
3,343
38,447
41,790
50,148
LQGs
1,838,765
367,753
183,877
183,877
551,630
551,630
Glass
Processor
Funnel
glass
245,826
4,917
240,910
Panel
glass
472,098
9,442
462,656
All
CRTs
2,005,925
450,987
0
274,839
610,196
717,924
601,778
703,566
Primary
Alternative
Original
Users
SQGs
CRT
only
40,727
40,727
SQGs
all
HW
2,129
2,129
LQGs
CRT
only
8,919
8,919
LQGs
all
HW
920
920
Former
SQG
­
CRT
only
1,995,785
1,556,712
39,916
299,368
99,789
Former
SQG
­
all
HW
103,624
80,827
2,072
15,544
5,181
Total
Number
of
CRTs
To
Collector
To
Reuse
To
MSW
Landfill
(Subtitle
D)
To
HW
Landfill
(Subtitle
C)
To
Reclaimer
To
Glass
Processor
To
Exporter
To
CRT
Manufacturer
August
24,
2001
­
DRAFT
Page
D­
2
Former
LQG
­
CRT
only
444,665
346,839
8,893
66,700
22,233
Former
LQG
­
all
HW
44,597
34,786
892
6,690
2,230
Collectors
SQGs
3,365
673
67
774
841
1,010
LQGs
37,018
7,404
740
5,553
16,658
6,663
Former
SQG
164,898
32,980
41,225
41,225
49,470
Former
LQG
1,813,882
362,776
308,360
816,247
326,499
Glass
Processor
Funnel
glass
343,921
6,878
337,042
Panel
glass
660,484
13,210
647,274
All
CRTs
2,019,164
455,606
0
53,502
764,300
1,004,405
383,641
984,317
CSI
Alternative
Original
Users
SQGs
CRT
only
305,535
45,830
259,705
SQGs
all
HW
15,843
2,376
13,467
LQGs
CRT
only
67,528
10,129
57,399
LQGs
all
HW
6,845
1,027
5,819
Collectors
SQGs
164,678
32,936
3,294
37,876
41,170
49,404
LQGs
1,811,462
362,292
36,229
235,490
815,158
362,292
Glass
Processor
Funnel
glass
370,110
7,402
362,708
Panel
glass
710,779
14,216
696,563
CSI
Handlers
CSI
SQHs
2,245,614
1,976,140
44,912
224,561
Total
Number
of
CRTs
To
Collector
To
Reuse
To
MSW
Landfill
(Subtitle
D)
To
HW
Landfill
(Subtitle
C)
To
Reclaimer
To
Glass
Processor
To
Exporter
To
CRT
Manufacturer
August
24,
2001
­
DRAFT
Page
D­
3
CSQ
LQHs
All
CRTs
1,976,140
440,140
0
98,886
631,373
1,080,889
411,696
1,059,271
Flow
of
CRTs
under
Subtitle
C
(Tons)

Total
Tons
of
CRTs
To
Collector
To
Reuse
To
MSW
Landfill
(Subtitle
D)
To
HW
Landfill
(Subtitle
C)
To
Reclaimer
To
Glass
Processor
To
Exporter
To
CRT
Manufacturer
Baseline
Original
Users
SQGs
CRT
only
35,639
27,086
713
713
5,346
1,782
SQGs
all
HW
1,851
1,388
463
LQGs
CRT
only
7,938
6,033
159
159
1,191
397
LQGs
all
HW
797
597
199
Collectors
SQGs
2,925
585
35
404
439
878
LQGs
32,178
6,436
1,931
1,931
5,792
9,654
Glass
Processor
Funnel
glass
2,581
52
2,530
Panel
glass
4,957
99
4,858
All
CRTs
35,104
7,892
3,499
9,022
7,538
10,531
7,387
Primary
Alternative
Original
Users
SQGs
CRT
only
713
713
SQGs
all
HW
37
37
LQGs
CRT
only
156
156
LQGs
all
HW
16
16
Total
Tons
of
CRTs
To
Collector
To
Reuse
To
MSW
Landfill
(Subtitle
D)
To
HW
Landfill
(Subtitle
C)
To
Reclaimer
To
Glass
Processor
To
Exporter
To
CRT
Manufacturer
August
24,
2001
­
DRAFT
Page
D­
4
Former
SQG
­
CRT
only
34,926
27,242
699
5,239
1,746
Former
SQG
­
all
HW
1,813
1,414
36
272
91
Former
LQG
­
CRT
only
7,782
6,070
156
1,167
389
Former
LQG
­
all
HW
780
609
16
117
39
Collectors
SQHs
59
12
1
8
9
18
LQHs
648
130
8
58
175
117
Former
SQH
2,886
577
433
433
866
Former
LQH
31,743
6,349
3,238
8,571
5,714
Glass
Processor
Funnel
glass
3,611
72
3,539
Panel
glass
6,935
139
6,796
All
CRTs
35,335
7,973
931
10,743
10,546
6,714
10,335
CSI
Alternative
Original
Users
SQGs
CRT
only
5,347
802
4,545
SQGs
all
HW
277
42
236
LQGs
CRT
only
1,182
177
1,004
LQGs
all
HW
120
18
102
Collectors
SQHs
2,882
576
35
398
432
865
LQHs
31,701
6,340
380
2,473
8,559
6,340
Glass
Processor
Total
Tons
of
CRTs
To
Collector
To
Reuse
To
MSW
Landfill
(Subtitle
D)
To
HW
Landfill
(Subtitle
C)
To
Reclaimer
To
Glass
Processor
To
Exporter
To
CRT
Manufacturer
August
24,
2001
­
DRAFT
Page
D­
5
Funnel
glass
3,886
78
3,808
Panel
glass
7,463
149
7,314
CSI
Handlers
CSI
SQHs
39,298
34,582
786
3,930
CSQ
LQHs
All
CRTs
34,582
7,702
0
1,454
8,984
11,349
7,205
11,122
Bolded
entries
include
the
weight
of
the
CRT
glass
only.
Non­
bolded
entries
include
the
weight
of
the
entire
monitor.
August
24,
2001
­
DRAFT
Page
D­
6
Flow
of
CRTs
under
Subtitle
D
(Number)

Total
Number
of
CRTs
To
Collector
To
Reuse
To
MSW
Landfill
(Subtitle
D)
To
HW
Landfill
(Subtitle
C)
To
Reclaimer
To
Glass
Processor
To
Exporter
To
CRT
Manufacturer
Baseline
Original
Users
SQGs
CRT
only
2,036,512
122,191
40,730
1,629,210
40,730
101,826
101,826
SQGs
all
HW
105,753
10,575
84,602
10,575
LQGs
CRT
only
453,584
27,215
9,072
362,867
9,072
22,679
22,679
LQGs
all
HW
45,517
4,552
36,414
4,552
Collectors
SQGs
13,711
2,742
6,856
686
686
2,742
LQGs
150,822
30,164
64,853
3,016
7,541
15,082
30,164
Glass
Processor
Funnel
glass
48,031
961
47,070
Panel
glass
92,241
1,845
90,397
All
CRTs
164,533
82,708
2,184,802
67,945
135,537
140,273
32,907
137,467
PrimaryAlternative
Original
Users
SQGs
CRT
only
40,727
40,727
SQGs
all
HW
2,129
2,129
LQGs
CRT
only
8,919
8,919
LQGs
all
HW
920
920
Former
SQG
CRT
only
1,995,785
199,579
39,916
1,496,839
139,705
119,747
Former
SQG
­HW
103,624
10,362
2,072
77,718
7,254
6,217
Former
LQG­
CRT
only
444,665
44,467
8,893
333,499
31,127
26,680
Total
Number
of
CRTs
To
Collector
To
Reuse
To
MSW
Landfill
(Subtitle
D)
To
HW
Landfill
(Subtitle
C)
To
Reclaimer
To
Glass
Processor
To
Exporter
To
CRT
Manufacturer
August
24,
2001
­
DRAFT
Page
D­
7
Former
LQG
­HW
44,597
4,460
892
33,448
3,122
2,676
Collectors
SQGs
431
86
173
9
56
43
65
LQGs
4,746
949
1,898
95
380
712
712
Former
SQG
21,141
4,228
8,456
3,171
2,114
3,171
Former
LQG
232,549
46,510
93,020
23,255
34,882
34,882
Glass
Processor
Funnel
glass
66,110
1,322
64,788
Panel
glass
126,962
2,539
124,422
All
CRTs
39,031
17,564
405,924
9,793
29,046
30,086
5,855
29,485
CSIAlternative
Original
Users
SQGs
CRT
only
305,535
183,321
45,830
76,384
SQGs
all
HW
15,843
9,506
2,376
3,961
LQGs
CRT
only
67,528
40,517
10,129
16,882
LQGs
all
HW
6,845
4,107
1,027
1,711
Collectors
SQGs
18,713
3,743
7,111
374
1,871
1,871
3,743
LQGs
205,848
41,170
78,222
4,117
10,292
30,877
41,170
Glass
Processor
Funnel
glass
88,106
1,762
86,344
Panel
glass
169,204
3,384
165,820
CSI
Handlers
CSI
SQHs
2,245,614
224,561
44,912
1,751,579
224,561
CSI
LQHs
All
CRTs
258,867
103,547
2,045,051
52,798
211,930
193,072
38,830
189,210
August
24,
2001
­
DRAFT
Page
D­
8
Flow
of
CRTs
under
Subtitle
D
(Tons)

