FINAL
REPORT
Economic
Assessment
of
the
Association
of
Battery
Recyclers
Proposed
Rule
Prepared
for:

U.
S.
Environmental
Protection
Agency,
Office
of
Solid
Waste
and
Emergency
Response
Economics,
Methods
and
Risk
Analysis
Division
401
M
Street
S.
W.
Washington,
D.
C.
20460
Prepared
by:

DPRA
Incorporated
332
Minnesota
Street,
Suite
E­
1500
St.
Paul,
Minnesota
55101
June
27,
2003
TABLE
OF
CONTENTS
1.0
Executive
Summary
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
1­
1
2.0
Introduction
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
1
2.1
Purpose
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
2
2.2
Scope
of
Study
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
3
2.3
Organization
of
Report
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
4
3.0
Methodology
and
Data
Limitations
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
1
3.1
Analytical
Methodology
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
1
3.1.1
Baseline
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
1
3.1.2
Alternative
Approach
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
1
3.1.3
Cost
and
Benefit
Estimates
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
1
3.1.4
Distributional
Effects
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
2
3.2
Data
Collection
Methodology
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
3
3.2.1
Data
Source
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
3
3.2.2
Methodology
For
Identifying
Inside
Industry
Group
Recovery
Management
Quantities
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
3
3.2.3
Methodology
For
Identifying
Outside
Industry
Group
Recovery
Management
Quantities
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
16
3.2.4
Methodology
For
Identifying
Disposed
Management
Quantities
That
Potentially
May
Be
Recovery
Onsite
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
18
3.3
Limitations
of
Analysis
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
24
4.0
Baseline
Metal,
Solvent,
and
Other
Recovery
Management
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
1
4.1
On­
Site
Recovery
Quantity
in
1999
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
1
4.2
Off­
site
Recovery
Quantity
Transferred
within
Same
Industry
Group
(
4­
Digit
NAICS
Code)
in
1999
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
3
4.3
Export
Recovery
Quantity
in
1999
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
6
4.4
Potential
Additional
Recovery
Quantity
from
1997
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
10
4.5
Off­
Site
Recovery
Quantity
Transferred
Outside
Industry
Group
in
1999
(
Selected
NAICS
Codes)
with
On­
Site
Recovery
Potential
.
.
.
.
.
.
.
.
4­
16
4.6
Disposal
Quantity
in
1999
with
On­
Site
Recovery
Potential
(
Selected
Waste
Types
and
SIC
Codes)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
18
4.6.1
Off­
Site
Disposal
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
18
4.6.2
On­
Site
Disposal
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
19
4.7
Summary
of
Management
Data
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
23
5.0
Cost
Impact
Analysis
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
1
5.1
Types
of
Cost
Savings
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
1
5.2
Baseline
Cost
Components
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
1
5.3
Post­
Regulatory
Cost
Components
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
5
TABLE
OF
CONTENTS
(
continued)

5.4
Annualization
Methodology
of
Before­
Tax
Compliance
Costs
.
.
.
.
.
.
.
.
.
.
.
.
5­
8
5.5
Example
Cost
Calculations
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
9
5.6
Unit
Cost
and
Cost
Function
Estimates
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
12
5.7
Summary
of
Breakeven
Analysis
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
38
5.8
Summary
of
Potential
Cost
Savings
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
40
6.0
Economic
Impact
Analysis
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
1
6.1
Major
Industries
Impacted
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
1
6.1.1
Basic
Chemical
Industry
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
1
6.1.1.1
Petrochemical
Industry
Profile
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
2
6.1.1.1.1
Production
and
Shipment
Values
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
2
6.1.1.1.2
Industry
Size
and
Market
Share
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
2
6.1.1.1.3
Average
Facility
Size
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
3
6.1.1.2
Other
Organic
Chemical
Industry
Profile
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
3
6.1.1.2.1
Production
and
Shipment
Values
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
3
6.1.1.2.2
Industry
Size
and
Market
Share
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
4
6.1.1.2.3
Average
Facility
Size
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
4
6.1.1.3
Other
Inorganic
Chemical
Industry
Profile
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
4
6.1.1.3.1
Production
and
Shipment
Values
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
5
6.1.1.3.2
Industry
Size
and
Market
Share
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
5
6.1.1.3.3
Average
Facility
Size
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
5
6.1.1.4
Inorganic
Dye
and
Pigment
Industry
Profile
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
6
6.1.1.4.1
Production
and
Shipment
Values
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
6
6.1.1.4.2
Industry
Size
and
Market
Share
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
6
6.1.1.4.3
Average
Facility
Size
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
7
6.1.1.5
Cyclic
Crudes
and
Intermediates
Industry
Profile
.
.
.
.
.
.
.
.
.
.
.
6­
7
6.1.1.5.1
Shipment
Values
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
7
6.1.1.5.2
Industry
Size
and
Market
Share
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
8
6.1.1.5.3
Average
Facility
Size
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
8
6.1.2
Resin,
Synthetic
Rubber,
and
Artificial
and
Synthetic
Fibers
and
Filaments
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
9
6.1.2.1
Plastic
Material
and
Resin
Manufacturing
Industry
Profile
.
.
.
.
6­
9
6.1.2.1.1
Production
and
Shipment
Values
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
9
6.1.2.1.2
Industry
Size
and
Market
Share
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
10
6.1.2.1.3
Typical
Products
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
10
6.1.2.1.4
Average
Facility
Size
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
11
6.1.3
Pharmaceutical
and
Medicine
Manufacturing
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
11
6.1.3.1
Pharmaceutical
Preparation
Industry
Profile
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
11
6.1.3.1.1
Shipment
Values
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
11
6.1.3.1.2
Industry
Size
and
Market
Share
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
12
TABLE
OF
CONTENTS
(
continued)

6.1.3.1.3
Average
Facility
Size
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
13
6.1.4
Nonferrous
Metal
(
except
Aluminum)
Production
and
Processing
Industry
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
13
6.1.4.1
Primary
Smelting
and
Refining
of
Copper
Industry
Profile
.
.
.
6­
13
6.1.4.1.1
Production
and
Shipment
Values
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
13
6.1.4.1.2
Industry
Size
and
Market
Share
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
14
6.1.4.1.3
Typical
Products
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
14
6.1.4.1.4
Average
Facility
Size
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
14
6.1.4.2
Other
Nonferrous
Metal
Primary
Smelting
and
Refining
Industry
Profile
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
15
6.1.4.2.1
Production
and
Shipment
Values
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
15
6.1.4.2.2
Industry
Size
and
Market
Share
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
15
6.1.4.2.3
Average
Facility
Size
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
16
6.1.4.3
The
Secondary
Smelting,
Refining
and
Alloying
of
Copper
Industry
Profile
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
16
6.1.4.3.1
Production
and
Shipment
Values
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
16
6.1.4.3.2
Industry
Size
and
Market
Share
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
17
6.1.4.3.3
Typical
Products
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
17
6.1.4.3.4
Average
Facility
Size
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
18
6.1.4.4
Other
Nonferrous
Metal
Secondary
Smelting,
Refining,
Alloying
Manufacturing
Industry
Profile
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
18
6.1.4.4.1
Production
and
Shipment
Values
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
18
6.1.4.4.2
Industry
Size
and
Market
Share
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
19
6.1.4.4.3
Typical
Products
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
19
6.1.4.4.4
Average
Facility
Size
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
20
6.1.5
Coating,
Engraving,
Heat
Treating,
and
Allied
Activities
.
.
.
.
.
.
.
.
.
.
6­
20
6.1.5.1
Plating
and
Polishing
Industry
Profile
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
20
6.1.5.1.1
Production
and
Shipment
Values
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
20
6.1.5.1.2
Industry
Size
and
Market
Share
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
21
6.1.5.1.3
Average
Facility
Size
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
21
6.1.6
Semiconductor
and
Other
Electronic
Component
Manufacturing
.
.
.
.
6­
21
6.1.6.1
Plating
and
Polishing
Industry
Profile
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
21
6.1.6.1.1
Production
and
Shipment
Values
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
22
6.1.6.1.2
Industry
Size
and
Market
Share
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
22
6.1.6.1.3
Average
Facility
Size
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
23
6.2
Facility
Level
Impacts
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
23
6.3
Distributional
Impacts
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
25
7.0
Benefits
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
7­
1
7.1
Qualitative
Benefits
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
7­
1
TABLE
OF
CONTENTS
(
continued)

7.2
Quantitative
Benefits
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
7­
2
8.0
References
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
8­
1
Appendix
A
Co­
Proposal
Option
for
the
Regulatory
Modification
to
the
Definition
of
Solid
Waste
for
the
Association
of
Battery
Recyclers
Notice
of
Proposed
Rulemaking
Appendix
B
Review
of
Recycled
Waste
Quantities
by
Manufacturing
Industries
Appendix
C
Limitation
on
Use
of
Reclaimed
Product
Appendix
D
Memorandum:
Recoverable
Waste
Type
Analysis
for
the
Economic
Assessment
of
the
Association
of
Battery
Recyclers
Proposed
Rulemaking
Appendix
E
Memorandum:
Analysis
of
Market
Changes
between
1997
and
1999
Appendix
F
State
Hazardous
Waste
Generation
Taxes
and
Fees
Appendices
G
through
V
Example
Cost
Calculations
Appendix
W
Methodology
for
Estimating
Residual
Generation
and
Management
Appendix
X
Analysis
of
Metals
Containing
and
Organic
Liquid
Disposal
Quantities
1­
1
1.0
EXECUTIVE
SUMMARY
Under
the
current
Resource
Conservation
and
Recovery
Act
(
RCRA)
regulations,
secondary
materials
(
i.
e.,
materials
that
are
neither
classified
as
virgin
materials
nor
primary
materials)
may
be
solid
wastes
and
also
hazardous
wastes
when
recycled
depending
on
the
type
of
material
(
e.
g.,
sludge,
spent
material,
or
byproduct)
and
the
type
of
recycling
(
e.
g.,
burning
for
energy
recovery,
use
constituting
disposal,
and
reclamation).
Currently,
the
Environmental
Protection
Agency
(
EPA)
is
revising
these
regulations
to
respond
to
concerns
articulated
in
the
U.
S.
D.
C.
Circuit
Court
of
Appeals
decisions
concerning
the
Agency's
legal
authority
to
regulate
certain
secondary
materials
being
recycled
under
RCRA.
The
most
recent
in
a
series
of
D.
C.
Circuit
decisions
addressing
RCRA
jurisdiction
over
secondary
materials
being
recycled
is
Association
of
Battery
Recyclers,
Inc.,
et
al.,
Petitioners
vs.
U.
S.
Environmental
Protection
Agency
No.
98­
1368,
April
21,
2000
(
ABR).
The
Court
held
in
ABR
that
EPA
could
not
regulate
secondary
materials
from
the
mineral
processing
industry
under
RCRA
that
are
stored
on
land
for
any
period
of
time.
The
Court
reasoned
that
EPA
had
not
demonstrated
that
such
materials
are
"
discarded"
within
the
statutory
meaning
of
the
term.
The
Court
vacated
the
regulatory
language
in
40
CFR
261.4(
a)(
17)
that
established
RCRA
jurisdiction
over
these
materials.
Finally,
the
Court
expressed
displeasure
that
EPA
had
again
classified
materials
as
"
solid
wastes"
for
its
Subtitle
C
regulatory
program
that
were
not
discarded,
but
rather
"
destined
for
reuse
or
recycling
in
a
continuous
process
by
the
generating
industry
itself."

EPA
is
revising
its
definition
of
solid
waste
regulations
in
response
to
the
series
of
D.
C.
Circuit
opinions.
These
revised
regulations
will
change
how
certain
secondary
materials
(
i.
e.,
spent
materials,
listed
sludges
and
listed
byproducts)
being
recycled
are
classified
under
the
Subtitle
C
regulatory
program.
In
response
to
these
regulatory
changes,
some
RCRA
regulated
entities
who
currently
recycle
secondary
materials
will
realize
cost
savings
from
the
change.
Other
RCRA
regulated
entities
who
currently
land
dispose,
incinerate,
or
recover
energy
from
hazardous
waste
will
be
induced
to
recycle
their
waste
to
obtain
lower
material
management
costs
resulting
from
the
change
in
regulatory
jurisdiction.

Executive
Order
No.
12866
requires
that
regulatory
agencies
determine
whether
a
new
regulation
constitutes
a
significant
regulatory
action.
The
Agency
is
proposing
to
exclude
from
RCRA
jurisdiction,
all
hazardous
secondary
materials
recycled
in
a
continuous
process
within
the
generating
industry.
This
extends
to
both
recycling
done
on
site
as
well
as
recycling
completed
off
site
from
the
generating
facility
when
the
off­
site
facility
is
in
the
same
generating
industry
as
the
facility
that
generated
the
material.
The
estimated
costs
and
potential
economic
impacts
of
this
proposal
to
exclude
recovered
materials
if
reclaimed
on
site
or
off
site
within
the
same
Industry
Group
(
i.
e.,
4­
digit
North
American
Industry
Classification
System
(
NAICS))
indicate
this
action
is
not
a
significant
regulatory
action
as
defined
by
the
Executive
Order.
The
action
will
result
in
a
potential
savings
to
generators
of
$
178
million
annually
and
will
have
an
decreased
annual
effect
on
the
economy
of
$
100
million
or
more.
The
rule
does
not
have
an
adverse
affect
1­
2
on
the
economy,
a
sector
of
the
economy,
productivity,
competition,
jobs,
the
environment,
health
or
public
safety.

Currently
under
RCRA,
spent
materials,
listed
sludges,
and
listed
by­
products
are
solid
wastes
if
reclaimed
(
40
CFR
261.2(
a)(
3)),
while,
sludges
and
by­
products
exhibiting
a
characteristic
of
hazardous
waste
are
not
solid
wastes.
The
proposed
regulation
would
exclude
the
former
group
of
materials
from
the
definition
of
solid
waste
if
they
are
reclaimed
on
site
or
off
site
within
the
same
industry
group
(
4­
digit
NAICS
code).

A
total
of
1,749
plants
recovering
approximately
1,570,000
tons
either
on
site
or
within
the
same
Industry
Group
may
benefit
from
the
exclusion
from
RCRA
jurisdiction.
Metals
recovery,
solvents
recovery,
and
other
recovery
account
for
678,000
tons,
280,000,
and
613,000
tons,
respectively.
The
plant
counts
and
quantities
will
be
higher
if
small
quantity
generators
are
included.

Excluding
metal,
solvent,
and
other
wastes
that
are
reclaimed
on
site
or
within
the
same
Industry
Group
from
the
Definition
of
Solid
Waste
will
make
it
more
economical
for
generators
and
within­
industry
off­
site
reclaimers
to
recover
the
values
from
these
wastes.
Savings
to
generators
are
expected
to
result
from
several
factors.
First,
generators
will
benefit
from
reduced
manifesting,
pre­
transport,
and
record
keeping
and
reporting
requirements
under
40
CFR
Part
262
of
RCRA.
Second,
given
that
the
excluded
quantities
are
no
longer
considered
hazardous
if
recovered,
the
generator
status
of
the
facility
may
switch
from
being
a
large
quantity
generator
to
a
small
or
conditionally
exempt
small
quantity
generator.
Small
and
conditionally
exempt
small
quantity
generators
have
fewer
administrative
requirements
than
large
quantity
generators
under
Part
262
of
RCRA.
Finally,
if
wastes
are
no
longer
considered
a
listed
hazardous
waste
if
reclaimed
either
on
site
or
within
the
same
Industry
Group,
residuals
from
the
recovery
processes
may
no
longer
be
hazardous
under
the
"
Derived­
from
Rule."
The
management
of
these
residuals
may
shift
from
Subtitle
C
to
Subtitle
D
disposal
if
they
do
not
test
characteristically
hazardous.
In
addition,
with
the
wastes
no
longer
being
defined
as
hazardous
waste
if
recovered,
generators
(
firms)
may
no
longer
need
to
pay
hazardous
waste
generation
taxes
and
fees.
Reductions
in
hazardous
waste
taxes
and
fees
are
not
social
cost
savings,
but,
a
reduction
in
transfer
costs
to
States.
Reductions
in
taxes
and
fees
may
influence
the
individual
firm's
waste
management
decisions
(
e.
g.,
reclamation)
and
are
included
when
appropriate
in
the
analysis.
Table
1­
1
1­
3
presents
the
cost
savings
and
costs
for
generators
recovering
wastes
on
and
off
site.
Total
cost
savings
are
estimated
to
be
$
178
million
per
year.
For
facilities
recovering
waste
on
site
and
within
the
same
industry
group,
total
cost
savings
are
estimated
to
be
approximately
$
34
million
per
year
($
27
million
for
on­
site
recovery
facilities
and
$
7
million
for
facilities
recovering
within
the
same
industry
group).
Approximately
$
63
million
per
year
in
additional
cost
savings
are
included
for
generators
who
currently
recover
wastes
off
site
outside
their
industry
group
now
finding
it
more
economical
to
construct
on­
site
recovery
facilities
post
rule.
A
break­
even
cost
estimate
was
conducted
to
determine
if
it
was
economically
feasible
for
these
generators
to
recover
their
waste
on
site.
In
addition,
approximately
$
80
million
per
year
in
additional
cost
savings
are
included
for
generators
who
currently
dispose
five
selected
waste
types
now
finding
it
more
economical
to
construct
on­
site
recovery
facilities
post
rule.
A
break­
even
cost
estimate
was
conducted
to
determine
if
it
was
economically
feasible
for
these
generators
to
recover
their
waste
on
site
For
reclaimers,
savings
are
expected
to
result
from
no
longer
needing
to
renew
their
RCRA
container
storage
and
tank
storage
permits.
The
number
of
within­
industry
off­
site
reclaimers
impacted
by
the
proposed
regulations
has
not
been
determined.
The
estimated
savings
from
not
renewing
RCRA
permits
ranges
from
$
14,953
to
$
29,906
every
10
years
for
metal
reclaiming
facilities.
For
facilities
reclaiming
solvents
or
acids,
the
estimated
savings
ranges
from
$
14,786
to
$
29,573
every
10
years.
This
barrier
will
no
longer
exist
for
those
generators
making
the
decision
to
reclaim
wastes
on
site.

Annualized
cost
savings
for
affected
facilities
vary
greatly
depending
upon
the
amount
of
waste
recycled
and
whether
the
amount
recycled
represents
100
percent
of
their
total
waste.
In
cases
where
the
waste
recycled
is
equivalent
to
all
waste
generated,
the
total
savings
is
greater
because
of
the
elimination
of
nearly
all
administrative
costs
associated
with
RCRA
regulations.
Because
of
these
variations
impacts
were
examined
for
average
facilities
in
terms
of
sales
volumes
and
cost
savings.
Cost
reductions
as
a
percent
of
total
sales
were
no
more
than
0.1
percent
for
the
major
industries
examined.
Impacts
in
terms
of
profitability
increases
were
estimated
to
range
from
approximately
0.2
to
over
2.9
percent.

Additionally,
increased
reclamation
of
metal,
solvent
and
other
waste
will
result
in
a
net
benefit
to
both
society
and
the
environment.
Some
of
the
expected
potential
benefits
include
lessening
the
future
burden
on
landfill
capacity;
conserving
scarce
metal
resources
which
provides
environmental
benefits
in
terms
of
energy
savings,
reduced
volumes
of
waste,
reduced
disturbances
to
land,
and
reduced
pollution;
and
lessening
the
dependance
of
the
United
States
on
foreign
metal
supplies
and
increasing
recovery
of
strategic
metals
such
as
chromium.

The
total
estimated
recovered
metal
value
is
$
590
million.
Plants
affected
by
this
rulemaking
reported
recovering
597,000
tons
of
metal­
bearing
waste.
Assuming
that
these
wastes
contain
20
percent
recoverable
metals
valued
at
an
average
of
$
4,770
per
ton
(
the
average
price
for
copper,
chromium,
and
nickel),
the
estimated
metal
value
for
total
recovery
is
nearly
$
569
million
per
year.
This
proposed
rule
encourages
these
plants
to
continue
recovering
these
metals
and
1­
4
maintaining
these
benefits.
Additionally
facilities
will
be
encouraged
to
recycle
additional
wastes
as
a
result
of
the
rule.
As
a
proxy
for
this
effect
it
was
assumed
that
facilities
that
reported
recovering
wastes
in
1997
but
not
in
1999
would
resume
recycling
as
a
result
of
the
rule.
Based
on
this
scenario
over
3,000
tons
of
metal
bearing
waste
would
be
recovered,
with
an
expected
value
of
approximately
$
2.9
million
per
year.
In
addition,
facilities
that
dispose
three
waste
types
(
48,235
tons
of
emission
control
dust
­
K061,
19,108
tons
of
metal­
containing
liquids
from
the
printed
circuit
board
industry,
and
10,869
tons
of
spent
catalyst
from
the
petroleum
refining
industry
­
K171/
K172)
were
estimated
to
find
it
more
economical
to
switch
to
on­
site
recovery
post
rule
and
be
of
sufficient
quality
for
recovery.
In
the
analysis,
it
is
assumed
that
recovered
emission
control
dust
wastes
contain
15
percent
recoverable
zinc
at
$
643
per
ton
of
zinc,
metalcontaining
liquids
contain
0.02
percent
copper
at
$
1,397
per
ton
of
copper,
and
spent
catalysts
contain
five
percent
molybdenum
at
$
23,940
per
ton
of
molybdenum.
The
estimated
metal
value
from
these
disposed
wastes
is
$
17.7
million.
This
proposed
rule
may
encourage
these
new
benefits.

The
total
estimated
recovered
solvent
value
is
$
290
million.
The
rule
will
affect
the
current
recovery
of
approximately
268,000
tons
of
solvent
waste
valued
at
over
$
277
million.
Further
the
rule
will
encourage
additional
recycling.
As
described
above,
a
proxy
for
this
effect
is
the
assumption
that
facilities
that
reported
recovering
wastes
in
1997
but
not
in
1999
would
resume
recycling
as
a
result
of
the
rule.
The
incremental
recovery
of
solvent
given
this
assumption
is
nearly
12,000
tons
of
solvent
with
a
total
value
of
almost
$
13
million
per
year.

The
total
estimated
recovered
acid
and
fluoride
value
is
$
122
million.
The
rule
will
affect
the
current
recovery
of
approximately
270,000
tons
of
acid
wastes
valued
at
$
60
million.
Further
the
rule
will
encourage
additional
recycling.
As
described
above,
a
proxy
for
this
effect
is
the
assumption
that
facilities
that
reported
recovering
wastes
in
1997
but
not
in
1999
would
resume
recycling
as
a
result
of
the
rule.
The
incremental
recovery
of
acid
given
this
assumption
is
nearly
17,000
tons
of
acids,
with
a
total
value
of
almost
$
3.7
million
per
year.
In
addition,
facilities
that
disposed
two
waste
types
(
71,698
tons
of
spent
aluminum
potliner,
K088,
and
254,109
tons
of
spent
pickle
liquor
from
the
steel
works
industry)
were
estimated
to
find
it
more
economical
to
switch
to
on­
site
recovery
post
rule
and
be
of
sufficient
quality
for
recovery.
In
the
analysis,
it
is
assumed
that
these
recovered
spent
aluminum
potliner
wastes
contain
two
percent
recoverable
fluoride
at
$
1,240
per
ton
and
the
spent
pickle
liquor
contains
74
percent
recoverable
acids
at
$
298
per
ton.
The
estimated
metal
value
from
these
disposed
wastes
is
$
57.8
million.
This
proposed
rule
may
encourage
these
new
benefits.
1­
5
Table
1­
1.
Estimated
Incremental
Costs
for
Generators
Reclaiming
Wastes
On
Site,
Reclaiming
Wastes
Off
Site
Within
Industry
Group,
Shifting
from
Off­
Site
Reclamation
Outside
Industry
Group
to
On
Site
Reclamation,
and
Shifting
from
Disposal
to
On­
Site
Reclamation
by
Cost
Item
(
2002$/
year)

Cost
Item
Estimated
Incremental
Costs
On­
Site
Reclamation
Waste
Reclamation
and
Residual
Management
($
1,222,000)

Waste
Characterization
Testing
($
3,729,000)

Manifesting
($
575,000)

Loading
$
153,000
Salvage
Revenue
($
16,898,000)

Hazardous
Materials
Training
($
3,392,000)

Manifest
Training
($
521,000)

BRS/
General
Administrative
Duties
($
615,000)

One­
Time
Contingency
Planning
($
1,018,000)

One­
Time
Notification
of
Exclusion
$
704,000
On­
site
Reclamation
Subtotal
($
27,113,000)
Table
1­
1.
Estimated
Incremental
Costs
for
Generators
Reclaiming
Wastes
On
Site,
Reclaiming
Wastes
Off
Site
Within
Industry
Group,
Shifting
from
Off­
Site
Reclamation
Outside
Industry
Group
to
On
Site
Reclamation,
and
Shifting
from
Disposal
to
On­
Site
Reclamation
by
Cost
Item
(
2002$/
year)

Cost
Item
Estimated
Incremental
Costs
1­
6
Off­
Site
Reclamation
Within
Industry
Group
Waste
Reclamation
and
Residual
Management
($
931,000)

Waste
Characterization
Testing
($
418,000)

Manifesting
($
114,000)

Loading
$
328,000
Recovery
Transportation
($
1,274,000)

Salvage
Revenue
($
4,439,000)

Hazardous
Materials
Training
($
426,000)

Manifest
Training
($
76,000)

BRS/
General
Administrative
Duties
($
79,000)

One­
Time
Contingency
Planning
($
124,000)

One­
Time
Notification
of
Exclusion
$
188,000
Off­
site
Reclamation
Within
Industry
Group
Subtotal
($
7,365,000)
Table
1­
1.
Estimated
Incremental
Costs
for
Generators
Reclaiming
Wastes
On
Site,
Reclaiming
Wastes
Off
Site
Within
Industry
Group,
Shifting
from
Off­
Site
Reclamation
Outside
Industry
Group
to
On
Site
Reclamation,
and
Shifting
from
Disposal
to
On­
Site
Reclamation
by
Cost
Item
(
2002$/
year)

Cost
Item
Estimated
Incremental
Costs
1­
7
Shifting
from
Off­
Site
Reclamation
Outside
Industry
Group
to
On­
Site
Reclamation
Waste
Reclamation
and
Residual
Management
($
43,422,000)

Waste
Characterization
Testing
($
15,265,000)

Manifesting
($
2,352,000)

Loading
$
1,077,000
Recovery
Transportation
($
2,003,000)

Salvage
Revenue
$
0
Hazardous
Materials
Training
($
728,000)

Manifest
Training
($
132,000)

BRS/
General
Administrative
Duties
($
139,000)

One­
Time
Contingency
Planning
($
209,000)

One­
Time
Notification
of
Exclusion
$
90,000
Shifting
from
Off­
Site
Reclamation
Outside
Industry
Group
to
On­
Site
Reclamation
Subtotal
($
63,083,000)
Table
1­
1.
Estimated
Incremental
Costs
for
Generators
Reclaiming
Wastes
On
Site,
Reclaiming
Wastes
Off
Site
Within
Industry
Group,
Shifting
from
Off­
Site
Reclamation
Outside
Industry
Group
to
On
Site
Reclamation,
and
Shifting
from
Disposal
to
On­
Site
Reclamation
by
Cost
Item
(
2002$/
year)

Cost
Item
Estimated
Incremental
Costs
1­
8
Shifting
from
Disposal
to
On­
Site
Reclamation
Waste
Disposal,
Reclamation
and
Residual
Management
$
18,080,500
Waste
Characterization
Testing
($
22,893,000)

Manifesting
($
3,527,000)

Loading
$
1,762,000
Recovery
Transportation
$
0
Salvage
Revenue
($
73,026,000)

Hazardous
Materials
Training
($
385,000)

Manifest
Training
($
41,000)

BRS/
General
Administrative
Duties
($
66,000)

One­
Time
Contingency
Planning
($
142,000)

One­
Time
Notification
of
Exclusion
$
135,000
Shifting
from
Disposal
to
On­
Site
Reclamation
Subtotal
($
80,102,500)

Total
Incremental
Costs
($
177,663,500)
Table
1­
1.
Estimated
Incremental
Costs
for
Generators
Reclaiming
Wastes
On
Site,
Reclaiming
Wastes
Off
Site
Within
Industry
Group,
Shifting
from
Off­
Site
Reclamation
Outside
Industry
Group
to
On
Site
Reclamation,
and
Shifting
from
Disposal
to
On­
Site
Reclamation
by
Cost
Item
(
2002$/
year)

Cost
Item
Estimated
Incremental
Costs
1­
9
Estimated
Reduction
in
State
Government
Program
Rents
from
Reduced
Hazardous
Waste
Tax
Collection
for
Each
Category
of
Generators
(
2002$/
year)

On­
site
Reclamation
($
2,118,000)

Off­
site
Reclamation
Within
Industry
Group
($
32,000)

Off­
Site
Reclamation
Outside
Industry
Group
Switching
to
On­
Site
Reclamation
($
172,000)

Off­
Site
Disposal
Switching
to
On­
Site
Reclamation
($
4,651,000)

Total
State
Tax
Costs
($
6,973,000)

Note:
Numbers
in
parentheses,
"(
)",
represent
negative
costs
that
reflect
revenues
or
cost
savings.
2­
1
2.0
INTRODUCTION
Under
the
current
Resource
Conservation
and
Recovery
Act
(
RCRA)
regulations,
secondary
materials
(
i.
e.,
materials
that
are
neither
classified
as
virgin
materials
nor
primary
materials)
may
be
solid
wastes
and
also
hazardous
wastes
when
recycled
depending
on
the
type
of
material
(
e.
g.,
sludge,
spent
material,
or
byproduct)
and
the
type
of
recycling
(
e.
g.,
burning
for
energy
recovery,
use
constituting
disposal,
and
reclamation).
Currently,
the
Environmental
Protection
Agency
(
EPA)
is
revising
these
regulations
to
respond
to
concerns
articulated
in
a
series
of
decisions
by
the
U.
S.
D.
C.
Circuit
Court
of
Appeals
concerning
the
Agency's
legal
authority
to
regulate,
as
hazardous
wastes,
certain
secondary
materials
being
recycled
under
RCRA.
The
most
recent
D.
C.
Circuit
decision
addressing
RCRA
jurisdiction
over
secondary
materials
being
recycled
is
Association
of
Battery
Recyclers,
Inc.,
et
al.,
Petitioners
vs.
U.
S.
Environmental
Protection
Agency
No.
98­
1368,
April
21,
2000
(
ABR).
The
Court
held
in
ABR
that
EPA
could
not
regulate
secondary
materials
from
the
mineral
processing
industry
under
RCRA
that
are
stored
on
land
for
any
period
of
time.
The
Court
reasoned
that
EPA
had
not
demonstrated
that
such
materials
were"
discarded"
within
the
statutory
meaning
of
the
term.
The
Court
vacated
the
regulatory
language
in
40
CFR
261.4(
a)(
17)
that
established
RCRA
jurisdiction
over
these
materials.
Finally,
the
Court
expressed
displeasure
that
EPA
had
again
classified
materials
as
"
solid
wastes"
for
its
Subtitle
C
regulatory
program
that
were
not
discarded,
but
rather
"
destined
for
reuse
or
recycling
in
a
continuous
process
by
the
generating
industry
itself."

EPA
is
revising
its
definition
of
solid
waste
regulations
in
response
to
the
series
of
D.
C.
Circuit
opinions.
These
revised
regulations
will
change
how
certain
secondary
materials
(
i.
e.,
spent
materials,
listed
sludges
and
listed
byproducts)
being
recycled
are
classified
under
the
Subtitle
C
regulatory
program.
In
response
to
these
regulatory
changes,
some
RCRA
regulated
entities
who
currently
recycle
secondary
materials
will
realize
cost
savings
from
the
regulatory
change.
Other
RCRA
regulated
entities
who
currently
land
dispose,
incinerate,
or
recover
energy
from
hazardous
waste
will
be
induced
to
recycle
their
waste
to
obtain
lower
material
management
costs
resulting
from
the
change
in
RCRA
regulation.

The
Agency
is
proposing
to
exclude
from
RCRA
jurisdiction,
all
hazardous
secondary
materials
recycled
in
a
continuous
process
within
the
generating
industry.
This
extends
to
both
recycling
done
onsite
as
well
as
recycling
completed
off­
site
from
the
generating
facility
when
the
off­
site
facility
is
in
the
same
generating
industry
as
the
facility
that
generated
the
material.
This
economic
assessment
presents
a
cost
and
economic
impact
analysis
corresponding
to
the
rule
to
exclude
metal,
solvent,
and
other
wastes
(
e.
g.,
acid)
from
the
Definition
of
Solid
Waste
if
reclaimed
on
site
or
within
the
same
Industry
Group
(
4­
digit
NAICS
code).
The
expected
effect
of
this
regulatory
modification
include
conformity
with
the
D.
C.
Circuit
Court
opinion
and
increased
reclamation
of
values
from
metal,
solvent
and
other
wastes
on
site
or
within
the
same
Industry
Group.
2­
2
Executive
Order
No.
12866
(
58
FR
51735,
October
4,
1993)
requires
that
regulatory
agencies
determine
whether
a
new
regulation
constitutes
a
significant
regulatory
action.
A
significant
regulatory
action
is
defined
as
an
action
likely
to
result
in
a
rule
that
may:


Have
an
annual
effect
on
the
economy
of
$
100
million
or
more
or
adversely
affect
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;


Create
a
serious
inconsistency
or
otherwise
interfere
with
an
action
taken
or
planned
by
another
agency;


Materially
alter
the
budgetary
impact
of
entitlements,
grants,
user
fees,
or
loan
programs
or
the
rights
and
obligations
of
recipients
thereof;
or

Raise
novel
legal
or
policy
issues
arising
out
of
legal
mandates,
the
President's
priorities,
or
the
principles
set
forth
in
Executive
Order
12866.

This
analysis
is
designed
to
address
the
first
and
third
factors
listed
above.
To
accomplish
this,
EPA
estimated
the
costs
and
potential
economic
impacts
of
this
regulatory
modification
on
generators
of
metal,
solvent
and
other
wastes
recovered
either
on
site
and
off
site
within
the
same
industry
group;
generators
who
will
find
it
more
economical
to
recover
these
wastes
on
site
instead
of
at
facilities
outside
their
industry
group;
generators
who
will
determining
it
more
economical
to
recover
these
wastes
on
site
instead
of
primarily
off
site
disposal;
and
State
hazardous
waste
program
budgets
from
reduced
rents
collected
through
taxes
and
fees
to
determine
if
it
is
a
significant
regulatory
action
as
defined
by
the
Executive
Order.

2.1
Purpose
This
economic
assessment
evaluates
the
costs
and
benefits
of
relieving
particular
regulatory
burdens
on
generators
and
within­
industry
off­
site
reclaimers
of
these
wastes.
EPA
is
proposing
to
allow
metal­
bearing,
solvent
and
other
types
of
waste
that
are
reclaimed
either
on
site
or
off
site
within
the
same
Industry
Group
(
4­
digit
NAICS
code)
be
excluded
from
the
Definition
of
Solid
Waste
under
RCRA.

This
analysis
estimates
how
generators
reclaiming
their
waste
and
within­
industry
off­
site
reclaimers
may
economically
benefit
from
the
regulatory
modification.
Estimates
of
the
cost
effects
of
the
regulation
were
determined
on
both
a
model­
plant
and
industry­
wide
basis.
2­
3
2.2
Scope
of
Study
Data
from
the
1999
and
1997
Biennial
Reporting
System
(
BRS)
databases
were
used
to
complete
this
analysis.
A
total
of
1,749
plants
recovering
approximately
1,570,000
tons
either
on
site
or
within
the
same
Industry
Group
may
benefit
from
the
exclusion
from
RCRA
jurisdiction.
These
totals
include
plants
that
recovered
wastes
off
site
outside
their
Industry
Group
where
it
was
determined
it
was
economically
feasible
to
construct
an
on­
site
recovery
facility.
The
total
also
includes
five
waste
types
currently
disposed
where
it
was
determined
it
is
economically
feasible
to
constuct
an
on­
site
recovery
facility
and
the
waste
itself
was
of
sufficient
quality
for
recovery.

Industries
most
heavily
impacted
by
this
proposed
rule
include
basic
chemical
manufacturing
(
NAICS
3251),
nonferrous
metal
(
except
aluminum)
production
and
processing
(
NAICS
3314),
steel
product
manufacturing
from
purchased
steel
(
NAICS
3312),
pharmaceutical
and
medicine
manufacturing
(
NAICS
3254),
paint,
coating,
and
adhesive
manufacturing
(
NAICS
3255),
sawmills
and
wood
preservation
(
NAICS
3211).

It
should
be
noted
that
small
quantity
generators
(
SQGs,
i.
e.,
generators
who
generated
less
than
1,000
kilograms
of
hazardous
waste
in
a
calendar
month)
are
not
required
to
complete
a
Biennial
Report.
Therefore,
the
BRS
data
used
in
this
analysis
under
represents
the
total
number
of
plants,
affected
by
the
rule.

The
main
regulatory
option
will
allow
generators
of
metal,
solvent,
and
other
types
of
waste
being
reclaimed
either
on
site
or
off
site
within
the
same
industry
group
to
be
excluded
from
the
Definition
of
a
Solid
Waste
and
RCRA
jurisdiction.
The
Main
Option
is
the
subject
of
the
main
report.
Other
regulatory
options
considered
are
presented
in
Appendix
A,
B
and
C.

Appendix
A
presents
a
Co­
Proposal
Option.
Under
the
Appendix
B
presents
the
Manufacturing
Sector
Option.
Under
this
option
only
reclaimed
wastes
in
the
manufacturing
sector
(
NAICS
codes
31
through
33)
will
be
granted
the
exclusion
from
the
Definition
of
Solid
Waste.
2­
4
Appendix
C
presents
the
Restricted
Product
Use
Option.
Under
this
option
the
recovery
material
has
to
be
the
primary
good
(
i.
e.,
main
product)
manufactured
by
that
industry
to
be
granted
the
exclusion
from
the
Definition
of
Solid
Waste.

2.3
Organization
of
Report
The
remainder
of
this
report
is
divided
into
seven
sections.
Section
3
presents
the
analytical
methodology,
data
collection
methodology,
and
limitations
of
the
analysis.
Section
4
presents
the
total
hazardous
waste
generation
and
reclamation
practices
impacted
by
the
proposed
rule.
Section
5
presents
the
cost
impact
analysis
of
the
proposed
regulation.
Section
6
documents
the
economic
impacts.
Section
7
summarizes
the
potential
qualitative
benefits
of
the
regulation.
Section
8
presents
the
references
used
in
the
analysis.
1
Office
of
Management
and
Budget,
"
Economic
Analysis
of
Federal
Regulations
under
Executive
Order
12866,"
January
11,
1996.

3­
1
3.0
METHODOLOGY
AND
LIMITATIONS
3.1
Analytical
Methodology
This
economic
assessment
follows
the
guidelines
spelled
out
in
the
Office
of
Management
and
Budget,
"
Economic
Analysis
of
Federal
Regulations
Under
Executive
Order
12866,"
January
11,
1996.
The
economic
assessment
identifies
and
assesses
the
costs
of
the
baseline
and
alternative
approach.
An
estimate
of
the
incremental
cost
or
benefit
(
cost
savings)
of
the
proposed
rule
is
determined
based
on
production
cost
estimates
at
a
seven
percent
real
discount
rate.
Finally,
an
evaluation
of
the
distribution
of
costs
and
benefits
across
populations
and
industry
groups
is
presented.

3.1.1
Baseline
The
baseline
is
the
assessment
of
the
way
the
world
looks
absent
the
proposed
regulation.
1
Baseline
in
this
economic
assessment
is
a
measure
of
current
reclamation
practices
and
associated
administrative
burdens
under
RCRA
by
generators
of
hazardous
waste.
Baseline
reclamation
practices
were
determined
in
this
assessment
using
data
reported
by
large
quantity
generators
of
hazardous
waste
in
EPA's
1999
and
1997
Biennial
Report
databases.

3.1.2
Alternative
Approach
The
alternative
approach
(
i.
e.,
Main
Option)
in
this
assessment,
as
discussed
previously,
responds
to
a
series
of
judicial
decisions.
This
economic
assessment
evaluates
the
costs
and
benefits
of
relieving
particular
regulatory
burdens
on
generators
and
within­
industry
off­
site
reclaimers
of
these
wastes
if
they
are
no
longer
regulated
under
RCRA
Subtitle
C
if
reclaimed.
EPA
is
proposing
to
allow
metal­
bearing,
solvent
and
other
types
of
waste
that
are
reclaimed
either
on
site
or
off
site
within
the
same
Industry
Group
(
4­
digit
NAICS
code)
to
be
excluded
from
the
Definition
of
Solid
Waste
under
RCRA
Subtitle
C.
Other
alternative
approaches
considered
are
presented
in
Appendix
A,
B
and
C.

3.1.3
Cost
and
Benefit
Estimates
Costs
are
measured
as
the
opportunity
cost
of
the
resources
used
or
the
benefits
forgone
or
gained
as
a
result
of
the
regulatory
action.
Opportunity
costs
include,
but
are
not
limited
to,
private­
sector
compliance
costs
and
government
administrative
costs.
Opportunity
costs
also
include
losses
in
consumers'
or
producers'
surpluses,
discomfort
or
inconvenience,
and
loss
of
2
Ibid.