Total
Tons
of
CRTs
To
Collector
To
Reuse
To
MSW
Landfill
(Subtitle
D)
To
HW
Landfill
(Subtitle
C)
To
Reclaimer
To
Glass
Processor
To
Exporter
To
CRT
Manufacturer
Baseline
Original
Users
SQGs
CRT
only
35,639
2,138
713
28,511
713
1,782
1,782
SQGs
all
HW
1,851
185
1,481
185
LQGs
CRT
only
7,938
476
159
6,350
159
397
397
LQGs
all
HW
797
80
637
80
Collectors
SQGs
240
48
120
0
7
7
48
LQGs
2,639
528
1,135
32
79
158
528
Glass
Processor
Funnel
glass
504
10
494
Panel
glass
969
19
949
All
CRTs
2,879
1,447
38,234
1,168
2,295
1,473
576
1,443
PrimaryAlternative
Original
Users
SQGs
CRT
only
713
713
SQGs
all
HW
37
37
LQGs
CRT
only
156
156
LQGs
all
HW
16
16
Former
SQG
CRT
only
34,926
3,493
699
26,195
2,445
2,096
Former
SQG
HW
1,813
181
36
1,360
127
109
Former
LQGCRT
only
7,782
778
156
5,836
545
467
Former
LQG
HW
780
78
16
585
55
47
Total
Tons
of
CRTs
To
Collector
To
Reuse
To
MSW
Landfill
(Subtitle
D)
To
HW
Landfill
(Subtitle
C)
To
Reclaimer
To
Glass
Processor
To
Exporter
To
CRT
Manufacturer
August
24,
2001
­
DRAFT
Page
D­
9
Collectors
SQHs
8
2
3
0
1
0
1
LQHs
83
17
33
1
4
7
12
Former
SQH
370
74
148
33
22
55
Former
LQH
4,070
814
1,628
244
366
610
Glass
Processor
Funnel
glass
694
14
680
Panel
glass
1,333
27
1,306
All
CRTs
4,530
1,812
35,788
923
3,494
2,027
680
1,987
CSI
Alternative
Original
User
SQGs
CRT
only
5,347
3,208
802
1,337
SQGs
all
HW
277
166
42
69
LQGs
CRT
only
1,182
709
177
295
LQGs
all
HW
120
72
18
30
Collectors
SQGs
327
65
124
4
20
20
65
LQGs
3,602
720
1,369
43
108
324
720
Glass
Processor
Funnel
glass
925
19
907
Panel
glass
1,777
36
1,741
CSI
Handlers
CSI
SQHs
39,298
3,930
786
30,653
3,930
CSI
LQHs
All
CRTs
3,930
1,572
36,301
1,086
1,913
2,702
786
2,648
Bolded
entries
include
the
weight
of
the
CRT
glass
only.
Non­
bolded
entries
include
the
weight
of
the
entire
monitor.
August
24,
2001
­
DRAFT
Page
E­
1
Appendix
E
Average
Shipment
Sizes
for
Each
Type
of
Establishment
Distributing
CRTs
to
Each
CRT
Management
Option
To
Collector
To
Reuse
To
HW
(Subtitle
C)
To
Reclaimer
To
Glass
Processor
To
Exporter
To
CRT
Manufacturer
Baseline
­
Subtitle
C
SQGs
CRT
only
1.4
1.4
1.4
1.4
1.4
SQGs
all
HW
0.4
­
0.4
­
­

LQGs
CRT
only
5.2
5.1
5.1
5.2
5.1
LQGs
all
HW
0.2
­
0.2
­
­

SQHs
11.8
7.1
7.4
7.4
11.8
LQHs
13.0
8.1
8.1
8.1
13.0
Glass
Processor
­
Funnel
9.3
13.2
Glass
Processor
­
Panel
13.4
13.6
Primary
Alternative
­
Subtitle
C
SQGs
CRT
only
­
­
1.4
­
­

SQGs
all
HW
­
­
0.4
­
­

LQGs
CRT
only
­
­
5.2
­
­

LQGs
all
HW
­
­
0.2
­
­

SQHs
9.5
0.6
6.6
7.1
7.1
LQHs
13.1
6.3
7.8
7.8
11.8
Glass
Processor
­
Funnel
12.7
13.5
Glass
Processor
­
Panel
12.2
13.8
Former
SQG
­
CRT
only
PA
2.8
2.8
­
2.8
2.8
Former
SQG
­
HW
PA
0.8
0.8
­
0.8
0.8
Former
LQG
­
CRT
only
PA
20.7
19.8
­
20.7
19.8
Former
LQG
­
HW
PA
0.8
0.7
­
0.8
0.8
Former
SQH
11.6
­
7.4
7.4
11.8
Former
LQH
21.9
­
13.7
13.8
21.9
CSI
Alternative
­
Subtitle
C
SQGs
CRT
only
­
­
1.4
1.4
­

SQGs
all
HW
­
­
0.4
0.4
­

LQGs
CRT
only
­
­
­
­
­

LQGs
all
HW
­
­
0.6
0.6
­

SQHs
11.6
7.0
7.3
7.3
11.6
LQHs
12.8
7.9
8.0
8.0
12.8
Glass
Processor
­
Funnel
13.2
13.6
Glass
Processor
­
Panel
12.7
13.6
CSI
SQHs
­
­
­
­
­

CSI
LQHs
­
­
­
­
­

Number
of
Shipments
each
Year
Under
Subtitle
C
August
24,
2001
­
DRAFT
Page
E­
2
Collectors
Reuse
Subtitle
C
Disposal
Reclaimers
Glass
Processors
Exporters
CRT
Glass
Manufacturers
Totals
Baseline
Original
Users
SQGs
CRT
only
15,526
409
409
3,065
1,022
20,431
SQGs
all
HW
3,342
1,114
4,456
LQGs
CRT
only
888
24
24
176
59
1,171
LQGs
all
HW
2,763
921
3,684
Collectors
SQGs
40
4
44
48
60
196
LQGs
400
192
192
574
600
1,958
Glass
Processors
Funnel
glass
2
94
96
Panel
glass
4
172
176
Primary
Alternative
Original
Users
SQGs
CRT
only
408
408
SQGs
all
HW
90
90
LQGs
CRT
only
24
24
LQGs
all
HW
72
72
Former
SQG
CRT
only
15,616
401
3,003
1,001
20,021
Former
SQG
­all
HW
1,703
44
328
110
2,185
Former
LQG
CRT
only
2,454
63
472
158
3,147
Former
LQG
­all
HW
705
19
136
46
906
Collectors
SQGs
1
1
1
1
2
6
LQGs
8
1
6
18
8
41
Former
SQGs
40
47
47
59
193
Former
LQGs
294
211
633
294
1,432
Glass
Processors
Funnel
glass
3
128
131
Panel
glass
5
241
246
CSI
Alternative
Collectors
Reuse
Subtitle
C
Disposal
Reclaimers
Glass
Processors
Exporters
CRT
Glass
Manufacturers
Totals
August
24,
2001
­
DRAFT
Page
E­
3
Original
Users
SQGs
CRT
only
460
2,605
3,065
SQGs
all
HW
101
568
669
LQGs
CRT
only
27
150
177
LQGs
all
HW
83
470
553
Collectors
SQHs
40
4
44
48
60
196
LQHs
400
39
287
861
360
1,947
Glass
Processors
Funnel
glass
3
138
141
Panel
glass
6
260
266
CSI
Handlers
CSI
SQHs
30,643
697
3,483
34,823
CSI
LQHs
August
24,
2001
­
DRAFT
Page
F­
1
Appendix
F
Average
Annual
Sales
per
Establishment
by
2­
Digit
SIC
Code
Industry
SIC
Code
Average
Sales
per
Establishment
($)

AGRICULTURE
Agricultural
services
7
$
­

Forestry
8
$
­

Fishing,
hunting,
trapping
9
$
­

Administrative
&
Auxiliary
MINING
Metal
Mining
10
$
9,642,717
Coal
Mining
12
$
8,841,349
Oil
&
Gas
Extraction
13
$
5,338,313
Non­
metallic
minerals,
except
fuels
14
$
2,338,749
Administrative
&
Auxiliary
­
$
1,545,768
CONSTRUCTION
General
contractors
15
$
1,280,404
Heavy
construction
16
$
2,570,507
Special
trade
contractors
17
$
590,600
Administrative
&
Auxiliary
­
$
2,207,600
MANUFACTURING
Food
&
kindred
products
20
$
19,567,362
Tobacco
products
21
$
308,752,632
Textile
mill
products
22
$
12,020,557
Apparel
&
other
textile
products
23
$
3,103,014
Lumber
&
wood
products
24
$
2,277,901
Furniture
&
Fixtures
25
$
3,759,298
Paper
&
allied
products
26
$
20,760,708
Printing
&
publishing
27
$
2,540,878
Chemicals
&
allied
products
28
$
25,443,194
Petroleum
and
coal
products
29
$
70,728,296
Rubber
&
miscellaneous
plastics
products
30
$
7,170,357
Leather
&
leather
products
31
$
4,751,863
Stone,
clay,
and
glass
products
32
$
3,846,475
Primary
metal
industries
33
$
21,271,651
Fabricated
metal
products
34
$
4,571,413
Industrial
machinery
&
equipment
35
$
4,793,932
Electronic
&
other
electronic
equipment
36
$
12,809,615
Industry
SIC
Code
Average
Sales
per
Establishment
($)

August
24,
2001
­
DRAFT
Page
F­
2
Transportation
equipment
37
$
35,374,262
Instrument
&
related
products
38
$
11,884,834
Miscellaneous
manufacturing
39
$
2,318,656
Administrative
&
Auxiliary
­
$
3,156,356
TRANSPORTATION
Local
&
Interurban
passenger
transit
41
$
710,436
Trucking
&
Warehousing
42
$
1,296,519
Water
transportation
44
$
3,585,027
Transportation
by
Air
45
$
2,338,134
Pipelines,
except
natural
gases
46
$
8,368,550
Transportation
services
47
$
512,735
Communication
48
$
5,877,769
Electronic,
gas,
&
sanitary
services
49
$
15,510,062
Administrative
&
Auxiliary
­
$
1,766,775
WHOLESALE
TRADE
Wholesale
trade­
durable
goods
50
$
5,084,711
Wholesale
trade­
nondurable
goods
51
$
9,036,867
Administrative
&
Auxiliary
­
$
781,548
RETAIL
TRADE
Bldg.
Materials
&
garden
supplies
52
$
1,422,393
General
merchandise
store
53
$
7,089,224
Food
stores
54
$
2,044,651
Auto
dealers
&
service
station
55
$
4,100,193
Apparel
&
accessory
stores
56
$
699,117
Furniture
&
home
furnishing
stores
57
$
846,766
Eating
&
drinking
places
58
$
450,446
Miscellaneous
retail
59
$
607,995
Administrative
&
Auxiliary
­
$
370,918
FINANCE,
INSURANCE,
AND
REAL
ESTATE
Depository
Institution
60
$
5,091,211
Nondepository
Institution
61
$
3,432,819
Security
&
commodity
brokers
62
$
3,491,738
Insurance
carriers
63
$
20,422,940
Insurance
agents,
brokers,
&
servicers
64
$
424,989
Real
Estate
65
$
617,331
Holding
&
other
investment
offices
67
$
3,237,932
Administrative
&
Auxiliary
­
$
1,054,687
Industry
SIC
Code
Average
Sales
per
Establishment
($)

August
24,
2001
­
DRAFT
Page
F­
3
SERVICES
Hotels
&
other
lodging
places
70
$
1,423,393
Personal
services
72
$
219,582
Business
services
73
$
896,726
Auto
repair,
services,
&
parking
75
$
407,237
Misc.
repair
services
76
$
429,359
Motion
picture
78
$
1,040,439
Amusement
&
recreation
services
79
$
793,715
Health
services
80
$
677,073
Legal
services
81
$
641,030
Educational
services
82
$
491,509
Social
services
83
$
225,786
Museums,
botanical,
zoological
gardens
84
$
611,305
Membership
organization
86
$
500,857
Engineering
&
management
service
87
$
827,956
Services,
n.
e.
c
89
$
546,119
Administrative
&
Auxiliary
­
$
1,053,680
Unclassified
­
NA
Source:
U.
S.
Bureau
of
the
Census
(1992).
Includes
County
Business
Patterns
data
and
data
from
the
Enterprise
Statistics
Program.
August
24,
2001
­
DRAFT
Page
G­
1
Appendix
G
Detailed
Sensitivity
Analysis
Results
on
All
Parameters
Tested
Parameter
Names
Sensitivity
Test
Parameter
Values
Percent
Change
from
Best
Estimate
Savings
Under
Primary
Alternative
Savings
Under
Primary
Alternative
Using
the
Sensitivity
Test
Parameter
Values
Percent
increase
(decrease)
in
amount
saved
Savings
Under
CSI
Alternative
Savings
Under
CSI
Alternative
Using
the
Sensitivity
Test
Parameter
Values
Percent
increase
(decrease)
in
amount
saved
Entry/
exit
rate
for
establishments
Best
Estimate
1
%

Low
Range
0.10
%
­90
%
$
4,840,000
$
4,811,000
­1
%
$
3,098,000
$
3,095,000
0
%

High
Range
5
%
400
%
$
4,840,000
$
4,962,000
3
%
$
3,098,000
$
3,109,000
0
%

Percent
laptops
disposed
Best
Estimate
18
%

Low
Range
10
%
­44
%
$
4,840,000
$
4,830,000
0
%
$
3,098,000
$
3,127,000
1
%

High
Range
33
%
83
%
$
4,840,000
$
4,132,000
­15
%
$
3,098,000
$
2,582,000
­17
%

Percent
funnel
glass
(vs
panel
glass)