3
Ibid.

4
Ibid.

5
Ibid.

3­
2
time.
2
This
economic
assessment
does
not
calculate
losses
in
consumers'
or
producers'
surpluses,
discomfort
or
inconvenience.
It
does
estimate
reductions
in
private­
sector
compliance
costs
and
gains
in
time
from
fewer
administrative
compliance
costs.

All
costs
calculated
are
incremental.
They
represent
the
changes
in
costs
that
would
occur
if
the
regulatory
option
is
implemented
compared
to
the
baseline.
Future
costs
that
would
be
incurred
even
if
the
regulation
is
not
promulgated,
as
well
as
costs
that
already
have
been
incurred
(
sunk
costs),
are
not
part
of
the
incremental
costs.
3
Goods
and
services
are
valued
at
their
market
prices
in
this
economic
assessment.
Increases
or
decreases
in
health
and
safety
risks
have
not
been
evaluated
to
estimate
the
cost
or
benefits
of
these
goods
that
are
indirectly
traded
in
markets.

Constant­
dollar
costs
and
benefits
are
discounted
to
present
value
to
determine
overall
net
benefits
of
the
proposed
rule.
Benefits
and
costs
are
estimated
in
real
dollars
(
i.
e.,
corrected
for
inflation).
This
economic
assessment
follows
the
basic
guidance
on
discount
rates
for
regulatory
analyses
provided
in
OMB
Circular
A­
94.
The
seven
percent
discount
rate
specified
in
the
guidance
approximates
the
opportunity
cost
of
capital,
which
is
the
before­
tax
rate
of
return
to
incremental
private
investment.
This
discount
rate
reflects
the
rates
of
return
on
low
yielding
forms
of
capital,
such
as
housing,
as
well
as
the
higher
rates
of
return
yielded
by
corporate
capital.
4
3.1.4
Distributional
Effects
The
distributional
effects
describes
the
net
effects
of
the
regulatory
alternative
across
the
population
and
economy.
5
In
this
economic
assessment
certain
industrial
groups
may
receive
more
benefits
than
other
groups
because
they
reclaim
more
waste.
In
addition,
larger
businesses
may
achieve
more
benefits
than
smaller
businesses
from
economies
of
scale
allowing
more
on­
site
reclamation
and
exclusions
from
the
Definition
of
Solid
Waste.
Finally,
certain
states
charge
hazardous
waste
generation
taxes
and
fees
(
i.
e.,
transfer
payments).
With
the
proposed
regulation
to
exclude
wastes
that
are
reclaimed
from
the
Definition
of
Solid
Waste,
these
wastes
are
no
longer
defined
as
hazardous
waste
and
thus
may
not
incur
a
hazardous
waste
generation
tax
or
fee.
As
a
result,
there
may
be
state
geographic
distributional
effects
on
generators
through
reduced
transfer
payments.
At
the
same
time,
certain
state
government
hazardous
waste
programs
may
have
reductions
in
program
revenues
from
collected
taxes
and
fees.
Transfer
payments
are
not
treated
as
social
costs
when
estimating
the
total
costs
and
benefits
of
the
proposed
rule
because
they
reflect
redistribution
of
income/
wealth
and
not
the
social
value
of
a
good
or
service
(
i.
e.,
resource).
State
taxes
and
fees
are
included
in
the
economic
impact
analysis.
3­
3
3.2
Data
Collection
Methodology
3.2.1
Data
Source
The
U.
S.
EPA
1999
and
1997
Hazardous
Waste
Report
census
of
large
quantity
generators
(
LQGs)
of
hazardous
waste
and
RCRA­
permitted
treatment,
storage,
and
disposal
facilities
(
TSDs)
were
used
to
compile
a
database
of
all
hazardous
wastes
generated
that
have
the
potential
to
become
excluded
from
RCRA
Subtitle
C
jurisdiction
under
the
proposed
rulemaking
if
the
waste
is
reclaimed.
The
Hazardous
Waste
Report
is
also
referred
to
as
the
Biennial
Report
because
LQGs
of
hazardous
waste
and
all
TSDs
are
required
to
report
their
hazardous
waste
generation
and
management
practices
every
two
years.
The
1999
and
1997
Biennial
Reports
were
used
instead
of
the
2001
Biennial
Report
because
the
2001
database
has
yet
to
be
developed.

3.2.2
Methodology
for
Identifying
Within
Industry
Group
(
Same
4­
Digit
NAICS
Code)
Recovery
Management
Quantities
The
following
steps
were
taken
to
develop
a
data
sets
of
same
NAICS
code
hazardous
waste
recovery
in
the
United
States
and
recovery
in
other
countries:

1.
Initial
Data
Downloaded
from
Databases:
1999
data
for
all
hazardous
wastes
generated
by
LQGs
and
managed
on
site
or
off
site
in
metal
recovery
(
M011­
M019),
solvent
recovery
(
M021­
M029),
and
other
recovery
(
M031­
M039)
system
types
were
included
in
the
initial
database.
Metals
recovery
includes
high
temperature
metals
recovery,
retorting,
secondary
smelting,
and
other
metals
recovery
(
e.
g.,
ion
exchange,
reverse
osmosis,
and
acid
leaching).
Solvents
recovery
includes
fractionation/
distillation,
thin
film
evaporation,
solvent
extraction,
and
other
solvent
recovery.
Other
recovery
includes
acid
regeneration
and
other
recovery
(
e.
g.,
waste
oil
recovery
and
nonsolvent
organics
recovery).

Similar
data
were
downloaded
for
the
1997
database;
however,
only
those
records
that
reclaimed
metal,
solvent,
or
other
values
in
1997,
but,
not
in
1999
were
kept.
These
facilities
may
switch
back
to
reclamation
given
the
more
favorable
economic
conditions
produced
by
the
proposed
regulation
given
they
have
reclaimed
these
wastes
in
the
past.

2.
Exclusion
of
Origin
Code
4
Records
from
Analysis:
The
data
were
then
sorted
and
all
waste
streams
originating
from
a
transfer
location,
origin
code
4,
were
eliminated
and
not
included
in
the
database
to
be
used
for
the
rule
making
to
avoid
double­
counting
waste
quantities.
The
definition
of
origin
code
4
is
"
the
hazardous
waste
received
from
off
site
and
not
recycled
or
treated
on
site"
(
1999
Hazardous
Waste
Report
Forms
and
Instructions,
pg.
13).
Tables
3­
1
and
3­
2
present
the
total
number
of
records
and
total
onsite
and
off­
site
management
quantity
changes
when
origin
code
4
waste
streams
were
removed
from
the
database.
The
number
of
records
included
in
the
database
went
from
18,917
to
14,509
with
the
exclusion
of
the
origin
code
4
records
for
the
1999
data
and
3­
4
from
5,094
to
4,728
for
the
1997
data.
The
total
generation
quantity
does
not
change
because
these
records
reflect
wastes
that
were
received
from
off
site
and
NOT
generated
by
the
facility.
The
instructions
for
the
1999
Biennial
Report
form
related
to
origin
code
4
records
are
not
to
report
the
waste
being
generated.
They
are
only
required
to
report
how
the
waste
is
managed.
Therefore,
the
on­
site
and
off­
site
recovery
management
quantities
changed
when
origin
code
4
records
were
removed.

With
the
exclusion
of
origin
code
4
records,
the
on­
site
recovery
management
quantity
went
from
approximately
5.5
million
tons
to
1.9
million
tons
in
the
1999
data
and
reduced
by
approximately
1,600
tons
in
the
1997
data.

Six
(
6)
records
accounted
for
3.6
million
tons
of
the
on­
site
management
quantity
reduction
in
1999.
These
records
were
examined
to
determine
if
any
reporting
or
data
entry
error
may
have
caused
these
wastes
to
be
erroneously
reported
as
origin
code
4
wastes.
Of
the
six
origin
code
4
records
reviewed,
99.9%
of
the
reduction
is
attributed
to
one
record.
The
record
(
EPA
ID
VA1210020730)
indicates
392,745.29
tons
of
"
DNT
contaminated
wastewater"
was
generated.
Managed
totals
were
reported
as
3,589,180
tons
by
system
type
M011
(
metals
recovery)
and
392,745.3
tons
by
system
type
M081
(
biological
treatment).
In
comparison
to
1997
BRS
Data,
the
generated
total
appears
correct.
However,
the
M011
system
type
appears
to
have
been
entered
in
error.
Also,
the
origin
code
should
have
been
reported
as
1,
as
the
waste
is
managed
on
site.
Of
the
remaining
five
records,
four
records
appeared
to
have
erroneous
on­
site
managed
totals
duplicating
reported
shipped
totals.
The
erroneous
on­
site
managed
totals
were
removed.
The
remaining
waste
stream
appears
to
have
been
mislabeled
as
origin
code
4
instead
of
1,
based
on
comparison
to
1997
BRS
data
and
reported
managed
totals.
Adjusting
origin
code
4
records
in
the
data
provides
a
better
data
set
from
which
do
conduct
the
economic
analysis
for
this
rulemaking.

TABLE
3­
1
Summary
of
1999
Total
Hazardous
Waste
Metal
Recovery,
Solvent
Recovery
and
Other
Recovery
Generation
and
Management
Quantities
(
Tons)

Database
Including
Origin
Code
4
Database
Excluding
Origin
Code
4
Total
number
of
records
(
waste
streams)
18,917
14,511
Total
generation
quantity
of
all
records
4,596,678
4,596,678
On­
site
recovery
management
quantity
of
all
records
5,520,660
1,928,745
TABLE
3­
1
Summary
of
1999
Total
Hazardous
Waste
Metal
Recovery,
Solvent
Recovery
and
Other
Recovery
Generation
and
Management
Quantities
(
Tons)

Database
Including
Origin
Code
4
Database
Excluding
Origin
Code
4
3­
5
Off­
site
recovery
management
quantity
of
all
records*
System
1
System
2
System
3
System
1
System
2
System
3
1,069,065
126,568
34,383
975,763
119,393
34,335
Data
Source:
1999
Biennial
Report
Origin
Code
4:
The
hazardous
waste
received
from
off
site
and
not
recycled
or
treated
on
site.
Limitation:
Only
includes
quantities
generated
by
large
quantity
generators.
*
Generators
can
report
multiple
off­
site
system
types
(
e.
g.,
System
1,
System
2,
System
3)
used
for
each
waste
if
needed.
A
close
estimate
of
the
total
off­
site
recovery
management
quantity
is
the
sum
of
the
three
systems.

TABLE
3­
2
Summary
of
1997
Total
Hazardous
Waste
Metal
Recovery,
Solvent
Recovery
and
Other
Recovery
Generation
and
Management
Quantities
(
Tons)

Database
Including
Origin
Code
4
Database
Excluding
Origin
Code
4
Total
number
of
records
(
waste
streams)
5,094
4,728
Total
generation
quantity
of
all
records
555,514
555,514
On­
site
recovery
management
quantity
of
all
records
130,705
129,101
Off­
site
recovery
management
quantity
of
all
records*
System
1
System
2
System
3
System
1
System
2
System
3
146,779
10,591
748
141,360
10,578
748
Data
Source:
1997
Biennial
Report
Origin
Code
4:
The
hazardous
waste
received
from
off
site
and
not
recycled
or
treated
on
site.
Limitation:
Only
includes
quantities
generated
by
large
quantity
generators.
*
Generators
can
report
multiple
off­
site
system
types
(
e.
g.,
System
1,
System
2,
System
3)
used
for
each
waste
if
needed.
A
close
estimate
of
the
total
off­
site
recovery
management
quantity
is
the
sum
of
the
three
systems.

3.
Identification
of
Statistical
Outliers
for
QA/
QC:
Following
the
removal
of
all
appropriate
origin
code
4
records,
an
analysis
of
statistical
outliers
was
conducted
on
the
reported
3­
6
total
waste
generation,
on­
site
recovery
management
quantities,
and
off­
site
recovery
management
quantities.
Up
to
six
different
off­
site
management
locations
may
have
been
reported
for
one
waste.
The
statistical
analysis
only
was
conducted
on
the
first
three
reported
off­
site
management
locations
given
they
comprised
nearly
all
of
the
reported
off
site
recovery
management
quantity.

For
each
generation
and
management
quantity
data
item
(
i.
e.,
total
generation,
on­
site
management,
off­
site
management
system
1,
off­
site
management
system
2,
and
off­
site
management
system
3)
the
sum,
mean,
and
standard
deviation
were
computed.
In
a
"
normal"
distribution
of
the
data,
two
standard
deviations
above
and
below
the
mean
quantity
capture
and
account
for
95%
of
the
total
quantity.
The
generation
and
management
distributions
are
not
normal,
but
skewed
to
the
right.
However,
those
records
with
reported
generation
or
management
quantities
greater
than
two
standard
deviations
above
the
mean
were
still
identified
as
statistical
`
outliers'
and
subject
to
QA/
QC
in
this
analysis.
A
1999
data
record
was
identified
as
an
outlier
for
the
total
generation
quantity
if
it
exceeded
28,981
tons.
On­
site
management
outliers
have
reported
quantities
greater
than
47,741
tons.
Similarly,
off­
site
management
system
1,
system
2,
and
system
3
outliers
have
reported
quantities
greater
than
1,656
tons,
2,067
tons,
and
2,397
tons,
respectively.

Table
3­
3
presents
the
number
of
records
identified
as
outliers
and
the
percentage
of
the
total
quantity
these
records
represented.
In
1999,
the
17
total
generation
outlier
records
account
for
62%
of
the
total
generation
quantity.
The
five
on­
site
management
outlier
records
account
for
64%
of
the
total
on­
site
management
quantity.
For
the
off­
site
management
records
there
are
overlap
between
management
system
1,
2,
and
3
quantities
exceeding
the
second
standard
deviation
quantity
which
explains
why
97
records
are
identified
as
offsite
outliers,
while
106
records
are
indicated
in
the
Table
3­
3.
Of
the
total
quantity
managed
off­
site,
65%
of
the
total
off­
site
quantity
is
represented
by
the
outlier
records.

For
the
1997
data
a
more
abbreviated
QA/
QC
was
conducted.
All
records
with
total
estimated
incremental
costs
between
pre­
and
post­
rule
exceeding
$
500,000
were
reviewed.
A
total
of
15
records
were
reviewed.
3­
7
TABLE
3­
3
Identification
of
1999
Hazardous
Waste
Metal
Recovery,
Solvent
Recovery
and
Other
Recovery
Generation
and
Management
Outlier
Records
and
Quantities
(
Tons)

Location/
Type
of
Generation
Total
Generation
On­
site
Management
Off­
site
Management
System
1
System
2
System
3
#
Outlier
Records
Identified
17
5
86
15
5
Sum
of
Outlier
Records
Quantity
2,841,423
1,234,293
616,909
85,796
26,769
Sum
of
All
Records
Quantity
(
no
origin
code
4)
4,596,678
1,928,745
975,762
119,393
34,335
Outlier
Quantity
as
Percentage
of
Total
Quantity
62%
64%
63%
72%
78%

65%
(
total
for
all
Off­
site
Management)

Data
Source:
1999
Biennial
Report
Outlier
Identification:
Included
records
that
are
over
two
standard
deviations
above
the
mean.
Note:
Analysis
excludes
records
with
origin
code
equal
4
("
the
hazardous
waste
received
from
off
site
and
not
recycled
or
treated
on
site")
Limitation:
Only
includes
quantities
generated
by
large
quantity
generators.

4.
QA/
QC
of
Identified
Statistical
Outliers:
the
outlier
records
were
evaluated
for
the
issues
identified
below:

­
Is
there
mass
balance
between
the
total
generation
quantity
and
the
quantities
managed
on
and
off
site?
­
Is
the
reported
unit
of
measure
consistent
with
other
waste
streams
reported
in
1999
and
in
the
1997
Biennial
Report?
­
For
off­
site
management
quantities,
did
the
facility
receiving
the
waste
report
a
similar
quantity?
­
Did
the
facility
report
generating
or
managing
a
similar
quantity
and
type
of
waste
in
1999
and
in
the
1997
Biennial
Report?
­
Did
the
facility
report
a
different
origin
codes
in
1999
and
in
the
1997
Biennial
Report?
­
Did
the
facility
report
a
different
(
non­
recovery)
system
type
codes
in
1999
and
in
the
1997
Biennial
Report?
­
Is
the
waste
stream
the
result
of
a
new
remediation
activity
or
one­
time
generation
activity?
3­
8
If
the
reported
generation
and
management
quantities
were
not
grossly
different
(
i.
e.,
within
a
factor
of
two),
the
reported
quantities
were
not
modified.
Tables
3­
4
and
3­
5
present
the
records
that
were
modified
as
a
result
of
DPRA's
analysis.

A
summary
of
the
QA/
QC
issues
and
modifications
are
as
follows:

­
Shipping
Disconnect
­
A
valid
receiver
(
i.
e.,
facility
showing
receipt
of
any
wastes
streams)
did
not
report
a
similar
waste
stream
as
reported
shipped
by
the
facility.
No
similar
waste
stream
was
reported
in
1997.
The
modification
involved
removal
of
the
waste
stream
from
the
database.

­
Mass
Balance
Issues
­
Reported
generation
differs
from
reported
on­
site
management/
shipping
totals.
Two
situations
arose
from
the
mass
imbalance.

1.)
The
generation
total
exceeded
a
single
management/
shipping
total
by
a
factor
greater
than
two.
Form
WR
volumes
and
1997
BRS
data
were
reviewed
for
comparing
management/
shipping
totals.
Appropriate
generation/
on­
site
management/
shipping
totals
were
modified.

2.)
On­
site
management
and
shipping
totals
were
being
double­
counted.
That
is,
the
on­
site
management
and
shipping
totals
were
identical,
and
the
total
was
double
the
reported
generated
total.
Removal
of
one
of
the
totals
(
management
or
shipping)
was
determined
based
on
review
of
1999
BRS
WR
data,
comparison
to
1997
BRS
data,
determination
if
the
facility
has
a
TDR
permit,
and
comparison
to
other
waste
streams
generated
at
the
facility.

­
Leachate
Contaminated
Groundwater
Reported
as
Generated
­
As
explained
in
the
special
instructions
section
of
the
1999
BRS
instructions
for
ground
water
contaminated
by
leachate:
"
Groundwater
contaminated
by
RCRA
hazardous
waste
is
not
considered
a
solid
waste
and
is,
therefore,
not
classified
as
a
hazardous
waste."
The
quantity
should
not
be
reported
in
the
generation
total.
However,
management
of
the
waste
must
be
reported.
As
such,
a
managed
or
shipped
total
must
be
reported
for
contaminated
ground
water.
Waste
streams
with
reported
generated
totals
of
contaminated
ground
water
were
modified
(
i.
e.,
generated
totals
were
deleted).
In
addition,
one
facility,
CAD981653553,
reported
774,546
tons
of
solvent
waste
(
contaminated
groundwater)
being
recovered
onsite
This
one
facility
(
quantity)
skewed
the
on­
site
recovery
profile
across
NAICS
codes
accounting
for
40
percent
of
the
total
on­
site
quantity.
Since
it
is
unlikely
to
be
impacted
in
a
negative
way
by
the
proposed
rule,
it
has
been
excluded
from
the
data
analysis.
The
associated
SIC
code
was
9223,
correctional
institutions,
and
the
current
solvents
recovery
method
is
by
fractionation/
distillation.

­
Origin
­
Waste
streams
with
reported
management/
generation
totals
but
with
an
origin
code
of
4
were
reviewed
and
modified.
Two
issues
were
identified
from
these
facilities.
3­
9
1.)
The
reported
origin
code
appeared
accurate.
This
determination
was
based
on
a
lack
of
a
treatment,
disposal,
or
recycling
(
TDR)
permit,
no
generation
quantity
reported,
and
other
waste
streams
at
the
facility
were
reported
with
origin
code
4.
The
waste
streams
were
modified
by
removing
the
on­
site
managed
total
and
retaining
the
shipped
total.

2.)
The
reported
origin
code
appeared
inaccurate.
This
determination
was
based
on
a
reported
quantity
in
the
generation
total
when
origin
code
4
is
an
indicator
that
the
waste
was
not
generated
on
site
and
comparisons
with
1997
BRS
data
and
other
reported
facility
waste
streams.
These
waste
streams
were
modified
by
changing
the
origin
code
to
1.

­
Unit
of
Measure
­
For
one
facility
the
unit
of
measure
(
UOM)
was
modified
from
short
tons
to
pounds.
This
modification
is
based
on
the
UOM
reported
in
1997
BRS
and
the
totals
reported
by
the
facility
receiving
the
waste
for
management.

­
System
Code
­
One
facility
system
code
was
modified
from
M021
to
M121.
The
modification
was
based
on
1997
BRS
data
for
the
waste
stream.
The
waste
stream
was
effectively
removed
as
the
system
code
is
outside
the
scope
of
the
proposed
rule.

For
the
QA/
QC
of
the
1997
BRS
data,
six
facilities
were
contacted
directly
to
verify
their
1997
data,
with
four
responses.
Based
on
the
information
received,
all
six
facilities
were
removed.
Two
facilities
were
removed
as
the
reported
waste
stream
is
no
longer
generated.
One
facility
currently
sells
the
formerly
reported
waste
stream.
One
facility
indicated
the
process
is
a
"
closed
loop"
system,
negating
any
reporting
requirements.
No
information
was
available
for
the
current
process
solvent
use
as
the
process
was
reported
to
have
changed.
One
facility
is
assumed
to
be
closed.
The
final
facility
was
removed
based
on
the
other
facility
discussions,
generally
indicating
large
metal/
solvent/
acid
recycling
facilities
that
did
not
report
similar
wastes
generated
in
1999
have
discontinued
or
switched
the
generation
process.

TABLE
3­
4
Modified
1999
BRS
Facility
Waste
Streams
EPA
ID
Number
Comments
GM
Form
Page
Shipping
Disconnect
CAT080033681
Receiver
not
showing
as
received;
No
similar
`
97
waste
stream.
Removed
waste
stream
due
to
lack
of
correlating
data
to
its
generation.
11
IND000717959
Receiver
not
showing
waste
received.
No
similar
`
97
waste
stream.
Removed
waste
stream
due
to
lack
of
correlating
data
to
its
generation.
6
TXD055330997
Mass
balanced.
No
comparable
1997
BRS
data.
Receiver
did
not
report
this
waste
as
received.
Cannot
determine
if
UOM
error.
Removed
waste
stream
due
to
lack
of
correlating
data
to
its
generation.
8
TABLE
3­
4
Modified
1999
BRS
Facility
Waste
Streams
EPA
ID
Number
Comments
GM
Form
Page
3­
10
Mass
Balance
MID047153077
Mass
not
balanced.
1997
BRS
data
reported
similar
generation
total
to
1999
BRS
data.
Modified
onsite
managed
total
to
match
generated
total.
2
TXD008092793
Mass
not
balanced.
No
comparison
of
1997
BRS
data
to
1999
BRS
data.
Management
of
waste
limited
to
one
type
(
M032).
Increased
managed
total
to
match
generated
total.
6
CTR000004457
Mass
not
balanced.
Shipped
total
similar
to
1997
BRS
data.
Generated
value
approx
13.2
times
greater
than
`
99
shipment
total
and
approx.
21
times
greater
than
`
97
generated
total.
1999
BRS
data
did
not
include
WR
for
shipped
waste.
Modified
generated
total
to
equal
shipped
total.
1
VA1210020730
DNT
Contaminated
Wastewater.
Generation
did
not
equal
managed
total.
Origin
for
waste
stream
is
4,
whereas
same
waste
stream
in
1997
BRS
Data
was
1.
1997
BRS
data
generated
and
managed
total
was
806,853
tons
and
managed
onsite
by
M081.
Assumed
generated
total
is
correct
and
managed
onsite
by
M081.
Removed
second
reported
managed
(
M011)
quantity.
Modified
Origin
from
4
to
1.
20
MID980615298
Mass
not
balanced.
Management
and
shipments
equal
to
each
other
(
334
tons
M029),
1997
BRS
data
showed
similar
waste
streams
were
generated
and
shipped.
1999
BRS
data
had
receivers
for
similar
wastes.
Removed
onsite
management
total
listed
with
system
type
M061.
As
this
modification
did
not
effect
the
population
scope,
no
change
to
the
totals
was
required.
9
OHD004206264
Mass
not
balanced.
Facility
does
not
have
a
TDR
permit.
Generated
total
matches
shipped
total.
1997
BRS
data
reported
similar
waste
streams,
without
managed
totals.
1999
BRS
data
managed
total
system
type
is
M031.
Removed
managed
total,
effectively
removing
this
record
from
scope
of
project.
1
Leachate
Contaminated
Groundwater
MID047153077
Groundwater
remediation
waste.
Mass
balanced.
Management
total
comparable
to
1997
BRS
data.
No
generated
total
in
1997
BRS
data
due
to
leachate
exclusion.
Generation
total
removed
due
to
leachate
exclusion
(
management
total
retained).
1
CAD9816535532
Remediation
derived
waste.
Not
reported
as
generated
due
to
"
Leachate
Generation"
rule
(
not
considered
a
solid
waste).
Managed
total
is
required
and
was
reported.
Removed
record
from
scope
of
project.
10
Origin
NYD013277454
Mass
not
balanced.
Origin
4
stated.
No
generation
reported.
Managed
quantity
equal
to
shipped
quantity.
1997
BRS
data
showed
similar
waste
stream
shipped
only.
Facility
is
not
permitted
for
treatment.
Removed
reported
onsite
managed
(
M029)
quantity.
4
NYD048148175
Mass
not
balanced.
No
generated
total.
Managed
total
equals
shipped
total.
No
1997
BRS
waste
stream
comparable
for
facility.
All
facility
waste
streams
are
reported
as
origin
4
and
shipped
off­
site.
Facility
is
not
permitted
for
treatment.
Removed
onsite
managed
(
M012)
total.
13
TABLE
3­
4
Modified
1999
BRS
Facility
Waste
Streams
EPA
ID
Number
Comments
GM
Form
Page
3­
11
NYD077444263
Mass
not
balanced.
Origin
4
stated.
No
generated
total
reported.
Managed
total
equal
to
shipped
total.
All
facility
waste
streams
are
reported
as
origin
4.
Facility
is
not
permitted
for
treatment.
No
1997
BRS
waste
stream
comparable
for
facility.
Removed
onsite
managed
(
M012)
total.
55
CAD008252405
Mass
not
balanced.
Shipped
total
equals
generated
total.
1997
BRS
data
indicated
origin
4
waste
stream
with
no
onsite
generation
with
a
similar
mass
shipped
to
1999
BRS
Data.
Removed
reported
onsite
managed
(
M022)
quantity
7
TX5360310283
Mass
balanced.
Origin
4
stated.
Managed
total
reported,
no
shipped
total.
Other
site
waste
streams
were
origin
1.
No
1997
BRS
waste
stream
comparable
for
facility.
Modified
waste
stream
by
using
managed
total
as
generated
total
and
changed
origin
from
4
to
1.
4
Unit
of
Measure
PAD004338091
Mass
balanced.
UOM
in
1997
BRS
data
was
lbs
(
not
tons).
Shipped
and
managed
by
M077,
with
similar
received
total.
Modified
UOM
for
generated
and
managed
to
lbs.
1
System
Code
KYD006371314
Mass
not
balanced.
1997
BRS
data
reported
similar
generated
total,
though
management
was
by
M121,
not
M021
as
reported
in
1999
BRS.
Modified
system
type
code
from
M021
to
M121,
essentially
removing
the
management
and
generation
total
from
the
analysis.
11
TABLE
3­
5
Modified
1997
BRS
Facility
Waste
Streams
EPA
ID
Number
Comments
GM
Form
Page
IAD065218737
Facility
reports
the
waste
stream
is
currently
sold.
The
waste
stream
is
classified
as
a
revenue
source
and
not
a
solid
waste.
Treatment
or
recovery
of
the
waste
stream
onsite
is
not
likely
in
the
foreseeable
future.
6
IND006050967
One
process
generating
the
waste
was
removed.
Further
review
by
the
facility
indicated
the
recovery
process
is
a
"
closed
loop"
system.
Therefore,
reporting
of
the
waste
stream
is
not
required.
No
information
regarding
the
quantity
of
the
solvent
used/
recycled
was
available.
26,
30,
35,
43,
44
MAD001016302
No
response.
22,
23
NHD058537960
The
reported
waste
solvent
has
been
removed
from
the
process.
14,
23
OKD074274333
Contact
information
was
not
current.
No
phone
number
was
found
for
the
business.
Assumed
business
is
closed.
3,
15
WAD980833099
The
reported
solvent
has
been
removed
from
the
process
along
with
an
equipment
upgrade.
The
solvent
is
no
longer
necessary.
7,
13
3­
12
5.
Remove
Records
Already
Excluded
Under
Definition
of
Solid
Waste:
Waste
streams
for
industry
groups
with
current
exclusions
from
the
Definition
of
Solid
Waste
were
removed
from
the
database.
Wastes
where
oil
was
recovered
was
excluded
for
SICs
1311,
1321,
1381,
1382,
1389,
2911,
4612,
4613,
4922,
4923,
4789,
5171,
and
5172
(
40
CFR
261.4(
a)(
12)(
ii)).

By­
products
exhibiting
a
characteristic
of
hazardous
waste
are
not
solid
wastes
when
reclaimed
(
40
CFR
261.2(
c)(
3)),
therefore
are
excluded
from
RCRA.
Wastes
with
the
words
"
solder"
or
"
dross"
in
their
waste
description,
that
are
within
the
following
physical
and
chemical
characteristics
of
inorganic
solids:
°
Other
"
dry"
ash,
slag,
or
thermal
residue
(
Form
Code
B304);
°
Metal
scale,
filings,
or
scrap
(
Form
Code
B307);
or
°
Other
waste
inorganic
solids
(
Form
Code
B319);
and
are
within
the
hazardous
waste
characteristic
of
lead
(
EPA
Code
D008)
were
removed
from
the
database
since
lead
solder
dross
is
a
by­
product
of
the
smelting
process.

Sludges
exhibiting
a
characteristic
of
hazardous
waste
are
not
solid
wastes
when
reclaimed
(
40
CFR
261.2(
c)(
3)),
therefore
are
excluded
from
RCRA.
Spent
carbon
organic
solid
wastes
(
Form
Code
B404)
within
the
source
codes
for
"
Remediation
Derived
Waste"
(
A61­
A69)
and
"
Pollution
Control
or
Waste
Treatment
Processes"
(
A71­
A89)
were
removed
from
the
database,
since
wastes
generated
from
pollution
control
devices
are
defined
under
RCRA
as
"
sludge".

Tables
3­
6
and
3­
7
present
the
new
generation
and
management
totals
as
a
result
of
the
QA/
QC
conducted
on
the
origin
code
4
records
and
outlier
records
and
removal
of
records
already
excluded
under
the
Definition
of
Solid
Waste.
The
1999
total
generation
quantity
(
4.2
million
tons)
reported
for
these
records
does
not
equal
the
sum
of
the
on­
site
management
quantity
(
0.8
million
tons)
and
off­
site
management
quantities
(
1.0
million
tons)
because
the
remaining
quantity
is
managed
in
non­
recovery
system
types
(
e.
g.,
incineration
and
landfill).
This
also
is
true
for
the
1997
data.

TABLE
3­
6
Summary
of
Modified
1999
Total
Hazardous
Waste
Metal
Recovery,
Solvent
Recovery
and
Other
Recovery
Generation
and
Management
Quantities
(
Tons)

Database
Including
Origin
Code
4
Database
Excluding
Origin
Code
4,
Outliers,
and
Currently
Excluded
Industry
Groups
Total
number
of
records
(
waste
streams)
14,117
3­
13
Total
generation
quantity
of
all
records
4,233,621
On­
site
recovery
management
quantity
of
all
records
818,374
Off­
site
recovery
management
quantity
of
all
records*
System
1
System
2
System
3
892,997
114,970
34,331
Data
Source:
1999
Biennial
Report
Origin
Code
4:
The
hazardous
waste
received
from
off
site
and
not
recycled
or
treated
on
site.
Limitation:
Only
includes
quantities
generated
by
large
quantity
generators.
*
Generators
can
report
multiple
off­
site
system
types
(
e.
g.,
System
1,
System
2,
System
3)
used
for
each
waste
if
needed.
A
close
estimate
of
the
total
off­
site
recovery
management
quantity
is
the
sum
of
the
three
systems.

TABLE
3­
7
Summary
of
Modified
1997
Total
Hazardous
Waste
Metal
Recovery,
Solvent
Recovery
and
Other
Recovery
Generation
and
Management
Quantities
(
Tons)

Database
Including
Origin
Code
4
Database
Excluding
Origin
Code
4,
Outliers,
and
Currently
Excluded
Industry
Groups
Total
number
of
records
(
waste
streams)
5,094
4,660
Total
generation
quantity
of
all
records
555,514
On­
site
recovery
management
quantity
of
all
records
130,705
27,544
Off­
site
recovery
management
quantity
of
all
records*
System
1
System
2
System
3
146,779
10,591
748
Data
Source:
1997
Biennial
Report
Origin
Code
4:
The
hazardous
waste
received
from
off
site
and
not
recycled
or
treated
on
site.
Limitation:
Only
includes
quantities
generated
by
large
quantity
generators.
*
Generators
can
report
multiple
off­
site
system
types
(
e.
g.,
System
1,
System
2,
System
3)
used
for
each
waste
if
needed.
A
close
estimate
of
the
total
off­
site
recovery
management
quantity
is
the
sum
of
the
three
systems.

6.
Main
Option
­
Only
Include
Off­
site
Transfers
Within
the
Same
Industry
Group
(
4­
Digit
NAICS):
In
the
Association
of
Battery
Recyclers
(
ABR)
Decision,
the
Court
said
that
EPA
overreached
its
authority
by
regulating
mineral
processing
materials
that
were
not
6
Warski,
Kristine.
SIC
vs.
NAICS:
Understanding
the
Difference,
Miller
Brooks
Inc.

7
Ibid.

8
U.
S.
Department
of
Commerce,
US
Census
Bureau,
Development
of
NAICS,
http://
www.
census.
gov/
epcd/
www/
naicsdev.
htm.

3­
14
"
discarded"
by
being
"
disposed
of,
thrown
away
or
abandoned,
but
rather
were
"
destined
for
beneficial
reuse
or
recycling
in
a
continuous
process
by
the
generating
industry
itself."
EPA
is
proposing
to
revise
its
Subtitle
C
regulations
by
generally
giving
up
control
over
materials
reclaimed
within
the
generating
industry
as
solid
wastes.
Consequently,
the
Agency
needs
to
establish,
among
other
things,
a
definition
for
"
generating
industry."

The
Agency's
preference
is
to
use
existing,
well­
defined,
widely
used
industry
classification
system
as
the
basis
for
identifying
"
industries"
for
this
rule.
The
North
American
Industry
Classification
System
(
NAICS),
which
was
developed
by
the
Department
of
Commerce
as
an
update
of
the
Standard
Industrial
Classification
(
SIC)
system
appears
to
be
an
appropriate
choice.

The
Standard
Industrial
Classification
(
SIC)
was
originally
developed
in
the
1930'
s
to
classify
industries
by
activities
and
to
promote
the
comparability
of
establishment
data.
Over
the
years,
the
SIC
codes
were
revised
periodically
to
reflect
the
changes
in
the
economy.
It
was
last
updated
in
1987
when
approximately
20
new
service
industries
were
added
to
the
SIC
and
a
few
new
industries
were
added
to
manufacturing
to
reflect
technological
changes
occurring
in
that
sector.
6
Since
1987,
world
economies
have
rapidly
changed,
bringing
SIC
codes
under
much
criticism.
A
major
change
in
the
system
was
needed;
thus
the
creation
of
NAICS
(
North
American
Industrial
Classification
System).

NAICS
industries
can
be
identified
by
as
much
as
a
6­
digit
code,
in
contrast
to
the
4­
digit
SIC
code.
This
allows
for
additional
detail
and
flexibility
in
designating
sub­
sectors
as
new
sub­
industries
emerge.
The
International
NAICS
agreement
fixes
only
the
first
5
digits
of
the
code.
The
sixth
digit,
where
used,
identifies
subdivisions
of
NAICS
industries
that
accommodate
user
needs
in
individual
countries.
Thus,
6­
digit
US
codes
may
vary
from
counterparts
in
Canada
or
Mexico,
but
at
the
5­
digit
level,
they
are
standardized.
7
The
nomenclature
of
the
groupings
within
the
system
is
different
in
NAICS.
NAICS
calls
the
highest
level
of
aggregation
in
the
system
a
sector;
the
SIC
referred
to
this
grouping
as
a
division.
Other
changes
have
been
made
to
the
nomenclature
as
shown
in
Table
3­
8.8
Table
3­
8.
NAICS
vs.
SIC:
Structure
and
Nomenclature
1/
3­
15
NAICS
SIC
Structure
Definition
Number
Structure
Definition
Number
2­
digit
Sector
18
Letter
Division
8
3­
digit
Subsector
87
2­
digit
Major
Group
67
4­
digit
Industry
Group
290
3­
digit
Industry
Group
360
5­
digit
NAICS
Industry
654
4­
digit
Industry
1303
6­
digit
National
1086
N/
A
N/
A
N/
A
1/
The
agricultural
and
public
administration
industries
were
excluded
from
this
tally.

Source:
U.
S.
Department
of
Commerce,
US
Census
Bureau,
Development
of
NAICS,
http://
www.
census.
gov/
epcd/
www/
naicsdev.
htm.

The
Agency
has
selected
the
4­
digit
NAICS
to
define
the
same
"
generating
industry"
(
i.
e.,
industry
group).
The
BRS
4­
digit
SIC
data
were
cross­
walked
into
the
4­
digit
NAICS
codes.
Waste
streams
that
are
not
transferred
off
site
within
the
same
4­
digit
NAICS
were
eliminated
from
the
database
because
they
are
not
impacted
by
the
proposed
regulation.
The
resulting
on­
site
and
off­
site
recovery
quantities
for
the
1999
and
1997
list
of
large
quantity
generators
are
presented
in
the
Table
3­
9
below.
The
plant
counts
and
recovered
quantities
listed
below
will
be
higher
if
small
quantity
generators
are
included.
The
Biennial
Report
database
does
not
include
small
quantity
generators.

Table
3­
9.
Summary
of
Within
Industry
Group
Affected
Plants
and
Recovery
Management
Quantities
No.
of
Plants
Recovered
Quantity
(
tons)

1999
On­
site
Recovery
Management
849
818,348
1997
On­
site
Recovery
Management
253
27,544
1999
Off­
site
Recovery
Management
Within
Industry
Group
249
59,436
1997
Off­
site
Recovery
Management
Within
industry
Group
46
4,505
Total*
1,374
909,833
3­
16
*
Some
plants
are
included
in
multiple
3.2.3
Methodology
for
Identifying
Outside
Industry
Group
Recovery
Management
Quantities
Generators
who
recover
values
from
wastes
at
off­
site
recyclers
outside
their
industry
group
(
4­
digit
NAICS
code)
may
additionally
benefit
from
the
rule
because
they
may
now
choose
to
construct
an
on­
site
recycling
unit
given
a
RCRA
storage
permit
and
other
RCRA
administrative
activities
are
no
longer
required.
Large
facilities
may
recover
large
enough
volumes
to
construct
an
on
site
recovery
unit.
Groups
of
facilities
within
the
same
industry
group
may
achieve
economies
of
scale.
These
facilities
under
baseline
were
not
willing
to
permit
a
captive
facility.
Post­
rule
they
may
be
willing.

This
data
set
was
developed
by
starting
with
the
list
of
generators
recovering
metal,
solvent,
and
acid
wastes
off
site
developed
in
Step
5
of
the
previous
section
(
Table
3­
6).
This
time
the
list
of
facilities
transferring
wastes
off
site
within
the
same
industry
group
(
4­
digit
NAICS
code)
are
removed
from
the
list
as
opposed
to
last
time
in
Step
6
above
they
were
kept.
Because
of
project
resource
constraints
the
analysis
was
limited
to
the
4­
digit
NAICS
codes
recovering
the
most
quantity
off
site
assuming
they
are
most
likely
to
achieve
economies
of
scale.
These
eleven
NAICS
codes
are
identified
in
Table
3­
10
with
their
recovery
quantities.
They
account
of
77
percent
of
the
quantity
currently
recovered
off
site
outside
the
same
industry
group.
A
breakeven
cost
analysis
was
conducted
on
this
data
set
to
determine
which
facilities
may
costeffectively
construct
on­
site
recovery
systems
post
rule.

Table
3­
10.
Summary
of
Outside
Industry
Group
POTENTIALLY
Affected
Number
of
Plants
and
Offsite
Recovery
Management
Quantities
4­
Digit
NAICS
Code
No.
of
Plants
Recovered
Quantity
(
tons)

3312
Steel
Product
Manufacturing
119
471,434
3344
Semiconductor
and
Other
Electronic
Component
Manufacturing
382
56,589
3252
Resin,
Synthetic
Rubber,
and
Artificial
and
Synthetic
Fibers
and
Filaments
Manufacturing
99
32,446
3359
Other
Electrical
Equipment
and
Component
Manufacturing
67
32,543
3314
Non­
Ferrous
Metal
(
except
Aluminum)
Production
and
Processing
83
29,046
3241
Petroleum
and
Coal
Products
Manufacturing
112
28,547
3­
17
3328
Coating,
Engraving,
Heat
Treating
and
Allied
Activities
417
25,069
3255
Paint,
Coating
and
Adhesive
manufacturing
156
23,181
3251
Basic
Chemical
Manufacturing
227
22,515
3362
Motor
Vehicle
Body
and
Trailer
Manufacturing
74
18,069
3254
Pharmaceutical
and
Medicine
Manufacturing
111
15,447
Subtotal
(
included
in
analysis)
1847*
754,886
Other
NAICS
4351
221,447
Totals
6177**
976,333
*
Some
plants
are
included
in
multiple
**
Some
plants
are
included
in
both
the
subtotal
and
other
NAICS
3­
18
3.2.4
Methodology
for
Identifying
Disposed
Management
Quantities
that
Potentially
May
Be
Recovered
On
Site
A
firm
may
decide
to
reclaim
wastes
previously
disposed
(
e.
g.,
landfilled
or
energy
recovery)
because
of
favorable
economics
under
the
proposed
regulation.
Because
of
limited
budget
resources
an
analysis
was
conducted
identifying
the
primary
waste
types
being
recovered
in
1999.
It
is
assumed
that
these
waste
types
have
a
higher
potential
for
recovery.
Based
on
the
waste
types
identified,
a
data
set
of
these
wastes
types
being
disposed
(
i.
e.,
land
disposed
or
thermally
destroyed)
was
developed
to
limit
the
scope
of
the
analysis.
The
facilities
disposing
these
waste
may
potentially
recover
them
on
site
post
rule
if
economically
feasible.

Given
budget
resource
constraints,
the
identification
of
recoverable
waste
types
was
limited
to
those
SIC
codes
that
reported
recovering
more
than
30,000
tons
either
on
site
or
off
site
in
1999.
Appendix
D
presents
a
memorandum
of
the
initial
analysis.
Subsequent
review
of
the
information
presented
in
Appendix
D
determined
that
some
facilities
were
reporting
characteristic
by­
products
(
e.
g.,
lead
slag
and
dross)
as
hazardous
waste.
Table
3­
11
presents
a
listing
of
the
waste
types,
industries
(
SIC
codes),
and
waste
forms
included
in
the
analysis.

Table
3­
11.
List
of
Waste
Types
Analyzed
for
Potential
On­
Site
Recovery
Waste
Types
SIC
Codes
Waste
Forms
Organic
Liquids
(
from
Industrial
Organic
Chemicals,
Paints
and
Allied
Products,
Pharmaceutical
Preparations,
and
Plastics
Materials
and
Resins
Industries)
2869,
2851,
2834,
2821
Liquid
Form
Codes
(
B101­
B119,
B201­
B219)

Emission
Control
Dust
(
from
Steel
Works
Industry)
3312
Solid
Form
Codes
(
B301­
B319,
B401­
B409)

Sludge
Form
Codes
(
B501­
B519,
B601­
B609)

Metal­
Containing
Liquids
(
from
Printed
Circuit
Board
Industry)
3672
Liquid
Form
Codes
(
B101­
B119,
B201­
B219)

Electroplating
Wastewater
Treatment
Sludges
(
from
Printed
Circuit
Board
Industry)
3672
Solid
Form
Codes
(
B301­
B319,
B401­
B409)

Sludge
Form
Codes
(
B501­
B519,
B601­
B609)

Spent
Carbon
(
from
Industrial
Organic
Chemicals
and
Petroleum
Refining
Industries)
2869,
2911
Solid
Form
Codes
(
B301­
B319,
B401­
B409)

Sludge
Form
Codes
(
B501­
B519,
B601­
B609)

Spent
Catalyst
(
from
Petroleum
Refining
Industry)
2911
Solid
Form
Codes
(
B301­
B319,
B401­
B409)

Sludge
Form
Codes
(
B501­
B519,
B601­
B609)

Spent
Aluminum
Potliner
(
from
Aluminum
Industry)
3334
Solid
Form
Codes
(
B301­
B319,
B401­
B409)

Sludge
Form
Codes
(
B501­
B519,
B601­
B609)
3­
19
Spent
Pickle
Liquor
(
from
Steel
Works
Industry)
3312
Liquid
Form
Codes
(
B101­
B119,
B201­
B219)

Table
3­
12
presents
a
summary
of
the
disposed
management
quantities
that
potentially
may
be
recovered,
indicating
step­
by­
step
changes
in
the
quantities
as
a
QA/
QC
analysis
was
conducted
on
the
initial
data
sets.
A
summary
of
the
QA/
QC
steps
is
as
follows:

1
­
Facilities
reporting
wastes
in
1997
as
recovered
and
1999
as
disposed
were
removed
from
the
analysis
to
avoid
double­
counting
waste
quantities
included
in
the
1997
on­
site
and
off­
site
recovery
quantities
in
Table
3­
9.

2
­
Facilities
reporting
wastes
with
Origin
Code
4,
"
the
hazardous
waste
was
received
from
off
site
and
was
not
recycled
or
treated
on
site,"
are
not
supposed
to
report
the
waste
as
generated
(
i.
e.,
zero
quantity
generated).
This
explains
why
the
generation
quantity
total
does
not
change
when
the
records
are
removed.
These
records
were
removed
because
the
generator
did
not
generate
the
waste.
Incremental
costs
for
management
of
this
waste
are
associated
with
the
original
generator.

3
­
Certain
wastes
reported
with
Origin
Code
5,
"
the
hazardous
waste
was
a
residual
from
the
on
site
treatment,
disposal,
or
recycling
of
a
previously
existing
hazardous
waste,"
were
excluded
because
values
from
these
wastes
are
not
likely
recoverable.

4
­
Wastes
generated
from
processes
(
e.
g.,
those
generated
from
remediation
or
one­
time
activities)
are
not
continuous
waste
streams
that
would
supply
a
continuous
feedstock
for
an
on­
site
recovery
facility.
Values
from
these
wastes
are
not
likely
recoverable.

5
­
Waste
descriptions
were
analyzed
to
ensure
only
the
appropriate
waste
streams
were
being
kept
in
the
analysis
for
each
set
of
data.
Waste
streams
(
e.
g.,
"
debris")
that
did
not
meet
the
criteria
for
each
data
set
were
removed
from
the
analysis.

6
­
Waste
streams
that
were
missing
one
or
more
of
the
following
codes:
SIC
Code,
Origin
Code,
Source
Code,
or
Form
Code,
were
analyzed
to
determine
if,
had
they
not
been
missing
the
codes,
they
may
have
been
removed
in
previous
QA/
QC
steps.
The
additional
analysis
primarily
involved
the
waste
stream's
EPA
Hazardous
Waste
Codes.

7
­
Waste
streams
with
unusually
large
quantities
were
evaluated
to
determine
if
they
were
wastewater
and
the
waste
quality
was
sufficient
for
recovery.
3­
20
9
­
Any
outliers
(
waste
streams
with
generation
quantities
greater
than
two
standard
deviations
above
the
mean
and
an
order
of
magnitude
greater
than
the
average)
were
removed
as
statistical
outliers
so
they
would
not
skew
the
results.

A
break­
even
cost
analysis
was
conducted
on
this
data
set
to
determine
which
facilities
may
costeffectively
construct
on­
site
recovery
systems
post
rule.
3­
21
Table
3­
12.
QA/
QC
Of
Disposed
Quantities
That
Potentially
May
Be
Recovered*

Organic
Liquids
from
Industrial
Organic
Chemicals,

Paints
&
Allied
Products,
Pharmaceutical
Preparations,
&

Plastics
Materials
&

Resins
Industries
(
SICs
2869,
2851,

2834,
2821
and
liquid
form
codes)
K061
­
Emission
Control
Dust
from
Steel
Works
Industry
(
SIC
3312
and
solid
&
sludge
form
codes)
Metal­
Containing
Liquids
from
Printed
Circuit
Board
Industry
(
SIC
3672
and
liquid
form
codes)
F006
­
Electroplating
Wastewater
Treatment
Sludges
from
Printed
Circuit
Board
Industry
(
SIC
3672
and
solid
&
sludge
form
codes)
Spent
Carbon
from
Industrial
Organic
Chemicals
and
Petroleum
Refining
Industries
(
SICs
2869,
2911
and
solid
&
sludge
form
codes)
K171
&
K172
­

Spent
Catalyst
from
Petroleum
Refining
Industry
(
SIC
2911
and
solid
&
sludge
form
codes)
K088
­
Spent
Aluminum
Potliner
from
Aluminum
Industry
(
SIC
3334
and
solid
&
sludge
form
codes)
K062
­
Spent
Pickle
Liquor
from
Steel
Works
Industry
(
SIC
3312
and
liquid
form
codes)

QA/
QC
Steps
Number
Waste
Streams
Quantity
(
tons)
Number
Waste
Streams
Qty.

(
tons)
Number
Waste
Streams
Quantity
(
tons)
Number
Waste
Streams
Quantity
(
tons)
Number
Waste
Streams
Quantity
(
tons)
Number
Waste
Streams
Quantity
(
tons)
Number
Waste
Streams
Quantity
(
tons)
Number
Waste
Streams
Quantity
(
tons)

Initial
Query
6,063
6,214,217
52
406,080
779
3,189,148
193
9,305
185
23,813
118
20,254
47
76,591
50
5,609,212
Remove
97/
99
EPA
ID
Matches
[
1]
6,045
6,213,453
52
406,080
779
3,189,148
193
9,305
182
23,804
118
20,254
47
76,591
50
5,609,212
Remove
Origin
Code
4
[
2]
5,973
6,213,453
52
406,080
779
3,189,148
193
9,305
175
23,804
116
20,254
46
76,591
50
5,609,212
Remove
Origin
Code
5
[
3]
­­­
­­­
50
364,374
773
3,188,220
­­­
­­­
­­­
­­­
116
20,254
­­­
­­­
­­­
­­­

Remove
Non­
Process
Wastes
[
4]
5,768
6,166,802
43
359,835
768
3,186,928
182
9,061
145
23,804
110
19,545
39
75,080
48
5,592,972
Remove
"
Odd
Wastes"

[
5]
5,712
6,166,457
36
359,569
768
3,186,928
158
8,944
132
3,227
107
19,543
34
74,178
48
5,592,972
Remove
wastes
with
"
Missing
Code
Issues"

[
6]
­­­
­­­
33
359,546
768
3,186,928
158
8,944
132
3,227
107
19,543
31
74,081
48
5,592,972
Table
3­
12.
QA/
QC
Of
Disposed
Quantities
That
Potentially
May
Be
Recovered*

Organic
Liquids
from
Industrial
Organic
Chemicals,

Paints
&
Allied
Products,
Pharmaceutical
Preparations,
&

Plastics
Materials
&

Resins
Industries
(
SICs
2869,
2851,

2834,
2821
and
liquid
form
codes)
K061
­
Emission
Control
Dust
from
Steel
Works
Industry
(
SIC
3312
and
solid
&
sludge
form
codes)
Metal­
Containing
Liquids
from
Printed
Circuit
Board
Industry
(
SIC
3672
and
liquid
form
codes)
F006
­
Electroplating
Wastewater
Treatment
Sludges
from
Printed
Circuit
Board
Industry
(
SIC
3672
and
solid
&
sludge
form
codes)
Spent
Carbon
from
Industrial
Organic
Chemicals
and
Petroleum
Refining
Industries
(
SICs
2869,
2911
and
solid
&
sludge
form
codes)
K171
&
K172
­

Spent
Catalyst
from
Petroleum
Refining
Industry
(
SIC
2911
and
solid
&
sludge
form
codes)
K088
­
Spent
Aluminum
Potliner
from
Aluminum
Industry
(
SIC
3334
and
solid
&
sludge
form
codes)
K062
­
Spent
Pickle
Liquor
from
Steel
Works
Industry
(
SIC
3312
and
liquid
form
codes)

QA/
QC
Steps
Number
Waste
Streams
Quantity
(
tons)
Number
Waste
Streams
Qty.

(
tons)
Number
Waste
Streams
Quantity
(
tons)
Number
Waste
Streams
Quantity
(
tons)
Number
Waste
Streams
Quantity
(
tons)
Number
Waste
Streams
Quantity
(
tons)
Number
Waste
Streams
Quantity
(
tons)
Number
Waste
Streams
Quantity
(
tons)

3­
22
Removal
of
large
waste
streams
not
of
sufficient
quality
for
recovery
[
7]
5,707
1,134,200
33
359,546
767
896,171
158
8,944
132
3,227
107
19,543
31
74,081
47
1,025,472
Remove
deep­
well
injection
quantities
for
spent
pickle
liquors
[
8]
5,707
1,134,200
33
359,546
767
896,171
158
8,944
132
3,227
107
19,543
31
74,081
44
837,566
Remove
statistical
outliers
[
9]
4,839**
412,091
**
31
347,767
***
746
554,701
154
6,998
125
2,448
99
11,278
31
74,081
41
192,259
FINAL
NUMBERS
4,839
412,091
31
347,767
746
554,701
154
6,998
125
2,448
99
11,278
31
74,081
41
192,259
Table
3­
12.
QA/
QC
Of
Disposed
Quantities
That
Potentially
May
Be
Recovered*

Organic
Liquids
from
Industrial
Organic
Chemicals,

Paints
&
Allied
Products,
Pharmaceutical
Preparations,
&

Plastics
Materials
&

Resins
Industries
(
SICs
2869,
2851,

2834,
2821
and
liquid
form
codes)
K061
­
Emission
Control
Dust
from
Steel
Works
Industry
(
SIC
3312
and
solid
&
sludge
form
codes)
Metal­
Containing
Liquids
from
Printed
Circuit
Board
Industry
(
SIC
3672
and
liquid
form
codes)
F006
­
Electroplating
Wastewater
Treatment
Sludges
from
Printed
Circuit
Board
Industry
(
SIC
3672
and
solid
&
sludge
form
codes)
Spent
Carbon
from
Industrial
Organic
Chemicals
and
Petroleum
Refining
Industries
(
SICs
2869,
2911
and
solid
&
sludge
form
codes)
K171
&
K172
­

Spent
Catalyst
from
Petroleum
Refining
Industry
(
SIC
2911
and
solid
&
sludge
form
codes)
K088
­
Spent
Aluminum
Potliner
from
Aluminum
Industry
(
SIC
3334
and
solid
&
sludge
form
codes)
K062
­
Spent
Pickle
Liquor
from
Steel
Works
Industry
(
SIC
3312
and
liquid
form
codes)

QA/
QC
Steps
Number
Waste
Streams
Quantity
(
tons)
Number
Waste
Streams
Qty.

(
tons)
Number
Waste
Streams
Quantity
(
tons)
Number
Waste
Streams
Quantity
(
tons)
Number
Waste
Streams
Quantity
(
tons)
Number
Waste
Streams
Quantity
(
tons)
Number
Waste
Streams
Quantity
(
tons)
Number
Waste
Streams
Quantity
(
tons)

3­
23
[
1]
Facilities
reporting
wastes
in
1997
as
recovered
and
1999
as
disposed
were
removed
from
the
analysis
to
avoid
double­
counting
waste
quantities
included
in
the
1997
on­
site
and
off­
site
recovery
quantities
in
Table
3­
9.

[
2]
Facilities
reporting
wastes
with
Origin
Code
4,
"
the
hazardous
waste
was
received
from
off
site
and
was
not
recycled
or
treated
on
site,"
are
not
supposed
to
report
the
waste
as
generated
(
i.
e.,
zero
quantity
generated).
This
explains
why
the
generation
quantity
total
does
not
change
when
the
records
are
removed.
These
records
were
removed
because
the
generator
did
not
generate
the
waste.
Incremental
costs
for
management
of
this
waste
are
associated
with
the
original
generator.

[
3]
Certain
wastes
reported
with
Origin
Code
5,
"
the
hazardous
waste
was
a
residual
from
the
on
site
treatment,
disposal,
or
recycling
of
a
previously
existing
hazardous
waste,"
were
excluded
because
values
from
these
wastes
are
not
likely
recoverable.

[
4]
Wastes
generated
from
processes
(
e.
g.,
those
generated
from
remediation
or
one­
time
activities)
are
not
continuous
waste
streams
that
would
supply
a
continuous
feedstock
for
an
on­
site
recovery
facility.
Values
from
these
wastes
are
not
likely
recoverable.

[
5]
Waste
descriptions
were
analyzed
to
ensure
only
the
appropriate
waste
streams
were
being
kept
in
the
analysis
for
each
set
of
data.
Waste
streams
(
e.
g.,
"
debris")
that
did
not
meet
the
criteria
for
each
data
set
were
removed
from
the
analysis.

[
6]
Waste
streams
that
were
missing
one
or
more
of
the
following
codes:
SIC
Code,
Origin
Code,
Source
Code,
or
Form
Code,
were
analyzed
to
determine
if,
had
they
not
been
missing
the
codes,
they
may
have
been
removed
in
previous
QA/
QC
steps.
The
additional
analysis
primarily
involved
the
waste
stream's
EPA
Hazardous
Waste
Codes.

[
7]
Waste
descriptions
were
analyzed
for
unusually
large
waste
streams
to
ensure
the
waste
quality
is
sufficient
for
recovery.

[
9]
Any
outliers
(
waste
streams
with
generation
quantities
greater
than
two
standard
deviations
above
the
mean
and
an
order
of
magnitude
greater
than
the
average)
were
removed
as
statistical
outliers
so
they
would
not
skew
the
results.

*
Quantities
reflect
generation
quantities
and
not
management
quantities.
Quantities
presented
in
Chapter
4
are
management
quantities.

**
Onsite
disposal
quantities
were
removed
from
this
analysis.
Onsite
disposal
of
organic
liquids
is
incineration,
which
requires
a
large
capital
expenditure.
For
the
purposes
of
this
analysis,
it
is
assumed
facilities
disposing
onsite
will
not
change
to
a
recovery
process.

***
Only
offsite
quantities
were
considered
in
this
analysis.
9
Borst,
Paul
A.,
U.
S.
EPA,
Office
of
Solid
Waste,
Economic,
Methods
and
Risk
Analysis
Division,
"
Recycling
of
Wastewater
Treatment
Sludges
from
Electroplating
Operations,"
F006,
18th
AESF/
EPA
Pollution
Prevention
and
Control
Conference,
January
27­
29,
1997,
p.
179.

10
Lamancusa,
James
P.,
P.
E.,
CEF,
"
Strategies
at
a
Decorative
Chromium
Electroplating
Facility:
On­
line
vs.
Offline
Recycling,"
Plating
and
Surface
Finishing,
April
1995,
p.
48.

3­
24
3.3
Limitations
of
Analysis
This
analysis
does
not
capture
all
of
the
variables
that
may
affect
a
generator's
decision
to
reclaim
or
landfill
these
types
of
wastes.
A
generator's
decision
also
may
be
affected
by
factors
such
as
the
presence
of
multiple
metals,
solvents,
or
other
waste
types
in
one
waste
stream;
total
content
of
metal,
solvent
and
other
values;
technical
feasibility
of
recovering
available
metals,
solvents,
etc..
Limitations
of
the
analysis
include
the
following:

°
The
presence
of
multiple
metals
or
other
values
in
a
waste
may
impact
both
the
marketability
and
feasibility
of
reclamation.
While
the
waste
may
contain
recoverable
levels
of
each
metal/
value
present,
within­
industry
off­
site
reclaimers
tend
to
prefer
co­
mingled
wastes
to
be
segregated
to
avoid
having
to
separate
the
metals
(
values)
again
into
a
mono­
metal
or
bi­
metal
sludge.
9
In
certain
instances,
within­
industry
off­
site
reclaimers
face
higher
costs
to
handle
impurities
(
metals/
values
considered
not
to
be
of
value
by
the
within­
industry
off­
site
reclaimer)
in
excess
of
a
specified
concentration.
10
°
The
type
and
percent
concentration
of
metals
or
other
values
present
in
the
waste
may
impact
the
cost
for
within­
industry
off­
site
reclaimers
to
manage
the
waste.
The
cost
of
reclamation
is
influenced
by
the
market
price
the
recyclers
can
obtain
for
the
values
they
recover.
Variations
in
future
prices
for
recovered
values
are
not
evaluated
in
the
analysis.

°
The
proximity
of
businesses
to
a
landfill
is
likely
to
continue
to
heavily
influence
off
site
transfers
within
the
same
Industry
Group
due
to
the
savings
associated
with
the
reduced
transportation
costs.

°
The
cost
estimates
for
landfill
management
are
overstated,
particularly
for
smaller
generators,
because
other
forms
of
hazardous
waste
are
generated
in
facility
operations.
These
wastes
may
be
shipped
with
the
reclaimable
waste
to
the
landfill
in
the
same
truck
if
the
wastes
are
compatible,
resulting
in
lower
per­
unit
transportation
costs
due
to
a
generator's
ability
to
take
advantage
of
economies
of
scale
and
avoid
incurring
the
minimum
landfill
charge
on
multiple
loads.

°
Reclamation
costs
are
overstated,
particularly
for
small
generators,
because
transporters
may
stop
at
two
or
more
facilities
creating
fuller
loads,
thereby
reducing
per­
unit
transportation
costs.
Economies
of
scale
may
be
achieved
that
exceed
the
minimum
recycling
processing
charge.
3­
25
°
There
may
exist
instances
where
facilities
improve
the
quality
of
their
waste
streams
with
potential
recoverable
values
to
improve
the
quality
of
the
waste
for
reclamation
and
allow
them
to
accumulate
more
economic
quantities
for
reclamation.
This
study
does
not
address
these
possible
benefits.
4­
1
4.0
BASELINE
METAL,
SOLVENT
AND
OTHER
RECOVERY
MANAGEMENT
4.1
On­
site
Recovery
Quantity
in
1999
A
total
of
818,

3314,
nonferrous
metal
(
except
aluminum)
production
and
processing,
recovered
on­
site
recovery
quantity.
Nearly
all
of
this
quantity
was
managed
by
other
recovery
(
acid
regeneration).

The
last
eight
NAICS
codes
listed
in
Table
4­
1
recover
more
than
10,000
tons
onsite
in
1999.
The
remaining
NAICS
codes
that
each
recover
less
than
10,000
tons
on­
site
in
1999
account
for
72,000
tons
(
8.8
percent)
of
the
total
on­
site
recovery
quantity.

No
SIC
codes
(
that
could
be
mapped
4­
2
TABLE
4­
1
1999
ONSITE
RECOVERY
MANAGEMENT
BY
NAICS
CODE
(
TONS)

NAI
CS
METALS
RECOVERY
Total
Metals
SOLVENTS
RECOVERY
Total
Solvents
OTHER
RECOVERY
Total
Other
TOTALS
Code
M011
M012
M013
M014
M01
9
Recovery
M021
M022
M023
M024
M029
Recovery
M031
M032
M039
Recovery
Quantity
%
Cumul.
%

3251
1,336
853
70,699
643
73,531
25,967
16
1,273
27,257
76,856
21,984
98,840
199,627
24.394
24.394
3314
9
114,864
374
51
115,297
0
338
338
115,636
14.130
38.524
3312
0
94
94
47,132
47,132
47,226
5.771
44.295
3254
0
31,337
4,241
4
35,583
0
35,583
4.348
48.643
3255
0
9,296
9,297
11,851
11,020
17
700
16
23,604
38
38
32,939
4.025
52.668
3211
0
0
32,273
99
32,373
32,373
3.956
56.624
3344
24,767
4
24,771
441
441
2
2
25,214
3.081
59.705
3252
158
755
913
1,897
437
13
72
2,420
10,731
10,014
20,744
24,077
2.942
62.647
3328
557
557
2,657
1,168
1
3,826
96
15,111
15,207
19,591
2.394
65.041
3399
9,265
242
9,506
383
96
22
502
3,401
3,401
13,409
1.639
66.680
3253
0
0
1,209
8,913
10,122
10,122
1.237
67.917
Others
355
6
653
9,091
4,372
14,477
27,143
4,071
7,725
2,228
754
41,922
5,281
10,448
261
15,989
72,387
8.846
76.762
No
Code
160,662
304
160,965
21,423
1,430
182
1,435
1
24,472
551
1,548
2,627
4,727
190,164
23.238
100.000
TOTAL
1,858
859
115,516
285,466
5,615
409,315
123,194
18,126
12,292
5,735
771
160,119
68,403
155,501
25,010
248,914
818,348
100.000
C
Metals
Recovery
Solvents
Recovery
Other
Recovery
M011
High
temperature
metals
recovery
M021
Fractionation/
distillation
M031
Acid
regeneration
M012
Retorting
M022
Thin
film
evaporation
M032
Other
recovery:
e.
g.,
waste
oil
recovery,

nonsolvent
organics
recovery
M013
Secondary
smelting
M023
Solvent
extraction
M039
Other
recovery
­
type
unknown
M014
Other
metals
recovery
for
reuse:
e.
g.,
ion
exchange,
reverse
osmosis,
acid
leaching
M024
Other
solvent
recovery
M019
Metals
recovery
­
type
unknown
M029
Solvents
recovery
­
type
unknown
4­
3
4.2
Off­
site
Recovery
Quantity
Transferred
Within
Same
Industry
Group
(
4­
Digit
NAICS
Code)
in
1999
The
proposed
regulation
will
allow
an
exclusion
from
RCRA
Subtitle
C
jurisdiction
if
the
hazardous
wastes
shipped
off
site
for
recovery
are
transferred
within
the
same
industry
group.
The
Biennial
Report
data
were
analyzed
for
off­
site
shipments
within
the
same
4­
digit
NAICS
codes.
These
off­
site
recovery
quantities
are
a
subset
of
the
total
quantity
of
hazardous
waste
shipped
off
site
for
recovery.

A
total
of
59,000
tons
of
hazardous
waste
were
recovered
off
site
in
1999
within
the
same
industry
group
by
249
plants
within
30
NAICS
codes.
Nine
NAICS
codes
recovered
greater
than
300
tons
each
(
0.5%
of
the
total
off­
site
recovery
quantity)
in
off­
site
recovery
practices
within
the
3251,
basic
chemical
manufacturing,
recovered
13,700
tons
(
23.1
percent)
of
the
total
off­
site
recovery
quantity.
Most
of
this
quantity
was
managed
by
solvents
recovery.

NAICS
5419,
other
professional,
scientific,
and
technical
services,
recovered
10,600
tons
(
17.9
percent)
of
the
total
off­
site
recovery
quantity.

NAICS
3314,
nonferrous
metal
(
except
aluminum)
production
and
processing,
recovered
7,700
tons
(
13.0
percent)
of
the
total
off­
site
recovery
quantity.
Nearly
all
of
this
quantity
was
managed
by
metals
recovery.

NAICS
3312,
steel
product
manufacturing
from
purchased
steel,
recovered
6,700
tons
(
11.3
percent)
of
the
total
off­
site
recovery
quantity.
All
of
this
quantity
was
managed
by
metals
recovery.

NAICS
3252,
resin,
4­
4
TABLE
4­
2
1999
OFFSITE
RECOVERY
WITHIN
SAME
INDUSTRY
GROUP
(
4­
DIGIT
NAICS
CODE)
(
TONS)

NAICS
METALS
RECOVERY
Total
Metals
SOLVENTS
RECOVERY
Total
Solvents
OTHER
RECOVERY
Total
Other
TOTALS
Code
M011
M012
M013
M014
M019
Recovery
M021
M022
M023
M024
M029
Recovery
M031
M032
M039
Recovery
Quantity
%
Cumul.
%

3254
65
16
6
87
14,467
1
14,468
0
14,555
24.489
24.489
3251
43
235
2,095
273
2,646
8,690
2
0
20
8,713
2,243
129
2,372
13,731
23.101
47.590
5419
0
2
2
7,212
3,410
10,622
0
10,625
17.875
65.466
3314
41
163
7,267
18
246
7,735
2
2
0
0
7,737
13.018
78.483
3312
6,734
6,734
0
0
6,734
11.330
89.813
3252
0
0
2,429
2,429
2,429
4.087
93.900
3363
0
0
688
688
0
688
1.157
95.058
6113
16
398
414
1
1
0
0
415
0.699
95.756
3241
0
0
312
312
312
0.525
96.281
3326
210
87
297
0
0
297
0.499
96.780
3344
8
5
225
31
270
1
1
0
271
0.456
97.237
8129
35
144
180
0
0
180
0.302
97.539
3359
158
0
158
0
0
158
0.266
97.805
4219
91
0
6
97
0
0
97
0.163
97.968
5622
1
1
5
5
90
0
90
96
0.162
98.130
3372
0
0
29
3
32
0
32
0.053
98.184
3255
1
0
0
1
15
7
22
0
24
0.040
98.223
4226
0
15
15
0
15
0.025
98.248
3328
2
0
2
7
11
0
0
11
0.018
98.267
3231
1
9
10
0
0
0
10
0.018
98.284
9241
0
0
1
1
1
1
2
0.004
98.288
TABLE
4­
2
1999
OFFSITE
RECOVERY
WITHIN
SAME
INDUSTRY
GROUP
(
4­
DIGIT
NAICS
CODE)
(
TONS)

NAICS
METALS
RECOVERY
Total
Metals
SOLVENTS
RECOVERY
Total
Solvents
OTHER
RECOVERY
Total
Other
TOTALS
Code
M011
M012
M013
M014
M019
Recovery
M021
M022
M023
M024
M029
Recovery
M031
M032
M039
Recovery
Quantity
%
Cumul.
%

4­
5
3321
0
2
2
0
2
0.003
98.291
9281
1
1
2
0
0
2
0.003
98.294
5414
0
1
1
0
1
0.001
98.295
3333
1
1
0
0
1
0.001
98.296
3259
0
0
0
0
0
0.001
98.296
3399
0
0
0
0
0
0.001
98.297
3222
0
0
0
0
0
0.000
98.297
3325
0
0
0
0
0
0.000
98.298
2122
0
0
0
0
0
0.000
98.298
No
Code
0
1,012
1,012
0
1,012
1.702
100.000
TOTALS
7,106
491
7,431
2,408
1,212
18,647
31,112
4,442
2
0
29
35,585
2,430
2,645
129
5,205
59,436
100.000
 
SYSTEM
TYPE
CODES:

Metals
Recovery
Solvents
Recovery
Other
Recovery
M011
High
temperature
metals
recovery
M021
Fractionation/
distillation
M031
Acid
regeneration
M012
Retorting
M022
Thin
film
evaporation
M032
Other
recovery:
e.
g.,
waste
oil
recovery,

nonsolvent
organics
recovery
M013
Secondary
smelting
M023
Solvent
extraction
M039
Other
recovery
­
type
unknown
M014
Other
metals
recovery
for
reuse:
e.
g.,
ion
exchange,
reverse
osmosis,
acid
leaching
M024
Other
solvent
recovery
M019
Metals
recovery
­
type
unknown
M029
Solvents
recovery
­
type
unknown
4­
6
4.3
Export
Recovery
Quantity
in
1999
A
total
of
125,000
tons
of
hazardous
waste
generated
by
80
plants
were
recovered
off
site
in
1999
in
a
foreign
country.
NAICS
code
data
were
unavailable
to
determine
if
the
transfers
(
exports)
occurred
within
the
same
industry
groups
(
4­
digit
NAICS)
and
subject
to
the
exclusion
of
the
proposed
regulation.
Mexico
received
90,000
tons,
Canada
11,000
tons,
and
Germany,
France,
Korea,
Belgium
and
Sweden
less
than
1,000
tons
(
Table
4­
3).
For
approximately
21,000
tons
recovered
outside
the
United
States,
the
foreign
country
is
not
specified.

NAICS
3312,
steel
product
manufacturing
and
purchased
steel,
recovered
approximately
91,000
tons
of
the
total
export
recovery
quantity.
All
of
this
quantity
was
managed
by
metals
recovery.
4­
7
TABLE
4­
3
1999
EXPORTS
BY
NAICS
CODE
(
TONS)

NAICS
METALS
RECOVERY
Total
Metals
SOLVENTS
RECOVERY
Total
Solvents
OTHER
RECOVERY
Total
Other
TOTALS
Code
M011
M012
M013
M014
M019
Recovery
M021
M022
M023
M024
M029
Recovery
M031
M032
M039
Recovery
Quantity
%
Cumulative
%
#
Plants
CANADA
3359
3,363
5
3,368
0
0
3,368
29.362
29.362
2
3333
1,936
1,936
179
179
0
2,115
18.438
47.800
2
5622
1,865
1,865
0
0
1,865
16.262
64.062
1
3315
887
134
1,020
0
0
1,020
8.896
72.957
2
5419
0
0
949
949
949
8.273
81.230
1
3254
0
720
720
0
720
6.278
87.508
1
3314
576
576
0
0
576
5.022
92.530
3
3251
70
70
316
316
0
386
3.365
95.895
3
3222
0
147
147
0
147
1.284
97.180
1
3241
0
0
70
72
143
143
1.243
98.423
2
4226
79
79
0
0
79
0.688
99.111
1
3321
61
61
0
0
61
0.530
99.641
1
3351
0
16
16
0
16
0.138
99.779
1
9281
0
11
11
0
0
11
0.098
99.877
6
4219
9
9
0
0
9
0.077
99.954
1
3255
0
4
4
0
4
0.034
99.988
1
no
code
0
0
0
0
0
0
0
0
1
1
1
0.012
100.000
9
9999
0
0
0
0
0
0.000
100.000
1
Subtotal
70
0
8,697
139
90
8,996
1,231
147
4
0
0
1,383
0
1,020
72
1,092
11,471
100.000
­­­
39
BELGIUM
5622
62
62
0
0
62
100.000
100.000
1
TABLE
4­
3
1999
EXPORTS
BY
NAICS
CODE
(
TONS)

NAICS
METALS
RECOVERY
Total
Metals
SOLVENTS
RECOVERY
Total
Solvents
OTHER
RECOVERY
Total
Other
TOTALS
Code
M011
M012
M013
M014
M019
Recovery
M021
M022
M023
M024
M029
Recovery
M031
M032
M039
Recovery
Quantity
%
Cumulative
%
#
Plants
4­
8
FRANCE
4219
622
622
0
0
622
90.187
90.187
1
5419
68
68
0
0
68
9.813
100.000
1
Subtotal
0
0
622
0
68
689
0
0
0
0
0
0
0
0
0
0
689
100.000
­­­
2
TABLE
4­
3
1999
EXPORTS
BY
NAICS
CODE
(
TONS)

NAICS
METALS
RECOVERY
Total
Metals
SOLVENTS
RECOVERY
Total
Solvents
OTHER
RECOVERY
Total
Other
TOTALS
Code
M011
M012
M013
M014
M019
Recovery
M021
M022
M023
M024
M029
Recovery
M031
M032
M039
Recovery
Quantity
%
Cumulative
%
#
Plants
4­
9
GERMANY
3314
820
820
0
0
820
100.000
100.000
1
KOREA
4219
102
102
0
0
102
100.000
100.000
1
MEXICO
3312
77,935
77,935
0
0
77,935
86.164
86.164
10
no
code
10,825
10,825
0
0
10,825
11.968
98.132
2
2211
0
0
1,690
1,690
1,690
1.868
100.000
1
Subtotal
88,760
0
0
0
0
88,760
0
0
0
0
0
0
0
0
1,690
1,690
90,450
100.000
­­­
13
SWEDEN
3359
41
41
41
100.000
100.000
1
OTHER
FOREIGN
COUNTRIES
(
COUNTRY
UNSPECIFIED)

3312
13,016
0
0
0
13,016
60.671
60.671
2
3399
0
0
5,352
5,352
5,352
24.946
85.618
1
3344
674
676
1,350
0
0
1,350
6.291
91.909
3
9281
549
549
0
0
549
2.559
94.468
1
3254
0
544
544
0
544
2.536
97.004
1
4883
0
0
0
212
212
212
0.986
97.990
1
3314
191
191
0
0
191
0.892
98.882
1
3328
1
18
75
94
0
0
94
0.440
99.322
4
3359
76
76
0
0
76
0.355
99.677
2
3342
68
68
0
0
68
0.318
99.995
1
TABLE
4­
3
1999
EXPORTS
BY
NAICS
CODE
(
TONS)

NAICS
METALS
RECOVERY
Total
Metals
SOLVENTS
RECOVERY
Total
Solvents
OTHER
RECOVERY
Total
Other
TOTALS
Code
M011
M012
M013
M014
M019
Recovery
M021
M022
M023
M024
M029
Recovery
M031
M032
M039
Recovery
Quantity
%
Cumulative
%
#
Plants
4­
10
3364
0
0
0
0
0
0.002
99.998
1
2211
0
0
0
0
0
0.001
99.999
2
5133
0
0
0
0
0
0.001
100.000
1
3333
0
0
0
0
0
0.000
100.000
1
Subtotal
13,759
0
753
210
624
15,346
0
0
0
0
544
544
0
0
5,564
5,564
21,453
100.000
­­­
22
TOTAL
103,450
0
10,235
348
782
114,815
1,231
147
4
0
544
1,927
0
1,020
7,326
8,346
125,088
­­­
­­­
80
SYSTEM
TYPE
CODES:

Metals
Recovery
Solvents
Recovery
Other
Recovery
M011
High
temperature
metals
recovery
M021
Fractionation/
distillation
M031
Acid
regeneration
M012
Retorting
M022
Thin
film
evaporation
M032
Other
recovery:
e.
g.,
waste
oil
recovery,

nonsolvent
organics
recovery
M013
Secondary
smelting
M023
Solvent
extraction
M039
Other
recovery
­
type
unknown
M014
Other
metals
recovery
for
reuse:
e.
g.,
ion
exchange,
reverse
osmosis,
acid
leaching
M024
Other
solvent
recovery
M019
Metals
recovery
­
type
unknown
M029
Solvents
recovery
­
type
unknown
4­
11
4.4
Potential
Additional
Recovery
Quantity
from
1997
If
hazardous
wastes
are
excluded
from
RCRA
Subtitle
C
jurisdiction
if
recovered,
additional
facilities
may
determine
that
recovering
their
waste
is
more
economical
than
treatment
or
disposal.
As
a
rough
proxy
of
the
additional
hazardous
waste
quantity
that
may
be
recovered,
the
quantity
of
waste
reported
recovered
in
1997
but
not
in
1999
was
determined.
1997
Biennial
Report
data
were
used
to
identify
the
plants
that
recovered
hazardous
wastes
in
1997.
This
list
of
plants
was
compared
with
the
1999
list
of
plants
discussed
above.
If
the
EPA
identification
number
was
not
found
in
the
1999
list
it
is
assumed
they
now
treat
or
dispose
their
waste.
It
is
assumed
these
quantities
again
may
be
recovered
under
the
proposed
regulation.
Some
of
the
limitations
with
this
assumption
is
that
the
plant
may
have
closed,
discontinued
the
process
generating
the
waste,
or
modified
the
process
such
that
the
waste
was
no
longer
generated,
or
the
waste
was
a
one­
time
generation
event
(
e.
g.,
spill
cleanup
or
remediation
activity)
in
1999.

3252,
resin,
synthetic
rubber,
and
artificial
synthetic
fibers
and
filaments
manufacturing,
recovered
1,300
tons
(
4.7
percent)
of
the
1997
total
on­
site
recovery
quantity.
All
of
this
quantity
was
managed
by
solvents
recovery.

The
remaining
NAICS
codes
that
recovered
less
than
1,300
tons
on­
site
in
1997
account
for
9,700
tons
(
35.1
percent)
of
the
1997
total
on­
site
recovery
quantity.