Best
Estimate
34
%

Low
Range
30
%
­12
%
$
4,840,000
$
4,840,000
0
%
$
3,098,000
$
3,098,000
0
%

High
Range
40
%
18
%
$
4,840,000
$
4,840,000
0
%
$
3,098,000
$
3,098,000
0
%

Percent
of
shipments
that
include
broken
CRTs
Best
Estimate
100
%

Low
Range
25
%
­75
%
$
4,840,000
$
4,754,000
­2
%
$
3,098,000
$
3,005,000
­3
%

High
Range
100
%
0
%
$
4,840,000
$
4,840,000
0
%
$
3,098,000
$
3,098,000
0
%

Percent
of
CRTs
sent
to
SQ
Collectors
Best
Estimate
8
%

Low
Range
2
%
­75
%
$
4,840,000
$
4,812,000
­1
%
$
3,098,000
$
3,152,000
2
%

High
Range
50
%
525
%
$
4,840,000
$
5,002,000
3
%
$
3,098,000
$
2,850,000
­8
%

Percent
of
CRTs
sent
to
former
SQ
Collectors
(Primary
Alternative
only)

Best
Estimate
98
%

Low
Range
50
%
­49
%
$
4,840,000
$
4,347,000
­10
%
N/
A
N/
A
N/
A
High
Range
99
%
1
%
$
4,840,000
$
4,849,000
0
%
N/
A
N/
A
N/
A
Percent
of
generators
sending
to
reuse
Parameter
Names
Sensitivity
Test
Parameter
Values
Percent
Change
from
Best
Estimate
Savings
Under
Primary
Alternative
Savings
Under
Primary
Alternative
Using
the
Sensitivity
Test
Parameter
Values
Percent
increase
(decrease)
in
amount
saved
Savings
Under
CSI
Alternative
Savings
Under
CSI
Alternative
Using
the
Sensitivity
Test
Parameter
Values
Percent
increase
(decrease)
in
amount
saved
August
24,
2001
­
DRAFT
Page
G­
2
Best
Estimate
2
%

Low
Range
0
%
­100
%
$
4,840,000
$
4,767,000
­2
%
$
3,098,000
$
3,195,000
3
%

High
Range
15
%
650
%
$
4,840,000
$
4,893,000
1
%
$
3,098,000
$
2,851,000
­8
%

Percent
of
CRTs
sent
for
export
(Baseline
only)

Best
Estimate
30
%

Low
Range
10
%
­67
%
$
4,840,000
$
4,630,000
­4
%
$
3,098,000
$
2,888,000
­7
%

High
Range
50
%
67
%
$
4,840,000
$
4,764,000
­2
%
$
3,098,000
$
3,022,000
­2
%

Percent
of
CRTs
sent
for
export
(Primary
Alternative
only)

Best
Estimate
30
%
or
18
%

Low
Range
5
%
­83
%
or
­72
%
$
4,840,000
$
5,244,000
8
%
N/
A
N/
A
N/
A
High
Range
30
%
0
%
or
66
%
$
4,840,000
$
4,523,000
­7
%
N/
A
N/
A
N/
A
Percent
of
CRTs
sent
for
export
(CSI
Alternative
only)

Best
Estimate
30
%
or
20
%

Low
Range
5
%
0
%
or
­75
%
N/
A
N/
A
N/
A
$
3,098,000
$
3,487,000
13
%

High
Range
40
%
33
%
or
100
%
N/
A
N/
A
N/
A
$
3,098,000
$
2,627,000
­15
%

Maximum
shipment
weight
(in
tons)
for
whole
CRTs
Best
Estimate
22
Low
Range
18
­18
%
$
4,840,000
$
4,670,000
­4
%
$
3,098,000
$
3,085,000
0
%

High
Range
24
9
%
$
4,840,000
$
4,897,000
1
%
$
3,098,000
$
3,104,000
0
%

Maximum
shipment
weight
(in
tons)
for
crushed
CRTs
Best
Estimate
23
Low
Range
20
­13
%
$
4,840,000
$
4,932,000
2
%
$
3,098,000
$
3,104,000
0
%

High
Range
25
9
%
$
4,840,000
$
4,788,000
­1
%
$
3,098,000
$
3,091,000
0
%

Shipping
Distances
(in
miles):

to
Handler
Best
Estimate
20
Low
Range
5
­75
%
$
4,840,000
$
4,840,000
0
%
$
3,098,000
$
3,096,000
0
%

High
Range
50
150
%
$
4,840,000
$
4,838,000
0
%
$
3,098,000
$
3,100,000
0
%

to
Reuse
Best
Estimate
20
Parameter
Names
Sensitivity
Test
Parameter
Values
Percent
Change
from
Best
Estimate
Savings
Under
Primary
Alternative
Savings
Under
Primary
Alternative
Using
the
Sensitivity
Test
Parameter
Values
Percent
increase
(decrease)
in
amount
saved
Savings
Under
CSI
Alternative
Savings
Under
CSI
Alternative
Using
the
Sensitivity
Test
Parameter
Values
Percent
increase
(decrease)
in
amount
saved
August
24,
2001
­
DRAFT
Page
G­
3
Low
Range
5
­75
%
$
4,840,000
$
4,840,000
0
%
$
3,098,000
$
3,097,000
0
%

High
Range
50
150
%
$
4,840,000
$
4,839,000
0
%
$
3,098,000
$
3,099,000
0
%

to
Subtitle
C
Landfill
Best
Estimate
250
Low
Range
100
­60
%
$
4,840,000
$
4,738,000
­2
%
$
3,098,000
$
3,018,000
­3
%

High
Range
500
100
%
$
4,840,000
$
5,008,000
3
%
$
3,098,000
$
3,230,000
4
%

to
Glass
Processor
Best
Estimate
200
Low
Range
100
­50
%
$
4,840,000
$
4,767,000
­2
%
$
3,098,000
$
3,137,000
1
%

High
Range
400
100
%
$
4,840,000
$
4,984,000
3
%
$
3,098,000
$
3,017,000
­3
%

to
CRT
Glass
Manufacturer
Best
Estimate
100
Low
Range
50
­50
%
$
4,840,000
$
4,844,000
0
%
$
3,098,000
$
3,104,000
0
%

High
Range
200
100
%
$
4,840,000
$
4,829,000
0
%
$
3,098,000
$
3,085,000
0
%

to
Reclaimer
(from
Generator
or
Collectors)

Best
Estimate
300
Low
Range
100
­67
%
$
4,840,000
$
4,744,000
­2
%
$
3,098,000
$
3,116,000
1
%

High
Range
500
67
%
$
4,840,000
$
4,935,000
2
%
$
3,098,000
$
3,080,000
­1
%

to
Reclaimer
(from
Glass
Processors)

Best
Estimate
350
Low
Range
200
­43
%
$
4,840,000
$
4,839,000
0
%
$
3,098,000
$
3,099,000
0
%

High
Range
500
43
%
$
4,840,000
$
4,839,000
0
%
$
3,098,000
$
3,096,000
0
%

Costs
for
Disposal
to
Glass
Processor
(per
ton):

Broken
CRTs,
no
metal
Best
Estimate
$
0
Low
Range
$
0
N/
A
$
4,840,000
$
4,840,000
0
%
$
3,098,000
$
3,098,000
0
%

High
Range
$
10.00
N/
A
$
4,840,000
$
4,820,000
0
%
$
3,098,000
$
3,136,000
1
%

Broken
CRTs,
with
metal
Best
Estimate
$
100.00
Low
Range
$
50.00
­50
%
$
4,840,000
$
4,859,000
0
%
$
3,098,000
$
3,115,000
1
%
Parameter
Names
Sensitivity
Test
Parameter
Values
Percent
Change
from
Best
Estimate
Savings
Under
Primary
Alternative
Savings
Under
Primary
Alternative
Using
the
Sensitivity
Test
Parameter
Values
Percent
increase
(decrease)
in
amount
saved
Savings
Under
CSI
Alternative
Savings
Under
CSI
Alternative
Using
the
Sensitivity
Test
Parameter
Values
Percent
increase
(decrease)
in
amount
saved
August
24,
2001
­
DRAFT
Page
G­
4
High
Range
$
150.00
50
%
$
4,840,000
$
4,818,000
0
%
$
3,098,000
$
3,077,000
­1
%