No
SIC
codes
(
that
could
be
mapped
4­
12
Approximately
4,500
tons
were
recovered
off
site
in
1997
but
not
in
1999
within
the
same
4­
13
TABLE
4­
4
WASTE
QUANTITIES
ASSUMED
TO
SHIFT
TO
ONSITE
RECOVERY
(
WASTES
WERE
RECOVERED
ONSITE
IN
1997
BUT
NOT
RECOVERED
IN
199
NAICS
METALS
RECOVERY
Total
Metals
SOLVENTS
RECOVERY
Total
Solvents
OTHER
RECOVERY
Total
Other
Code
M011
M012
M013
M014
M019
Recovery
M021
M022
M023
M024
M029
Recovery
M031
M032
M039
Recovery
Quant
3326
0
0
6,497
6,497
6,497
3211
0
0
2,585
3,168
5,753
5,753
3253
0
0
1,368
1,368
1,368
3252
0
1,181
124
1,305
0
1,305
3231
2
2
1,242
8
6
1,256
0
1,258
3344
279
60
340
274
422
696
14
14
1,050
3261
0
468
198
55
721
0
721
3222
0
530
36
105
671
0
671
3314
120
3
123
22
9
31
408
408
561
3255
0
347
121
3
34
505
0
505
3333
0
29
450
479
0
479
3312
318
318
0
63
63
381
3251
67
127
6
200
52
52
100
5
0
105
357
3372
0
177
177
172
172
349
3328
0
0
2
2
343
343
346
3133
0
251
5
257
0
257
3259
0
213
213
42
42
255
3351
0
0
245
245
245
3329
17
17
210
210
0
226
3363
0
194
194
0
194
4229
0
173
173
0
173
3399
0
0
163
163
2
2
165
TABLE
4­
4
WASTE
QUANTITIES
ASSUMED
TO
SHIFT
TO
ONSITE
RECOVERY
(
WASTES
WERE
RECOVERED
ONSITE
IN
1997
BUT
NOT
RECOVERED
IN
199
NAICS
METALS
RECOVERY
Total
Metals
SOLVENTS
RECOVERY
Total
Solvents
OTHER
RECOVERY
Total
Other
Code
M011
M012
M013
M014
M019
Recovery
M021
M022
M023
M024
M029
Recovery
M031
M032
M039
Recovery
Quant
4­
14
3339
0
133
1
134
0
134
3219
0
127
127
0
127
Others
0
1
66
86
61
215
705
159
22
4
1
890
0
82
16
98
1,203
No
Code
13
1,551
1,564
191
191
29
1,180
1,208
2,964
TOTAL
S
385
128
186
406
1,673
2,778
6,510
843
429
142
523
8,448
6,906
3,043
6,368
16,318
27,54
SYSTEM
TYPE
CODES:

Metals
Recovery
Solvents
Recovery
Other
Recovery
M011
High
temperature
metals
recovery
M021
Fractionation/
distillation
M031
Acid
regen
M012
Retorting
M022
Thin
film
evaporation
M032
Other
recov
nonsolvent
organics
M013
Secondary
smelting
M023
Solvent
extraction
M039
Other
recov
M014
Other
metals
recovery
for
reuse:
e.
g.,
ion
exchange,
reverse
osmosis,
acid
leaching
M024
Other
solvent
recovery
M019
Metals
recovery
­
type
unknown
M029
Solvents
recovery
­
type
unknown
4­
15
TABLE
4­
5
WASTE
QUANTITIES
RECOVERED
OFFSITE
IN
1997
BUT
NOT
RECOVERED
IN
1999
­
BY
NAICS
CODE
(
TONS))

NAICS
METALS
RECOVERY
Total
Metals
SOLVENTS
RECOVERY
Total
Solvents
OTHER
RECOVERY
Total
Other
Code
M011
M012
M013
M014
M019
Recovery
M021
M022
M023
M024
M029
Recovery
M031
M032
M039
Recovery
Q
5419
14
14
2,610
2,610
0
3251
2
18
95
0
116
1,233
15
1,248
1
134
135
5622
0
128
128
1
1
3312
0
0
94
94
3314
75
0
75
0
0
3259
0
46
46
0
5417
0
0
0
15
15
3231
13
13
0
0
4219
8
8
0
0
3328
2
2
0
0
3254
1
1
0
0
3342
0
0
0
0
3222
0
0
0
0
3371
0
0
0
0
9999
0
0
0
0
2122
0
0
0
0
3372
0
0
0
0
No
Code
0
0
0
0
TOTALS
79
26
0
110
14
229
3,888
128
0
0
15
4,031
95
1
149
245
SYSTEM
TYPE
CODES:
TABLE
4­
5
WASTE
QUANTITIES
RECOVERED
OFFSITE
IN
1997
BUT
NOT
RECOVERED
IN
1999
­
BY
NAICS
CODE
(
TONS))

NAICS
METALS
RECOVERY
Total
Metals
SOLVENTS
RECOVERY
Total
Solvents
OTHER
RECOVERY
Total
Other
Code
M011
M012
M013
M014
M019
Recovery
M021
M022
M023
M024
M029
Recovery
M031
M032
M039
Recovery
Q
4­
16
Metals
Recovery
Solvents
Recovery
Other
Recovery
M011
High
temperature
metals
recovery
M021
Fractionation/
distillation
M031
Acid
r
M012
Retorting
M022
Thin
film
evaporation
M032
Other
nonsolvent
org
M013
Secondary
smelting
M023
Solvent
extraction
M039
Other
M014
Other
metals
recovery
for
reuse:
e.
g.,
ion
exchange,
reverse
osmosis,
acid
leaching
M024
Other
solvent
recovery
M019
Metals
recovery
­
type
unknown
M029
Solvents
recovery
­
type
unknown
4­
17
4.5
Off­
Site
Recovery
Quantity
Transferred
Outside
Industry
Group
in
1999
(
Selected
NAICS
Codes)
with
On­
Site
Recovery
Potential
The
proposed
regulation
will
allow
an
exclusion
from
RCRA
Subtitle
C
jurisdiction
if
the
hazardous
wastes
currently
shipped
off
site
for
recovery
are
recovered
on
site.
This
regulation
may
induce
facilities
to
construct
on­
site
recovery
facilities
to
gain
the
exclusion.
The
regulation
will
eliminate
the
economic
barrier
of
applying
for
a
RCRA
permit
to
store
waste
at
the
generating
facility
for
longer
than
90
days.
The
Biennial
Report
data
were
analyzed
for
off­
site
shipments
outside
the
same
industry
group
(
i.
e.,
not
within
the
same
4­
digit
NAICS
code).
These
off­
site
recovery
quantities
are
a
subset
of
the
total
quantity
of
hazardous
waste
shipped
off
site
for
recovery.

A
total
of
755,000
tons
of
hazardous
waste
within
eleven
selected
4­
digit
NAICS
codes
were
not
transferred
within
the
same
industry
group
in
1999,
and
have
the
potential
for
onsite
recovery.
One
NAICS
code
recovered
greater
than
470,000
tons
(
62%
of
the
potential
on­
site
recovery
quantity).

NAICS
3312,
steel
product
manufacturing
from
purchased
steel,
recovered
470,000
tons
(
62.5
percent)
of
the
potential
on­
site
recovery
quantity.
Most
of
this
quantity
was
managed
by
metals
recovery.

NAICS
3344,
,
recovered
57,000
tons
(
7.5
percent)
of
the
potential
on­
site
recovery
quantity.
Most
of
this
quantity
was
managed
by
metals
recovery.

NAICS
3252,
resin,

NAICS
3359,
,
recovered
33,000
tons
(
4.3
percent)
of
the
potential
on­
site
recovery
quantity.
Nearly
all
of
this
quantity
was
managed
by
metals
recovery.

The
remaining
seven
NAICS
codes
that
recovered
less
than
30,000
tons
off­
site
in
1999
account
for
162,000
tons
(
21.4
percent)
of
the
potential
on­
site
recovery
quantity.
4­
18
TABLE
4­
6
1999
OFF­
SITE
RECOVERY
QUANTITY
TRANSFERRED
OUTSIDE
INDUSTRY
GROUP
(
FOR
SELECTED
NAICS
CODES)
WITH
ON­
SITE
RECOVERY
POTENTIAL
(
TONS)

NAICS
CODE
METALS
RECOVERY
SOLVENTS
RECOVERY
OTHER
RECOVERY
TOTALS
#
Waste
Streams
Quantity
(
tons)
#
Waste
Streams
Quantity
(
tons)
#
Waste
Streams
Quantity
(
tons)
#
Waste
Streams*
Quantity
(
tons)
%
Cumul.
%

3312
157
452,950
70
348
6
18,136
205
471,434
62.451
62.451
3344
980
48,639
138
2,159
143
5,792
1,151
56,589
7.496
69.947
3252
80
5,133
87
26,811
12
722
166
32,666
4.327
74.275
3359
163
32,333
38
139
11
72
195
32,543
4.311
78.586
3314
69
9,963
61
535
23
18,548
145
29,046
3.848
82.434
3241
127
8,540
54
284
130
19,723
287
28,547
3.782
86.215
3328
778
23,306
140
629
70
1,139
906
25,075
3.322
89.537
3255
58
94
167
22,764
19
66
227
22,924
3.037
92.574
3251
176
2,311
196
14,969
82
5,180
431
22,460
2.975
95.549
3362
40
54
107
17,883
11
130
145
18,067
2.393
97.942
3254
131
117
289
15,258
14
158
420
15,533
2.058
100.000
TOTALS
2,759
583,440
1,347
101,778
521
69,667
4,278
754,885
100.000
 
*
The
total
number
of
waste
streams
is
not
equal
to
the
sum
of
the
number
of
waste
streams
for
the
three
recovery
types,
since
portions
of
each
waste
stream
may
be
recovered
by
different
method.
The
numbers
in
the
total
number
of
waste
streams
column
represent
the
total
number
of
unique
waste
streams.
4­
19
4.6
Disposal
Quantity
in
1999
with
On­
Site
Recovery
Potential
(
Selected
Waste
Types
and
SIC
Codes)

The
proposed
regulation
will
allow
an
exclusion
from
RCRA
Subtitle
C
jurisdiction
if
the
hazardous
wastes
currently
land­
disposed
are
recovered
on
site.
This
regulation
may
induce
facilities
to
construct
on­
site
recovery
facilities
to
gain
the
exclusion.
The
regulation
will
eliminate
the
economic
barrier
of
applying
for
a
RCRA
permit
to
operate
the
facility.
The
Biennial
Report
data
were
analyzed
for
disposal
of
eight
selected
waste
types
with
a
higher
potential
for
recovery.

4.6.1
Off­
Site
Disposal
A
total
of
696,000
tons
of
hazardous
waste
within
selected
waste
types
and
SIC
codes,
and
with
on­
site
recovery
potential,
were
disposed
off
site
in
1999
by
1,758
plants
(
1,585
unique
plants).
Two
waste
types
disposed
greater
than
210,000
tons
each
(
30.2%
of
the
total
off­
site
disposal
quantity)
in
off­
site
disposal
practices.
These
two
waste
types
account
for
71
percent
of
the
total
disposal
quantity
with
on­
site
recovery
potential.
Incineration,
energy
recovery
and
fuel
blending,
aqueous
inorganic
treatment,
aqueous
organic
and
inorganic
treatment,
stabilization,
and
disposal
are
the
primary
disposal
methods.

disposed
220,000
tons
(
31.6
percent)
of
the
total
off­
site
disposal
quantity.
Most
of
this
quantity
was
managed
by
incineration
and
energy
recovery
and
fuel
blending.

K061
­
Emission
Control
Dust
from
Steel
Works
Industry
(
SIC
3312
and
solid
&
sludge
form
codes)
disposed
273,000
tons
(
39.2
percent)
of
the
total
off­
site
disposal
quantity.
Over
half
of
this
quantity
was
managed
by
stabilization.

Metal­
Containing
Liquids
from
Printed
Circuit
Board
Industry
(
SIC
3672
and
liquid
form
codes)
disposed
22,000
tons
(
3.1
percent)
of
the
total
off­
site
disposal
quantity.
Most
of
this
quantity
was
managed
by
aqueous
inorganic
treatment.

F006
­
Electroplating
Wastewater
Treatment
Sludges
from
Printed
Circuit
Board
Industry
(
SIC
3672
and
solid
&
sludge
form
codes)
disposed
7,000
tons
(
1.0
percent)
of
the
total
off­
site
disposal
quantity.
Most
of
this
quantity
was
managed
by
sludge
treatment,
other
treatment,
and
transfer
facility
storage.
4­
20
Spent
Carbon
from
Industrial
Organic
Chemicals
and
Petroleum
Refining
Industries
(
SICs
2869,
2911
and
solid
&
sludge
form
codes)
disposed
2,000
tons
(
0.4
percent)
of
the
total
off­
site
disposal
quantity.
Most
of
this
quantity
was
managed
by
incineration
and
other
treatment.

K171
&
K172
­
Spent
Catalyst
from
Petroleum
Refining
Industry
(
SIC
2911
and
solid
&
sludge
form
codes)
disposed
11,000
tons
(
1.6
percent)
of
the
total
off­
site
disposal
quantity.
Most
of
this
quantity
was
managed
by
incineration,
and
other
treatment.

K088
­
Spent
Aluminum
Potliner
from
Aluminum
Industry
(
SIC
3334
and
solid
&
sludge
form
codes)
disposed
73,000
tons
(
10.4
percent)
of
the
total
off­
site
disposal
quantity.
Most
of
this
quantity
was
managed
by
incineration,
aqueous
inorganic
treatment,
other
treatment,
and
disposal.

K062
­
Spent
Pickle
Liquor
from
Steel
Works
Industry
(
SIC
3312
and
liquid
form
codes)
disposed
88,000
tons
(
12.7
percent)
of
the
total
off­
site
disposal
quantity.
Most
of
this
quantity
was
managed
by
aqueous
inorganic
treatment
and
disposal.

4.6.2
On­
Site
Disposal
A
total
of
315,000
tons
of
hazardous
waste
within
selected
waste
types
and
SIC
codes,
and
with
on­
site
recovery
potential,
were
disposed
on
site
in
1999
by
86
plants.
Two
waste
types
account
for
100
percent
of
the
total
disposal
quantity
with
on­
site
recovery
potential.
Aqueous
inorganic
treatment,
other
treatment,
and
disposal
are
the
primary
disposal
methods.
These
disposal
methods
account
for
35,000
tons,
88,000
tons,
and
191,000
tons
of
the
total,
respectively.
Table
4­
8
presents
the
quantity
of
hazardous
waste
disposed
on
site
by
waste
type
and
disposal
management
type
for
selected
waste
types
and
SIC
codes.

Metal­
Containing
Liquids
from
Printed
Circuit
Board
Industry
(
SIC
3672
and
liquid
form
codes)
disposed
134,000
tons
(
42.6
percent)
of
the
total
on­
site
disposal
quantity.
Most
of
this
quantity
was
managed
by
disposal.

K062
­
Spent
Pickle
Liquor
from
Steel
Works
Industry
(
SIC
3312
and
liquid
form
codes)
disposed
181,000
tons
(
57.5
percent)
of
the
total
on­
site
disposal
quantity.
Most
of
this
quantity
was
managed
by
other
treatment
and
disposal.
4­
21
TABLE
4­
7
1999
OFF­
SITE
DISPOSAL
QUANTITY
WITH
ON­
SITE
RECOVERY
POTENTIAL
(
SELECTED
WASTE
TYPES
AND
Selected
Waste
Types
and
SIC
Codes
Incineration
(
M041­
M049)
Energy
Recovery
and
Fuel
Blending
(
M051­
M061)
Aqueous
Inorganic
Treatment
(
M071­
M079)
Aqueous
Organic
Treatment
(
M081­
M089)
Aqueous
Organic
and
Inorganic
Treatment
(
M091­
M099)
Sludge
Treatment
(
M101­
M109)
Stabilization
(
M111­
M119)
Other
Treatment
(
M121­
M129)
Disposal
(
M131­
M137)
Transfer
Facility
Stor
(
M141)

#
Waste
Streams
Quantity
#
Waste
Streams
Quantity
#
Waste
Streams
Quantity
#
Waste
Streams
Quantity
#
Waste
Streams
Quantity
#
Waste
Streams
Quantity
#
Waste
Streams
Quantity
#
Waste
Streams
Quantity
#
Waste
Streams
Quantity
#
Waste
Streams
Qua
Organic
Liquids
from
Industrial
Organic
Chemicals,
Paints
and
Allied
Products,
Pharmaceutical
Preparations,
and
Plastics
Materials
and
Resins
Industries
(
SICs
2869,
2851,

2834,
2821
and
liquid
form
codes)
1,681
44,221
2,481
158,048
3
19
14
2,350
12
834
1
2
17
430
241
1,882
29
2,210
1,331
9,6
K061
­
Emission
Control
Dust
from
Steel
Works
Industry
(
SIC
3312
and
solid
&
sludge
form
codes)
0
0
0
0
0
0
0
0
7
62,536
0
0
22
141,447
2
2,365
12
50,816
0
Metal­
Containing
Liquids
from
Printed
Circuit
Board
Industry
(
SIC
3672
and
liquid
form
codes)
17
106
13
290
183
14,808
1
23
9
1,911
2
19
23
1,446
44
815
4
24
189
2,3
F006
­
Electroplating
Wastewater
Treatment
Sludges
from
Printed
Circuit
Board
Industry
(
SIC
3672
and
solid
&
sludge
form
codes)
8
369
3
141
13
738
0
0
0
0
18
874
29
769
33
1,509
9
165
63
2,5
Spent
Carbon
from
Industrial
Organic
Chemicals
and
Petroleum
Refining
Industries
(
SICs
2869,
2911
and
solid
&

sludge
form
codes)
65
743
17
419
0
0
3
65
0
0
1
2
1
0
16
836
4
131
35
20
TABLE
4­
7
1999
OFF­
SITE
DISPOSAL
QUANTITY
WITH
ON­
SITE
RECOVERY
POTENTIAL
(
SELECTED
WASTE
TYPES
AND
SIC
CODES)

Selected
Waste
Types
and
SIC
Codes
Incineration
(
M041­
M049)
Energy
Recovery
and
Fuel
Blending
(
M051­
M061)
Aqueous
Inorganic
Treatment
(
M071­
M079)
Aqueous
Organic
Treatment
(
M081­
M089)
Aqueous
Organic
and
Inorganic
Treatment
(
M091­
M099)
Sludge
Treatment
(
M101­
M109)
Stabilization
(
M111­
M119)
Other
Treatment
(
M121­
M129)
Disposal
(
M131­
M137)
Transfer
Facility
Storage
(
M141)
No
System
Type
Code
TOTAL
QUANTITY
#
Waste
Streams
Quantity
#
Waste
Streams
Quantity
#
Waste
Streams
Quantity
#
Waste
Streams
Quantity
#
Waste
Streams
Quantity
#
Waste
Streams
Quantity
#
Waste
Streams
Quantity
#
Waste
Streams
Quantity
#
Waste
Streams
Quantity
#
Waste
Streams
Quantity
#
Waste
Streams
Quantity
4­
22
K171
&
K172
­
Spent
Catalyst
from
Petroleum
Refining
Industry
(
SIC
2911
and
solid
&
sludge
form
codes)
40
2,616
3
34
2
18
0
0
1
42
0
0
9
748
37
5,146
12
407
15
787
7
1,118
10,916
K088
­
Spent
Aluminum
Potliner
from
Aluminum
Industry
(
SIC
3334
and
solid
&
sludge
form
codes)
9
18,222
0
0
2
9,873
0
0
3
1,934
0
0
5
4,957
2
9,024
16
25,369
1
3,168
0
0
72,547
K062
­
Spent
Pickle
Liquor
from
Steel
Works
Industry
(
SIC
3312
and
liquid
form
codes)
0
0
0
0
24
64,622
0
0
2
21
0
0
5
1,499
3
1,257
7
20,646
2
54
0
0
88,099
TOTALS
1,820
66,277
2,517
158,932
227
90,078
18
2,438
34
67,278
22
897
111
151,296
378
22,834
93
99,768
1,636
18,630
31
17,684
696,112
4­
23
TABLE
4­
8
1999
ON­
SITE
DISPOSAL
QUANTITY
WITH
ON­
SITE
RECOVERY
POTENTIAL
(
SELECTED
WASTE
TYPES
AND
SIC
CODES)

Selected
Waste
Types
and
SIC
Codes
Aqueous
Inorganic
Treatment
(
M071­
M079)
Aqueous
Organic
Treatment
(
M081­
M089)
Aqueous
Organic
and
Inorganic
Treatment
(
M091­
M099)
Sludge
Treatment
(
M101­
M109)
Other
Treatment
(
M121­
M129)
Disposal
(
M131­
M137)
TOTAL
QUANTITY
#
Waste
Streams
Quantity
#
Waste
Streams
Quantity
#
Waste
Streams
Quantity
#
Waste
Streams
Quantity
#
Waste
Streams
Quantity
#
Waste
Streams
Quantity
Metal­
Containing
Liquids
from
Printed
Circuit
Board
Industry
(
SIC
3672
and
liquid
form
codes)
187
23,918
7
28
2
304
1
334
23
3,081
95
105,846
133,511
K062
­
Spent
Pickle
Liquor
from
Steel
Works
Industry
(
SIC
3312
and
liquid
form
codes)
4
11,571
0
0
0
0
0
0
1
84,798
4
84,802
181,171
TOTALS
191
35,489
7
28
2
304
1
334
24
87,879
99
190,648
314,682
4­
24
4.7
Summary
of
Management
Data
A
total
of
849
plants
(
large
quantity
generators)
recovered
818,000
tons
of
hazardous
waste
on
site
in
on
1997
BRS
data
indicating
the
waste
had
been
recovered
previously,
an
additional
In
addition,
if
it
is
economically
feasible
to
construct
on­
site
recovery
facilities,
part
of
a
population
of
6,177
plants
recovering
approximately
976,000
tons
off
site
outside
the
same
industry
group
may
receive
benefits
from
the
proposed
rule.
A
break­
even
cost
analysis
was
conducted
on
wastes
recovered
by
eleven
NAICS
codes.
These
eleven
NAICS
codes
comprise
1,847
plants
and
755,000
tons
of
the
above
totals.
Metal
recovery,
solvent
recovery,
and
other
recovery
within
the
selected
NAICS
codes
account
for
583,000
tons,
102,000,
and
70,000
tons,
respectively.
Based
on
a
break­
even
cost
analysis,
142
of
the
1,847
plants
representing
257,000
of
the
755,000
tons
(
168,695
tons
for
metals
recovery,
72,040
tons
for
solvent
recovery,
and
15,952
tons
for
other
recovery)
may
construct
on­
site
recovery
facilities.

Finally,
if
it
is
economically
feasible
to
construct
on­
site
recovery
facilities,
part
of
a
population
of
1,758
plants
(
1,585
unique
plants)
disposing
approximately
696,000
tons
off
site
may
receive
benefits
from
the
proposed
rule.
A
break­
even
cost
analysis
was
conducted
on
the
eight
waste
4­
25
types
from
selected
SIC
codes
included
in
the
analysis
(
results
presented
in
Table
5­
21).
Based
on
the
break­
even
cost
analysis,
681
of
the
1,758
plants
(
some
plants
are
double­
counted
because
they
disposed
more
than
one
of
the
eight
waste
types)
representing
415,000
of
the
696,000
tons
may
construct
on­
site
recovery
facilities.
Incineration,
energy
recovery
and
fuel
blending,
aqueous
inorganic
treatment,
aqueous
organic
and
inorganic
treatment,
stabilization,
and
disposal
account
for
81,000
tons,
305,000
tons,
171,000
tons,
67,000
tons,
161,000
tons,
and
107,000
tons,
respectively.
In
addition,
part
of
a
population
of
86
plants
disposing
approximately
315,000
tons
on
site
may
receive
benefits
from
the
proposed
rule.
A
break­
even
cost
analysis
was
conducted
on
the
two
waste
types
from
selected
SIC
codes
included
in
the
analysis
(
results
presented
in
Table
5­
22).
Based
on
the
break­
even
cost
analysis,
27
of
the
86
plants
representing
181,000
of
the
315,000
tons
may
construct
on­
site
recovery
facilities.
Aqueous
inorganic
treatment,
other
treatment,
and
disposal
account
for
35,000
tons,
88,000
tons,
and
191,000
tons,
respectively.

For
the
wastes
that
already
are
being
recovered
or
were
being
recovered
in
1997
and
five
waste
types
being
disposed
with
high
recovery
potential
(
discussed
in
Section
5),
the
total
number
of
plants
affected
is
estimated
to
be
1,749.
These
plants
recover
approximately
1,570,000
tons
either
on
site
or
within
the
same
industry
group
and
may
benefit
from
the
exclusion
from
RCRA
jurisdiction.
5­
1
5.0
COST
IMPACT
ANALYSIS
5.1
Types
of
Cost
Savings
The
proposed
rule
will
create
cost
savings.
First,
given
an
exclusion
from
the
Definition
of
Solid
Waste,
the
generator
no
longer
needs
to
comply
with
manifest,
pre­
transport,
and
recordkeeping
and
reporting
requirements
under
40
CFR
Part
262
of
RCRA
for
those
wastes.
Second,
given
that
the
excluded
quantities
are
no
longer
considered
hazardous
if
recovered,
the
generator
status
of
the
facility
may
switch
from
being
a
large
quantity
generator
to
a
small
or
conditionally
exempt
small
quantity
generator.
Small
and
conditionally
exempt
small
quantity
generators
have
fewer
administrative
requirements
than
large
quantity
generators
under
Part
262
of
RCRA.
Finally,
if
wastes
are
no
longer
listed
as
hazardous
if
recovered
either
on
site
or
off
site
within
the
same
industry
group
(
4­
digit
NAICS),
residuals
from
the
recovery
processes
may
no
longer
be
hazardous
under
the
"
Derived­
from
Rule."
The
management
of
these
residuals
may
shift
from
Subtitle
C
to
Subtitle
D
disposal
if
they
do
not
test
characteristically
hazardous.
In
addition,
with
the
wastes
no
longer
being
defined
as
hazardous
waste
if
recovered,
generators
may
no
longer
need
to
pay
hazardous
waste
generation
taxes
and
fees.
Reductions
in
hazardous
waste
taxes
and
fees
are
not
social
cost
savings,
but,
reductions
in
transfer
costs.
However,
these
reductions
may
influence
a
firms's
decision
to
reclaim
it's
wastes.

5.2
Baseline
Cost
Components
The
baseline
management
practices
for
recovered
wastes
were
identified
using
the
1999
Biennial
Report.
For
facilities
recovering
wastes
on
site
in
1999,
the
primary
metals,
solvents,
and
other
recovery
practices
are
high
temperature
metals
recovery/
secondary
smelting,
fractionation/
distillation,
and
acid
regeneration
used
to
represent
all
"
other
recovery
practices",
respectively.
Residuals
from
these
recovery
practices
that
are
derived
from
a
listed
waste
or
have
a
hazardous
characteristic
are
managed
as
hazardous.
High
temperature
metals
recovery/
secondary
smelting,
fractionation/
distillation,
and
acid
regeneration
residuals
are
assumed
to
be
managed
by
hazardous
waste
landfill
disposal
with
stabilization,
energy
recovery,
and
chemical
precipitation
with
off­
site
stabilization
and
landfill
disposal
of
precipitates
and
sewer
discharge
of
neutralized
wastewater,
respectively,
in
this
economic
assessment.

For
facilities
recovering
wastes
off
site
within
the
industry
group
in
1999,
the
primary
metals,
solvents,
and
other
recovery
practices
are
high
temperature
metals
recovery/
secondary
smelting,
fractionation/
distillation,
and
acid
regeneration,
respectively.
Residuals
from
these
management
practices
that
are
derived
from
a
listed
waste
or
have
a
hazardous
characteristic
are
managed
as
hazardous.
High
temperature
metals
recovery/
secondary
smelting,
fractionation/
distillation,
and
acid
regeneration
residuals
are
assumed
to
be
managed
by
hazardous
waste
landfill
disposal
with
stabilization,
energy
recovery,
and
chemical
precipitation
with
off­
site
stabilization
and
landfill
disposal
of
precipitates
and
sewer
discharge
of
neutralized
wastewater,
respectively.
5­
2
If
hazardous
wastes
are
excluded
from
RCRA
Subtitle
C
jurisdiction
if
recovered
additional
facilities
may
determine
that
recovering
their
waste
is
more
economical
than
treatment
or
disposal.
Three
groups
of
waste
are
evaluated
for
their
potential
new
recovery
practices.
The
first
group
of
plants
are
those
that
reported
a
quantity
of
waste
recovered
in
1997
but
not
in
1999.
1997
Biennial
Report
data
were
used
to
identify
the
plants
that
recovered
hazardous
wastes
in
1997.
Based
on
an
analysis
of
market
price
changes
between
1997
and
1999,
it
is
assumed
that
100
percent
of
the
1997
waste
streams
which
went
to
recycling
(
but
did
not
in
1999)
would
again
be
sent
to
recycling
as
a
result
of
the
change
in
regulatory
status
for
these
wastes
(
see
Appendix
E).
Some
of
the
limitations
with
this
assumption
is
that
the
plant
may
have
closed,
discontinued
the
process
generating
the
waste,
modified
the
process
such
that
the
waste
was
no
longer
generated,
or
the
waste
was
a
one­
time
generation
event
(
e.
g.,
spill
cleanup
or
remediation
activity).
For
facilities
that
recovered
wastes
on
site
or
off
site
in
1997,
the
assumed
baseline
management
practices
in
1999
for
metal­
bearing,
solvent
and
acidic
wastes
are
off­
site
commercial
hazardous
waste
landfill,
off­
site
energy
recovery,
and
on­
site
neutralization,
respectively.
Residuals
from
these
management
practices
are
minimal
or
non­
hazardous.
Off­
site
landfill
residual
(
leachate)
management
costs
would
be
included
in
the
commercial
landfill
price.
Off­
site
energy
recovery
residual
management
costs
would
be
included
in
the
commercial
energy
recovery
(
e.
g.,
cement
kiln)
price.
Acid
neutralization
residuals
would
be
discharged
to
a
POTW
which
has
a
relatively
small
cost.

The
second
group
of
plants
are
those
that
recovered
wastes
off
site
outside
their
industry
group
in
1999.
If
economically
feasible,
some
of
these
plants
may
construct
on­
site
recovery
facilities
to
recover
metal,
solvent
and
acid
values
from
their
wastes.
The
primary
(
baseline)
off­
site
metals,
solvents,
and
other
recovery
practices
are
high
temperature
metals
recovery/
secondary
smelting,
fractionation/
distillation,
and
acid
regeneration,
respectively.
Residuals
from
these
management
practices
that
are
derived
from
a
listed
waste
or
have
a
hazardous
characteristic
are
managed
as
hazardous.
High
temperature
metals
recovery/
secondary
smelting,
fractionation/
distillation,
and
acid
regeneration
residuals
are
assumed
to
be
managed
by
hazardous
waste
landfill
disposal
with
stabilization,
energy
recovery,
and
chemical
precipitation
with
off­
site
stabilization
and
landfill
disposal
of
precipitates
and
sewer
discharge
of
neutralized
wastewater,
respectively.
A
breakeven
cost
analysis
was
conducted
to
determine
which
plants
would
construct
on­
site
recovery
facilities.

The
third
group
of
plants
are
those
that
disposed
wastes
on
site
or
off
site
in
1999.
If
economically
feasible,
some
of
these
plants
may
construct
on­
site
recovery
facilities
to
recover
metal,
solvent
and
acid
values
from
their
wastes.
Table
5­
1
presents
the
specific
waste
types
that
were
evaluated
and
their
respective
baseline
management
practices
and
residual
management
practices.
A
break­
even
cost
analysis
was
conducted
to
determine
which
plants
would
construct
on­
site
recovery
facilities.
5­
3
Table
5­
1.
Baseline
Management
Practices
for
List
of
Disposed
Waste
Types
Analyzed
for
Potential
On­
Site
Recovery
Waste
Types
SIC
Codes
Waste
Forms
Baseline
Management
(
Residual
Management)

Organic
Liquids
(
from
Industrial
Organic
Chemicals,
Paints
and
Allied
Products,
Pharmaceutical
Preparations,
and
Plastics
Materials
and
Resins
Industries)
2869
2851
2834
2821
Liquid
Form
Codes
(
B101­
B119,
B201­
B219)
Off­
site
Fuel
Blending
Emission
Control
Dust
(
from
Steel
Works
Industry)
3312
Solid
Form
Codes
(
B301­
B319,
B401­
B409)
Sludge
Form
Codes
(
B501­
B519,
B601­
B609)
Off­
site
Stabilization
and
Subtitle
D
Landfill
(
Envirosource
delisting
technology)

Metal­
Containing
Liquids
(
from
Printed
Circuit
Board
Industry)
3672
Liquid
Form
Codes
(
B101­
B119,
B201­
B219)
On­
site
or
Off­
site
Chemical
Precipitation
Electroplating
Wastewater
Treatment
Sludges
(
from
Printed
Circuit
Board
Industry)
3672
Solid
Form
Codes
(
B301­
B319,
B401­
B409)
Sludge
Form
Codes
(
B501­
B519,
B601­
B609)
Off­
site
Stabilization
and
Landfill
Spent
Carbon
(
from
Industrial
Organic
Chemicals
and
Petroleum
Refining
Industries)
2869
2911
Solid
Form
Codes
(
B301­
B319,
B401­
B409)
Sludge
Form
Codes
(
B501­
B519,
B601­
B609)
Off­
site
Incineration
or
Carbon
Regeneration1
Spent
Catalyst
(
from
Petroleum
Refining
Industry)
2911
Solid
Form
Codes
(
B301­
B319,
B401­
B409)
Sludge
Form
Codes
(
B501­
B519,
B601­
B609)
Off­
site
Stabilization
and
Landfill
Spent
Aluminum
Potliner
(
from
Aluminum
Industry)
3334
Solid
Form
Codes
(
B301­
B319,
B401­
B409)
Sludge
Form
Codes
(
B501­
B519,
B601­
B609)
Off­
site
Incineration
Spent
Pickle
Liquor
(
from
Steel
Works
Industry)
3312
Liquid
Form
Codes
(
B101­
B119,
B201­
B219)
On­
site
or
Off­
site
Chemical
Precipitation
1
Facilities
reporting
Other
Treatment
(
M125)
waste
stream
management
in
the
1999
BRS
were
assumed
to
use
off
site
regeneration
of
carbon
as
the
disposal
method.
All
other
facilities
were
assumed
to
use
incineration
as
the
baseline
management
method.
5­
4
Current
RCRA
administrative
requirements
for
the
baseline
large
quantity
generators
(
LQGs)
identified
through
the
Biennial
Report
System
are
listed
in
Table
5­
2.
A
summary
of
potential
cost
impacts
for
each
administrative
requirement,
pre­
and
post­
rule,
are
included
in
the
table
from
any
changes
in
generator
status
that
may
result
from
the
exclusion
from
the
Definition
of
Solid
Waste.

In
addition,
transfer
costs
may
be
reduced
with
the
reduction
in
hazardous
waste
generation
taxes
and
fees
paid
by
generators
who
reclaim
their
wastes.
These
costs
do
not
count
as
social
cost
savings
because
they
are
a
redistribution
(
transfer)
of
wealth.
However,
they
do
influence
a
generators's
(
firm's)
decision
to
reclaim
their
waste.
See
Appendix
F
for
an
analysis
of
current
state
hazardous
waste
generator
taxes
and
fees.

Table
5­
2.
RCRA
Administrative
Requirements
for
Generators
RCRA
Generator
Requirement
Generator
Status
Cost
Impacts
LQG
(>
13.2
tons/
yr)
SQG
(
1.3
­
13.2
tons/
yr)
CESQG
(<
1.3
tons/
yr)

EPA
ID
Number
Required
Required
Not
required
Assumed
no
cost
savings
because
generators
already
have
incurred
costs
for
obtaining
EPA
ID
number.

RCRA
Personnel
Training
Required
(
40
CFR
262.34)
Basic
training
required
(
40
CFR
262.34)
Not
required
Cost
savings
incurred
if
generator
becomes
a
small
or
conditionally
exempt
small
quantity
generator
with
exclusion
from
the
Definition
of
Solid
Waste.

Recordkeeping
Required
for
manifests,
exception
report,
and
biennial
report.
Required
for
manifests
and
exception
reports.
Not
required
Cost
savings
incurred
if
recovered
waste
not
defined
as
a
hazardous
waste
or
if
generator
becomes
a
small
or
conditionally
exempt
small
quantity
generator
with
exclusion
from
the
Definition
of
Solid
Waste.

Exception
Report
Required
within
45
days
of
hazardous
waste
being
accepted
by
initial
transporter
Required
within
60
days
of
hazardous
waste
being
accepted
by
initial
transporter
Not
Required
Cost
savings
incurred
if
generator
becomes
a
small
or
conditionally
exempt
small
quantity
generator
with
exclusion
from
the
Definition
of
Solid
Waste.

Biennial
Report
Required
Not
required
Not
required
Cost
savings
incurred
if
generator
becomes
a
small
or
conditionally
exempt
small
quantity
generator
with
exclusion
from
the
Definition
of
Solid
Waste.
Table
5­
2.
RCRA
Administrative
Requirements
for
Generators
RCRA
Generator
Requirement
Generator
Status
Cost
Impacts
LQG
(>
13.2
tons/
yr)
SQG
(
1.3
­
13.2
tons/
yr)
CESQG
(<
1.3
tons/
yr)

5­
5
Accumulation
Time
Limits
90
days
180
days
[
or
270
days
if
transported
more
than
200
miles]
None
Cost
savings
incurred
if
generator
becomes
a
small
or
conditionally
exempt
small
quantity
generator
with
exclusion
from
the
Definition
of
Solid
Waste.

Storage
Requirements
for
Accumulated
Hazardous
Waste
Full
compliance
with
management
of
containers
or
tanks
Basic
requirements
with
technical
standards
for
containers
or
tanks
None
Assumed
no
cost
savings
if
generator
status
changes
because
facilities
already
have
incurred
costs.

Use
Manifests
Required
Required,
unless
the
waste
is
reclaimed
under
a
contractual
agreement
Not
required
Cost
savings
incurred
if
recovered
waste
not
defined
as
a
hazardous
waste
or
if
generator
becomes
a
small
(
with
contract
agreement)
or
conditionally
exempt
small
quantity
generator
with
exclusion
from
the
Definition
of
Solid
Waste.

Contingency
Plan
Required
Not
required
Not
required
Cost
savings
incurred
if
generator
becomes
a
conditionally
exempt
small
quantity
generator
with
exclusion
from
the
Definition
of
Solid
Waste.

LQG
=
Large
quantity
generator
SQG
=
Small
quantity
generator
CESQG
=
Conditionally
exempt
small
quantity
generator
5.3
Post­
Regulatory
Cost
Components
Under
post­
regulatory
conditions,
facilities
that
recovered
wastes
on­
site
and
off­
site
(
within
the
same
industry
group)
for
the
1999
site
list
have
the
same
recovery
management
practices
as
those
for
the
baseline
scenario,
however,
residual
management
may
change.
If
wastes
are
no
longer
"
listed"
as
hazardous
if
they
are
recovered
either
on
site
or
off
site
within
the
same
industry
group
(
4­
digit
NAICS),
residuals
from
the
recovery
processes
will
no
longer
be
hazardous
under
the
"
Derived­
from
Rule"
unless
they
exhibit
a
hazardous
characteristic.
For
high
temperature
metals
recovery/
secondary
smelting,
hazardous
residual
management
is
assumed
to
be
disposed
in
a
5­
6
Subtitle
C
landfill
with
stabilization.
The
management
of
these
residuals
will
shift
from
Subtitle
C
to
Subtitle
D
landfill
if
they
do
not
test
characteristically
hazardous.
Non­
hazardous
residual
management
is
assumed
to
be
Subtitle
D
landfilling.
For
fractionation/
distillation,
hazardous
and
non­
hazardous
residual
management
is
assumed
to
be
fuel
blending.
For
acid
regeneration,
hazardous
residual
management
is
assumed
to
be
chemical
precipitation.
The
management
of
these
residuals
will
shift
from
Subtitle
C
to
Subtitle
D
disposal
if
they
do
not
test
characteristically
hazardous.
Non­
hazardous
residual
management
is
assumed
to
be
sewer
discharge
to
a
local
publically
owned
treatment
works
(
POTW).
It
is
assumed
as
a
rough
approximation
that
5
percent,
15
percent,
and
25
percent
of
the
residual
quantity
is
nonhazardous
post
rule,
for
secondary
smelting,
distillation,
and
acid
regeneration,
respectively.
These
percentages
are
based
on
an
analysis
of
the
frequency
and
quantity
of
wastes
currently
classified
as
characteristic
only
waste
(
i.
e.,
single
or
multiple
D­
code
wastes)
entering
on­
site
recovery
processes
in
1999.
These
percentages
reflect
the
portion
of
the
waste
entering
recovery
processes
that
are
not
characteristically
hazardous
(
i.
e.,
single
or
multiple
D­
code
wastes),
but,
listed
hazardous
waste
which
will
become
nonhazardous
post
rule.

For
facilities
that
recovered
wastes
on
site
and
off
site
in
1997
but
not
in
1999,
the
postregulatory
management
practices
for
metal­
bearing,
solvent
and
acidic
wastes
are
high
temperature
metals
recovery/
secondary
smelting,
fractionation/
distillation,
and
acid
regeneration,
respectively,
based
on
recovery
practices
reported
in
1997.
The
residual
management
assumptions
are
the
same
as
those
presented
above.

For
facilities
that
recovered
wastes
off­
site
outside
their
industry
group
in
1999,
the
postregulatory
recovery
management
practices
for
metal­
bearing,
solvent
and
acidic
wastes
are
ONSITE
high
temperature
metals
recovery/
secondary
smelting,
fractionation/
distillation,
and
acid
regeneration,
respectively,
if
economically
feasible.
A
break­
even
cost
analysis
was
conducted
to
determine
which
plants
would
construct
on­
site
recovery
facilities.
Otherwise
there
is
no
change
from
the
baseline
management
practice.
The
residual
management
assumptions
are
the
same
as
those
presented
above
for
on­
site
recovery
systems.

For
facilities
of
selected
waste
types
that
disposed
wastes
off­
site
in
1999,
the
post­
regulatory
ON­
SITE
recovery
management
practices
and
residual
management
practices
are
presented
in
Table
5­
3,
if
economically
feasible.
A
break­
even
cost
analysis
was
conducted
to
determine
which
plants
would
construct
on­
site
recovery
facilities.
If
it
is
not
economically
feasible
to
construct
an
on­
site
recovery
system
there
is
no
change
from
the
baseline
management
practice.
5­
7
Table
5­
3.
Post­
Regulatory
Management
Practices
for
List
of
Disposed
Waste
Types
Analyzed
for
Potential
On­
Site
Recovery
Waste
Types
SIC
Codes
Waste
Forms
Post­
Regulatory
Management
(
Residual
Management)

Organic
Liquids
(
from
Industrial
Organic
Chemicals,
Paints
and
Allied
Products,
Pharmaceutical
Preparations,
and
Plastics
Materials
and
Resins
Industries)
2869
2851
2834
2821
Liquid
Form
Codes
(
B101­
B119,
B201­
B219)
On­
site
Fractionation/
Distillation
Emission
Control
Dust
(
from
Steel
Works
Industry)
3312
Solid
Form
Codes
(
B301­
B319,
B401­
B409)
Sludge
Form
Codes
(
B501­
B519,
B601­
B609)
On­
site
Smelting
Metal­
Containing
Liquids
(
from
Printed
Circuit
Board
Industry)
3672
Liquid
Form
Codes
(
B101­
B119,
B201­
B219)
On­
site
Ion
Exchange
Electroplating
Wastewater
Treatment
Sludges
(
from
Printed
Circuit
Board
Industry)
3672
Solid
Form
Codes
(
B301­
B319,
B401­
B409)
Sludge
Form
Codes
(
B501­
B519,
B601­
B609)
On­
site
Smelting
Spent
Carbon
(
from
Industrial
Organic
Chemicals
and
Petroleum
Refining
Industries)
2869
2911
Solid
Form
Codes
(
B301­
B319,
B401­
B409)
Sludge
Form
Codes
(
B501­
B519,
B601­
B609)
On­
site
Carbon
Regeneration:
"
Roasting"

Spent
Catalyst
(
from
Petroleum
Refining
Industry)
2911
Solid
Form
Codes
(
B301­
B319,
B401­
B409)
Sludge
Form
Codes
(
B501­
B519,
B601­
B609)
On­
site
Smelting
Spent
Aluminum
Potliner
(
from
Aluminum
Industry)
3334
Solid
Form
Codes
(
B301­
B319,
B401­
B409)
Sludge
Form
Codes
(
B501­
B519,
B601­
B609)
On­
site
Fluoride
Recovery
using
Vortec
technology
Spent
Pickle
Liquor
(
from
Steel
Works
Industry)
3312
Liquid
Form
Codes
(
B101­
B119,
B201­
B219)
On­
site
Acid
Regeneration
5­
8
Potential
cost
savings
from
changes
in
RCRA
administrative
requirements
because
of
reduced
manifest,
recordkeeping,
and
generator
status
(
i.
e.,
SQG
and
CESQG)
requirements
are
listed
in
Table
5­
2.

An
additional
one­
time
costs
will
be
incurred
by
each
generator
for
completing
a
notification
of
RCRA
exclusion
for
their
waste.

There
is
a
distributional
affect
on
transfer
costs.
If
wastes
are
no
longer
"
listed"
as
hazardous
if
they
are
recovered
either
on
site
or
off
site
within
the
same
Industry
Group
(
4­
digit
NAICS),
state
hazardous
waste
generation
taxes
and
fees
may
no
longer
apply.
These
reductions
in
costs
are
not
social
cost
savings
but
do
impact
a
generator's
decision
to
reclaim
its
wastes.
State
hazardous
waste
taxes
and
fees
are
presented
in
Appendix
F.

5.4
Annualization
Methodology
of
Before­
Tax
Compliance
Costs
Under
Executive
Order
12866,
EPA
must
determine
whether
a
regulation
constitutes
a
"
significant
regulatory
action."
One
of
the
criteria
for
defining
a
significant
regulatory
action,
as
defined
under
the
Executive
Order,
is
if
the
rule
has
an
annual
effect
on
the
economy
of
$
100
million
or
more.
To
determine
whether
the
proposed
exclusion
from
the
Definition
of
Solid
Waste
is
a
significant
regulatory
action
under
this
criteria,
all
costs
are
annualized
on
a
before­
tax
basis
assuming
a
seven
percent
real
discount
rate.
The
savings
attributable
to
corporate
tax
deductions
or
depreciation
on
capital
expenditures
for
equipment
are
not
considered
in
calculating
before­
tax
costs.

A
plant­
specific
annualized
before­
tax
cost
analysis
was
conducted
for
each
plant
affected
by
the
proposed
rulemaking.
Annual
before­
tax
baseline,
compliance,
and
incremental
compliance
costs
were
estimated
for
each
plant.
Before­
tax
incremental
compliance
costs
were
used
because
they
represent
a
resource
or
social
cost
of
the
rulemaking,
measured
before
any
business
expense
tax
deductions
that
are
available
to
affected
companies.
In
reformulating
the
social
costs
of
compliance,
a
discount
rate
(
real
rate
of
return)
of
seven
percent
was
used,
assuming
either
a
10­
year
or
14­
year
borrowing
period.

The
following
formula
was
used
to
determine
the
before­
tax
annualized
costs:

Annual
Before­
Tax
Costs
=
(
Capital
Costs)(
CRF
n)+
(
Annual
O&
M
Costs)

Where:
CRF
n
=
Capital
recovery
factor
(
i.
e.,
the
amount
of
each
future
annuity
payment
required
to
accumulate
a
given
present
value)
based
on
a
7
percent
real
rate
of
return
(
i)
and
a
10­
year
borrowing
period
(
n)
as
follows:

(
1
+
i)
n(
i)
=
0.14238
when
n
=
10
(
1
+
i)
n­
1
0.11435
when
n
=
14
5­
9
Costs
for
contingency
planning,
initial
waste
characterization,
and
the
notification
of
exclusion
are
one­
time
costs.
These
costs
will
be
incurred
the
first
year,
but
not
subsequent
years.

5.5
Example
Cost
Calculations
Using
the
waste
quantity/
recovery
technology
inputs,
unit
costs,
and
annualized
cost
functions
described
in
the
following
subsections,
cost
impacts/
savings
were
calculated
on
a
per
plant
basis.
All
the
plant­
specific
cost
impact/
savings
calculations
are
summed
over
all
plants
identified
as
potentially
impacted
by
the
proposed
rule
to
determine
the
total
cost
impact/
savings
from
the
rule.
Cost
determinants
are
the
plant's
quantity
of
hazardous
waste
recovered
on
site
or
off
site
within
the
same
Industry
Group
(
4­
digit
NAICS
code),
recovery
management
method,
and
the
total
quantity
of
hazardous
waste
generated
to
determine
RCRA
administrative
requirements
that
vary
depending
on
generator
status
(
i.
e.,
large,
small,
or
conditionally
exempt).

Example
cost
calculations
are
presented
for
the
following
six
plant
categories:
1)
plants
that
recovered
hazardous
waste
on
site
in
1999,
2)
plants
that
recovered
hazardous
waste
on
site
in
1997
but
not
in
1999,
3)
plants
that
recovered
waste
off
site
in
1999
within
the
same
industry
group,
4)
plants
that
recovered
waste
off
site
in
1997
within
the
same
industry
group,
5)
plants
that
recovered
waste
off
site
in
other
industry
groups,
and
6)
plants
that
disposed
potentially
recoverable
wastes
on­
site
or
of
 
site
in
1999.
The
type
of
waste
being
recovered
(
metal­
bearing,
solvent,
or
acid),
the
year
the
waste
was
recovered
and
the
location
(
on­
or
off­
site)
determined
the
cost
calculation
methodology.
Table
5­
4
references
the
appendices
at
the
end
of
this
analysis
that
present
an
example
calculation
demonstrating
how
the
costs
were
calculated
for
each
plant
for
that
plant
category
and
waste
type.
Given
resource
constraints,
example
cost
calculations
are
not
presented
in
the
appendices
for
all
the
waste
types
within
the
off­
site
recovery
in
other
industry
group
plant
category
and
on­
site
and
off­
site
disposal
plant
category
where
a
break­
even
cost
analysis
was
conducted
to
determine
economic
feasibility
for
constructing
an
on­
site
recovery
system.
Four
examples
are
presented
demonstrating
how
the
break­
even
cost­
analysis
calculations
were
conducted
Table
5­
4.
Example
Cost
Calculation
Reference
List
by
Plant
Category
Plant
Category
Waste
Type
Baseline
(
Pre­
Rule)
Management
Post­
Rule
Management
No.
of
Plants*
Quantity
(
tons)
Example
Cost
Calculation
Reference
On­
site
Recovery
1999
On­
site
Recovery
Plants
metalbearing
waste
On­
site
Metal
Recovery
On­
site
Metal
Recovery
175
409,315
Appendix
G
spent
solvents
On­
site
Solvent
Recovery
On­
site
Solvent
Recovery
640
160,139
Appendix
H
Table
5­
4.
Example
Cost
Calculation
Reference
List
by
Plant
Category
Plant
Category
Waste
Type
Baseline
(
Pre­
Rule)
Management
Post­
Rule
Management
No.
of
Plants*
Quantity
(
tons)
Example
Cost
Calculation
Reference
5­
10
spent
acid
On­
site
Acid
(
Other)
Recovery
On­
site
Acid
(
Other)
Recovery
74
249,904
Appendix
I
1997
On­
site
Recovery
Plants
metalbearing
waste
Off­
site
Hazardous
Landfill
On­
site
Metal
Recovery
33
2,854
Appendix
J
spent
solvent
Off­
site
Energy
Recovery
On­
site
Solvent
Recovery
189
8,451
Appendix
K
spent
acid
On­
site
Acid
Neutralization
On­
site
Acid
(
Other)
Recovery
34
16,312
Appendix
L
Off­
site
Recovery
Within
Industry
Group
(
4­
Digit
NAICS
Code)

1999
Off­
site
Recovery
Plants
Within
Industry
Group
metalbearing
waste
Off­
site
Metal
Recovery
Off­
site
Metal
Recovery
160
25,618
Appendix
M
spent
solvent
Off­
site
Solvent
Recovery
Off­
site
Solvent
Recovery
76
28,635
Appendix
N
spent
acid
Off­
site
Acid
(
Other)
Recovery
Off­
site
Acid
(
Other)
Recovery
22
5,183
Appendix
O
1997
Off­
site
Recovery
Plants
Within
Industry
Group
metalbearing
waste
Off­
site
Hazardous
Landfill
Off­
site
Metal
Recovery
27
229
Appendix
P
spent
solvent
Off­
site
Energy
Recovery
Off­
site
Solvent
Recovery
10
4,031
Appendix
Q
spent
acid
On­
site
Acid
Neutralization
Off­
site
Acid
(
Other)
Recovery
9
245
Appendix
R
Table
5­
4.
Example
Cost
Calculation
Reference
List
by
Plant
Category
Plant
Category
Waste
Type
Baseline
(
Pre­
Rule)
Management
Post­
Rule
Management
No.
of
Plants*
Quantity
(
tons)
Example
Cost
Calculation
Reference
5­
11
Shifting
from
Off­
site
Recovery
Outside
Industry
Group
to
On­
site
Recovery
1999
Off­
Site
Recovery
Plants
Outside
Industry
Group
metalbearing
waste
Off­
site
Metals
Recovery
On­
site
Metals
Recovery
1,244
583,440
Did
not
prepare
an
example
cost
calculation.

spent
solvent
Off­
site
Energy
Recovery
On­
Site
Energy
Recovery
763
101,778
Appendix
S
spent
acid
Off­
site
Acid
(
Other)
Recovery
On­
Site
Acid
Recovery
276
69,667
Appendix
T
Shifting
from
Disposal
to
On­
site
Recovery
1999
On­
Site
or
Off­
Site
Disposal
Plants
K061
­
electric
arc
furnace
dust
Off­
site
Stabilization
and
Subtitle
D
Landfill
(
Envirosource
delisting
technology)
On­
site
Smelting
30
273,208
Appendix
U
Metal­
Containing
Liquids
(
from
Printed
Circuit
Board
Industry)
On­
site
or
Offsite
Chemical
Precipitation
On­
site
Ion
Exchange
Metals
Recovery
using
MR3
System
technology
252
155,354
Did
not
prepare
an
example
cost
calculation.

Spent
Catalyst
(
from
Petroleum
Refining
Industry)
Off­
site
Stabilization
and
Landfill
On­
site
Smelting
75
11,001
Did
not
prepare
an
example
cost
calculation.

K088
­
spent
aluminum
potliner
Off­
site
Incineration
On­
site
Fluoride
Recovery
using
Vortec
technology
21
72,547
Appendix
V
Table
5­
4.
Example
Cost
Calculation
Reference
List
by
Plant
Category
Plant
Category
Waste
Type
Baseline
(
Pre­
Rule)
Management
Post­
Rule
Management
No.
of
Plants*
Quantity
(
tons)
Example
Cost
Calculation
Reference
5­
12
K062
­
spent
pickle
liquor
On­
site
or
Offsite
Chemical
Precipitation
On­
site
Acid
Regeneration
35
269,329
Did
not
prepare
an
example
cost
calculation.

*
Some
plants
are
counted
more
than
once
because
they
recover
a
combination
of
metal,
solvent
and/
or
other
wastes.

5.6
Unit
Cost
and
Cost
Function
Estimates
Metal
Recycling
(
Secondary
Smelting)
Costs
Offsite
Metal
Recovery
Recycling
cost
estimates
were
taken
from
a
previous
Agency
rulemaking
titled
Regulatory
Impact
Analysis
of
the
Final
Rule
for
a
180­
Day
Accumulation
Time
for
F006
Wastewater
Treatment
Sludges,
November
10,
1999
(
F006
180­
Day
Accumulation
Rule).
In
that
analysis
recycling
costs
for
recovering
metals
from
F006
wastewater
treatment
sludges
were
estimated
from
1993
cost
data
provided
in
Exhibit
7­
1
of
Cushnie,
George
C.,
CAI
Engineering,
"
Pollution
Prevention
and
Control
Technology
for
Plating
Operations,"
prepared
for
NCMS/
NAMF.
Table
5­
5
presents
the
estimate
from
the
above
report
for
the
metal
recycling/
recovery
unit
costs
being
paid
by
F006
sludge
generators.
Transportation
costs
were
subtracted
from
the
estimated
recycling
costs.
1997
unit
transportation
prices
reported
in
Environmental
Cost
Handling
Options
and
Solutions
(
ECHOS),
Environmental
Remediation
Cost
Data­
Unit
Price,
4th
Annual
Edition,
published
by
R.
S.
Means
and
Delta
Technologies
Group,
Inc.,
1998,
were
used
to
estimate
transportation
costs
in
that
analysis.
Differences
in
average
unit
recycling
costs
in
Table
5­
5
are
the
result
of
variability
in
the
amount
various
recyclers
charge
generators.
A
major
factor
contributing
to
the
differences
in
recycling
costs
is
metal
content
(
i.
e.,
concentration
and
type
of
metals
present
in
the
waste).
The
generally
lower
costs
for
the
small
facilities
that
recover
metals
may
be
due
to
the
fact
that
these
facilities
tend
to
generate
single­
metal
wastes
which
are
more
amenable
to
recycling.

No
minimum
charge
is
assumed
for
transfers
of
bulk
shipments
within
the
same
Industry
Group
(
4­
digit
NAICS).
It
is
assumed
that
transfers
are
typically
occurring
within
the
same
parent
company
and
that
they
would
not
charge
a
minimum
fee,
unlike
a
commercial
metal
recovery
facility.
Normally,
one
would
assume
that
a
commercial
off­
site
facility
will
have
a
minimum
charge
for
accepting
small
quantities
of
waste
for
recovery.
11
The
estimates
of
average
recycling
costs
were
confirmed
by
industry
contacts
(
Jarvis,
1999,
Personal
Communication,
Eritech,
North
Carolina;
Anonymous,
1999,
Personal
Communication,
Sun­
Glo
Pating,
Florida
).

12
Shields,
1999,
Personal
Communication,
American
Nickeloid,
Illinois.

13
Jarvis,
1999,
Personal
Communication,
Eritech,
North
Carolina;
and
Anonymous,
1999,
Personal
Communication,
Dearborn
Brass,
Texas.

5­
13
In
the
F006
180­
Day
Accumulation
Rule
report,
an
average
unit
recycling
cost
of
$
0.20/
lb
was
assumed
as
an
upper­
end
typical
price
charged
by
a
metals
recovery
facility
based
on
the
1993
data
provided
in
Cushnie.
One
recycler
that
was
contacted
provided
an
average
1998
price
of
approximately
$
0.10/
lb.
For
that
analysis,
impacts
are
evaluated
based
on
average
recycling
prices
ranging
from
$
0.10/
lb
to
$
0.20/
lb
($
200/
ton
to
$
400/
ton).
11
In
some
cases,
when
the
metal
value
is
very
high,
the
charges
can
be
somewhat
lower.
12
Minimum
charges
are
at
least
sometimes
avoided
when
the
recycler
actually
picks
up
the
F006
directly
from
the
generator.
13
Residuals
generation
from
metals
recovery
were
estimated
using
1999
BRS
data.
Waste
streams
at
selected
recovery
facilities
were
reviewed
by
comments,
disposal
system
type,
and
origin
to
determine
the
likely
waste
streams
generated
from
the
recovery
operations.
Approximately
32
percent
of
the
metals
recovery
mass
was
identified
as
residuals
in
the
1999
BRS
data
(
see
Appendix
W).
The
hazardous
fraction
of
the
residuals
were
determined
by
reviewing
the
waste
codes
for
the
waste
streams
reporting
metals
reclamation.
Waste
streams
reporting
characteristic
codes
were
assumed
to
have
residuals
that
would
be
characteristically
hazardous
waste.
For
metals
recovery,
approximately
95
percent
of
the
residual
waste
volume
and
frequency
of
waste
streams
are
estimated
to
be
characteristically
hazardous
with
the
remaining
5
percent
containing
listed
hazardous
wastes
which
will
become
nonhazardous
post
rule.

For
purposes
of
this
rule
making,
a
unit
cost
of
$
316
per
ton
(
2002$)
was
assumed
for
commercial
metals
recovery.
This
unit
cost
was
used
as
a
proxy
to
estimate
the
unit
cost
to
recover
metals
onsite
for
those
who
conducted
the
practice
on­
site
in
1997,
assuming
a
15%
profit
factor
(
i.
e.,
direct
cost
to
recover
waste
is
$
268
per
ton
in
2002
dollars).
The
commercial
unit
cost
is
assumed
to
include
all
capital
and
annual
expenditures
necessary
for
the
metals
recovery
system.
It
is
assumed
that
these
facilities
already
have
invested
a
significant
amount
of
capital
into
recovery
units
that
exist
on
site
(
but
were
not
used
in
1999).
Metal
salvage
value
was
considered
separate
from
the
recovery
unit
cost.
5­
14
Table
5­
5.
Estimated
F006
Off­
site
Metals
Recycling
Costs
(
1993$)

Generator
Type
No.
of
Data
Points
Transport
Recycling
Average
Unit
Cost
($/
lb)
(+/­
st.
dev.)
Minimum
Median
Maximum
Unit
Cost
($/
lb)
Average
Unit
Cost
($/
lb)
(+/­
st.
dev.)
Minimum
Median
Maximum
Unit
Cost
($/
lb)

Small
LQG
­
small
shipment
(<
13.2
t/
yr)*
31
0.49
+/­
0.50
0.11
0.27
2.07
0.02
+/­
0.56
­
1.77
0.07
0.76
Small
LQG
­
large
shipment
(
13.2
­
<
60
t/
yr)
36
0.11
+/­
0.08
0.02
0.08
0.39
0.20
+/­
0.21
­
0.14
0.18
1.04
Large
LQG
(
60
t/
yr
or
greater)
20
0.06
+/­
0.05
0.02
0.02
0.16
0.17
+/­
0.15
0.01
0.14
0.61
Total
87
0.15
+/­
0.18
0.02
0.09
1.04
0.22
+/­
0.27
­
0.74
0.18
0.9
*
Assumes
all
facilities
are
LQGs
and
ship
four
times
per
year.
This
data
may
include
SQGs
which
ship
at
a
maximum
of
2
times
per
year.
If
these
facilities
are
SQGs,
the
average
transport
unit
cost
is
$
0.25/
lb
(+/­
0.25)
and
average
recycling
unit
cost
is
$
0.26/
lb
(+/­
0.36).
Assumptions:
Step
1:
Used
1993
cost
data
provided
in
Exhibit
7­
1
of
Cushnie,
George
C.,
CAI
Engineering,
"
Pollution
Prevention
and
Control
Technology
for
Plating
Operations,"
prepared
for
NCMS/
NAMF.
Step
2:
Eliminated
seven
data
records
from
Cushnie
that
do
not
provide
either
shipping
distance,
quantity
shipped,
or
unit
cost.
Based
on
inspection,
four
records
eliminated
as
statistical
outliers.
Step
3:
Assumed
the
following
distances:
Category
<
500
miles
=
250
miles,
Category
500
to
1,000
miles
=
750
miles,
Category
1,000
to
1,500
miles
=
1,250
miles,
Category
1,500
to
2,000
miles
=
1,750
miles,
and
Category
2,000
to
2,500
miles
=
2,250
miles.
Step
4:
Assumed
LQG
and
90­
day
storage
if
>
26,400
lbs
generated
annually.
Step
5:
Assumed
a
full
shipment
size
of
15
tons
based
upon
EPA's
Common
Sense
Initiative
report.
Step
6:
Assumed
minimum
of
4
shipments/
year
(
i.
e.,
90­
day
storage
limit)
for
LQGs.
Step
7:
Used
1998
ECHOS
transportation
unit
price
estimates
($/
mile)
for
van
trailer
transportation
of
hazardous
waste.
Assume
transportation
prices
have
not
changed
significantly
since
1993
given
that
increased
labor
costs
are
likely
being
balanced
by
historically
low
fuel
costs.
Step
8:
Used
1998
ECHOS
minimum
charge
for
van
trailer
transportation
of
small
hazardous
waste
loads
of
$
732.33
per
shipment
as
a
minimum
cost.
Assumed
$
2.64/
each
supersack
for
loading
on
to
the
truck.
Assumed
transportation
prices
have
not
changed
significantly
since
1993
given
that
increased
labor
costs
are
likely
being
balanced
by
historically
low
fuel
costs.
14MR3
Systems
Inc.,
http://
www.
mr3systems.
com
5­
15
Recovery
from
Metals
Containing
Liquids
For
recovery
of
metals
from
metals
containing
liquids,
cost
for
an
ion
exchange
process
for
MR3
Systems
Inc.
14
recovery
process
was
estimated
(
Table
5­
6).
Company
literature
provided
capital
and
operation
costs
of
$
4
million
and
$
2
million,
respectively,
for
a
50,000
ton
per
year
facility.
The
data
was
scaled
using
a
0.54
factor
for
capital
and
0.7
factor
for
operation
and
maintenance.
Capital
costs
were
annualized
over
14
years
at
7
percent
using
a
capital
recovery
factor
(
CRF)
of
0.11435.

Table
5­
6.
Estimated
On­
site
Metal
Recovery
Costs
for
Metal
Containing
Liquids
(
2002$)

Cost
Element
Annual
Expenditure
($/
ton)

Capital
Expenditure
(
Annualized)
1
$
1,095*
(
Recovered
Waste
Quantity)^
0.54
Operation
and
Maintenance
$
1,027*(
Recovered
Waste
Quantity)^
0.70
1
Annualized
over
14
years
at
7
percent
interest
rate
using
a
CRF
of
0.11435.

Primary
Electric
Arc
Furnace
Dust
Metals
Recovery
and
Stabilization
Technologies
In
1980,
the
United
States
Environmental
Protection
Agency
(
EPA)
classified
emission
control
dust
and
sludge
from
the
primary
production
of
steel
in
electric
arc
furnaces
as
listed
hazardous
waste
K061
(
40
CFR
261.32),
due
to
the
fact
that
it
contains
toxic
levels
of
metals
such
as
zinc,
iron,
lead,
cadmium
and
chromium.
Currently,
the
EPA
requires
that
electric
arc
furnace
(
EAF)
dust
be
disposed
of
by
one
of
two
approved
methods:
high
temperature
metals
recovery
(
HTMR)
or
stabilization.

HTMR
 
Horsehead
Resources
Development
Co.:
Horsehead
Resource
Development
Co.
recycles
330,000
tons
of
EAF
dust
per
year
with
a
process
known
as
High
Temperature
Metals
Recovery
(
HTMR),
using
a
Waelz
reduction
kiln.
The
Waelz
kiln
process
is
used
to
enrich
the
EAF
dust
to
a
product
with
greater
than
45%
zinc.
The
zinc
oxide
material
is
mixed
with
reducing
agents,
such
as
lime
and
coke,
and
heated
in
the
kiln
to
a
point
where
zinc
vapor
is
formed.
The
zinc
fumes
are
then
carried
off
with
the
offgases
and
collected
in
dustbags
to
be
sold.
Horsehead
operates
Waelz
reduction
kilns
in
Palmerton,
PA;
Calumet,
IL;
and
Rockwood,
TN.
In
1988,
the
EPA
stated
that
this
process
is
the
best­
demonstrated
control
technology
for
treating
EAF
dust.

Stabilization
­
Envirosource
Technologies:
Envirosource
describes
its
stabilization
technology
on
its
website
as
follows:
"
Super
Detox
®
is
a
technologically
advanced
stabilization
process
which
involves
a
series
of
complex
chemical
and
physical
reactions
including
oxidation/
reduction;
5­
16
metals
insolubilization;
silicate
polymerization
and
substitution;
pozzolonic
bonding
and
solidification
which
chemically
change
the
metals
to
their
least
soluble
state
and
physically
immobilize
them.
The
stabilized
material,
which
meets
the
regulatory
standards
and
exhibits
low
permeability
and
high
strength
properties,
can
then
be
treated
as
a
non­
hazardous
material.
This
patented
process,
which
was
developed
specifically
to
treat
EAF
dust
by
Bethlehem
Steel
Corporation,
has
been
perfected
and
extensively
tested
by
Envirosource
during
ten
years
of
research
and
commercial
application.
The
first
Super
Detox
plant
was
installed
eight
years
ago
at
Northwestern
Steel
and
Wire
Co.
in
Sterling,
Illinois.
In
June
of
1995,
the
EPA
granted
a
unique
multi­
site
delisting
for
Super
Detox.
The
EPA
delisting
validates
the
environmental
soundness
of
the
technology
and
marks
the
recognition
by
the
regulators
of
the
need
for
alternatives
to
HTMR
processes
such
as
the
Waelz
Kiln."

HTMR
Technologies
Several
companies
are
currently
developing
or
provide
HTMR
technologies
for
recovering
metals
from
EAF
dust,
through
laboratory
and
pilot
plant
tests.
The
following
paragraphs
provide
brief
descriptions
of
some
of
these
technologies:

Midrex
Direct
Reduction
Corporation/
Kobe
Steel,
Ltd.:
Midrex's
FASTMET
process
converts
steel
mill
wastes
and/
or
iron
ore
fines
into
metallic
direct­
reduced
iron
(
DRI)
in
a
rotary
hearth
furnace
(
RHF)
using
carbon
as
the
reductant.
The
DRI
can
be
hot
briquetted,
discharged
as
hot
DRI
into
transfer
containers,
cooled
if
cold
DRI
is
required,
or
directly
charged
to
a
melter
for
the
production
of
FASTIRON.
Midrex's
process
for
the
production
of
FASTIRON
is
called
FASTMELT.
In
the
FASTMELT
process,
zinc
recovery
can
be
accomplished
by
designing
the
RHF
in
a
way
that
minimizes
the
amount
of
iron
being
carried
over
to
the
offgas
system.
The
offgas
can
then
be
sent
through
a
baghouse,
where
high
zinc
content
dust
(
70­
90%)
is
produced
for
sale
to
zinc
processors.
The
first
commercial
FASTMET
plant
was
constructed,
commissioned
and
turned
over
to
the
client
for
commercial
operation
at
Nippon
Steel's
Hirohata
Works
in
Himeji,
Hyogo
Prefecture,
Japan
in
2000.

Nucor:
Nucor
is
the
nation's
largest
EAF­
steel
producer,
and
according
to
Nucor's
vice
president
of
technology,
"[
Nucor
has]
gone
with
two
different
processes
[
for
EAF­
dust
recycling]
because
there
is
no
process
that
has
really
stepped
up
and
demonstrated
itself
as
being
clearly
the
choice
for
recycling
or
recovering
the
constituents
in
arc­
furnace
dust".
The
two
EAF­
dust
recycling
processes
that
Nucor
has
employed
are
currently
in
the
evaluation
and
comparison
stage.
Inorganic
Recycling
Corp
has
been
contracted
to
recycle
25,000
tons
of
dust
annually
at
Nucor's
flat­
rolled
mill
in
Hickman,
AR.
The
dust
is
melted
with
other
ingredients
to
create
ceramic
grit
that
is
sold
to
distributors
as
a
sandblasting
abrasive.
Nucor
has
contracted
AllMet
Technologies
to
recycle
30,000
tons
of
dust
annually
at
its
Nucor­
Yamato
structurals
mill
in
Blytheville,
AR.
AllMet
blends
dust
and
mill
scale
to
increase
the
iron
content.
This
mix
is
briquetted
with
carbon
and
fed
to
a
rotary­
hearth
furnace
(
RHF),
where
zinc,
lead
and
cadmium
are
oxidized
and
fumed
off.
Final
products
include
prime
western
zinc
and
chloride
that
can
be
sold
as
flux
materials
to
secondary­
aluminum
processors.
5­
17
AmeriSteel:
AmeriSteel's
dust
processing
facility
in
Jackson,
TN
produces
DRI
and
recycles
the
zinc
oxide.
At
the
plant,
the
EAF
dust
is
blended
with
coal
and
put
into
an
RHF,
where
the
crude
zinc
oxide
is
separated
from
the
iron.
The
zinc
oxide
is
captured
in
a
baghouse
to
be
sold,
and
the
remaining
iron­
rich
material
goes
to
the
mill's
melt
shop,
where
it
accounts
for
1­
1
½
percent
of
the
charge.

Phoenix
Environmental
Ltd.:
Phoenix
Environmental
Ltd.'
s
process
will
convert
byproducts
from
steel
and
bearing
manufacturing,
such
as
EAF
dust,
metal
grindings
and
scale,
into
magnetite.
The
magnetite
will
be
sold
as
a
raw
material
to
manufacturers
of
blasting
media,
shingle
granules,
pigments
and
colorants
for
paint
and
concrete,
and
filler
additives
for
plastic.
During
the
process,
the
byproducts
will
be
melted
in
a
reactor
with
an
oxygen­
enriched
atmosphere,
and
the
resulting
molten
iron
oxide
will
become
magnetite.
The
facility
will
also
recover
zinc
and
lead
for
resale.
Phoenix
Environmental
Ltd.
plans
to
build
a
byproduct
recycling
plant
at
Timken
Co,'
s
Faircrest
steel
plant
in
Canton,
OH.

Frame
Engineering
Co./
Richland
Moulded
Brick:
Richland
Moulded
Brick
in
Mansfield,
OH
began
making
bricks
from
EAF
dust
in
early
1998,
and
can
currently
recycle
12,000
tons
of
EAF
dust
annually.
Steel
mills
are
currently
paying
Richland
an
average
of
$
100/
ton
to
take
their
EAF
dust.
At
the
plant,
the
dust
and
coke
are
mixed
with
water,
and
the
mixture
is
poured
into
wooden
molds.
The
mixture
is
then
heated
for
at
least
3
days
at
1900
º
F.
Twenty
percent
of
the
mixture
is
driven
off
as
volatile
compounds,
including
zinc,
lead,
and
cadmium.
The
remaining
80%
of
the
mixture
is
left
for
brick.
The
zinc
and
lead
are
recovered
and
sold
to
zinc
processors.
The
process
typically
produces
2,000
tons
of
zinc
oxide
annually.

Kawasaki
Steel
Corp
of
Japan
 
Chiba
Works
Pilot
Plant:
At
Kawasaki
Steel
Corp's
Chiba
Works
pilot
plant,
a
5­
meter
tall
dust­
recycling
furnace
is
used.
Coke
is
loaded
through
the
top
of
the
furnace,
and
oxygen
is
blown
into
the
furnace
through
upper
and
lower
tuyeres.
The
oxygen
combusts
in
the
burning
coke
to
form
two
ultra­
high­
heating
zones.
A
dust­
injection
blower,
which
is
alongside
the
upper
tuyere,
sends
the
EAF
dust
to
the
upper
heating
zone
where
the
dust
is
superheated
at
3000
º
C
and
melted
instantly.
The
molten
dust
filters
down
through
the
layers
of
burning
coke
and
drops
into
the
lower
heating
zone
for
compensative
heating.
As
it
travels
between
heating
zones,
the
molten
dust
 
which
is
now
molten
zinc
oxide
 
separates
into
zinc
vapor,
molten
iron,
and
molten
slag.
The
molten
iron
and
slag
sink
to
the
bottom
of
the
furnace,
where
the
molten
iron
is
then
tapped
through
a
skimmer.
During
this
time,
the
zinc
gas
and
the
exhaust
gas
rise
to
the
top
of
the
furnace.
A
wet­
type
gas
recovery
system
near
the
top
of
the
furnace
captures
the
zinc
vapor.

HIsmelt
Corporation:
The
HIsmelt
process
smelts
iron
ore
and
coal
in
a
water­
cooled
refractory
lined
vertical
vessel.
The
resulting
hot
metal
is
then
used
as
feed
stock
for
Electric
Arc
Furnaces
or
Blast
Furnaces.
The
technology
has
been
implemented
at
several
USA
and
Australian
facilities
at
production
rates
of
0.5
to
1.5
million
tons
per
annum.
The
smelter
has
been
proven
effective
for
accepting
a
range
of
iron
feed
stock
including
high
phosphorus
iron
ore
fines
and
1
Bates,
Peter
and
Coad,
Andrew,
"
HIsmelt,
The
Future
in
Ironmaking
Technology",
4th
European
Coke
&
Ironmaking
Congress,
Paris,
June
2000.
http://
www.
hismelt.
com
2
"
MR3
Systems
Announces
Execution
of
Land
Lease
for
MR3
Taiwan
Metals
Processing
Plant
 
Reports
On
Empire
Gold
Project
Progress"
SEMISEEKNEWS,
January
28,
2003,
http://
www.
semiseeknews.
com/
press_
release4465.
htm
5­
18
steel
plant
wastes
(
reverts).
Steel
plant
wastes
include
blast
furnace
sludges,
millscale,
and
casthouse
dust.
The
HIsmelt
process
consists
of
injecting
ground
ferrous
material
and
coal
into
a
molten
iron
bath
by
a
nitrogen
carrier
gas.
The
contact
with
the
iron
bath
drives
off
the
carbon
(
as
carbon
monoxide)
and
hydrogen.
The
carbon
monoxide
and
hydrogen
is
post
combusted
with
oxygen
by
an
oxygen
enriched
hot
air
blast
(
1200
C).
The
heated
metal
is
continuously
tapped
from
the
hearth;
the
slag
is
batch
tapped1.

No
additional
handling
of
reverts
was
required
for
use
in
the
HIsmelt
process.
For
reverts
containing
lead
and
zinc
(
which
include
EAF
dust),
the
majority
of
the
zinc
and
lead
partitioned
into
the
dust
collected
from
the
process.
The
dust
could
be
recycled
into
the
smelt
reduction
vessel
to
concentrate
zinc
to
a
saleable
product.
No
information
regarding
the
direct
applicability
of
the
concentration
of
zinc
dust
was
documented
and
was
only
proposed
as
a
potential
additional
commercial
option.

Ion
Exchange
Technology
for
Electric
Arc
Furnace
Dust
Metals
Recovery
At
least
one
company
has
been
identified
that
is
currently
developing
an
ion
exchange
technology
that
can
recover
metals
from
EAF
dust.

MR3
Systems
Inc.:
MR3
Systems
Inc.
has
developed
a
specialty
ion­
exchange
media
to
remove
metals
from
an
aqueous
solution.
Other
companies
(
such
as
US
Filter)
also
provide
ion
exchange
media
suitable
for
reclaiming
metals
from
an
aqueous
solution;
however,
MR3
Systems
Inc.
was
the
only
manufacture,
which
included
a
method
for
bringing
metal
bearing
solids
into
an
aqueous
state
to
pass
through
the
ion
exchange
media.
The
separated
metals
are
processed
individual
into
a
saleable
product
(
e.
g.,
zinc
sulfate
[
ZnSO4.
H2]
for
fertilizer).
MR3
Systems
Inc.
have
conducted
benchtop
tests
for
the
recovery
of
zinc
from
electric
arc
furnace
dust
(
K061)
and
operated
two
metal
recovery
facilities.
A
zinc
recovery
facility
from
zinc
ash
was
operated
in
Butte,
Montana,
facility
(
now
closed)
and
an
ongoing
project
at
the
Grace
Gold
Mine
Complex
in
Empire,
Colorado.
The
technology
is
also
being
used
to
process
metal
wastes
generated
from
the
electroplating,
metal
finishing,
and
printed
circuit
board
industries2.
3Bates,
Peter,
and
Muir,
Adrian,
Hismelt­
Low
Cost
Iron
Making",
Gorham
Conference
June
2000,
Commercializing
New
Hot
Metal
Process
­
Beyond
the
Blast
Furnace,
http://
www.
hismelt.
com
4Toon,
John,
"
The
Cost
of
Cleaning
the
Air:
Study
Shows
Permit
Application
Costs
Lower
Than
Expected
 
With
Key
Benefits
to
Industry",
Georgia
Tech
Research
News,
September
21,
1999.

5­
19
Selected
Electric
Arc
Furnace
Dust
Metals
Recovery
Technology
The
HIsmelt
technology
was
used
to
represent
the
current
technology
commercially
available
to
recover
metals
from
EAF
(
K061)
wastes.
Other
HTMR
technologies,
while
potentially
applicable,
were
limited
by
their
current
stage
of
the
process
development
and
availability
of
published
cost
examples.
The
HIsmelt
technology
has
published
costs
for
several
US
and
abroad
facilities.
Though
the
HIsmelt
technology
is
not
specific
to
the
recovery
of
metal
from
EAF
and
was
developed
as
a
more
cost
effective
means
of
smelting
iron
ore,
the
technology
does
lend
itself
to
the
recovery
of
metals
from
EAF.
As
developed
for
large­
scale
iron
fabrication,
the
cost
economics
for
the
facilities
are
generally
for
larger­
scale
facilities.
Future
technologies
in
development
as
discussed
above
may
mature
to
a
level
and
be
feasible
for
smaller
scale
generators,
with
improved
cost
economies
and
size
requirements.

The
ion
exchange
system
produced
by
MR3
Systems
was
not
utilized
as
an
EAF
recovery
method,
though
the
process
is
less
expensive
than
the
HTMR
process
reviewed.
The
ion
exchange
technology
is
not
a
method
currently
approved
under
Universal
Treatment
Standards
by
EPA
for
treatment
of
EAF.
Limited
information
regarding
the
suspension/
leaching
of
solids
into
an
aqueous
form
is
publicly
available.
Traditional
use
of
an
ion
exchange
system
is
for
wastes
already
in
aqueous
form.
Though
the
MR3
system
was
not
used
in
this
analysis,
future
development
of
the
system
may
enable
broader
us
of
the
ion
exchange
systems
for
EAF.
An
ion
exchange
system
would
have
the
advantages
of
smaller
space
requirements,
unit
expandability,
limited
or
no
residuals,
and
automated
systems.

Metal­
Containing
Solids
For
construction
of
on­
site
metal
recovery
systems
for
solid
wastes
containing
metals
(
e.
g.,
EAF),
a
smelting
process
used
in
steel
manufacturing
was
used
as
a
proxy.
The
smelting
process
assumed
is
described
as
HIsmelt3,
a
process
developed
as
an
lower
cost
alternative
to
a
traditional
blast
furnace.
Air
permitting
costs
were
added
to
construction
and
operation
and
maintenance
costs.
An
air
permit
is
assumed
to
be
renewed
every
5
years
at
a
estimated
cost
of
$
68,8764
(
2002$);
therefore,
the
application
costs
were
capitalized
over
five
years
using
a
capital
recovery
factor
of
0.24389
assuming
a
7
percent
interest
rate.
Additional
air
monitoring
costs
for
compliance
with
the
permit
are
estimated
at
10%
of
the
original
permit
application
cost
($
6,888
per
year)
(
see
Table
5­
7
for
cost
equations).
5­
20
Table
5­
7.
Estimated
On­
site
Metal
Recovery
Costs
(
2002$)

Cost
Element
1
Annual
Expenditure
($/
ton)
3
Capital
Expenditure
(
Annualized)
2
$
6,744*
(
Recovered
Waste
Quantity)^
0.59
+
$
16,798
Operation
and
Maintenance
$
1,934*(
Recovered
Waste
Quantity)^
0.78
+
$
6,888
1
Costs
inflated
from
1999
dollars
to
2002
dollars.
2
Annualized
over
14
years
at
7
percent
interest
rate
using
a
capital
recovery
factor
(
CRF)
of
0.11435.
3
Includes
air
permit
expenditures.

Solvent
Recovery
(
Distillation)
Costs
Solvent
recycling
costs
estimates
were
taken
from
a
U.
S.
Army
Corp
of
Engineers
Public
Works
Technical
Bulletin
200­
01­
04,
dated
August
31,
1999
(
USACE
Tech
Bulletin).
The
systems
reviewed
were
batch
distillation
with
vacuum
systems.
Two
system
capacities,
15
gallons
and
55
gallons,
are
estimated.
The
capital
costs
for
batch
systems
including
timers,
thermal
controls,
and
transfer
pumps,
are
$
13,283
and
$
25,468,
respectively.
A
one
time
installation
cost
is
estimated
on
a
per
system
basis
of
$
583.
Annual
costs
include
annual
labor
of
2
hours
per
batch,
power
use,
water
use,
and
materials.
Each
system
was
assumed
to
run
from
2
to
5
batches
per
week,
with
a
through­
put
of
3.3
to
120
tons
of
solvent
recoverable
waste
per
year.
Larger
systems
are
composed
of
multiple
batch
units
in
15
and
55
gallon
increments.
Smaller
systems
would
be
composed
of
a
15
gallon
batch
unit,
with
fewer
batches
per
year.

Capital
costs
were
annualized
using
a
10­
year
life
for
the
equipment
at
a
7
percent
real
rate
of
return.
Costs
are
assumed
to
be
the
same
for
recovery
at
off­
site
("
sister")
facilities
owned
by
the
same
company
within
the
same
industry
group.