Whole
Bare
CRTs
Best
Estimate
$
192.00
Low
Range
$
100.00
­48
%
$
4,840,000
$
4,859,000
0
%
$
3,098,000
$
3,115,000
1
%

High
Range
$
300.00
56
%
$
4,840,000
$
4,814,000
­1
%
$
3,098,000
$
3,073,000
­1
%

Broken
mixed
color/
monochrome
Best
Estimate
$
325.00
Low
Range
$
250.00
­23
%
$
4,840,000
$
4,868,000
1
%
$
3,098,000
$
3,124,000
1
%

High
Range
$
400.00
23
%
$
4,840,000
$
4,808,000
­1
%
$
3,098,000
$
3,067,000
­1
%

Whole
CRTs
with
casing
Best
Estimate
$
333.33
Low
Range
$
200.00
­40
%
$
4,840,000
$
4,853,000
0
%
$
3,098,000
$
3,332,000
8
%

High
Range
$
450.00
35
%
$
4,840,000
$
4,825,000
0
%
$
3,098,000
$
2,889,000
­7
%

Exporter,
Disposal
Best
Estimate
$
107.00
Low
Range
$
0
­100
%
$
4,840,000
$
4,431,000
­8
%
$
3,098,000
$
2,741,000
­12
%

High
Range
$
200.00
87
%
$
4,840,000
$
5,195,000
7
%
$
3,098,000
$
3,407,000
10
%

CRT
Glass
Manufacturer,
Disposal
Best
Estimate
$
(175.00)

Low
Range
$
(250.00)
43
%
$
4,840,000
$
4,914,000
2
%
$
3,098,000
$
3,191,000
3
%

High
Range
$
0
­100
%
$
4,840,000
$
4,661,000
­4
%
$
3,098,000
$
2,871,000
­7
%

Number
of
TVs
from
unregulated
users
Best
Estimate
20,000,000
LowRange
15,000,000
­25
%
$
1,117,000
$
1,660,000
49
%
$
4,202,000
$
4,024,000
­4
%

High
Range
30,000,000
50
%
$
1,117,000
$
(10,000)
­101
%
$
4,202,000
$
4,552,000
8
%

Number
of
monitors
from
unregulated
users
Best
Estimate
16,886,411
Low
Range
10,000,000
­41
%
$
1,117,000
$
1,621,000
45
%
$
4,202,000
$
4,033,000
­4
%

High
Range
25,000,000
48
%
$
1,117,000
$
434,000
­61
%
$
4,202,000
$
4,402,000
5
%
August
24,
2001
­
DRAFT
Page
G­
5
August
24,
2001
­
DRAFT
Page
H­
1
Appendix
H
Telephone
Contacts
Contacts
made
by
Sue
Chotikajan:

Tony
Catareno,
I.
G.
Inc.,
3476
Saint
Rocco
CT.,
Cleveland,
OH
44109,
(216)
631
­7710.
November
6,
1998.

Questions:
(1)
Where
do
you
get
your
discarded
CRTs?
(2)
What
types
of
industries/
manufacturers
are
your
sources
(TV
and
computer
manufacturers
or
post­
consumer)?
(3)
How
much
do
you
charge
for
taking
discarded
CRTs
(Specifically
for
a
30
pound
monitor)?
(4)
What
do
you
with
the
glass?
Is
it
landfilled,
sent
to
smelters,
or
sent
to
CRT
glass
manufacturers?
(5)
What
is
the
percentage
of
this
allocation?
(6)
What
is
the
cost
of
sending
glass
to
each
disposal
or
recycling
alternative?
(7)
What
is
the
total
number
of
CRTs
processed
annually
and
total
weight
processed?
(8)
Do
you
have
information
on
the
number
of
color
vs.
monochrome
monitors
processed?

Responses:
C
I.
G.
Inc.
receives
used
CRTs
from
leasing
companies,
a
few
from
households,
but
none
from
manufacturers.

C
I.
G.
Inc.
charges
$3­$
5
per
monitor
for
pick­
up
services
of
discarded
computers,
and
leasing
companies
pay
for
their
own
transportation.

C
CRTs
are
pulled
out
of
monitor
and
processed.
Some
parts
(phosphorous,
metals,
glass)
are
sent
to
recycling
companies
and
glass
manufacturers.

C
All
CRT
glass
is
sent
to
CRT
glass
manufacturers.

C
Information
on
cost
sent
to
each
glass
manufacturers
isn't
shared
with
the
public.

C
The
total
number
of
CRTs
processed
annually
is
approximately
5,000
monitors.
C
Since
I.
G.,
Inc.
is
only
processing
CRTs
as
a
sideline,
we
do
not
track
down
the
types
of
monitors
processed.
August
24,
2001
­
DRAFT
Page
H­
2
Jim
Weber,
Federal
Prison
Industries,
Ohio,
(330)
424
–7448
(ext.
1313).
November
6,
1998.

Questions:
(1)
Where
do
you
get
your
discarded
CRTs?
(2)
What
types
of
industries/
manufacturers
are
your
sources
(TV
and
computer
manufacturers
or
post­
consumer)?
(3)
How
much
do
you
charge
for
taking
discarded
CRTs
(Specifically
for
a
30
pound
monitor)?
(4)
What
do
you
with
the
glass?
Is
it
landfilled,
sent
to
smelters,
or
sent
to
CRT
glass
manufacturers?
(5)
What
is
the
percentage
of
this
allocation?
(6)
What
is
the
cost
of
sending
glass
to
each
disposal
or
recycling
alternative?
(7)
What
is
the
total
number
of
CRTs
processed
annually
and
total
weight
processed?
(8)
Do
you
have
information
on
the
number
of
color
vs.
monochrome
monitors
processed?

Responses:
C
Federal
Prison
Industries
receives
discarded
computers
from
GE,
Motorola,
computer
manufacturers,
and
schools.
Federal
Prison
Industries
doesn't
receive
any
discarded
televisions.

C
Federal
Prison
Industries
charges
$4­$
5
per
monitor,
and
the
manufacturer
or
entity
discarding
the
computer
monitors
pays
for
the
shipping.

C
Generally,
Federal
Prison
Industries'
picks
up
and
sorts
the
computer
monitors
and
then
sends
them
to
Envirocycle,
a
CRT
glass­
to­
glass
recycling
center.
None
of
the
discarded
CRTs
are
landfilled
or
sent
to
smelters.

C
All
discarded
CRTs
are
sent
to
CRT
glass
manufacturers,
through
CRT
glass­
to­
glass
recyclers,
such
as
Envirocycle.

C
Envirocycle
pays
$0.25
per
pound
of
glass
or
$500
per
ton
of
glass.

C
Federal
Prison
Industries
processes
around
4,000
monitors
per
year.

C
On
average,
they
process
an
equal
number
of
color
and
monochrome
monitors.
The
most
common
types
of
color
monitors
discarded
are
GEA
and
CEA.
They
separate
the
glass
into
four
types:
PB,
color,
NPHS,
and
miscellaneous
plastic
filament.

Gary
DiRusso,
DMC
Recycling,
New
Hampshire,
gdirusso@
dmcrecycling.
com.
October
30,
1998.

Questions:
(1)
Where
do
you
get
your
discarded
CRTs?
August
24,
2001
­
DRAFT
Page
H­
3
(2)
What
types
of
industries/
manufacturers
are
your
sources
(TV
and
computer
manufacturers
or
post­
consumer)?
(3)
How
much
do
you
charge
for
taking
discarded
CRTs
(Specifically
for
a
30
pound
monitor)?
(4)
What
do
you
with
the
glass?
Is
it
landfilled,
sent
to
smelters,
or
sent
to
CRT
glass
manufacturers?
(5)
What
is
the
percentage
of
this
allocation?
(6)
What
is
the
cost
sent
to
each?
(7)
What
is
the
total
number
of
CRTs
processed
annually
and
total
weight
processed?
(8)
Do
you
have
information
on
the
number
of
color
vs.
monochrome
monitors
processed?