Residuals
generation
from
solvent
recovery
were
estimated
using
1999
BRS
data.
Waste
streams
at
selected
recovery
facilities
were
reviewed
by
comments,
disposal
system
type,
and
origin
to
determine
the
likely
waste
streams
generated
from
the
recovery
operations.
Approximately
33
percent
of
the
solvents
recovery
mass
was
identified
as
residuals
in
the
1999
BRS
data
(
see
Appendix
W).
The
hazardous
fraction
of
the
residuals
were
determined
by
reviewing
the
waste
codes
for
the
waste
streams
reporting
solvent
reclamation.
Waste
streams
reporting
characteristic
codes
were
assumed
to
have
residuals
that
would
be
characteristically
hazardous
waste.
For
solvent
recovery,
approximately
85
percent
of
the
residual
waste
volume
is
estimated
to
be
characteristically
hazardous
with
the
remaining
15
percent
containing
listed
hazardous
wastes
which
will
become
nonhazardous
post
rule.
5Toon,
John,
"
The
Cost
of
Cleaning
the
Air:
Study
Shows
Permit
Application
Costs
Lower
Than
Expected
 
With
Key
Benefits
to
Industry",
GeorgiaTech
Research
News,
September
21,
1999.

5­
21
Air
permitting
costs
were
added
to
construction
and
operation
and
maintenance
costs.
An
air
permit
is
assumed
to
be
renewed
every
5
years
at
a
estimated
cost
of
$
68,8765
(
2002$);
therefore,
the
application
costs
were
capitalized
using
a
capital
recovery
factor
of
0.24389
using
a
7
percent
interest
rate.
Additional
air
monitoring
costs
for
compliance
with
the
permit
are
estimated
at
10%
of
the
original
permit
application
cost
($
6,888
per
year).

Commercial
off­
site
solvent
recovery
costs
were
developed
using
U.
S.
Army
Corp
of
Engineers
Public
Works
Technical
Bulletin
200­
01­
04,
dated
August
31,
1999
(
USACE
Tech
Bulletin).
Recovery
costs
include
handling
and
transportation
of
the
solvent
waste
stream.
The
estimate
is
a
service
contract
with
one
recovery
facility
for
annual
management
of
1,000
gallons
at
a
cost
of
$
4.23
per
gallon.

Table
5­
8.
Estimated
Solvent
Distillation
On­
site
Recovery
Costs
(
2002$)

Cost
Element
1
Annual
Expenditure
($/
ton)
3
Capital
Expenditure
(
Annualized)
2
$
44.62*
(
Recovered
Waste
Quantity)
+
$
18,456
Operation
and
Maintenance
$
5,519*(
Recovered
Waste
Quantity)^
0.45
+
$
6,888
1
Costs
inflated
from
1999
dollars
to
2002
dollars.
2
Annualized
over
10
years
at
7
percent
interest
rate
using
a
capital
recovery
factor
(
CRF)
of
0.14238.
3
Includes
air
permit
expenditures.

Acid
Regeneration
Estimates
of
on­
site
acid
recovery
system
costs
were
taken
from
the
Pilot
of
the
Pollution
Prevention
Technology
Application
Analysis
Template
Utilizing
Acid
Recovery
System
prepared
by
Zero
Discharge
Technologies,
Inc
for
the
USEPA
­
New
England,
dated
October
1999.
A
capital
cost
of
roughly
$
17,500
to
$
31,800
for
recovery
systems
sized
at
20
and
65
gallons
per
day
(
gpd)
were
utilized
for
this
estimate.
A
factor
of
1.5
was
assumed
to
cover
installation
and
startup
costs
for
the
systems.
An
annual
expenditure
of
$
639
for
operation
and
$
1,418
for
repair
and
maintenance
was
estimated
per
system,
respectively.
Each
system
was
assumed
to
operate
with
a
through­
put
of
25
to
160
tons
of
acid
recoverable
waste
per
year.
Larger
systems
are
composed
of
multiple
units
in
20
and
65
gallon
increments.
Smaller
systems
would
be
composed
of
a
20
gallon
unit,
with
reduced
operational
period.

Capital
costs
were
annualized
using
a
10­
year
life
for
the
equipment
at
a
7
percent
real
rate
of
return.
Costs
are
assumed
to
be
the
same
for
recovery
at
off­
site
("
sister")
facilities
owned
by
the
same
company
within
the
same
industry
group.
5­
22
Residuals
generation
from
acid
regeneration
were
estimated
using
1999
BRS
data.
Waste
streams
at
selected
recovery
facilities
were
reviewed
by
comments,
disposal
system
type,
and
origin
to
determine
the
likely
waste
streams
generated
from
the
recovery
operations.
Approximately
26
percent
of
the
acid
regeneration
mass
was
identified
as
residuals
in
the
1999
BRS
data.
The
hazardous
fraction
of
the
residuals
were
determined
by
reviewing
the
waste
codes
for
the
waste
streams
reporting
solvent
reclamation.
Waste
streams
reporting
characteristic
codes
were
assumed
to
have
residuals
that
would
be
characteristically
hazardous
waste.
For
acid
regeneration,
approximately
75
percent
of
the
residual
waste
volume
is
estimated
to
be
characteristically
hazardous
with
the
remaining
25
percent
containing
listed
hazardous
waste
subsequently
becoming
nonhazardous
post
rule.

Commercial
off­
site
acid
recovery
costs
were
estimated
using
Pilot
of
the
Pollution
Prevention
Technology
Application
Analysis
Template
Utilizing
Acid
Recovery
System
prepared
by
Zero
Discharge
Technologies,
Inc
for
the
USEPA
­
New
England,
dated
October
1999.
Commercial
off­
site
acid
recovery
was
estimated
using
the
system
capital
cost
and
operation
and
maintenance
costs
curves
with
an
additional
30
percent
for
commercial
profit.
A
range
of
facility
sizes
for
offsite
recovery
facilities
was
estimated
using
1999
BRS
data.
Acid
recovery
facilities
were
identified
using
the
offsite
EPA
ID
(
receiver)
of
waste
streams
with
the
reported
management
system
of
acid
recovery
(
M031).
The
average
acid
recovery
facility
size
used
is
250
tons
per
year.
A
facility
size
of
250
tons
per
year
is
estimated
to
have
an
unit
acid
recovery
cost
of
$
170
per
ton.
Unit
costs
for
facilities
sized
above
250
tons
per
year
begin
to
reach
asymptotic
limits,
with
a
minimum
unit
cost
for
acid
recovery
of
approximately
$
154
tons
per
year.
Commercial
off­
site
recovery
unit
costs
do
not
include
transportation
and
handling.

Table
5­
9.
Estimated
Acid
Regeneration
On­
site
Recovery
Costs
(
2002$)

Cost
Element
1
Annual
Expenditure
($/
ton)

Capital
Expenditure
(
Annualized)
2
$
79.50*
(
Recovered
Waste
Quantity)
+
$
1,804
Operation
and
Maintenance
$
29.07*
(
Recovered
Waste
Quantity)
+
$
1,320
1
Costs
inflated
from
1999
dollars
to
2002
dollars.
2
Annualized
over
10
years
at
7
percent
interest
rate
using
a
CRF
of
0.14238.

Landfill
Costs
2000
unit
costs
reported
in
Environmental
Cost
Handling
Operations
and
Solutions
(
ECHOS),
Environmental
Remediation
Cost
Data­
Unit
Price,
4th
Annual
Edition,
published
by
R.
S.
Means
and
Delta
Technologies
Group,
Inc.,
2001
were
used
to
estimate
Subtitle
C
and
Subtitle
D
commercial
landfill
disposal
costs.
The
cost
reported
in
ECHOS
was
$
304
per
ton
for
bulk
hazardous
waste
with
stabilization.
These
costs
were
inflated
to
2002
dollars
($
320
per
ton)
for
this
estimate.
Non
hazardous
disposal
was
reported
as
$
111
per
ton
in
bulk
quantities.
The
January
2002
Landfill
Cost
Data
from
the
Hazardous
Waste
Resource
Center
reports
an
average
6
Based
on
a
survey
of
landfill
prices
conducted
between
October
2001
and
January
2002.
7
Telephone
communication
with
Mr.
Earl
Finnder,
U.
S.
Filter,
October
2001.
8
Bagsarian,
Tom
Ed.
"
Cashing
in
on
steelmaking
byproducts",
New
Steel
March
1999,
http://
www.
newsteel.
com/
features/
NS9903f2.
htm
9
MR3
Systems
Inc.,
http://
www.
mr3systems.
com
5­
23
cost
of
$
159
per
ton
for
bulk
hazardous
waste
disposal
with
treatment
at
a
commercial
landfill.
6
Earl
Finnder
of
U.
S.
Filter
estimated
that
electroplaters
pay
approximately
$
260
to
$
300
per
ton
for
Subtitle
C
landfill
disposal.
7
The
ECHOS
unit
cost
was
used
as
an
average
disposal
cost
for
hazardous
waste.
The
ECHOS
disposal
cost
for
Hazardous
and
non
hazardous
wastes
is
presented
as
a
30
city
average
of
major
cities
across
the
United
States.
The
landfill
disposal
costs
assumed
under
baseline
are
presented
below.
ECHOS
also
lists
the
following
minimum
charge
for
bulk
shipments
to
commercial
landfill
with
stabilization
of
$
2,246.
No
minimum
charge
is
assumed
for
the
disposal
of
waste
in
Subtitle
D
landfills
as
there
is
no
regulation
of
non­
hazardous
waste
storage
times;
therefore,
each
non­
hazardous
waste
load
will
be
a
full
18­
ton
load.

Electric
arc
furnace
emission
control
dust
(
EAF)
­
K061
waste
is
disposed
by
at
an
Envirosource
using
a
stabilization
technology
called
Super
Detox
®
.
The
technology
is
further
described
above
under
the
Metal
Recycling
(
Secondary
Smelting)
Costs
heading.
Estimates
for
disposal
of
EAF
range
from
$
100
to
$
1758
to
$
150
to
$
2009
per
ton.
A
mid
point
($
150
per
ton)
was
selected
for
the
disposal
cost
and
inflated
to
2002
dollars
($
153.42
per
ton)
from
1999
dollars
for
this
estimate.

Table
5­
10.
Subtitle
C
and
D
Landfill
Unit
Costs
(
2002$)
Cost
Element
1
($/
ton)
Subtitle
C
Landfill
with
Stabilization
$
320/
ton
$
2,246
minimum
charge
Subtitle
D
Landfill
$
111/
ton
ECD
Disposal
(
Super
Detox
®
)
$
153.42/
ton
1
Costs
inflated
from
1999
dollars
to
2002
dollars.

Acid
Neutralization
Costs
Acid
neutralization
costs
were
developed
from
the
Remedial
Action
Cost
Engineering
and
Requirements
(
RACER)
cost
estimating
software;
costs
in
this
software
are
based
on
the
2001
Environmental
Cost
Handling
Options
and
Solutions
(
ECHOS)
cost
database.
Systems
estimated
ranged
from
10
to
50
gallons
per
minute
(
gpm),
with
a
throughput
of
5,890
to
29,430
tons
per
year.
Capital
costs
ranged
from
$
42,700
to
$
110,500,
with
annual
operation
costs
ranging
from
$
28,700
to
$
83,600
per
year.
No
residual
was
assumed
to
be
generated;
all
wastewater
is
disposed
into
the
wastewater
sewer
to
the
POTW.

Capital
costs
were
annualized
using
a
10­
year
life
for
the
equipment
at
a
7
percent
real
rate
of
return.
10
EPA's
Common
Sense
Initiative
Report
indicates
a
15
tons
per
truck
load
size
and
ECHOS
2001
indicates
a
maximum
truck
load
size
of
18
tons.
RACER
indicates
a
tanker
truck
capacity
of
5,000
gallons.

5­
24
Table
5­
11.
Estimated
On­
site
Acid
Neutralization
Costs
(
2002$)

Annual
Expenditure
($/
ton)

Capital
Expenditure
(
Annualized)
1
$
0.41*(
Waste
Stream
Quantity)
+
$
3,233
Operation
and
Maintenance
$
2.85*(
Waste
Stream
Quantity
+
$
15,600
1
Annualized
over
10
years
at
7
percent
interest
rate
using
a
CRF
of
0.14238.

Unit
costs
for
commercial
off­
site
acid
disposal
unit
cost
were
estimated
using
RACER
cost
estimating
software.
RACER
lists
costs
for
disposing
of
liquid
wastes
ranging
from
$
1.50
to
$
3.50
per
gallon
($
2002).
A
unit
cost
of
$
1.50
per
gallon
was
used
for
commercial
off­
site
disposal.
For
loads
less
than
60
percent
full,
an
added
charge
of
15
percent
of
the
unit
cost
was
added
($
1.50
*
1.15
=
$
1.73
per
gallon)
to
account
for
minimum
charges.

Loading/
Handling
Cost
for
loading/
handling
waste
streams
and
residuals
disposed
off­
site
were
estimated
based
on
costs
reported
in
RACER
2002.
Three
waste/
residual
streams
are
assumed;
solids,
sludges,
and
liquids.
Solids,
such
as
electric
arc
furnace
dust,
can
be
loaded
with
front
end
loaders
into
rolloff
bins.
Sludges,
such
as
solvent
recovery
distillation
bottoms,
are
contained
in
55
gallon
drums
for
handling.
Liquids,
such
as
acid
recovery
residuals,
condensed
acids
with
other
impurities,
are
pumpable
and
stored
in
tanks
and
containers
prior
to
loading
into
a
tanker
truck.
Solid
waste,
sludge
waste,
and
liquid
waste
unit
costs
are
estimated
to
be
$
2.57
per
ton,
$
26.23
per
ton,
and
$
40.94
per
ton,
respectively.

Transportation
Costs
Hazardous
waste
transportation
costs
(
excluding
manifesting
costs
which
are
estimated
separately)
were
estimated
based
on
unit
costs
reported
in
ECHOS
2001
and
RACER
cost
estimating
software
for
van
trailers
and
tanker
trucks
(
Table
5­
12).
Costs
are
based
on
distance
and
maximum
truck
load
size
of
18
tons
for
van
trailers
and
5,000
gallons
for
tanker
trucks.
10
A
minimum
of
four
loads
per
year
is
assumed
based
on
the
maximum
accumulation
period
of
90
days
for
hazardous
waste
landfill
disposal
and
180
days
for
product
recovery
based
on
accumulation
time
regulations.
Otherwise,
the
number
of
loads
per
year
is
calculated
by
dividing
the
total
annual
generation
quantity
by
the
assumed
maximum
truck
load
size
of
18
tons.
The
ECHOS
minimum
shipment
fee
of
$
714
is
used
to
determine
transportation
unit
costs
below
200
miles
for
hazardous
waste.
For
example,
the
transportation
cost
for
shipping
waste
100
miles
is
calculated
by
dividing
the
minimum
shipment
fee
by
100
miles
($
714/
100
miles
=
$
7.14/
mile).
5­
25
Transportation
costs
are
presented
below.
Tables
5­
13A
and
5­
13B
presents
how
shipping
distances
vary
when
shipping
to
Subtitle
C
landfills
(
338
mile
average)
compared
to
product
recovery
facilities
(
521
mile
average).
The
distances
presented
reflect
estimates
for
shipments
of
F006
wastes
from
the
EPA
draft
report,
Evaluation
of
Cost
and
Economic
Impacts
of
F006
Recycling
Rulemaking
Options
from
December
2001
for
landfill
and
metals
recovery
facilities
were
utilized
as
a
proxy
for
the
transportation
distances
within
the
same
Industry
Group
(
4­
digit
NAICS
code)
and
residual
disposal.

Non­
hazardous
waste
transportation
costs
(
excluding
manifesting
costs)
also
were
estimated
based
on
bulk
hazardous
waste
transportation
cost
reported
in
ECHOS
2001.
Costs
are
based
on
distance
and
maximum
load
size
of
18
tons.
Due
to
the
relatively
close
transportation
distances
estimated
for
Subtitle
D
landfills,
a
unit
cost
of
$
2.16
per
mile
($
0.12
per
ton­
mile)
was
used.
The
transportation
cost
is
estimated
to
be
less
than
the
hazardous
transportation
unit
cost
due
to
the
regularly
scheduled,
full
18­
ton,
bulk
non­
hazardous
waste
shipments.
For
non
hazardous
waste
and
post
rule
product
recovery,
no
minimum
number
of
loads
is
assumed.
The
number
of
shipments
per
year
is
calculated
by
dividing
the
total
annual
generation
quantity
by
the
assumed
maximum
truck
load
size
of
18
tons.

Table
5­
12.
Transportation
Unit
Costs
(
2002$)
Cost
Element
Baseline
Van
Trailer
Tanker
Truck
Loading/
Unloading
Hazardous
Waste
Minimum
Charge
Hazardous
Waste
Shipping
200­
299
miles
300­
399
miles
400­
499
miles
500­
599
miles
600­
699
miles
700­
799
miles
800­
899
miles
900­
999
miles
1,000+
miles
Non­
Hazardous
Waste
$
2.50/
ton
$
713/
shipment
$
2.60/
mile
$
2.36/
mile
$
2.15/
mile
$
2.05/
mile
$
2.01/
mile
$
1.94/
mile
$
1.94/
mile
$
1.94/
mile
$
1.90/
mile
$
2.16/
mile
$
40.94/
ton
$
1,032/
shipment
$
3.69/
mile
$
3.19/
mile
$
3.26/
mile
$
3.35/
mile
$
3.15/
mile
$
3.08/
mile
$
3.05/
mile
$
3.02/
mile
$
2.99/
mile
POTW
discharge
Weighted
transportation
costs
are
presented
in
Tables
5­
13A
and
5­
13B.
The
weighted
average
transportation
unit
cost
to
Subtitle
C
landfill
is
$
3.73/
mile
and
the
weighted
average
distance
is
338
miles.
The
weighted
average
transportation
unit
cost
to
a
recovery
facility
is
$
6.20/
mile
and
the
weighted
average
distance
is
521
miles.
The
assumed
average
transportation
unit
cost
to
a
Subtitle
D
landfill
is
$
2.16/
mile
and
an
average
distance
of
50
miles.
The
assumed
average
transportation
unit
cost
to
a
fuel
blending
facility
is
$
2.94/
mile
and
an
average
distance
of
577
miles.
The
assumed
average
transportation
unit
cost
to
an
acid
recovery/
acid
neutralization
is
$
3.50/
mile
and
an
average
distance
of
405
miles.
The
assumed
average
transportation
unit
cost
to
5­
26
a
catalyst
recovery
facility
is
$
3.73/
mile
and
an
average
distance
of
338
miles.
The
assumed
average
transportation
unit
cost
to
an
incinerator
is
$
3.73/
mile
and
an
average
distance
of
1,000
miles.
The
estimates
for
metals
recovery
distances
from
facilities
identified
in
the
EPA,
Evaluation
of
Cost
and
Economic
Impacts
of
F006
Recycling
Rulemaking
Options
from
December
2001
were
used
to
model
product
recovery
and
Subtitle
C
landfill
distances.

Transportation
distances
for
fuel
blending,
and
acid
recovery/
acid
neutralization
were
determined
after
review
of
1999
BRS
data
of
facilities
shipping
the
wastes
and
the
receiving
facilities.
A
distribution
for
shipping
was
generated
using
potential
transportation
ranges
of
250,
350,
450,
550,
650,
750,
850,
950,
and
1050
miles.
For
waste
streams
with
facilities
tending
to
ship
within
the
state,
the
transportation
distribution
was
skewed
to
the
250
and
350
mile
ranges.
For
waste
streams
with
facilities
tending
to
ship
outside
the
state,
the
transportation
distribution
was
skewed
to
distances
between
450
and
650
miles.
A
average
distance
of
1,000
miles
for
incineration
managed
waste
streams
was
estimated
due
to
the
limited
number
of
facilities
available
providing
the
service.
Based
on
a
review
of
the
1999
BRS
data,
no
incineration
managed
waste
streams
were
shipped
within
the
state.

Table
5­
13A.
Weighted
Average
Transportation
Unit
Costs
to
Subtitle
C
Landfills
for
SIC
3471
Generators
(
2002$)

Percentile
(%)
Distance
to
Landfill
or
Stabilization
for
Top
95
Percent
of
Waste
Shipped
(
miles,
n
=
75)
Average
Distance
per
10th
Percentile
(
miles)
Weighted
Distance
to
Subtitle
C
Landfill
(
miles)
Unit
Price
($/
mile)
Weighted
Unit
Price
($/
mile)

0
38
­­­
­­­
­­­
­­­

10
129
83.5
8.35
$
8.55
$
0.855
20
147
138
13.8
$
5.17
$
0.517
30
166
156.5
15.65
$
4.56
$
0.456
40
175
170.5
17.05
$
4.19
$
0.419
50
234
204.5
20.45
$
2.60
$
0.260
60
283
258.5
25.85
$
2.60
$
0.260
70
348
315.5
31.55
$
2.36
$
0.236
80
434
391
39.1
$
2.36
$
0.236
90
636
535
53.5
$
2.05
$
0.205
100
1627
1,131.5
113.15
$
1.90
$
0.190
Table
5­
13A.
Weighted
Average
Transportation
Unit
Costs
to
Subtitle
C
Landfills
for
SIC
3471
Generators
(
2002$)

Percentile
(%)
Distance
to
Landfill
or
Stabilization
for
Top
95
Percent
of
Waste
Shipped
(
miles,
n
=
75)
Average
Distance
per
10th
Percentile
(
miles)
Weighted
Distance
to
Subtitle
C
Landfill
(
miles)
Unit
Price
($/
mile)
Weighted
Unit
Price
($/
mile)

5­
27
Total
338.45
$
3.63
($
3.73)
1
1
Costs
inflated
from
2000
dollars
to
2002
dollars.

Table
5­
13B.
Weighted
Average
Transportation
Unit
Costs
to
Metals
Recovery
(
Secondary
Smelting)
for
SIC
3471
Generators1
(
2002$)

Percentile
(%)
Distance
to
Metals
Recovery
Facilities
for
Top
95
Percent
of
Waste
Shipped
(
miles,
n
=
51)
Average
Distance
per
10th
Percentile
(
miles)
Weighted
Distance
to
Metals
Recovery
(
miles)
Unit
Price
($/
mile)
Weighted
Unit
Price
($/
mile)

0
7
­­­
­­­
­­­
­­­

10
32
19.5
1.95
$
36.62
$
3.662
20
193
112.5
11.25
$
6.35
$
0.635
30
231
212
21.2
$
2.60
$
0.260
40
329
280
28.0
$
2.60
$
0.260
50
372
350.5
35.05
$
2.36
$
0.236
60
481
427
42.7
$
2.15
$
0.215
70
567
524
52.4
$
2.05
$
0.205
80
846
706.5
70.65
$
1.94
$
0.194
90
1,253
1,049.5
104.95
$
1.90
$
0.190
100
1,802
1,527.5
152.75
$
1.90
$
0.190
Total
520.9
$
6.05
($
6.20)
2
1
These
values
were
used
as
a
proxy
for
same
Industry
Group
(
4­
digit
NAICS)
product
recovery
distances
and
transportation
unit
costs.
2
Costs
inflated
from
2000
dollars
to
2002
dollars.
5­
28
Manifesting
Costs
In
general,
under
the
current
hazardous
waste
regulations,
wastes
are
tracked
through
the
use
of
a
hazardous
waste
manifest
which
accompanies
each
waste
shipment.
Manifesting
costs
were
obtained
from
the
Hazardous
Waste
Manifest
Cost
Benefit
Analysis,
prepared
by
Logistics
Management
Institute
in
October
2000.
Costs
were
inflated
to
2002
dollars.
The
manifesting
cost
incurred
by
the
generator
per
manifest
was
determined
to
be
$
89.31
for
small
quantity
generators
and
$
136.91
for
large
quantity
generators.
An
average
cost
of
$
113.11
($
116.05
inflated
to
2002$)
per
manifest
was
assumed
to
be
incurred
by
the
generator.
The
transporter
is
assumed
to
incur
$
117.35
($
120.40
inflated
to
2002$)
in
manifesting
costs
per
shipment.
The
transporter
and
generator
costs
were
combined
to
estimate
a
total
manifesting
cost
per
shipment
of
$
236
(
2002$).

Costs
also
have
been
estimated
for
shipping
papers
under
a
reclamation
agreement.
Costs
to
prepare,
carry,
and
retain
shipping
papers
were
obtained
from
the
Hazardous
Waste
Manifest
Cost
Benefit
Analysis.
The
cost
for
the
generator
to
complete
the
shipping
papers
for
each
load
is
estimated
to
be
$
26.50,
based
on
assumed
effort
of
0.5
hours
by
a
technical
staff
member
at
$
53
per
hour.
The
cost
for
the
generator
to
maintain
a
copy
of
the
reclamation
agreement
is
$
2.70
per
year.
Assuming
an
average
of
4
shipments
per
transporter
per
year,
the
cost
per
shipment
for
the
generator
to
retain
the
reclamation
agreement
is
approximately
$
0.68
per
shipment.
The
cost
for
the
transporter
to
record
and
carry
the
shipping
papers
and
reclamation
agreement
is
estimated
at
$
58.53
per
shipment.
An
additional
$
4.59
was
assumed
to
be
incurred
by
the
transporter
to
retain
the
records
for
each
generator.
Assuming
an
average
of
4
shipments
per
generator
for
each
transporter
a
year,
the
cost
per
shipment
for
the
transporter
to
retain
the
records
for
each
generator
is
approximately
$
1.15.
The
transporter
and
generator
costs
were
combined
to
estimate
a
total
cost
to
prepare,
carry
and
retain
shipping
papers
of
$
86.86
per
shipment
($
89.26
inflated
to
2002$).
All
pre
rule
scenario
shipments
were
assumed
to
require
hazardous
waste
manifests
(
including
same
NAICS
recovery
transportation
shipments).
Post
rule
shipments
are
all
assumed
to
require
non­
hazardous
manifesting,
except
for
the
portion
of
the
residuals
assumed
to
be
characteristically
hazardous
(
95%
of
metals
recovery
residuals,
85%
of
solvent
recovery
residuals,
and
75%
of
acid
regeneration
residuals).

Training
Training
includes
costs
for
manifesting
and
hazardous
materials
handling
training.
These
costs
are
assumed
to
be
incurred
for
all
large
and
small
quantity
generators.
Facilities
classified
as
conditionally
exempt
small
quantity
generators
were
not
assumed
to
have
training
costs
for
manifesting
as
these
facilities
are
not
required
to
manifest
wastes
generated
or
the
resulting
manifest
reporting/
storage
requirements.
Conditionally
exempt
small
quantity
generators
were
excluded
from
hazardous
materials
handling
training
as
described
in
40
CFR
262.16
Subpart
B.
The
hazardous
materials
handling
training
requirements
for
small
and
large
quantity
generators
include
on
the
job
training
for
emergency
response
requirements
and
inspection
of
the
facilities
emergency
response
equipment.
5­
29
Manifest
training
is
estimated
to
cost
$
1,828
per
year
(
2002$).
Training
costs
include
an
estimated
8
hours
per
year
each
for
a
process
technician
and
a
manager.
Each
year,
3
hours
is
devoted
to
review/
refresher
of
the
training,
1
hour
for
administrative
requirements
associated
with
the
training
(
updating
records,
refresher/
new
class
scheduling,
etc.),
and
annual
turn
over
for
the
position
occurring
once
every
two
years
resulting
in
4
hours
per
year
devoted
to
training.
A
manual/
class
training
is
estimated
to
cost
$
125
based
on
current
pricing
for
the
training
services
from
on­
line
providers.

Hazardous
materials
handling
training
is
estimated
to
cost
$
2,191
per
year
for
small
quantity
generators
(
2002$)
and
$
9,974
per
year
for
large
quantity
generators
(
2002$).
Training
costs
for
small
quantity
generators
include
an
estimated
8
hours
per
year
each
for
a
process
technician
and
a
manager.
Training
costs
for
large
quantity
generators
include
an
estimated
8
hours
per
year
each
for
four
process
technicians,
a
manager,
and
a
branch
manager.
Each
year,
3
hours
is
devoted
for
review
or
refresher
training,
1
hour
for
administrative
requirements
associated
with
the
training
(
updating
records,
refresher/
new
class
scheduling,
etc.),
and
annual
turn
over
for
the
position
occurring
once
every
two
years
resulting
in
4
hours
per
year
devoted
to
training.
All
training
is
assumed
to
be
on
the
job
and
provided
by
the
managers.

Contingency
Planning
Costs
This
cost
covers
the
requirements
as
stated
in
40
CFR
264
Subpart
D
relating
to
the
development
of
a
contingency
plan.
The
estimated
basis
was
taken
from
the
Estimating
Costs
for
the
Economic
Benefits
of
RCRA
Noncompliance,
prepared
for
the
Office
of
Regulatory
Enforcement,
USEPA,
dated
September
1994.
The
labor
rates
were
updated
to
2001
using
RACER
costs
estimating
software.
Facilities
generating
more
than
1,000
kilograms
per
month
of
hazardous
waste
(
i.
e.,
Large
Quantity
Generators)
are
required
to
prepare
and
maintain
a
contingency
plan.
The
cost
includes
labor
for
a
drafter
(
3
hours),
process
technician
(
11
hours),
an
engineer
(
16
hours),
and
a
manager
(
3
hours),
for
a
total
expense
of
$
2,800
(
2002$).
This
cost
is
incurred
once.
Costs
incurred
from
updating
the
contingency
plan
is
included
in
the
BRS/
General
Administrative
Duties
Cost.

Table
5­
14.
Estimated
Contingency
Planning
Costs
(
2002$)

Labor
Class:
Labor
Rate
($/
hour)
Estimated
Utilization
(
hrs)
Labor
Cost
1
Drafter
$
78.36
3
$
235.08
Process
Technician
$
61.02
11
$
671.22
Engineer
$
89.61
16
$
1,433.76
Manager
$
151.89
3
$
455.67
Total
33
$
2,795.73
1
Costs
inflated
to
2002$.
11
MR3
Systems
Inc.,
http://
www.
mr3systms.
com/
pages/
corp2.
html
12London
Metals
Exchange,
http://
www.
lme.
co.
uk/
data_
prices/
monthly_
prices.
asp,
dated
July
19th,
2003
13London
Metals
Exchange,
http://
www.
lme.
co.
uk/
data_
prices/
monthly_
prices.
asp,
dated
July
19th,
2003
14
Coplan,
Myron
J,
C.
E.,
"
Comments
on
the
Relative
Cost
of
Fluoride
from
NAF
and
FSA",
http://
www.
dartmouth.
edu/~
rmasters/
AHABS/
costof.
html
15
http://
www.
micronmetals.
com/
molybdenum_
disulfide.
htm
5­
30
Salvage
(
Recovered
Product)
Value
of
Recovery
Products
Salvage
value
of
recovered
products
was
estimated
based
on
cost
savings
(
i.
e.,
reduced
quantity
of
solvent
or
acid
purchase)
or
a
secondary
sale
(
i.
e.,
sale
of
recovered
metals).
A
salvage
value/
revenue
is
estimated
using
the
commercial
market
value
of
the
product
(
solvent,
acid,
granular
activated
carbon,
fluoride,
catalyst,
or
metal).
The
metal
salvage
value
(
unless
otherwise
indicated)
is
based
on
$
5,300/
ton,
which
is
the
three
year
average
price
for
chromium,
nickel
and
copper­­
the
three
most
recycled
metals.
This
assumes
that
of
the
metal
going
to
recycling,
it
is
split
evenly
among
the
three
metals.
The
salvage
value
for
EAF
metals
is
based
on
zinc
recovery.
11
The
market
value
for
zinc
was
estimated
using
the
London
Metals
Exchange
price
of
$
714.8/
ton.
12
The
salvage
value
for
metal­
containing
liquids
is
based
on
copper
recovery.
The
printed
circuit
board
industry
(
SIC
3672)
is
the
primary
generator
of
metals
containing
liquid
wastes.
The
printed
circuit
board
industry
uses
copper
in
the
etching
and
plating
process;
therefore,
copper
is
assumed
to
be
the
primary
metal
recovered
from
the
metals
containing
liquid
wastes.
The
market
value
for
copper
was
estimated
using
the
London
Metals
Exchange
price
of
$
1,552.60/
ton.
13
The
salvage
value
for
solvent
was
estimated
using
the
average
price
as
reported
in
the
USACE
Tech
Bulletin
of
mineral
spirits
at
$
2.25/
gallon
and
1,1,1­
trichloroethane
at
$
11.33/
gallon.
The
salvage
value
for
acid
and
granular
activated
carbon
(
GAC)
was
estimated
with
RACER
cost
estimating
software.
For
acids,
sulfuric
acid
was
used
as
a
proxy.
Sulfuric
acid
is
estimated
to
cost
$
331/
ton
(
2002$).
GAC
is
estimated
to
cost
$
3,845
per
ton.
The
salvage
value
of
fluoride,
using
sodium
fluoride
as
a
proxy,
was
estimated
from
an
online
document
at
Dartmouth
University
Comments
on
the
Relative
Cost
of
Fluoride
from
NAF
and
FSA.
Sodium
fluoride
is
estimated
to
cost
$
1,240
per
ton14
(
2002$).
The
salvage
value
of
catalysts
was
estimated
from
an
online
quote15.
Molybdenum
disulfide
was
used
as
a
proxy
for
catalysts
reported
recovered
in
the
1999
BRS.
Molybdenum
disulfide
was
identified
as
a
catalyst
in
the
comments
of
disposed
quantities
of
spent
catalyst
from
the
petroleum
refining
industry
(
SIC
2911)
with
waste
codes
of
K171
or
K172.
Molybdenum
disulfide
is
estimated
to
cost
$
26,600
per
ton
(
2002$).

The
recovered
products
were
assumed
to
be
less
than
"
pure".
Through
the
recovery
process,
a
loss
of
effectiveness
for
the
solvents
and
acids
is
expected.
For
metals
recovery,
the
quality
loss
is
represented
by
a
reduction
in
purity
of
the
metal.
A
factor
of
90
percent
is
applied
to
the
above
listed
commercial
cost
associated
with
the
product
to
represent
this
loss.

The
mass
recovered
varies
depending
on
the
type
of
recovery
waste
streams.
Using
select
1999
BRS
facility
data,
the
residual
mass
fractions
of
solvents
and
acids
recovered
from
solvent
and
acid
waste
streams
was
estimated.
Assuming
there
are
minimal
lost
products
by
spillage
or
16Bagsarian,
Tom
Ed.
"
Cashing
in
on
steelmaking
byproducts",
New
Steel
March
1999,
http://
www.
newsteel.
com/
features/
NS9903f2.
htm
5­
31
evaporation,
the
mass
of
the
original
waste
stream
(
recovery
waste
stream)
minus
the
reported
residuals
waste
stream
(
i.
e.,
still
bottoms,
sludge,
and
wastewater)
is
the
mass
of
the
recovered
product.
The
residual
mass
fraction
is
described
in
the
respective
recovery
technology
section.
Based
on
the
estimated
residual
waste
mass
fraction,
the
product
mass
fraction
is
estimated
at
67
percent
and
74
percent
for
solvent
and
acid
product
recovery,
respectively
(
see
Appendix
W).
The
product
mass
fraction
is
highly
dependant
on
the
facility
process
and
recovery
technology
and
may
vary
greatly
from
this
estimate.
The
mass
fraction
recovered
from
spent
catalyst
(
waste
codes
K171
and
K172),
spent
granular
activated
carbon,
fluoride
from
spent
aluminum
potliner
(
waste
code
K088),
and
metals
from
liquids
containing
metals
were
estimated
using
engineering
judgement
as
to
the
concentration
of
the
recoverable
product
from
the
waste
stream,
likelihood
of
destruction
during
the
recovery
process
and
potential
of
the
recovered
product
to
retain
useable
characteristics.
The
product
mass
fractions
estimated
for
spent
catalyst
(
waste
codes
K171
and
K172),
spent
granular
activated
carbon,
fluoride
from
spent
aluminum
potliner
(
waste
code
K088),
electric
arc
furnace
control
dust
(
ECD)
(
waste
code
K061),
and
metals
from
liquids
containing
metals
are
5
percent
(
i.
e.,
5
percent
of
catalyst
is
reusable),
90
percent
(
i.
e.,
90
percent
of
carbon
is
reusable),
2
percent
recovered
fluoride
values,
15
percent
recovered
zinc,
and
0.02
percent
recovered
copper.

The
mass
fraction
of
metals
recovered
during
smelting/
high
temperature
metals
recovery
was
estimated
using
F006
180­
Day
Accumulation
Rule
assumptions
regarding
the
quality
of
the
sludge
produced
from
SIC
3471
facilities
with
the
exception
of
EAF.
A
mass
conservation
approach
was
not
utilized
for
smelting/
high
temperature
recovery
due
to
the
assumed
volatilization
of
the
water
in
the
sludge
wastes.
The
metals
mass
fraction
is
estimated
at
20
percent
for
wastes
currently
being
recovered.
The
metals
mass
fraction
is
estimated
to
be
five
percent
for
wastes
currently
being
disposed
assuming
they
have
lower
metals
content.
A
five
percent
metals
concentration
is
the
approximate
break­
even
point
between
the
cost
of
landfill
verses
metals
recovery.
Zinc
concentration
in
EAF
ranges
from
15
to
30
percent16.
The
zinc
concentration
is
dependant
on
the
grade
of
iron
ore
processed
and
coal
used
in
the
smelting
process.
The
other
major
constituents
of
EAF
include
lead
and
iron.
Additional
revenue
may
be
generated
from
the
recovery
of
iron
in
the
HTMR
process.
The
potential
revenue
from
reclaiming
the
iron
in
EAF
was
not
estimated
for
this
estimate,
given
the
majority
of
the
recovery
technologies
for
EAF
are
used
to
accumulate
zinc
oxide.

BRS/
General
Administrative
Duties
Cost
Biennial
reporting
as
well
as
other
generator
recordkeeping
and
reporting
is
required
for
all
LQGs.
Similar,
but
less
stringent,
administrative
requirements
apply
on
an
annual
basis
for
SQGs.
In
addition
to
reporting
requirements
for
hazardous
waste
generating
facilities,
review
of
contingency
plans
and
other
miscellaneous
actions
are
also
necessary.
These
costs
are
assumed
to
be
direct
labor
costs
for
one
manager
with
a
labor
rate
of
$
152
per
hour.
For
a
CESQG
facility
5­
32
BRS/
general
administrative
duties
labor
is
estimated
at
4
hours
at
a
cost
of
$
608
per
year,
a
SQG
facility
is
estimated
at
8
hours
at
a
cost
of
$
1,216
per
year,
and
a
LQG
is
estimated
at
16
hours
at
a
cost
of
$
2,430
per
year
(
2002$).

Initial
Characterization/
Waste
Characterization
Cost
The
estimated
cost
was
taken
from
the
Estimating
Costs
for
the
Economic
Benefits
of
RCRA
Noncompliance,
prepared
for
the
Office
of
Regulatory
Enforcement,
USEPA,
dated
September
1994.
The
labor
rates
and
analytical
costs
were
updated
to
2001
using
RACER
cost
estimating
software.
The
collection
of
cost
includes
labor
for
a
field
technician
(
10.5
hours),
an
engineer
(
11
hours),
and
a
manager
(
2
hours).
Three
samples
are
collected
per
waste
stream,
estimated
at
$
1,410
per
sample,
for
a
total
expense
including
labor
of
$
6,160
per
waste
stream
(
2002$).
This
cost
is
incurred
once.

One­
Time
Notification
of
Exclusion
Costs
were
estimated
for
generators
to
complete
a
notification
of
RCRA
exclusion
for
their
recovered
waste(
s).
Labor
rates
were
obtained
from
the
RACER
cost
estimating
software.
The
one
time
notification
is
assumed
to
be
composed
of
6
hours
of
a
staff
engineer
and
2
hours
clerical
and
cost
$
638.78,
including
mark
ups
(
2002$).

Part
B
Permit
Renewal
Costs
Savings
to
within­
industry
off­
site
reclaimers
are
expected
to
result
from
no
longer
needing
to
renew
their
RCRA
permits.
The
maximum
duration
that
a
RCRA
permit
is
valid
is
10
years;
therefore,
a
TSD
facility
is
required
to
renew
the
Part
B
portion
of
the
permit
application
a
minimum
of
once
every
10
years.
The
Part
B
application
is
composed
of
the
a
general
facility
section
and
the
technology
specific
section
for
storage
and/
or
disposal
of
the
hazardous
waste.
Facilities
reclaiming
metals,
solvents,
or
acids
on
site
may
not
require
a
TSD
permit
under
the
proposed
rule
making,
as
these
wastes
would
not
be
considered
solid
wastes.
Therefore,
the
facility
would
not
be
a
RCRA
TSD.
The
facilities
effected
by
the
proposed
rule
making
would
not
need
to
resubmit
the
Part
B
application
to
renew
the
TSD
permit.

Estimated
costs
for
preparing
and
renewing
the
Part
B
application
were
presented
in
the
Estimating
Costs
for
the
Economic
Benefits
of
RCRA
Noncompliance,
prepared
for
the
Office
of
Regulatory
Enforcement,
USEPA,
dated
September
1994.
The
general
facility
portion
of
the
Part
B
application
estimated
cost
was
$
43,693
($
49,249
inflated
to
2002
dollars).
The
technology
specific
requirements
estimated
costs
were
$
9,371
($
10,562
inflated
to
2002
dollars)
for
container
systems
and
$
8,780
($
9,896
inflated
to
2002
dollars)
for
tank
systems.