Responses:
C
DMC
receives
monitors
from
a
government
agency
(NSA),
businesses
such
as
(SunMicro,
AT&
T,
etc)
and
computer
monitor
manufacturers,
such
as
Nissei,
Sangyo
(Hitachi).

C
Approximately
50
percent
by
weight
of
the
monitors
that
DMC
receives
from
the
government
can
be
reused;
the
other
50
percent
is
disassembled
and
recycled.
Reusable
computer
monitors
represent
approximately
30
percent
of
the
total
materials
received
from
the
government.
The
remaining
70
percent
is
computers,
telecommunications
equipment,
and
other
electronic
equipment.

C
DMC
charges
$0.11
–
0.13
per
pound
(based
on
quantity)
for
recycling
monitors.

C
DMC
receives
shipments
of
10,000
to
30,000
pounds
at
a
time
from
monitor
manufacturers.

C
DMC
currently
processes
approximately
1
million
pounds
of
monitors
per
year
with
expectations
that
this
could
increase
considerably
because
of
the
landfill
ban
pending
in
Massachusetts
effective
July
1999.
[One
million
pounds
of
monitors
is
approximately
33,000,
30
pound
computer
monitors.]

C
DMCs
current
capacity
is
6.5
million
pounds
in
a
40­
hour
workweek.
DMC
can
process
this
large
capacity
because
all
of
their
equipment
is
automated
to
recycle
whole
monitors
or
CRTs.

C
DMC
recycles
glass,
steel,
copper,
plastic,
and
aluminum
from
the
computer
monitors.

C
All
the
glass
from
CRTs
that
DMC
recycles
is
sent
to
a
lead
smelter.
Typically
they
ship
the
glass
by
rail
in
quantities
of
about
100,000
pounds
(50
tons).
C
The
primary
lead
smelter
uses
the
glass
silicate
in
place
of
a
commercial
fluxing
agent
and
recovers
the
lead.

C
DMC's
recycling
process
entails
5
steps
to
breakup
and
separate
the
computer
monitor
materials:
(1)
shredding;
(2)
ferrous
separation;
(3)
pulverizing
the
glass;
(4)
sifting
the
glass;
(5)
containerizing
the
copper,
aluminum,
and
plastic.
August
24,
2001
­
DRAFT
Page
H­
4
Contacts
made
by
Tom
Uden:

Robert
Bouma,
Noranda,
Toronto,
Ontario,
(416)
982­
7237.
November
4,
1998.

Questions:
(1)
What
is
the
cost
for
disposal/
recycling
of
CRTs
at
your
facility?
(2)
Where
do
CRTs
fit
in
your
process?
(3)
How
many
CRTs
are
processed
each
year?
(4)
What
types
of
companies/
organizations
typically
provide
you
CRTs?
(5)
Any
other
general
information?

Responses:
C
The
price
for
taking
CRTs
is
several
hundred
dollars,
but
typically
less
than
$500
per
ton.
This
value
is
closely
guarded,
because
various
companies
"compete"
for
monitors.
The
fee
is
the
money
maker
in
this
operation,
not
the
copper,
silica,
and
precious
metal
values
recovered.
CRT
glass
is
less
valuable
than
a
whole
monitor,
because
there
are
no
precious
metals
or
copper
in
the
CRT
glass.

C
CRTs
are
introduced
whole,
or
shredded
into
a
copper
smelter.
Copper
(principally
from
the
yoke)
and
small
amounts
of
precious
metal
are
recovered.
Lead
is
discarded
in
the
furnace
slag
to
a
secure
impoundment.
CRTs
also
contain
silica,
which
is
useful
as
a
fluxing
agent.

C
Noranda
accepts
approximately
1,000
­
2,000
tons
of
monitors
per
year.
[This
weight
range
represents
between
50,000
to
130,000
monitors.]
Weight
assumptions
would
allow
calculation
of
absolute
numbers.
The
principle
input
is
whole
monitors,
as
opposed
to
broken
CRT
glass,
or
only
the
CRT.
TVS
are
generally
too
large
for
the
shredder.
Some
non­
viable
TV
tubes
are
obtained
from
OEMs.

C
Generally
electronic
scrap
brokers
supply
the
CRTs.
Often,
these
brokers
will
go
into
an
office
facility,
to
obtain
the
highest
value
components
(the
computer
"boxes").
They
may
attempt
to
refurbish
and
sell
monitors.
However,
most
brokers
take
the
monitors
even
though
they
do
not
want
them.
They
take
the
monitors
as
part
of
a
package
deal,
to
get
the
computers
which
contain
much
greater
levels
of
precious
metals.
Another
source
of
monitors
is
from
OEMs.
If
an
OEM
(e.
g.,
IBM,
Digital,
HP)
replaces
an
entire
office's
PCS,
the
broker,
as
part
of
a
package
deal,
will
take
away
the
old
systems,
including
monitors.
Taking
the
monitors
is
part
of
the
service.

C
CRT
glass
direct
from
OEMs
(broken
in
manufacturing
for
example)
is
an
ideal
input
for
their
lead
smelter
in
New
Brunswick.
The
glass
must
be
clean,
because
plastic
fouls
the
sulfuric
acid
plant
that
is
part
of
the
process.
August
24,
2001
­
DRAFT
Page
H­
5
Cliff
Asbury,
Doe
Run,
Glover,
MO,
(573)
546­
7492,
x­
237.
November
10,
1998.

Questions:
(1)
What
is
the
cost
for
disposal/
recycling
of
CRTs
at
your
facility?
(2)
Where
do
CRTs
fit
in
your
process?
(3)
How
many
CRTs
are
processed
each
year?
(4)
What
types
of
companies/
organizations
typically
provide
you
CRTs?
(5)
Any
other
general
information?

Responses:
C
A
general
number
for
disposal
of
CRTs
at
Doe
Run
is
$140
per
ton
of
CRT
glass.
The
number
will
vary
depending
on
the
quality
of
the
glass,
and
the
volume
(Doe
Run
offers
high­
volume
discounts).

C
CRT
glass
is
introduced
as
a
fluxing
agent
at
the
primary
smelter.
Some
lead
is
recovered
from
the
lead
content
in
the
glass,
but
the
primary
value
is
as
a
fluxing
agent.
The
CRTs
are
exempt
from
being
manifested
to
the
smelter,
under
a
50%
material
substitution
provision.

C
100­
125
tons
of
CRT
glass
are
processed
each
year.
[This
weight
range
represents
between
5,000
to
8,000
monitors.]
CRT
glass
is
generally
shipped
in
"gaylord"
boxes.
These
are
1
cubic
yard
cardboard
boxes.
Doe
Run
would
like
to
receive
the
glass
in
dump
trucks,
or
rail
cars.
This
would
eliminate
the
need
to
dispose
of
several
thousand
boxes
a
year.

C
CRT
glass
comes
from
recovery
services,
that
scavenge
used
computers.
Some
try
to
refurbish
the
computers,
often
sending
them
overseas.
A
lot
of
these
companies
are
primarily
interested
in
the
precious
metal
and
copper
values
in
the
computer
"box."
They
take
the
monitors
as
part
of
the
deal,
and
have
to
get
rid
of
the
glass.
They
only
dump
the
glass
after
fully
disassembling
and
recovering
valuable
components
from
the
monitor.

C
One
broker/
processor
(DMC)
sends
glass
to
Doe
Run
crushed
to
3/
8
inch
particles.
The
crushing
is
good
for
the
broker/
processor
(because
they
can
use
magnetic
separation
techniques
to
get
the
metal
out),
and
for
Doe
Run
(because
fewer
contaminants
remain
in
the
glass,
and
the
glass
is
already
crushed
for
introduction
into
the
smelting
furnace).

C
Mr.
Asbury
mentioned
three
brokers/
processors:
C
Asset
Recovery,
MN;
612­
602­
0789,
Bruce
Janovic.
This
may
be
an
affiliate
of
Digital
Corp.
C
DMC,
NH;
603­
772­
7236,
Mike
Mogliano.
C
SEER,
FL;
800­
376­
7888,
Mike
Flynn.

C
Mr.
Asbury
expressed
concern
that
the
current
CSI
proposal
favors
glass­
to­
glass
recycling.
Doe
Run
does
not
want
to
lose
CRTs
as
an
input
and
revenue
generator.
[CRTs
may
represent
an
important
revenue
source,
especially
when
the
price
of
lead
is
low.]
August
24,
2001
­
DRAFT
Page
H­
6
Mike
Flynn,
SEER
(Secure
Environmental
Electronic
Recovery),
Tampa,
FL.
(888)
600­
7337.
November
11,
1998.

Questions:
(1)
What
is
the
cost
for
disposal/
recycling
of
CRTs
at
your
facility?
(2)
Where
do
CRTs
fit
in
your
process?
(3)
How
many
CRTs
are
processed
each
year?
(4)
What
types
of
companies/
organizations
typically
provide
you
CRTs?
(5)
Any
other
general
information?

Responses:
C
SEER
charges
$7.50
per
computer
monitor,
$12.50
per
table­
top
television,
and
$35.00
per
console
television.

C
Typically
whole
computer
systems
are
recovered
from
companies.
Usually
this
results
from
a
modernization
of
company
hardware.
Very
often,
these
companies
have
old
equipment
in
a
warehouse
that
is
removed
at
the
same
time.
SEER
determines
if
the
equipment
(including
monitor)
has
resale
or
refurbishment
value.
If
re­
sale
or
refurbishment
is
not
an
option
(as
with
older
equipment
that
has
been
stored
for
a
while)
demanufacturing
occurs.
Some
consumers
give
SEER
computer
monitors
and
televisions,
if
they
are
concerned
with
"doing
the
right
thing"
environmentally.

C
For
monitors,
the
mercury
switches,
and
valuable
parts
are
removed.
The
vacuum
is
released.
The
front
panel
is
cut
away.
CRTs
are
shipped
in
gaylord
boxes.
950
pounds
of
CRTs
fit
in
one
box,
although
Mike
could
not
say
how
many
CRTs
this
represents.
[950
pounds
of
CRTs
is
approximately
30
CRTs.]
They
currently
ship
to
Doe
Run
only.
Mr.
Flynn
is
going
to
visit
Envirocycle
next
week
to
look
into
sending
some
CRT
glass
to
them.
He
predicts
that
there
will
be
increased
disposal
in
the
near
future,
and
that
he
will
need
more
than
one
outlet
for
CRTs.
If
SEER
contracts
with
Envirocycle,
the
monitor
flow
would
be:
(1)
end
user,
(2)
SEER,
(3)
Envirocycle,
(4)
Techniglass.

C
Mr.
Flynn
did
not
have
the
number
of
CRTs
processed
per
year
available
at
the
time
of
the
call.

C
Companies
with
a
large
computer
base,
usually
located
in
large
office
buildings
or
complexes,
are
SEER's
typical
customers.
They
find
out
about
SEER
through
Subtitle
D
landfills.
For
instance,
many
CWM
Inc.
Subtitle
D
landfills
in
the
area
refer
companies
with
large
CRT
volumes
to
SEER.
It
was
not
apparent
whether
this
is
a
formal
arrangement,
although
it
seems
unlikely.

C
Florida
recently
adopted
Universal
Waste
Regulations,
and
SEER
is
a
Universal
Waste
Handler
and
Transporter.
This
allows
them
to
handle
batteries
and
mercury
switches.
Mr.
Flynn
claimed
that
when
the
CRTs
are
brought
to
SEER,
they
are
in
monitor
format
and
are
August
24,
2001
­
DRAFT
Page
H­
7
therefore
still
potentially
a
viable
product.
They
are
therefore
exempt
from
RCRA
manifest
and
other
requirements.
When
they
are
sent
to
Doe
Run,
they
are
exempt
because
they
are
primary
process
feed.
He
is
not
sure
what
the
RCRA
status
of
shipping
to
Envirocycle
would
be;
he
intends
to
find
out
next
week.

C
Mr.
Flynn
also
expressed
concern
that
the
CSI
proposal
will
preferentially
treat
the
glass­
toglass
channel.
He
thinks
that
any
increased
regulations
on
smelters
would
create
a
problem,
because
the
glass­
to­
glass
processors
do
not
have
the
capacity
to
handle
the
projected
increase
in
CRT
disposal.

Various,
Chemical
Waste
Management
(CWM).
November
2­
3,
1998.

Questions:
(1)
What
is
the
cost
for
disposal/
recycling
of
CRTs
at
your
facility?
(2)
Where
do
CRTs
fit
in
your
process?
(3)
How
many
CRTs
are
processed
each
year?
(4)
What
types
of
companies/
organizations
typically
provide
you
CRTs?
(5)
Any
other
general
information?

Responses:
C
The
disposal
cost
is
$285/
cu
yard
for
macroencapsulation,
and
$150­
175
for
55
gal
drum
of
whole
monitors/
CRTs
(Street,
AL).
In
addition,
for
Model
City
NY,
if
the
shipment
is
from
out
of
state
it
is
subject
to
a
$27/
ton
state
hazardous
waste
tax.
All
shipments
to
the
facility
are
subject
to
a
6%
town
tax,
and
a
7%
sales
tax
(Customer
Service,
NY).
Mr.
Street
mentioned
that
LA
has
a
more
favorable
tax
structure.

C
CWM
is
a
RCRA
Subtitle
C
facility,
with
the
ability
to
stabilize
lead
leaching
components.
Monitors
would
be
encapsulated
(without
crushing/
breakage)
in
impermeable
containers,
with
a
concrete
type
substance
poured
around
them
(Customer
Service,
NY).

C
Model
City
(Buffalo)
NY
and
Emelle
AL
could
not
think
of
specific
instances
of
CRT
disposal.
(Although
Dr.
Street
in
Emelle
thought
that
the
NY
facility
would
likely
deal
with
CRTs;
he
suggested
talking
to
their
environmental
person,
Jill
Knickerbocker,
who
did
not
return
my
calls).
The
Lake
Charles
LA
facility
contact
could
recall
one
shipment
of
CRTs
that
was
macroencapsulated
(Grant,
LA).

C
The
contact
at
Emelle
thought
that
shipments
of
monitors
would
likely
come
from
Fortune
500
companies
with
strong
environmental
programs.
He
thinks
that
many
monitors
are
being
recycled,
some
by
the
same
facilities
that
recycle
Hg
lamps
(Street,
AL).

C
Contacts:
CWM
Model
City
NY
(716)
754­
8231
Jill
Knickerbocker
August
24,
2001
­
DRAFT
Page
H­
8
CWM
Emelle
AL
(205)
652­
9721
Dr.
Jim
Street
CWM
Lake
Charles
LA
(318)
583­
2144
Chuck
Grant
Heather
McCarthy,
Clean
Harbors
of
Braintree.
May
9
and
24,
2001.

Questions:
(1)
Have
you
mostly
received
CRTs
from
the
users,
brokers,
or
other
types
of
businesses?
(2)
Are
the
CRTs
mostly
sent
to
you
whole
or
crushed?
(3)
What
are
your
rates
for
stabilization
and
disposal
of
bulk
waste?
(4)
Can
you
estimate
how
many
CRTs
or
how
many
tons
of
CRTs
your
facility
has
processed
in
the
last
year?
(5)
Does
your
company
provide
transportation
services?

Responses:
C
CRTs
are
mostly
received
from
businesses,
but
some
are
received
from
brokers.

C
CRTs
are
received
whole
in
flex
bins,
which
are
similar
to
but
smaller
than
gaylord
boxes.