It
is
assumed
the
majority
of
the
Part
B
application
information
has
already
been
accumulated
in
the
initial
preparation.
The
update
of
the
Part
B
application
is
estimated
to
cost
25
to
50
percent
the
original
preparation
cost.
All
TSD
facilities
would
be
required
to
submit
the
general
facility
5­
33
portion
of
the
Part
B
application.
In
general,
it
is
assumed
that
TSD
facilities
reclaiming
metals
would
require
the
container
systems
technical
requirements
of
the
Part
B
application
and
the
solvent
and
acid
reclamation
facilities
would
require
the
tank
system
technical
requirements
of
the
Part
B
application.
The
estimated
savings
through
not
renewing
the
TSD
permit
ranges
from
$
14,953
to
$
29,906
every
10
years
for
metal
reclaiming
facilities.
For
facilities
reclaiming
solvents
or
acids,
the
estimated
savings
ranges
from
$
14,786
to
$
29,573
every
10
years.

Spent
Aluminum
Potliner
(
K088)
Cost
Estimates
Baseline
waste
management
unit
costs
are
presented
in
Table
5­
15.
Following
the
promulgation
of
the
current
K088
land
disposal
treatment
standards
in
October
of
1997
management
shifted
to
three
facilities.
Two
off
site
facilities
include
the
Reynolds'
thermal
treatment
plant
in
Gum
Springs,
Arkansas,
and
Chem
Waste
Management's
on­
site
storage
facility
in
Gilliam
County,
Oregon
(
near
the
City
of
Arlington).
One
facility,
Ormet
Primary
Aluminum
Corporation,
Hannibal,
Ohio,
has
installed
the
Vortec
vitrification
technology
which
has
been
proven
to
treat
to
the
new
land
disposal
restriction
standard
the
EPA
is
considering.
All
text
and
unit
cost
estimates
contained
in
this
section
were
taken
or
edited
from
the
following
report:
U.
S.
EPA,
Economic
Assessment
of
the
Revised
LDR
Treatment
Standards
for
Spent
Aluminum
Potliner
(
K088),
prepared
by
DPRA
Incorporated,
March
1,
2000.
In
the
analysis
all
unit
costs
were
inflated
from
1999
dollars
to
2002
dollars.

The
Vortec
process
is
a
direct­
fired
vitrification
system
that
destroys
cyanide
and
other
organic
compounds
contained
in
K088
waste,
while
recovering
the
fluoride
values
for
use.
K088
waste
is
mixed
with
sand
and
limestone
and
vitrified
to
form
a
glass­
like
residue
or
frit.
The
treatment
process
does
not
immobilize
the
fluoride
in
the
glass
matrix,
but,
it
effectively
partitions
the
fluoride
into
the
baghouse
dust
for
reuse.

The
process
unit
performing
this
vitrification
process
is
referred
to
as
a
combustion
melting
system
(
CMS)
and
consists
of
a
Counter
Rotating
Vortec
(
CRV)
Reactor,
a
cyclone
melter
and
a
separator/
reservoir.
The
finely
crushed
K088
waste,
sand
and
limestone
mixture
are
preheated
in
a
rapid
suspension
heating
system
before
physical
and
chemical
melting,
which
occurs
within
the
cyclone
reactor.
The
reactor
is
a
refractory­
lined,
carbon
steel,
water­
cooled
vessel.
Natural
gas
and
preheated
air
are
used
to
achieve
temperatures
of
approximately
2,400
F
in
the
reactor.
Materials
begin
to
melt
in
the
reactor
and
flow
downward
to
the
cyclone
melter.
Melting
of
the
waste
and
other
additives,
as
well
as
combustion
of
the
cyanide
and
other
organic
compounds,
is
completed
in
this
vessel
and
the
resultant
molten
glass
is
separated
from
the
gas.
The
separated
gas
is
used
to
preheat
the
air
entering
the
reactor,
and
is
then
sent
to
a
primary
baghouse
to
remove
particulate
matter,
primarily
sodium
fluoride.
The
exhaust
from
the
baghouse
is
then
transferred
into
the
potroom
"
secondary"
dry
scrubber
system
(
a
baghouse
air
pollution
device
using
alumina
to
dry
scrub
fluoride
from
aluminum
reduction
pot
exhaust
gas)
where
gaseous
fluoride
is
removed
and
additional
particulate
removal
occurs.
The
material
from
the
primary
and
secondary
baghouse
systems
are
fluoride­
enriched
alumina
material
is
collected
for
reuse
(
e.
g.,
charged
back
into
aluminum
pots
if
feasible
or
sold
as
a
substitute
for
fluorospar).
The
molten
17
Personal
communication
between
Elaine
Eby,
U.
S.
EPA,
and
John
Reggi,
Ormet,
December
6,
1999.

5­
34
glass
is
dropped
into
a
water
quench
tank
where
it
solidifies
into
a
glass­
like
residue
or
frit
which
is
sold
as
a
product
(
e.
g.,
industrial­
grade
glass).
This
process
is
referred
to
as
K088
vitrification.

Currently,
only
the
Ormet
facility
in
Ohio
operates
a
50
ton­
per­
day
Vortec
system.
The
baghouse
dust
containing
fluoride
is
sold
to
the
steel
industry
as
a
substitute
for
fluorospar.
The
frit,
a
granular
glass­
like
material,
that
they
generate
is
presently
sold
as
a
grinding
and
polishing
material
to
a
machinery
shop.
17
Ormet
generates
approximately
6,500
short
tons
of
frit
annually.

TABLE
5­
15.
K088
BASELINE
MANAGEMENT
AND
ANALYTICAL
UNIT
COSTS
Baseline
Management
Method
Baseline
Unit
Cost
(
1999
$/
ton)

Off­
Site
Thermal
Treatment
(
Reynolds,
Gum
Springs,
Arkansas)
$
200
­
$
500
1
Off­
Site
Storage
(
Chem
Waste
Management,
Gilliam
County,
Oregon)
$
245
2
treatment
=
$
80
disposal
=
$
80
storage
=
$
85
1
Federal
Register,
Volume
63,
Number
185,
September
24,
1998,
pp.
51260;
1994
price
quote.
Price
quote
still
valid
based
on
communication
between
Linda
Barr,
U.
S.
EPA,
Office
of
Solid
Waste
and
Reynolds
in
1999.
2
Federal
Register,
Volume
63,
Number
185,
September
24,
1998,
pp.
51260;
1998
price
quote.

Table
5­
16
presents
the
estimated
compliance
management
unit
costs.
Crusher
and
hammer
mill
unit
costs
were
developed
by
scaling
vendor
cost
estimates
received
from
Nordberg,
Inc.
assuming
a
7
percent
interest
rate
on
borrowed
capital,
a
7
percent
discount
rate
(
consistent
with
OMB
Circular
No.
A­
94,
October,
1992),
10­
year
equipment
life,
20­
year
plant
life,
and
a
30
percent
profit
margin.
The
Vortec
technology
is
the
only
proven
technology
that
can
meet
possible
the
new
Land
Disposal
Treatment
standards
the
Agency
has
been
considering.
So,
it
is
assumed
that
facilities
will
install
this
technology.

One
36
ton
per
day
plant
using
the
Vortec
technology
has
been
constructed
in
Paducah,
Kentucky,
in
1996
for
the
DOE
at
a
cost
$
11.6
million.
Assuming
operating
costs
of
between
$
150
­
$
300/
ton
similar
to
the
NHW
vitrification
system,
a
7
percent
interest
rate
on
borrowed
capital,
a
7
percent
discount
rate,
20­
year
equipment
life,
20­
year
plant
life,
3
percent
annual
inflation,
30
percent
profit
margin,
an
initial
licensing
fee
of
$
200,000
and
an
annual
licensing
fee
equivalent
to
10%
of
annual
cost
savings
(
assumed
to
be
annual
quantity
of
waste
times
$
300/
ton
to
treat
waste)
over
a
10­
year
period,
the
unit
commercial
(
off­
site)
price
would
range
between
$
483/
ton
and
$
693/
ton
(
excluding
permitting)
for
a
36
ton
per
day
Vortec
system,
including
a
jaw
crusher,
impact
mill
and
hammer
mill.
5­
35
For
comparison
purposes,
it
is
assumed
that
vitrification
and
incineration
vendors
have
similar
cost
structures
to
the
Vortec
technology
if
costs
for
additional
crushers
and
mills
are
added
to
account
for
the
cost
of
reducing
the
K088
blocks
of
waste
(
e.
g.,
potentially
up
to
3
feet
in
length)
to
sizes
that
can
be
fed
into
the
Vortec
technology.
Therefore,
published
commercial
prices
for
vitrification
($
300/
ton)
and
incineration
($
650/
ton)
were
used
as
potential
price
ceilings
for
the
Vortec
technology
in
the
market
when
new
capacity
is
constructed.
Estimates
of
commercial
crushing
($
18/
ton
to
$
26/
ton
depending
on
equipment
size)
and
milling
($
30/
ton
to
$
43/
ton
depending
on
equipment
size)
prices
are
added
to
the
vitrification
and
incineration
prices
to
determine
the
total
compliance
management
unit
cost.
Assuming
two
crushing
units,
one
hammer
mill,
and
a
vitrification
unit,
commercial
prices
range
from
$
366/
ton
to
$
395/
ton,
excluding
transportation.
Similarly,
assuming
two
crushing
units,
one
hammer
mill,
and
an
incineration
unit,
commercial
prices
range
from
$
716/
ton
to
$
745/
ton,
excluding
transportation.

TABLE
5­
16.
K088
COMPLIANCE
MANAGEMENT
UNIT
COSTS
Compliance
Management
Method
Compliance
Unit
Cost
(
1999
$/
ton)

Crushers
(
assume
one
of
each
unit)(
estimated
commercial
price):
1
­
30"
x
42"
jaw
crusher
(
150
hp
motor)
1
1
­
78"
x
40"
impact
mill
(
150
hp
motor)
1
Same
unit
price
per
unit:
5
5,000
tpy
=
$
26/
ton/
unit
10,000
tpy
=
$
24/
ton/
unit
30,000
tpy
=
$
21/
ton/
unit
55,000
tpy
=
$
19/
ton/
unit
85,000
tpy
=
$
18/
ton/
unit
Hammer
Mill
(
10,000
tons/
year;
+
200
mesh
to
1"
initial
size)
Price
per
unit:
5
5,000
tpy
=
$
43/
ton
10,000
tpy
=
$
39/
ton
30,000
tpy
=
$
34/
ton
55,000
tpy
=
$
31/
ton
85,000
tpy
=
$
30/
ton
Off­
site
Vitrification
(
ground
solid)

ECHOS
(
in
situ
soil
vitrification)
7
NHW
Vitrification
System
(
3,000
tons/
year)
2
Capital
Costs
($
1,000,000)
Operating
Costs
($
150/
ton
­
$
300/
ton)
GeoMelt
Vitrification
4
assume
$
300/
ton
$
300/
ton
$
240
­
$
430/
ton
3
$
370
­
$
420/
ton
Off­
site
Incineration
(
ground
solid)
$
650/
ton
6
to
$
1,300/
ton
7
On­
site
Vortec
Technology
(
estimated
cost
for
noncommercial
crusher,
impact
mill
and
hammer
mill
added
into
unit
cost):
Capital:
$
11,600,000
for
36
ton
of
soil/
day
facility
($
1996)
8
License
Agreement:
$
5
to
$
10
million/
municipal
ash
facility,
size
unspecified
9
Price
per
unit
(
example
sizes):
10
1,000
tpy
=
$
499/
ton
3,000
tpy
=
$
409/
ton
5,000
tpy
=
$
414/
ton
7,000
tpy
=
$
437/
ton
10,000
tpy
=
$
485/
ton
TABLE
5­
16.
K088
COMPLIANCE
MANAGEMENT
UNIT
COSTS
Compliance
Management
Method
Compliance
Unit
Cost
(
1999
$/
ton)

5­
36
Incinerator
RCRA/
MACT
Permit
(
assumed
similar
to
the
cost
of
permitting
the
Vortec
process):
Initial
Permit
Renewal
of
Permit
(
every
10
years)
$
350,000/
facility
11
$
130,000/
facility/
10­
years
11
1
Reynolds
Metals
Company
Spent
Potliner
Treatment
Plant,
http://
www.
rmc.
com/
gbu/
metals/
gum_
spr.
html.
2
NHW
Home
Page,
http://
www.
qn.
net/~
nhw/
nhwtoc.
html.
3
Annualized
capital
cost
were
estimated
using
a
capital
recovery
factor
based
on
a
7
percent
real
interest
rate
on
borrowed
capital,
a
7
percent
real
discount
rate,
a
20­
year
operating
life,
and
assuming
a
30
percent
profit
margin.
4
GeoMelt
Comparison
with
Alternative
Technology
Types,
http://
www.
geomelt.
com/
geomeltnf_
comparison_
with_
alternat.
htm.
5
EPA
derived
cost
based
on
scaling
of
vendor
quotes
from
Nordberg.
Inc..
Assumed
a
plant
life
of
20
years
(
equipment
life
of
10
years)
and
a
30
percent
profit
margin
for
commercial
operation.
6
Per
communication
with
author
of
Environmental
Cost
Handling
Options
and
Solutions
(
ECHOS),
Environmental
Remediation
Cost
Data­
Unit
Price,
5th
Annual
Edition,
published
by
R.
S.
Means,
1999,
average
unit
cost
of
$
1,300/
ton
is
skewed
given
conservative
unit
price
quotes
received
from
commercial
incinerators.
$
650/
ton
is
more
reasonable
unit
price
estimate
if
outliers
removed
from
average.
7
Environmental
Cost
Handling
Options
and
Solutions
(
ECHOS),
Environmental
Remediation
Cost
Data­
Unit
Price,
5th
Annual
Edition,
published
by
R.
S.
Means,
1999.
8
Vortec,
http://
www.
vortec­
cms.
com/
paducah.
htm
9
"
Montgomery
County
Green
Technology
News
Clips",
Louis
S.
Hansen,
Philadelphia
Inquirer,
July
22,
1996;
http://
www.
ehb.
state.
pa.
us/
dep/
counties/
Montgomery/
Green_
Technology_
News.
htm.
Vortec
licensed
its
technology
to
Japan's
Mitsubishi
Kasei
Engineering
Co.
for
treatment
of
municipal
incinerator
ash
with
the
agreement
bringing
Vortec
between
$
5
and
$
10
million
for
each
plant
built.
10
One
36
tons
of
soil
per
day
plant
has
been
constructed
in
Paducah,
Kentucky,
in
1996
for
the
DOE
at
a
cost
$
11.6
million.
EPA
scaled
capital
costs
using
a
scaling
factor
of
0.6.
EPA
assumed
operating
costs
at
the
high
end
of
the
$
150
­
$
300/
ton
range
estimated
for
the
NHW
vitrification
system.
EPA
scaled
operating
costs
using
a
scaling
factor
of
0.9.
EPA
assumed
a
7
percent
real
interest
rate
on
borrowed
capital,
a
7
percent
discount
rate,
20­
year
equipment
life,
20­
year
plant
life,
and
3
percent
annual
inflation.
EPA
assumed
an
initial
licensing
fee
of
$
200,000
and
an
annual
licensing
fee
equivalent
to
10%
of
annual
cost
savings
(
assumed
to
be
annual
quantity
of
waste
times
$
300/
ton
to
treat
waste)
over
a
10­
year
period.
Estimate
includes
40
percent
excess
capacity
for
Vortec
Combustion
Melting
System.
Cost
estimates
for
a
crusher,
impact
mill,
and
hammer
mill
are
included.
11
EPA,
Office
of
Solid
Waste,
Cost
and
Economic
Impact
Analysis
of
Listing
Hazardous
Wastes
from
the
Petroleum
Refining
Industry,
prepared
by
DPRA
Incorporated,
September
21,
1995.
The
1992
cost
estimates
were
inflated
to
1999
dollars
assuming
a
4
percent
annual
rate
of
inflation.
5­
37
Commercial
Incineration
Incineration
unit
costs
were
estimated
using
RACER
cost
estimating
software.
RACER
reports
incineration
costs
of
$
827.38
per
cubic
yard
of
bulk
material.
A
unit
weight
of
1.5
tons
per
cubic
yards
was
assumed,
resulting
in
an
unit
cost
of
$
552
per
ton.
The
incineration
unit
cost
includes
management
and
disposal
of
residuals.
For
loads
less
than
60
percent
full,
an
added
charge
of
15
percent
of
the
unit
cost
was
added
($
827.38
*
1.15
=
$
951.49
per
cubic
yard)
to
account
for
minimum
charges.

Energy
Recovery
(
Fuel
Blending)

Energy
recovery
costs
were
reviewed
from
several
sources.
The
U.
S.
Environmental
Protection
Agency
Office
of
Solid
Waste,
Economics,
Methods
and
Risk
Analysis
Division
Unit
Cost
Compendium
(
UCC)
reported
offsite
utility
co­
burning
costs
of
$
149/
ton
($
142
escalated
to
2002$)
and
offsite
cement
kiln
costs
of
$
497/
ton
($
473
escalated
to
2002$).
Solvent
disposal
costs
(
assumed
to
be
a
energy
recovery
process)
from
the
USACE
Tech
Bulletin
reported
a
cost
of
$
173/
ton
($
160
escalated
to
2002$).
An
offsite
energy
recovery
cost
of
$
292/
ton
was
estimated
as
a
reasonable
approximation
of
the
differing
types
of
energy
recovery
facilities.
The
unit
cost
is
a
processing
fee
("
tipping")
and
does
not
include
transportation,
handling,
or
any
other
costs.

Chemical
Precipitation
Chemical
precipitation
costs
were
estimated
using
the
UCC.
Systems
estimated
ranged
from
5
to
100
gallons
per
minute
(
gpm),
with
a
throughput
of
2,445
to
58,960
tons
per
year.
Pickle
liquor
was
used
as
a
proxy
for
waste
characteristics
in
estimating
costs
for
the
system.
The
estimated
costs
do
no
include
residual
management.
Capital
costs
were
annualized
using
a
10­
year
life
for
the
equipment
at
a
7
percent
real
rate
of
return.

Table
5­
17.
Estimated
On­
site
Chemical
Precipitation
Costs
(
2002$)

Annual
Expenditure
($/
ton)

Capital
Expenditure
(
Annualized)
1
$
32.37*(
Waste
Stream
Quantity)
+
$
33,553
Operation
and
Maintenance
$
204.83*(
Waste
Stream
Quantity)
+
$
21,766
1
Annualized
over
10
years
at
7
percent
interest
rate
using
a
CRF
of
0.14238.

Carbon
Regeneration
Off­
site
carbon
regeneration
("
roasting")
costs
were
estimated
using
RACER
cost
estimating
software.
RACER
reports
a
unit
cost
of
$
0.85
per
pound
for
masses
less
than
2,000
pounds,
and
$
0.39
per
pound
for
masses
greater
than
2,000
pounds.
5­
38
On­
site
carbon
regeneration
costs
were
estimated
using
off­
site
unit
costs.
Profit,
estimated
at
15
percent,
was
subtracted
from
the
unit
cost.
A
scale
factor
of
0.83
is
used
to
represent
economies
of
scale.
A
range
of
facility
sizes
for
off­
site
carbon
regeneration
facilities
was
estimated
using
1999
BRS
data.
Carbon
regeneration
facilities
were
identified
using
the
offsite
EPA
ID
(
receiver)
of
waste
streams
with
the
reported
management
system
of
"
other
recovery"
(
M125).
The
average
carbon
regeneration
facility
size
is
100
tons
per
year,
with
the
largest
receiver
facility
accepting
493
tons
in
1999.
A
facility
size
of
100
tons
per
year
is
estimated
to
have
an
carbon
regeneration
cost
of
$
655
per
ton.

5.7
Summary
of
Breakeven
Analysis
A
comparison
of
base
line
management
practices
with
the
on­
site
compliance
management
option
for
offsite
disposal
facilities
and
off­
site
recovery
facilities
with
different
NAICS
is
presented
in
Table
5­
18.
The
breakeven
analysis
reflects
the
effect
of
the
salvage
value
of
the
recovered
products.
In
general,
products
with
high
salvage
value
reduced
the
facility
size
required
for
a
cost
savings
from
constructing
an
on­
site
recovery
process.

The
breakeven
analysis
considered
all
elements
of
the
waste
disposal
or
recovery
process,
including
residual/
waste
stream
disposal,
recovery
costs,
waste
characterization,
manifesting,
loading,
transportation,
salvage
revenue,
training,
BRS
and
general
administrative
duties,
contingency
planning,
and
generation
taxes.
However,
the
generator
size
was
assumed
to
remain
constant.
Additional
cost
benefit
will
be
generated
with
the
reduction
in
generator
status
in
the
post
rule
environment
(
i.
e.,
generator
status
drop
from
LQG
to
SQG
or
CESQG).
These
cost
savings
will
include
reductions
in
hazardous
materials
training,
BRS
and
general
administrative
duties,
contingency
planning,
and
generation
taxes.

Recovery
of
spent
carbon
is
shown
to
be
profitable
at
all
size
facilities
in
the
proposed
rule
making,
as
are
many
catalyst
recovery
facilities.
However,
profitability
of
spent
carbon
recovery
processes
may
be
the
result
of
economic
pressures
such
as
an
abundance
of
spent
carbon
recovery
facilities
or
manufacturing
of
activated
carbon
is
more
expensive
than
recovering
spent
activated
carbon.
5­
39
Table
5­
18.
Breakeven
Point
(
tons/
year)
Where
On­
Site
Recovery
is
More
Economical
than
Offsite
or
On­
site
Disposal
(
2002$)

Waste
Type
Baseline
Management
Compliance
Management
Breakeven
(
tons/
year)

Off­
site
Disposal
Wastes
Organic
Liquids
(
from
Industrial
Organic
Chemicals,
Paints
and
Allied
Products,
Pharmaceutical
Preparations,
and
Plastics
Materials
and
Resins
Industries)
Off­
site
Fuel
Blending
On­
site
Fractionation/
Distillation
47
Emission
Control
Dust
(
from
Steel
Works
Industry)
Stabilization
and
Subtitle
D
Landfill
On­
site
Smelting
47,067
Metal­
Containing
Liquids
(
from
Printed
Circuit
Board
Industry)
Off­
site
Chemical
Precipitation
On­
site
Ion
Exchange
125
(
79
for
onsite

Electroplating
Wastewater
Treatment
Sludges
(
from
Printed
Circuit
Board
Industry)
Stabilization
and
Landfill
On­
site
Smelting
3,443
Spent
Carbon
(
from
Industrial
Organic
Chemicals
and
Petroleum
Refining
Industries)
Off­
site
Incineration
or
Carbon
Regeneration1
On­
site
Carbon
Regeneration:
"
Roasting"
0
Spent
Catalyst
(
from
Petroleum
Refining
Industry)
Stabilization
and
Landfill
On­
site
Smelting
11
Spent
Aluminum
Potliner
(
from
Aluminum
Industry)
Off­
site
Incineration
On­
site
Fluoride
Recovery
using
Vortec
technology
347
Spent
Pickle
Liquor
(
from
Steel
Works
Industry)
Off­
site
Chemical
Precipitation
On­
site
Acid
Regeneration
4,311
(
0
for
on
site)

Offsite
Recovery
at
NON­
same
NAICS
Facilities
Metal
Recovery
Wastes
Off­
site
Smelting
On­
site
Smelting
21,587
Solvent
Recovery
Wastes
Off­
site
Solvent
Recovery
On­
site
Fractionation/
Distillation
125
Acid
Recovery
Wastes
Off­
site
Acid
Regeneration
On­
site
Acid
Regeneration
36
1
Costs
inflated
to
2002$.
5­
40
5.8
Summary
of
Potential
Cost
Savings
Based
on
the
above
unit
costs
estimates
of
total
costs
and
recovered
values
were
estimated
for
the
baseline
scenario
(
pre­
rule)
and
post­
regulatory
scenario
(
post­
rule).
Incremental
cost
savings
(
post­
rule
costs
minus
pre­
rule
costs)
were
estimated
for
the
total
number
of
plants
currently
recovering
wastes
in
1999
or
recovered
wastes
in
1997.
The
total
number
of
large
quantity
generators
(
plants)
currently
identified
that
may
receive
benefits
from
this
rule
are
1,374.
These
plants
reclaim
metal,
solvent
and
other
values
from
910,000
tons
of
waste.
The
sum
of
the
prerule
costs,
post­
rule
costs,
and
incremental
cost
savings
for
all
plants
that
either
recovered
wastes
on­
site
or
off
site
within
the
same
industry
group
(
4­
digit
NAICS
code)
in
1999
and
1997
are
presented
in
Table
5­
19
by
individual
unit
cost
item.

The
potential
incremental
annual
cost
savings
range
from
$
13.6
million
if
only
1999
plants
benefit
to
$
34.5
million
if
the
plants
that
recovered
wastes
in
1997
and
not
in
1999
switch
back
to
recovery
are
included.
This
total
increases
by
$
63
million
to
$
97.5
million
if
plants
that
recovered
wastes
off
site
at
facilities
outside
the
same
industry
group
elect
to
construct
on­
site
recovery
facilities
because
of
potential
cost
savings
(
Table
5­
20
and
5­
23).
All
these
wastes
have
proven
recovery
value.

In
addition,
disposed
quantities
for
eight
waste
types
with
high
recovery
potential
were
evaluated
to
determine
if
it
was
economically
viable
to
construct
on­
site
recovery
systems.
Up
to
$
266
million
(
excluding
incremental
state
tax
savings)
in
potential
incremental
cost
savings
(
Tables
5­
21
and
5­
22)
for
roughly
708
out
of
1,844
facilities
(
38
percent)
has
been
estimated
if
the
quality
of
the
waste
is
sufficient
for
recovery.
However,
a
significant
limitation
is
that
it
is
unknown
if
all
eight
of
these
wastes
are
of
sufficient
quality
for
recovery.
Five
of
the
eight
wastes
types
have
been
identified
as
likely
having
sufficient
constituent
mix/
concentration
quality
for
recovery.
Emission
control
dust
(
K061)
from
the
steel
works
industry
has
a
past
history
of
being
recovered
for
zinc
values
prior
to
the
delisting
of
the
significantly
cheaper
Envirosource
stabilization
technology.
Most
of
the
metal­
containing
liquids
from
the
printed
circuit
board
industry
were
reported
being
disposed
either
on­
site
or
off­
site
by
chemical
precipitation
and
included
in
this
group
of
waste.
Upon
further
inspection
of
the
Biennial
Report
data,
the
copper­
containing
sludge
precipitated
from
this
treatment
process
often
goes
on
to
metals
recovery.
This
waste
is
of
sufficient
quality
for
recovery.
Spent
aluminum
potliner
(
K088)
from
the
aluminum
industry
has
a
proven
technology
for
recovering
fluoride
values.
The
Vortec
technology
has
been
implemented
at
least
at
two
sites
and
licensing
agreements
can
be
arranged
for
construction
at
other
sites.
The
Vortec
technology
meets
universal
treatment
standards
for
potliner
waste.
Spent
catalyst
(
K171/
K172)
from
the
petroleum
refining
industry
is
believed
to
be
recoverable
based
on
communications
with
reclaimers.
Spent
pickle
liquor
(
K062)
from
the
steel
works
industry
also
is
believed
to
have
sufficient
quality
for
recovery
of
acid
values.
Assuming
these
five
wastes
are
of
sufficient
quality
for
recovery
an
additional
$
81
million
in
potential
costs
savings
may
be
incurred
because
it
will
be
more
economical
for
facilities
to
construct
on­
site
recovery
facilities
(
Table
5­
24).
The
remaining
three
wastes
are
not
assumed
to
be
of
sufficient
quality
for
recovery
in
this
analysis.
A
breakdown
of
the
potential
cost
savings
by
waste
type
are
presented
in
Table
5­
21
and
Table
5­
22.
The
total
cost
savings
estimate
increases
to
$
178
million
if
plants
that
disposed
these
five
wastes
elect
to
construct
on­
site
recovery
facilities
because
of
potential
cost
savings.
5­
41
For
the
1999
on­
site
recovery
plants,
the
total
estimated
annual
cost
savings
is
$
11
million.
This
total
includes
one­
time
(
first
year)
contingency
planning
cost
savings
of
$
0.8
million
that
likely
are
sunk
and
one­
time
notification
of
exclusion
costs
of
$
0.5
million.
The
greatest
annual
savings
result
from
a
portion
of
the
residual
quantity
generated
by
the
recovery
processes
being
classified
as
nonhazardous
($
5.3
million
in
residual
hazardous
waste
landfill
cost
savings
­
$
3.0
million
in
new
non­
hazardous
waste
landfill
costs
+
$
2.3
million
in
nonhazardous
transportation
cost
savings
=
$
4.6
million
in
cost
savings).
The
second
largest
annual
cost
savings
is
from
a
reduction
in
hazardous
materials
training
costs
($
2.8
million
in
cost
savings).
The
third
largest
annual
cost
savings
is
from
a
reduction
in
waste
characterization
testing
costs
($
2.1
million).

For
the
1997
on­
site
recovery
plants,
the
total
estimated
annual
cost
savings
is
$
16.2
million.
This
total
includes
one­
time
(
first
year)
contingency
planning
cost
savings
of
$
0.2
million
that
likely
are
not
sunk
because
plants
are
switching
management
technologies
and
one­
time
notification
of
exclusion
costs
of
$
0.2
million.
The
greatest
annual
savings
result
from
a
portion
of
the
residual
quantity
generated
by
the
recovery
processes
being
classified
as
nonhazardous
($
4.3
million
in
pre­
rule
baseline
management
costs
­
$
1.5
million
in
post­
rule
residual
hazardous
waste
landfill
costs
­
$
0.2
million
in
post­
rule
non­
hazardous
waste
landfill
costs
­
$
8.0
million
in
post­
rule
recovery
system
costs
+
$
2.0
million
in
nonhazardous
transportation
cost
savings
+
$
16.9
million
in
value
from
the
recovered
products
=
$
13.5
million
in
cost
savings).
The
second
largest
annual
cost
savings
is
from
a
reduction
in
waste
characterization
testing
costs
($
1.7
million).
The
third
largest
annual
cost
savings
is
from
a
reduction
in
hazardous
materials
training
costs
($
0.6
million).

For
those
1999
plants
that
recovered
wastes
off­
site
within
the
same
industry
group
(
4­
digit
NAICS),
the
total
estimated
annual
cost
savings
is
$
2.7
million.
This
total
includes
one­
time
(
first
year)
contingency
planning
cost
savings
of
$
0.1
million
that
likely
are
sunk
and
one­
time
notification
of
exclusion
costs
of
$
0.2
million.
The
greatest
annual
savings
result
from
a
portion
of
the
residual
quantity
generated
by
the
recovery
processes
being
classified
as
nonhazardous
($
0.7
million
in
residual
hazardous
waste
landfill
cost
savings
­
$
0.5
million
in
post­
rule
nonhazardous
waste
landfill
costs
+
$
0.2
million
in
nonhazardous
transportation
cost
savings
=
$
0.4
million
in
cost
savings).
The
second
largest
annual
cost
savings
is
from
a
reduction
in
hazardous
materials
training
costs
($
0.4
million).
The
third
largest
annual
cost
savings
is
from
a
reduction
in
waste
characterization
testing
costs
($
0.2
million).

For
those
1997
plants
that
recovered
wastes
off­
site
within
the
same
industry
group,
the
total
estimated
annual
cost
savings
is
$
4.7
million.
This
total
includes
one­
time
(
first
year)
contingency
planning
cost
savings
of
$
0.02
million
that
likely
are
not
sunk
because
the
plants
are
switching
management
technologies
and
one­
time
notification
of
exclusion
costs
of
$
0.03
million.
The
greatest
annual
savings
result
from
a
portion
of
the
residual
quantity
generated
by
the
recovery
processes
being
classified
as
nonhazardous
($
1.6
million
in
pre­
rule
hazardous
waste
management
costs
­
$
0.5
million
in
post­
rule
residual
hazardous
waste
landfill
costs
­
$
0.05
million
in
post­
rule
non­
hazardous
waste
landfill
costs
­
$
0.9
million
in
post­
rule
recovery
system
costs
+
$
0.4
million
in
post­
rule
nonhazardous
transportation
cost
savings
­
$
0.4
million
in
post­
rule
off­
site
recovery
transport
costs
+
$
4.4
million
in
value
from
the
recovered
products
=
$
4.4
million
in
cost
5­
42
savings).
The
second
largest
annual
cost
savings
is
from
a
reduction
in
waste
characterization
testing
costs
($
0.3
million).

For
those
1999
plants
that
recovered
wastes
off­
site
outside
their
industry
group,
the
total
estimated
annual
cost
savings
is
$
63
million.
The
greatest
annual
savings
result
from
a
portion
of
the
residual
quantity
generated
by
the
recovery
processes
being
classified
as
nonhazardous
(­$
19.5
million
in
residual
hazardous
waste
landfill
costs
­
$
1.7
million
in
post­
rule
non­
hazardous
residual
landfill
costs
+
$
64.6
million
in
on­
site
recovery
process
savings
+
$
2.0
million
in
hazardous
transportation
cost
savings
=
$
45.4
million
in
cost
savings).
The
second
largest
annual
cost
savings
is
from
a
reduction
in
waste
characterization
testing
costs
($
15.3
million).
The
third
largest
annual
cost
savings
is
from
a
reduction
in
manifest
costs
($
2.4
million).

For
those
1999
plants
that
disposed
the
five
waste
types
identified
with
sufficient
quality
for
recovery
either
on­
site
or
off­
site,
the
total
estimated
annual
cost
savings
is
$
80.1
million.
This
total
includes
one­
time
(
first
year)
contingency
planning
cost
savings
of
$
0.14
million
that
likely
are
sunk
and
one­
time
notification
of
exclusion
costs
of
$
0.14
million.
The
greatest
annual
savings
result
from
a
portion
of
the
residual
quantity
generated
by
the
recovery
processes
being
classified
as
nonhazardous
($
84.5
million
in
pre­
rule
hazardous
waste
management
costs
­$
13.7
million
in
residual
hazardous
waste
landfill
cost
savings
­
$
3.5
million
in
post­
rule
non­
hazardous
waste
landfill
costs
+
$
13.2
million
in
nonhazardous
transportation
cost
savings
­
$
98.6
million
in
post­
rule
recovery
system
costs
+
$
73.0
million
in
value
from
the
recovered
products
=
$
54.9
million
in
cost
savings).
The
second
largest
annual
cost
savings
is
from
a
reduction
in
waste
characterization
testing
costs
($
22.9
million).
The
third
largest
annual
cost
savings
is
from
a
reduction
in
manifest
costs
($
3.5
million).
5­
43
Table
5­
19.
Summary
of
Pre­
and
Post­
Rule
Costs
and
Incremental
Costs
Cost
Item
1999
Plants
1997
Plants
Total
Costs
($/
yr)

Pre­
Rule
Costs
($/
yr)
Post­
Rule
Costs
($/
yr)
Incremental
Costs
($/
yr)
Pre­
Rule
Costs
($/
yr)
Post­
Rule
Costs
($/
yr)
Incremental
Costs
($/
yr)

On­
site
Recovery
Residual
Hazardous
Landfill
Disposal
$
60,719,000
$
55,431,000
($
5,288,000)
$
0
$
1,525,000
$
1,525,000
($
3,763,000)

Residual
Non­

Hazardous
Landfill
Disposal
$
0
$
2,976,000
$
2,976,000
$
0
$
165,000
$
165,000
$
3,141,000
Pre­
Rule
Management
(
Hazardous
Landfill,
Energy
Recovery,

onsite
Acid
Neutralization)
$
0
$
0
$
0
$
4,257,000
$
0
($
4,257,000)
($
4,257,000)

Pre­
Rule
and
Post­
Rule
Metal/
Solvent/
Acid
Recovery
$
167,814,000
$
167,814,000
$
0
$
0
$
7,953,000
$
7,953,000
$
7,953,000
Waste
Characterization
Testing
$
24,026,000
$
21,961,000
($
2,065,000)
$
3,245,000
$
1,581,000
($
1,664,000)
($
3,729,000)

Manifesting
$
3,701,000
$
3,383,000
($
318,000)
$
500,000
$
243,000
($
257,000)
($
575,000)
Table
5­
19.
Summary
of
Pre­
and
Post­
Rule
Costs
and
Incremental
Costs
Cost
Item
1999
Plants
1997
Plants
Total
Costs
($/
yr)

Pre­
Rule
Costs
($/
yr)
Post­
Rule
Costs
($/
yr)
Incremental
Costs
($/
yr)
Pre­
Rule
Costs
($/
yr)
Post­
Rule
Costs
($/
yr)
Incremental
Costs
($/
yr)

5­
44
Loading
$
4,371,000
$
4,371,000
$
0
$
71,000
$
224,000
$
153,000
$
153,000
Waste
Transportation
$
23,184,000
$
20,903,000
($
2,281,000)
$
3,749,000
$
1,734,000
($
2,015,000)
($
4,296,000)

Recovery
Transportation
$
0
$
0
$
0
$
0
$
0
$
0
$
0
Salvage
Revenue
($
610,881,000)
($
610,881,000)
$
0
$
0
($
16,898,000)
($
16,898,000)
($
16,898,000)

Hazardous
Materials
Training
$
7,479,000
$
4,719,000
($
2,760,000)
$
2,291,000
$
1,659,000
($
632,000)
($
3,392,000)

Manifest
Training
$
1,539,000
$
1,095,000
($
444,000)
$
459,000
$
382,000
($
77,000)
($
521,000)

BRS/
General
Administrative
Duties
$
1,927,000
$
1,423,000
($
504,000)
$
584,000
$
473,000
($
111,000)
($
615,000)

One­
Time
Contingency
Planning
$
2,072,000
$
1,252,000
($
820,000)
$
640,000
$
442,000
($
198,000)
($
1,018,000)

Initial
Characterization
$
7,066,000
$
7,066,000
$
0
$
1,805,000
$
1,805,000
$
0
$
0
One­
Time
Notification
of
Exclusion
$
0
$
542,000
$
542,000
$
0
$
162,000
$
162,000
$
704,000
Table
5­
19.
Summary
of
Pre­
and
Post­
Rule
Costs
and
Incremental
Costs
Cost
Item
1999
Plants
1997
Plants
Total
Costs
($/
yr)

Pre­
Rule
Costs
($/
yr)
Post­
Rule
Costs
($/
yr)
Incremental
Costs
($/
yr)
Pre­
Rule
Costs
($/
yr)
Post­
Rule
Costs
($/
yr)
Incremental
Costs
($/
yr)

5­
45
On­
site
Recovery
Subtotal
($
306,983,000)
($
317,945,000)
($
10,962,000)
$
17,601,000
$
1,450,000
($
16,151,000)
($
27,113,000)

Off­
site
Recovery
Within
the
Same
Industry
Group
(
4­
Digit
NAICS
Code)

Residual
Hazardous
Landfill
Disposal
$
6,389,000
$
5,675,000
($
714,000)
$
0
$
540,000
$
540,000
($
174,000)

Residual
Non­

Hazardous
Landfill
Disposal
$
0
$
481,000
$
481,000
$
0
$
50,000
$
50,000
$
531,000
Pre­
Rule
Management
(
Hazardous
Landfill,
Energy
Recovery,

Onsite
Acid
Neutralization)
$
0
$
0
$
0
$
1,605,000
$
0
($
1,605,000)
($
1,605,000)

Pre­
Rule
and
Post­
Rule
Metal/
Solvent/
Acid
Recovery
Cost
$
12,117,000
$
12,117,000
$
0
$
0
$
928,000
$
928,000
$
928,000
Table
5­
19.
Summary
of
Pre­
and
Post­
Rule
Costs
and
Incremental
Costs
Cost
Item
1999
Plants
1997
Plants
Total
Costs
($/
yr)

Pre­
Rule
Costs
($/
yr)
Post­
Rule
Costs
($/
yr)
Incremental
Costs
($/
yr)
Pre­
Rule
Costs
($/
yr)
Post­
Rule
Costs
($/
yr)
Incremental
Costs
($/
yr)

5­
46
Waste
Characterization
Testing
$
2,677,000
$
2,510,000
($
167,000)
$
571,000
$
320,000
($
251,000)
($
418,000)

Manifesting
$
761,000
$
665,000
($
96,000)
$
88,000
$
70,000
($
18,000)
($
114,000)

Loading
$
1,387,000
$
1,573,000
$
186,000
$
12,000
$
154,000
$
142,000
$
328,000
Waste
Transportation
$
2,567,000
$
2,344,000
($
223,000)
$
689,000
$
301,000
($
388,000)
($
611,000)

Recovery
Transportation
$
8,585,000
$
6,898,000
($
1,687,000)
$
0
$
413,000
$
413,000
($
1,274,000)

Salvage
Revenue
($
55,712,000)
($
55,712,000)
$
0
$
0
($
4,439,000)
($
4,439,000)
($
4,439,000)

Hazardous
Materials
Training
$
2,105,000
$
1,729,000
($
376,000)
$
410,000
$
360,000
($
50,000)
($
426,000)

Manifest
Training
$
437,000
$
364,000
($
73,000)
$
82,000
$
79,000
($
3,000)
($
76,000)

BRS/
General
Administrative
Duties
$
549,000
$
478,000
($
71,000)
$
105,000
$
97,000
($
8,000)
($
79,000)

One­
Time
Contingency
Planning
$
582,000
$
475,000
($
107,000)
$
115,000
$
98,000
($
17,000)
($
124,000)
Table
5­
19.
Summary
of
Pre­
and
Post­
Rule
Costs
and
Incremental
Costs
Cost
Item
1999
Plants
1997
Plants
Total
Costs
($/
yr)

Pre­
Rule
Costs
($/
yr)
Post­
Rule
Costs
($/
yr)
Incremental
Costs
($/
yr)
Pre­
Rule
Costs
($/
yr)
Post­
Rule
Costs
($/
yr)
Incremental
Costs
($/
yr)

5­
47
Initial
Characterization
$
2,661,000
$
2,661,000
$
0
$
302,000
$
302,000
$
0
$
0
One­
Time
Notification
of
Exclusion
$
0
$
159,000
$
159,000
$
0
$
29,000
$
29,000
$
188,000
Off­
site
Recovery
Subtotal
($
14,895,000)
($
17,583,000)
($
2,688,000)
$
3,979,000
($
698,000)
($
4,677,000)
($
7,365,000)

Aggregate
Cost
Total
($
321,878,000)
($
335,528,000)
($
13,650,000)
$
21,580,000
$
752,000
($
20,828,000)
($
34,478,000)

NOTES:
1.)
Numbers
in
parentheses,
"(
)",
represent
negative
costs
that
reflect
revenues
or
cost
savings.