C
CRTs
are
dismantled
and
recycled
to
the
maximum
extent
possible
in
their
Bristol,
CT
facility.
Clean
Harbors
charges
$300
to
$500
per
flex
bin
depending
on
the
size
and
frequency
of
shipments.
The
CRT
glass
is
sent
to
Canada
where
it
is
crushed,
treated,
and
disposed.
Clean
Harbors
does
not
have
a
minimum
charge
for
shipments
of
CRTs
C
Do
not
have
a
current
estimate
of
the
number
or
tons
of
CRTs
processed.

C
Clean
Harbors
provides
transportation
services
and
charges
a
flat
rate
of
$150
per
shipment
for
the
Boston
area.
For
locations
farther
away
(e.
g.,
Maine)
they
charge
about
$300
per
shipment.

Lisa
Humfry,
Envirosafe
Services
of
Ohio.
May
10,
2001.

Questions:
(1)
Have
you
mostly
received
CRTs
from
the
users,
brokers,
or
other
types
of
businesses?
(2)
Are
the
CRTs
mostly
sent
to
you
whole
or
crushed?
(3)
What
are
your
rates
for
stabilization
and
disposal
of
bulk
waste?
(4)
Can
you
estimate
how
many
CRTs
or
how
many
tons
of
CRTs
your
facility
has
processed
in
the
last
year?
(5)
Does
your
company
provide
transportation
services?

Responses:
August
24,
2001
­
DRAFT
Page
H­
9
C
CRTs
are
mostly
received
from
brokers,
but
some
are
received
from
businesses.
One
customer
consolidated
CRTs
from
many
of
its
facilities
and
crushed
the
CRTs
before
sending
them
to
Envirosafe.
Envirosafe
macro­
encapsulates
CRTs
sent
in
poly
drums,
and
encapsulates
whole
CRTs.
If
the
CRTs
are
sent
crushed
in
a
roll­
off
container,
they
will
stabilize
the
CRTs
for
disposal.

C
CRTs
sometimes
are
received
whole,
but
mostly
crushed
in
roll
off
containers.

C
The
rate
for
crushed
CRTs
in
a
roll­
off
container
is
$160
per
ton.
The
rate
for
whole
monitors
is
$360
per
cubic
yard.
The
rate
for
whole
CRTs
in
drums
is
$150
per
drum.
Envirosafe
does
not
have
a
minimum
charge
for
shipments
of
CRTs.

C
Envirosafe
received
no
CRTs
last
year
and
about
20
to
30
tons
the
previous
year.

C
Envirosafe
subcontracts
out
transportation.

Mark
Cardamone,
F&
M
Bay
Electronics
Co.
Inc./
SEER
Inc.,
Tampa,
FL.
(813)
621­
8870.
May
14,
2001.

Questions:
(1)
What
do
you
do
with
the
CRTs
you
receive?
(2)
Who
do
you
receive
CRTs
from?
e.
g.,
the
users,
brokers,
or
other
types
of
businesses?
(3)
What
are
your
rates
for
processing
monitors?
(4)
Can
you
estimate
how
many
CRTs
or
how
many
tons
of
CRTs
your
facility
has
processed
in
the
last
year?
(5)
What
do
you
do
with
the
CRT
glass?
(6)
Does
your
company
provide
transportation
services?

Responses:
C
All
monitors
that
were
manufactured
during
or
after
1996
are
tested
to
see
if
they
are
operational.
About
10
percent
of
the
CRTs
received
are
resold.
The
remaining
monitors
are
demanufactured
and
the
plastic,
steel,
aluminum,
and
copper
are
recycled.
The
bare
CRTs
are
cut
in
half
to
separate
the
panel
from
the
funnel.
The
CRT
glass
is
sent
to
Envirocycle
and
to
Dlubeck
Glass.

C
Most
of
the
monitors
are
received
from
original
users.
Monitors
are
also
obtained
from
municipal
solid
waste
facilities
that
remove
the
CRTs
from
the
solid
waste
stream
at
landfills
or
transfer
stations.

C
For
monitors
that
are
17
inches
or
less,
they
charge
$6
to
$7.50
per
monitor.
For
monitors
that
are
larger
than
17
inches,
they
charge
$9.50
per
monitor.
For
bare
CRTs,
they
charge
$4.00
per
bare
CRT.
August
24,
2001
­
DRAFT
Page
H­
10
C
The
facility
processed
40,000
CRTs
in
the
last
year.
This
includes
both
TVs
and
monitors.

C
The
CRT
glass
is
sent
to
Envirocycle
and
to
Dlubeck
Glass.

C
Transportation
services
are
provided
and
include
scheduled
pickups
through
common
carriers
and
their
own
trucks.
Local
pickup
includes
a
range
of
50
miles
and
costs
$25
per
pickup.
In
Florida
transportation
costs
are
generally
$25
to
$150
per
pickup.

Jack
Hope,
WasteNot
Recycling,
Sterling,
VA.
(703)
787­
0200.
May
15,
2001.

Questions:
(1)
What
do
you
do
with
the
CRTs
you
receive?
(2)
Who
do
you
receive
CRTs
from?
e.
g.,
the
users,
brokers,
or
other
types
of
businesses?
(3)
What
are
your
rates
for
processing
monitors?
(4)
Can
you
estimate
how
many
CRTs
or
how
many
tons
of
CRTs
your
facility
has
processed
in
the
last
year?

Responses:
C
WasteNot
Recycling
is
a
not
for
profit
organization
that
trains
and
employs
developmentally
disabled
adults.
They
only
take
functional
monitors
right
now.
They
are
looking
into
the
options
for
demanufacturing
monitors
in
the
future.

C
Monitors
are
received
from
local
companies,
such
as
ATT,
SAIC,
and
Boeing.

C
There
is
no
charge
for
donating
monitors.

C
Mr.
Hope
did
not
have
an
estimate
of
the
number
of
computer
or
monitors
received.

Greg
Voorhees,
Envirocycle,
Halstead,
PA.
(570)
879­
2862.
April
25,
2001.

Questions:
(1)
What
percent
of
the
CRT
glass
that
you
receive
is
sold
as
fines?
(2)
What
percent
of
Envirocycle's
processed
CRT
glass
is
sent
to
lead
smelters?
(3)
What
is
Envirocycle's
recycling
capacity?
(4)
Is
the
facility
in
North
Carolina
that
is
mentioned
on
your
web
site
open
yet?
(5)
What
do
you
charge
for
intact
whole
monitors?
(6)
What
percent
of
CRTs
are
received
as
whole
monitors,
bare
CRTs,
or
crushed
glass?

Responses:
August
24,
2001
­
DRAFT
Page
H­
11
C
None.

C
All
of
the
fines
generated
in
the
processing
of
CRTs
are
sent
to
a
primary
lead
smelter,
for
which
Envirocycle
must
pay.
The
processing
of
CRTs
generates
about
two
percent
fines
by
weight.
Envirocycle
is
working
to
improve
the
efficiency
of
its
process
to
reduce
the
generation
of
fines.

C
Envirocycle
is
currently
operating
at
about
20
percent
of
its
capacity
in
its
Halstead,
PA
facility.
Envirocycle's
current
operating
tempo
is
about
1.5
million
pounds
per
month
C
The
North
Carolina
facility
will
not
be
opened.
Two
other
locations
are
being
pursued
and
will
be
open
by
the
end
of
the
year.
One
facility
will
be
located
in
the
north
east
and
the
other
will
be
on
the
west
coast.

C
Envirocycle
charges
about
$5
to
$6
per
monitor
for
whole
monitors.
The
actual
price
paid
is
volume
dependant.

C
About
50
to
60
percent
of
the
glass
received
is
"dirty­
mix
with
no
metals."
This
glass
comes
from
other
demanufacturing
facilities.
Envirocycle
still
receives
about
the
same
amount
of
CRT
glass
from
OEMs
as
in
1996.
August
24,
2001
­
DRAFT
Page
I­
1
Appendix
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