2.)
Incremental
facility­
level
state
tax
costs
for
firms
are
estimated
to
be
($
372,000)
[$
470,000
pre­
rule
and
$
98,000
post­
rule]
for
1999
on­
site
recovery
facilities
and
($
165,000)
[$
191,000
pre­
rule
and
$
26,000
post­
rule]
for
1997
on­
site
recovery
facilities.
For
off­
site
recovery
facilities,
they
are
($
16,000
)

[$
20,000
pre­
rule
and
$
4,000
post­
rule]
for
1999
off­
site
recovery
facilities
and
($
0)
[$
282
pre­
rule
and
$
38
post­
rule]
for
1997
off­
site
recovery
facilities.

Total
facility­
level
state
tax
costs
are
($
553,000).

3.)
Incremental
generation
(
per
ton)
state
tax
costs
for
firms
are
estimated
to
be
($
1,552,000)
[$
3,364,000
pre­
rule
and
$
1,812,000
post­
rule]
for
1999
onsite
recovery
facilities
and
($
29,000)
[$
393,000
pre­
rule
and
$
364,000
post­
rule]
for
1997
on­
site
recovery
facilities.
For
off­
site
recovery
facilities,
they
are
($
7,000
)
[$
1,495,000
pre­
rule
and
$
1,488,000
post­
rule]
for
1999
off­
site
recovery
facilities
and
($
9,000)
[$
17,000
pre­
rule
and
$
8,000
post­
rule]
for
1997
off­
site
recovery
facilities.
Total
generation
(
per
ton)
state
tax
costs
are
($
1,597,000).
5­
48
Table
5­
20.
Summary
of
Potential
Incremental
Cost
Savings
from
Conducting
On­
Site
Recovery
Instead
of
Recovering
in
Other
Industry
Groups
4­
Digit
NAICS
Code
(
Industry
Group)
No.
Facilities
with
Potential
Savings
Quantity
(
tons)
Incremental
Savings
(
2002
$)*

3241
Petroleum
&
Coal
Products
Mfg.
5
out
of
112
8,229
out
of
28,547
$
272,513
3251
Basic
Chemical
Manufacturing
14
out
of
227
15,917
out
of
22,515
$
9,293,753
3252
Resin,
Synthetic
Rubber,
and
Artificial
and
Synthetic
Fibers
and
Filaments
Manufacturing
10
out
of
99
25,803
out
of
32,446
$
18,709,701
3254
Pharmaceutical
&
Medicine
Mfg.
14
out
of
111
12,140
out
of
15,447
$
6,643,330
3255
Paint,
Coating
&
Adhesive
Mfg.
49
out
of
156
21,549
out
of
23,181
$
12,117,532
3312
Steel
Product
Manufacturing
from
Purchased
Steel
6
out
of
119
136,518
out
of
471,434
$
5,012,838
3314
Non­
Ferrous
Metal
(
except
Aluminum)
Production
and
Processing
6
out
of
83
18,826
out
of
29,046
$
1,219,361
3328
Coating,
Engraving,
Heat
Treating
and
Allied
Activities
1
out
of
417
116
out
of
25,069
$
19,920
3344
Semiconductor
and
Other
Electronic
Component
Mftg.
4
out
of
382
1,174
out
of
56,589
$
527,843
3359
Other
Electrical
Equipment
and
Component
Manufacturing
1
out
of
67
71
out
of
32,543
$
8,670
3362
Motor
Vehicle
Body
and
Trailer
Manufacturing
32
out
of
74
17,400
out
of
18,069
$
9,518,978
Total
142
out
of
1,847
257,743
out
of
754,886
$
63,346,441
*
Includes
$
171,808
in
incremental
state
tax
savings.
Does
not
include
costs
for
one­
time
notification
of
exclusion.
5­
49
Table
5­
21.
Summary
of
Potential
Incremental
Cost
Savings
from
Conducting
On­
Site
Recovery
Instead
of
Off­
site
Disposal
by
Waste
Type
Waste
Types
SIC
Codes
Waste
Forms
No.
Facilities
Quantity
(
tons)
Incremental
Cost
Savings
(
2002
$)*

Organic
Liquids
(
Industrial
Organic
Chemicals,
Paints
&
Allied
Products,

Pharmaceutical
Preparations,
&

Plastics
Materials
&
Resins
Industries)
2869
2851
2834
2821
Liquid
Form
Codes
(
B101­
B119,
B201­
B219)
389
(
out
of
1,189)
190,003
(
out
of
219,929)
$
174,599,586
Electric
Arc
Furnace
Emission
Control
Dust
(
K061
­
Steel
Works
Industry)
3312
Solid
Form
Codes
(
B301­
B319,
B401­
B409)

Sludge
Form
Codes
(
B501­
B519,
B601­
B609)
1
(
out
of
30)
48,235
(
out
of
273,208)
$
103,181
Metal­
Containing
Liquids
(
Printed
Circuit
Board
Industry)
3672
Liquid
Form
Codes
(
B101­
B119,
B201­
B219)
102
(
out
of
173)
18,795
(
out
of
21,842)
$
2,884,000
Electroplating
Wastewater
Treatment
Sludges
(
Printed
Circuit
Board
Industry)
3672
Solid
Form
Codes
(
B301­
B319,
B401­
B409)

Sludge
Form
Codes
(
B501­
B519,
B601­
B609)
0
(
out
of
129)
0
(
out
of
7,095)
$
0
Spent
Carbon
(
Industrial
Organic
Chemicals
&
Petroleum
Refining
Industries)
2869
2911
Solid
Form
Codes
(
B301­
B319,
B401­
B409)

Sludge
Form
Codes
(
B501­
B519,
B601­
B609)
109
(
out
of
109)
2,376
(
out
of
2,376)
$
10,839,402
Spent
Catalyst
(
Petroleum
Refining
Industry)
2911
Solid
Form
Codes
(
B301­
B319,
B401­
B409)

Sludge
Form
Codes
(
B501­
B519,
B601­
B609)
57
(
out
of
75)
10,843
(
out
of
11,001)
$
7,089,685
Spent
Aluminum
Potliner
(
K088
­

Aluminum
Industry)
3334
Solid
Form
Codes
(
B301­
B319,
B401­
B409)

Sludge
Form
Codes
(
B501­
B519,
B601­
B609)
19
(
out
of
21)
71,698
(
out
of
72,547)
$
31,712,523
Spent
Pickle
Liquor
(
K062
­
Steel
Works
Industry)
3312
Liquid
Form
Codes
(
B101­
B119,
B201­
B219)
4
(
out
of
32)
72,938
(
out
of
88,128)
$
14,360,111
Total
681
(
out
of
1,758)**
414,914
(
out
of
696,126)
$
241,602,376
Table
5­
21.
Summary
of
Potential
Incremental
Cost
Savings
from
Conducting
On­
Site
Recovery
Instead
of
Off­
site
Disposal
by
Waste
Type
Waste
Types
SIC
Codes
Waste
Forms
No.
Facilities
Quantity
(
tons)
Incremental
Cost
Savings
(
2002
$)*

5­
50
*
Includes
$
6,933,750
in
incremental
state
tax
savings.
Does
not
include
costs
for
one­
time
notification
of
exclusion.

**
The
total
number
of
unique
plants
is
1,585.
Based
on
the
above
numbers,
173
plants
dispose
more
than
one
of
the
eight
waste
types.

Table
5­
22.
Summary
of
Potential
Incremental
Cost
Savings
from
Conducting
On­
Site
Recovery
Instead
of
On­
site
Disposal
by
Waste
Type
Waste
Types
SIC
Codes
Waste
Forms
No.
Facilities
Quantity
(
tons)
Incremental
Cost
Savings
(
2002
$)*

Metal­
Containing
Liquids
(
Printed
Circuit
Board
Industry)
3672
Liquid
Form
Codes
(
B101­
B119,
B201­

B219)
20
(
out
of
79)
313
(
out
of
133,512)
$
254,000
Spent
Pickle
Liquor
(
Steel
Works
Industry)
3312
Liquid
Form
Codes
(
B101­
B119,
B201­

B219)
7
(
out
of
7)
181,171
(
out
of
181,171)
$
24,411,861
Total
27
(
out
of
86)
181,484
(
out
of
314,683)
$
24,667,863
*
Includes
$
2,266,653
in
incremental
state
tax
savings.
Does
not
include
costs
for
one­
time
notification
of
exclusion.
5­
51
Table
5­
23.
Summary
of
Pre­
and
Post­
Rule
Costs
and
Incremental
Costs
Cost
Item
Off­
Site
Recovery
in
Other
Industry
Groups
(
Different
NAICS)

Pre­
Rule
Costs
($/
yr)
Post­
Rule
Costs
($/
yr)
Incremental
Costs
($/
yr)

Residual
Hazardous
Landfill
Disposal
$
0
$
19,483,000
$
19,483,000
Residual
Non­
Hazardous
Landfill
Disposal
$
0
$
1,652,000
$
1,652,000
Pre­
Rule
Management
(
Hazardous
Landfill,
Energy
Recovery,
on­
site
Acid
Neutralization)
$
0
$
0
$
0
Pre­
Rule
and
Post­
Rule
Metal/
Solvent/
Acid
Recovery
$
129,989,000
$
65,432,000
($
64,557,000)

Waste
Characterization
Testing
$
22,103,000
$
6,838,000
($
15,265,000)

Manifesting
$
3,405,000
$
1,053,000
($
2,352,000)

Loading
$
305,000
$
1,382,000
$
1,077,000
Waste
Transportation
$
8,552,000
$
6,549,000
($
2,003,000)

Recovery
Transportation
$
0
$
0
$
0
Salvage
Revenue
($
218,311,000)
($
218,311,000)
$
0
Hazardous
Materials
Training
$
1,381,000
$
653,000
($
728,000)

Manifest
Training
$
258,000
$
126,000
($
132,000)

BRS/
General
Administrative
Duties
$
343,000
$
204,000
($
139,000)

One­
Time
Contingency
Planning
$
394,000
$
185,000
($
209,000)

Initial
Characterization
$
1,682,000
$
1,682,000
$
0
One­
Time
Notification
of
Exclusion
$
0
$
90,000
$
90,000
Recovery
Total
($
49,899,000)
($
112,982,000)
($
63,083,000)

NOTES:
1.)
Numbers
in
parentheses,
"(
)",
represent
negative
costs
that
reflect
revenues
or
cost
savings.
2.)
Total
incremental
state
tax
costs
are
($
172,000).
5­
52
Table
5­
24.
Summary
of
Pre­
and
Post­
Rule
Costs
and
Incremental
Costs
Cost
Item
Disposal
Wastes
(
K061,
K062,
K088,
Metal­
Containing
Liquids,
K171/
K172)

Pre­
Rule
Costs
($/
yr)
Post­
Rule
Costs
($/
yr)
Incremental
Costs
($/
yr)

Residual
Hazardous
Landfill
Disposal
$
0
$
13,742,000
$
13,742,000
Residual
Non­
Hazardous
Landfill
Disposal
$
0
$
3,487,500
$
3,487,500
Pre­
Rule
Management
(
Hazardous
Landfill,
Energy
Recovery,
on­
site
Acid
Neutralization)
$
84,541,000
$
0
($
84,541,000)

Pre­
Rule
and
Post­
Rule
Metal/
Solvent/
Acid
Recovery
$
0
$
98,595,000
$
98,595,000
Waste
Characterization
Testing
$
33,713,000
$
10,820,000
($
22,893,000)

Manifesting
$
5,193,000
$
1,666,000
($
3,527,000)

Loading
$
336,000
$
2,098,000
$
1,762,000
Waste
Transportation
$
19,060,000
$
5,857,000
($
13,203,000)

Recovery
Transportation
$
0
$
0
$
0
Salvage
Revenue
$
0
($
73,026,000)
($
73,026,000)

Hazardous
Materials
Training
$
1,950,000
$
1,565,000
($
385,000)

Manifest
Training
$
371,000
$
330,000
($
41,000)

BRS/
General
Administrative
Duties
$
487,000
$
421,000
($
66,000)

One­
Time
Contingency
Planning
$
573,000
$
431,000
($
142,000)

Initial
Characterization
$
2,033,000
$
2,033,000
$
0
One­
Time
Notification
of
Exclusion
$
0
$
135,000
$
135,000
Recovery
Total
$
148,257,000
$
68,154,500
($
80,102,500)

NOTES:
1.)
Numbers
in
parentheses,
"(
)",
represent
negative
costs
that
reflect
revenues
or
cost
savings.
2.)
Total
incremental
state
tax
costs
are
($
4,651,000).
6­
1
6.0
ECONOMIC
IMPACT
ANALYSIS
6.1
Major
Industries
Impacted
In
this
section
the
industries
which
will
have
some
of
the
greatest
impacts
are
profiled,
using
1997
Census
of
Manufacturers
data.
The
industries
profiled,
listed
below,
represent
much
of
the
total
waste
which
is
affected
under
the
anticipated
rule.

°
Basic
Chemicals
(
NAICS
3251)
°
Petrochemical
(
NAICS
325110)
°
Other
Basic
Organic
Chemicals
(
NAICS
325199)
°
Other
Inorganic
Chemicals
(
NAICS
325188)
°
Inorganic
Dyes
and
Pigments
(
NAICS
325131)
°
Cyclic
Crudes
and
Intermediates
(
NAICS
325192)

°
Resin,
Synthetic
Rubber,
and
Artificial
and
Synthetic
Fibers
and
Filaments
(
3252)
°
Plastic
Materials
and
Resins
(
NAICS
325211)

°
Pharmaceutical
and
Medicine
Manufacturing
(
NAICS
3254)
°
Pharmaceutical
Preparations
(
NAICS
325412)

°
Nonferrous
Metal
(
except
aluminum)
Production
and
Processing
(
NAICS
3314)
°
Primary
Smelting
and
Refining
of
Copper
(
NAICS
331411)
°
Other
Nonferrous
Metal
Primary
Smelting
and
Refining
(
NAICS
331419)
°
Secondary
Smelting,
Refining
and
Alloying
of
Copper
(
NAICS
331423)
°
Other
Nonferrous
Metal
Secondary
Smelting,
Refining,
Alloying
Manufacturing
(
NAICS
331492)

°
Coating,
Engraving,
Heat
Treating,
and
Allied
Activities
(
NAICS
3328)

°
Plating
and
Polishing
(
NAICS
332813)

°
Semiconductor
and
Other
Electronic
Component
Manufacturing
(
NAICS
3344)
°
Printed
Circuit
Board
(
NAICS
334412)

6.1.1
Basic
Chemical
Industry
The
Basic
Chemical
Industry
includes
a
broad
range
of
industries.
For
the
purpose
of
our
analysis,
we
will
be
focusing
on
the
four
major
industries:
Petrochemical
(
NAICS
325110),
Other
Basic
Inorganic
Chemical
(
NAICS
32518),
Other
Basic
Organic
Chemical
(
NAICS
32519)
and
Inorganic
Dye
and
Pigment
(
NAICS
325131).
18
U.
S.
Department
of
Commerce,
US
Census
Bureau,
1997
Economic
Census:
Bridge
Between
NAICS
and
SIC.

6­
2
6.1.1.1
Petrochemical
Industry
Profile
The
petrochemical
manufacturers
are
listed
under
the
NAICS
code
325110
(
SIC
2865
and
2869).
This
industry
is
a
part
of
the
chemical
manufacturing
industry
(
NAICS
325)
and
comprises
establishments
primarily
engaged
in
(
1)
manufacturing
acrylic,
and
(
2)
manufacturing
cyclic
aromatic
hydrocarbons.
18
6.1.1.1.1
Production
and
Shipment
Values
Table
6­
1
provides
a
summary
of
the
estimated
U.
S.
total
value
of
shipments
of
petrochemicals
for
1997.

Table
6­
1.
Estimated
United
States
Total
Value
of
Shipments
of
Petrochemical
Products:
1997
YEAR
TOTAL
VALUE
OF
SHIPMENTS
($
1,000)

1997
20,534,750
Source:
1997
Census
of
Manufacturers,
USDC.

6.1.1.1.2
Industry
Size
and
Market
Share
Data
used
to
characterize
this
industry
are
from
the
1997
Census
of
Manufacturers
and
Census
Current
Industrial
reports.
The
1997
Census
data
indicate
that
there
are
54
facilities
located
in
within
the
U.
S.,
owned
by
42
companies.
More
than
half
of
the
industry,
in
terms
of
aggregate
value
of
shipments,
is
dominated
by
approximately
11
percent
of
all
facilities.
A
distribution
of
facilities
by
number
of
employees,
and
their
respective
share
of
the
total
value
of
shipments
is
provided
in
Table
6­
2.

Table
6­
2.
Distribution
of
Facilities
by
Employment
for
the
Petrochemical
Industry
Employees
Per
Facility
Number
of
Facilities
Percent
of
Facilities
Percent
of
Total
Shipments
Value
1­
19
11
20.4%
0.1%

20
­
49
5
9.3%
0.5%

50
­
99
10
18.5%
4.2%

100
­
249
13
24.1%
13.0%
Table
6­
2.
Distribution
of
Facilities
by
Employment
for
the
Petrochemical
Industry
Employees
Per
Facility
Number
of
Facilities
Percent
of
Facilities
Percent
of
Total
Shipments
Value
19
U.
S.
Department
of
Commerce,
US
Census
Bureau,
1997
Economic
Census:
Bridge
Between
NAICS
and
SIC.

6­
3
250
­
499
9
16.7%
25.4%

500
&
above
6
11.0%
56.8%

Total
54
100.0%
100.0%

Source:
1997
Census
of
Manufacturers,
USDC.

6.1.1.1.3
Average
Facility
Size
Annual
sales
for
the
average
facility
was
estimated
assuming
that
the
largest
facilities
in
the
industry
were
reporting
BRS
waste
quantities.
Using
this
assumption,
we
estimated
average
annual
sales,
based
on
1997
Census
data,
updated
to
2001
dollars
using
the
GNP
Implicit
Price
Deflator
to
be
$
576,357,000.

6.1.1.2
Other
Organic
Chemical
Industry
Profile
The
other
organic
chemical
manufacturers
are
listed
under
the
NAICS
code
325199.
This
industry
is
a
part
of
the
chemical
manufacturing
industry
(
NAICS
325)
and
comprises
establishments
primarily
engaged
in
manufacturing
basic
organic
chemicals
(
except
petrochemicals,
industrial
gases,
and
synthetic
dyes
and
pigments).
19
6.1.1.2.1
Production
and
Shipment
Values
Table
6­
3
provides
a
summary
of
the
estimated
U.
S.
total
value
of
shipments
of
other
organic
chemical
products
for
1997.

Table
6­
3.
Estimated
United
States
Total
Value
of
Shipments
of
Other
Organic
Chemical
Products:
1997
YEAR
TOTAL
VALUE
OF
SHIPMENTS
($
1,000)

1997
53,542,377
Source:
1997
Census
of
Manufacturers,
USDC.
20
U.
S.
Department
of
Commerce,
US
Census
Bureau,
1997
Economic
Census:
Bridge
Between
NAICS
and
SIC.

6­
4
6.1.1.2.2
Industry
Size
and
Market
Share
Data
used
to
characterize
this
industry
are
from
the
1997
Census
of
Manufacturers
and
Census
Current
Industrial
reports.
The
1997
Census
data
indicate
that
there
are
676
facilities
located
in
within
the
U.
S.,
owned
by
487
companies.
Over
70
percent
of
all
facilities
employ
fewer
than
100
people.
While
more
than
half
of
the
industry,
in
terms
of
aggregate
value
of
shipments,
is
dominated
by
approximately
5
percent
of
all
facilities.
A
distribution
of
facilities
by
number
of
employees,
and
their
respective
share
of
the
total
value
of
shipments
is
provided
in
Table
6­
4.

Table
6­
4.
Distribution
of
Facilities
by
Employment
for
the
Other
Organic
Chemicals
Industry
Employees
Per
Facility
Number
of
Facilities
Percent
of
Facilities
Percent
of
Total
Shipments
Value
1­
19
251
37.1%
2.5%

20
­
49
136
20.1%
4.1%

50
­
99
100
14.8%
8.2%

100
­
249
118
17.5%
20.4%

250
­
499
33
4.9%
14.2%

500
&
above
38
5.6%
50.6%

Total
676
100.0%
100.0%

Source:
1997
Census
of
Manufacturers,
USDC.

6.1.1.2.3
Average
Facility
Size
Annual
sales
for
the
average
facility
was
estimated
assuming
that
the
largest
facilities
in
the
industry
were
reporting
BRS
waste
quantities.
Using
this
assumption,
we
estimated
average
annual
sales,
based
on
1997
Census
data,
updated
to
2001
dollars
using
the
GNP
Implicit
Price
Deflator
to
be
$
185,672,000.

6.1.1.3
Other
Inorganic
Chemical
Industry
Profile
The
other
inorganic
chemical
manufacturers
are
listed
under
the
NAICS
code
325188
(
and
SIC
2819).
This
industry
is
a
part
of
the
chemical
manufacturing
industry
(
NAICS
325)
and
comprises
establishments
primarily
engaged
in
manufacturing
basic
inorganic
chemicals
(
except
industrial
gases,
inorganic
dyes
and
pigments,
alkalies
and
chlorine
and
carbon
black).
20
6.1.1.3.1
Production
and
Shipment
Values
6­
5
Table
6­
5
provides
a
summary
of
the
estimated
U.
S.
total
value
of
shipments
of
other
inorganic
chemical
products
for
1997.

Table
6­
5.
Estimated
United
States
Total
Value
of
Shipments
of
Other
Inorganic
Chemical
Products:
1997
YEAR
TOTAL
VALUE
OF
SHIPMENTS
($
1,000)

1997
17,255,506
Source:
1997
Census
of
Manufacturers,
USDC.

6.1.1.3.2
Industry
Size
and
Market
Share
Data
used
to
characterize
this
industry
are
from
the
1997
Census
of
Manufacturers
and
Census
Current
Industrial
reports.
The
1997
Census
data
indicate
that
there
are
638
facilities
located
in
within
the
U.
S.,
owned
by
387
companies.
About
28.6
percent
of
all
facilities
employ
fewer
than
100
people.
Almost
half
of
the
industry,
in
terms
of
aggregate
value
of
shipments,
is
dominated
by
approximately
5
percent
of
all
facilities.
A
distribution
of
facilities
by
number
of
employees,
and
their
respective
share
of
the
total
value
of
shipments
is
provided
in
Table
6­
6.

Table
6­
6.
Distribution
of
Facilities
by
Employment
for
the
Other
Inorganic
Chemicals
Industry
Employees
Per
Facility
Number
of
Facilities
Percent
of
Facilities
Percent
of
Total
Shipments
Value
1­
19
330
51.7%
5.9%

20
­
49
139
21.8%
10.7%

50
­
99
73
11.4%
12.0%

100
­
249
63
9.9%
25.5%

250
­
499
21
3.3%
12.5%

500
&
above
12
1.9%
33.4%

Total
638
100.0%
100.0%

Source:
1997
Census
of
Manufacturers,
USDC.

6.1.1.3.3
Average
Facility
Size
Annual
sales
for
the
average
facility
was
estimated
assuming
that
the
largest
facilities
in
the
industry
were
reporting
BRS
waste
quantities.
Using
this
assumption,
we
estimated
average
21
U.
S.
Department
of
Commerce,
US
Census
Bureau,
1997
Economic
Census:
Bridge
Between
NAICS
and
SIC.

6­
6
annual
sales,
based
on
1997
Census
data,
updated
to
2001
dollars
using
the
GNP
Implicit
Price
Deflator
to
be
$
91,371,000.

6.1.1.4
Inorganic
Dye
and
Pigment
Industry
Profile
Inorganic
dye
and
pigment
manufacturers
are
listed
under
the
North
American
Industrial
Classification
(
NAICS)
code
325131
(
and
SIC
2816
and
2819).
The
inorganic
dye
and
pigment
manufacturers
are
a
part
of
the
chemical
manufacturing
industry
(
NAICS
325)
and
this
industry
comprises
establishments
primarily
engaged
in
manufacturing
industrial
inorganic
chemicals
and
inorganic
pigments.
21
6.1.1.4.1
Production
and
Shipment
Values
Table
6­
7
provides
a
summary
of
the
estimated
U.
S.
total
value
of
shipments
of
inorganic
dye
and
pigments
from
1994
­
1998.

Table
6­
7.
Estimated
United
States
Total
Value
of
Shipments
of
Inorganic
Dye
and
Pigments:
1994
­
1998
YEAR
TOTAL
VALUE
OF
SHIPMENTS
($
1,000)

1998
2,526,126
1997
2,606,048
1996
2,486,663
1995
2,284,232
1994
2,470,873
Source:
U.
S.
Department
of
Commerce,
Bureau
of
the
Census,
Current
Industrial
Reports,
Inorganic
Chemicals
1998,
MA
325A(
98)­
1,
February,
2000
6.1.1.4.2
Industry
Size
and
Market
Share
Data
used
to
characterize
the
inorganic
dye
and
pigment
industry
are
from
the
1997
Census
of
Manufacturers
and
Census
Current
Industrial
reports.
The
1997
Census
data
indicate
that
there
are
74
facilities
located
in
within
the
U.
S.,
owned
by
58
companies.
About
65
percent
of
all
6­
7
facilities
employ
fewer
than
100
people.
Almost
half
of
the
industry,
in
terms
of
aggregate
value
of
shipments,
is
dominated
by
approximately
6
percent
of
all
facilities.
A
distribution
of
facilities
by
number
of
employees,
and
their
respective
share
of
the
total
value
of
shipments
is
provided
in
Table
6­
8.

Table
6­
8.
Distribution
of
Facilities
by
Employment
for
the
Inorganic
Dye
and
Pigment
Industry
Employees
Per
Facility
Number
of
Facilities
Percent
of
Facilities
Percent
of
Total
Shipments
Value
1­
19
24
32.4%
1.4%

20
­
49
16
21.6%
4.3%

50
­
99
8
10.8%
4.4%

100
­
249
14
18.9%
18.5%

250
­
499
8
10.8%
27.6%

500
&
above
4
5.5%
43.9%

Total
74
100.0%
100.0%

Source:
1997
Census
of
Manufacturers,
USDC.

6.1.1.3.3
Average
Facility
Size
Annual
sales
for
the
average
facility
was
estimated
assuming
that
the
largest
facilities
in
the
industry
were
reporting
BRS
waste
quantities.
Using
this
assumption,
we
estimated
average
annual
sales,
based
on
1997
Census
data,
updated
to
2001
dollars
using
the
GNP
Implicit
Price
Deflator
to
be
$
77,556,000.

6.1.1.5
Cyclic
Crudes
and
Intermediates
Industry
Profile
Cyclic
crudes
and
intermediates
manufacturers
are
listed
under
the
NAICS
code
325192
(
and
under
the
SIC
as
industry
2865).
The
cyclic
crudes
and
intermediates
manufacturing
industry
is
a
part
of
the
chemical
manufacturing
industry
(
NAICS
325).
Establishments
in
this
industry
are
primarily
engaged
in
manufacturing
cyclic
organic
crudes
and
intermediates,
and
organic
dyes
and
pigments.
Important
products
of
this
industry
include:
(
1)
aromatic
chemicals,
such
as
benzene,
toluene,
mixed
xylenes
naphthalene;
(
2)
synthetic
organic
dyes;
and
(
3)
synthetic
organic
pigments.
87,345
6.1.1.5.1
Shipment
Values
Table
6­
9
shows
the
estimated
total
value
of
shipments
of
cyclic
crudes
and
intermediate
products
for
1997.
6­
8
Table
6­
9.
Estimated
United
States
Total
Value
of
Shipments
of
Cyclic
Crudes
and
Intermediate
Products:
1997
YEAR
VALUE
OF
SHIPMENTS
($
1,000)

1997
5,975,157
Source:
1997
Census
of
Manufacturers,
USDC.

6.1.1.5.2
Industry
Size
and
Market
Share
Data
used
to
characterize
the
cyclic
crudes
and
intermediates
industry
are
from
the
1997
Census
of
Manufacturers.
The
1997
Census
data
indicate
that
there
are
50
facilities
located
in
the
U.
S.,
owned
by
35
companies.
Over
60
percent
of
facilities
employ
fewer
than
100
people.
A
distribution
of
facilities
by
number
of
employees,
and
their
respective
share
of
the
total
value
of
shipments
is
provided
in
Table
6­
10.

Table
6­
10.
Distribution
of
Facilities
by
Employment
for
the
Cyclic
Crudes
and
Intermediates
Industry
Employees
Per
Facility
Number
of
Facilities
Percent
of
Facilities
Percent
of
Total
Shipments
Value
1­
19
12
24.0%
15.7%

20
­
49
9
18.0%
2.8%

50
­
99
11
22.0%
5.3%

100
­
249
7
14.0%
15.8%

250
&
above
11
22.0%
60.4%

Total
50
100.0%
100.0%

Source:
1997
Census
of
Manufacturers,
USDC.

6.1.1.5.3
Average
Facility
Size
Annual
sales
for
the
average
facility
was
estimated
assuming
that
the
largest
facilities
in
the
industry
were
reporting
BRS
waste
quantities.
Using
this
assumption,
we
estimated
average
annual
sales,
based
on
1997
Census
data,
updated
to
2001
dollars
using
the
GNP
Implicit
Price
Deflator
to
be
$
180,181,000.
22
U.
S.
Department
of
Commerce,
US
Census
Bureau,
1997
Economic
Census:
Bridge
Between
NAICS
and
SIC
23
EPA.
1995.
EPA
Office
of
Compliance
Sector
Notebook
Project:
Profile
of
the
Plastic
Resin
and
Manmade
Fiber
Industry.
EPA/
310­
R­
97­
006
24
Ibid
6­
9
6.1.2
Resin,
Synthetic
Rubber,
and
Artificial
and
Synthetic
Fibers
and
Filaments
The
Resin,
Synthetic
Rubber,
and
Artificial
and
Synthetic
Fibers
and
Filaments
industry
(
NAICS
3252)
includes
a
broad
range
of
industries.
For
the
purpose
of
our
analysis,
only
the
Plastic
Material
and
Resin
Manufacturing
Industry
will
be
examined.

6.1.2.1
Plastic
Material
and
Resin
Manufacturing
Industry
Profile
Plastics
material
and
resin
manufacturers
are
listed
under
the
NAICS
code
325211
(
and
under
the
SIC
as
industry
2821).
This
industry
is
a
sub­
sector
of
the
chemical
manufacturing
industry
(
NAICS
325).
This
industry
comprises
establishments
primarily
engaged
in
the
manufacturing
of
synthetic
resins,
plastics
materials,
and
non­
vulcanizable
elastomers.
22
The
plastic
resin
industry
produces
resins
which
are
further
treated
in
plastics
processing
facilities
and
sold
largely
to
the
packaging,
building
and
construction,
and
consumer
markets.
Specific
product
formulations
and
manufacturing
parameters
are
often
kept
as
trade
secrets
since
the
competitiveness
of
many
companies
depends
on
the
ability
to
produce
resins
with
different
physical
characteristics,
such
as
strength,
toughness,
and
flexibility.
23
Plastic
resins
are
typically
broken
down
into
two
categories:
thermoplastics
and
thermosets.
Thermoplastic
resins
are
resins
that
can
be
heated
and
molded
into
shapes
repeatedly,
while
thermoset
resins
are
resins
that
can
be
heated
and
molded
only
once.
Thermoplastic
resins
dominate
plastic
resin
sales
and
production.
In
1994,
thermoplastics
made
up
about
90
percent,
or
63.3
billion
pounds,
of
plastic
resin
production
by
dry
weight
and
accounted
for
82
percent,
or
$
27.2
billion
dollars
of
the
total
value
of
shipments
for
plastic
resin.
Commercially
important
thermoplastics
include
polyethylene
(
all
forms),
polyvinyl
chloride,
polypropylene,
and
polystyrene
and
are
shown
in
Figure
3.
These
four
thermoplastics
make
up
over
69
percent
of
plastic
resin
sales.
These
thermoplastics
are
considered
general
purpose,
or
commodity
plastics
since
they
are
usually
manufactured
in
large
quantities
using
well
established
technology
and
are
typically
geared
towards
a
small
number
of
high
volume
users.
24
6.1.2.1.1
Production
and
Shipment
Values
Table
6­
11
shows
the
estimated
U.
S.
total
value
of
shipments
for
plastic
material
and
resins
for
1997.
6­
10
Table
6­
11.
Estimated
United
States
Total
Value
of
Shipments
of
Plastic
Materials
and
Resin
Products:
1997
YEAR
TOTAL
VALUE
OF
SHIPMENTS
($
1,000)

1997
44,574,918
Source:
1997
Census
of
Manufacturers,
USDC.

6.1.2.1.2
Industry
Size
and
Market
Share
Data
used
to
characterize
the
plastic
material
and
resin
manufacturing
industry
are
from
the
1997
Census
of
Manufacturers.
The
1997
Census
data
indicate
that
there
are
532
facilities
located
in
the
U.
S.,
owned
by
301
companies.
Over
70
percent
of
the
of
all
facilities
employ
fewer
than
100
people.
A
distribution
of
facilities
by
number
of
employees,
and
their
respective
share
of
the
total
value
of
shipments
is
provided
in
Table
6­
12.

Table
6­
12.
Distribution
of
Facilities
by
Employment
for
the
Plastics
Material
and
Resin
Manufacturing
Industry
Employees
Per
Facility
Number
of
Facilities
Percent
of
Facilities
Percent
of
Total
Shipments
Value
1­
19
115
21.6%
1.5%

20
­
49
160
30.1%
6.9%

50
­
99
114
21.4%
12.1%

100
­
249
94
17.7%
28.1%

250
&
above
49
9.2%
34.4%

Total
532
100.0%
83.0%

Source:
1997
Census
of
Manufacturers,
USDC.

6.1.2.1.3
Typical
Products
Important
products
of
this
industry
include:
cellulose
plastics
materials;
phenolic
and
other
tar
acid
resins;
urea
and
melamine
resins;
vinyl
resins;
styrene
resins;
alkyd
resins;
acrylic
resins;
polyethylene
resins;
polypropylene
resins;
rosin
modified
resins;
coumarone­
indene
and
petroleum
polymer
resins;
miscellaneous
resins,
including
polyamide
resins,
silicones,
polyisobutylenes,
25
U.
S.
Department
of
Commerce,
US
Census
Bureau,
1997
Economic
Census:
Bridge
Between
NAICS
and
SIC
26
EPA.
1995.
EPA
Office
of
Compliance
Sector
Notebook
Project:
Profile
of
the
Pharmaceutical
Industry.
EPA/
310­
R­
97­
005
27
U.
S.
Department
of
Commerce,
Bureau
of
the
Census,
Current
Industrial
Reports,
Pharmaceutical
Preparations,
Except
Biologicals,
Annual
Report
2000,
MA
325G(
00)­
1,
August
2001.

6­
11
polyesters,
resins,
acetyl
resins,
and
fluorohydrocarbon
resins;
and
casein
plastics.
polycarbonate
resins,
acetyl
resins,
and
fluorohydrocarbon
resins;
and
casein
plastics.
25
6.1.2.1.4
Average
Facility
Size
Annual
sales
for
the
average
facility
was
estimated
assuming
that
the
largest
facilities
in
the
industry
were
reporting
BRS
waste
quantities.
Using
this
assumption,
we
estimated
average
annual
sales,
based
on
1997
Census
data,
updated
to
2001
dollars
using
the
GNP
Implicit
Price
Deflator
to
be
$
170,472,000.

6.1.3
Pharmaceutical
and
Medicine
Manufacturing
The
Pharmaceutical
and
Medicine
Manufacturing
Industry
(
NAICS
3254)
contains
a
broad
range
of
industries.
For
the
purpose
of
this
analysis
the
Pharmaceutical
Preparations
Industry
will
be
examined.

6.1.3.1
Pharmaceutical
Preparations
Industry
Profile
Pharmaceutical
preparations
manufacturers
are
listed
under
the
North
American
Industrial
Classification
NAICS
code
as
325412
(
SIC
2834
and
2835).
This
industry
is
a
part
of
the
chemical
manufacturing
industry
(
NAICS
325).
The
pharmaceutical
preparations
industry
is
made
up
of
companies
that
manufacture,
fabricate,
and
process
raw
materials
into
pharmaceutical
preparations
for
human
and
veterinary
uses.
Finished
products
are
sold
in
various
dosage
forms
including,
for
example,
tablets,
capsules,
ointments,
solutions,
suspensions,
and
powders.
These
are
1)
preparations
aimed
for
use
mainly
by
dental,
medical,
or
veterinary
professionals,
and
2)
those
aimed
for
use
by
patients
and
the
general
public.
26
6.1.3.1.1
Shipment
Values
The
total
value
of
shipments
for
pharmaceutical
preparations
in
the
United
States
totaled
$
78.9
billion
in
2000,
a
12­
percent
increase
from
$
70.2
billion
in
1999.
The
leading
product
category
was
pharmaceutical
preparations
that
act
on
the
central
nervous
system
and
sense
organs
in
humans.
Table
6­
13
provides
a
summary
of
estimated
U.
S.
total
value
of
shipments
for
pharmaceutical
preparations.
27
6­
12
Table
6­
13.
Estimated
United
States
Total
Value
of
Shipments
of
Pharmaceutical
Preparations,
Except
Biologicals:
2000
and
1999
YEAR
VALUE
OF
SHIPMENTS
($
1,000)

Total
Prescription
legend
Nonprescription
Bulk
Shipments
2000
78,907,599
63,768,674
13,999,294
1,139,631
1999
70,171,309
54,669,894
14,411,968
1,089,447
Source:
U.
S.
Department
of
Commerce,
Bureau
of
the
Census,
Current
Industrial
Reports,
Pharmaceutical
Preparations,
Except
Biologicals,
Annual
Report
2000,
MA
325G(
00)­
1,
August
2001.

6.1.3.1.2
Industry
Size
and
Market
Share
Data
used
to
characterize
the
pharmaceutical
preparations
industry
are
from
the
1997
Census
of
Manufacturers
and
Census
Current
Industrial
reports.
The
1997
Census
data
indicate
that
there
are
837
facilities
located
in
within
the
U.
S.,
owned
by
710
companies.
More
than
half
of
this
industry,
in
terms
of
aggregate
value
of
shipments,
is
dominated
by
only
6
percent
of
all
facilities.
Over
70
percent
of
all
facilities
employ
fewer
than
100
people.
A
distribution
of
facilities
by
number
of
employees,
and
their
respective
share
of
the
total
value
of
shipments
is
provided
in
Table
6­
14.

Table
6­
14.
Distribution
of
Facilities
by
Employment
for
the
Pharmaceutical
Preparations
Industry
Employees
Per
Facility
Number
of
Facilities
Percent
of
Facilities
Percent
of
Total
Shipments
Value
1­
19
395
47.2%
1.0%

20
­
49
138
16.5%
1.6%

50
­
99
85
10.2%
3.7%

100
­
249
107
12.8%
11.6%

250
&
above
112
13.3%
82.1%

Total
837
100.0%
100.0%

Source:
1997
Census
of
Manufacturers,
USDC.

6.1.3.1.3
Average
Facility
Size
28
U.
S.
Department
of
Commerce,
US
Census
Bureau,
1997
Economic
Census:
Bridge
Between
NAICS
and
SIC
6­
13
Annual
sales
for
the
average
facility
was
estimated
assuming
that
the
largest
facilities
in
the
industry
were
reporting
BRS
waste
quantities.
Using
this
assumption,
we
estimated
average
annual
sales,
based
on
1997
Census
data,
updated
to
2001
dollars
using
the
GNP
Implicit
Price
Deflator
to
be
$
258,378,000.

6.1.4
Nonferrous
Metal
(
except
Aluminum)
Production
and
Processing
Industry
Profile
The
nonferrous
metal
production
and
processing
industry
includes
a
broad
range
of
industries.
For
the
purpose
of
this
analysis
we
will
be
focusing
on:
Primary
Smelting
and
Refining
of
Copper
(
NAICS
331411),
Other
Nonferrous
Metal
Primary
Smelting
and
Refining
(
NAICS
331419),
Secondary
Smelting,
Refining
and
Alloying
of
Copper
(
NAICS
331423),
and
Other
Nonferrous
Metals
Smelting,
Refining
and
Alloying
(
NAICS
331492).

6.1.4.1
Primary
Smelting
and
Refining
of
Copper
Industry
Profile
This
industry
is
listed
under
the
NAICS
code
331411
(
SIC
331).
This
industry
is
a
subsector
of
the
primary
metal
industry
(
NAICS
331).
This
industry
comprises
establishments
primarily
engaged
in
(
1)
smelting
copper
ore
and/
or
(
2)
the
primary
refining
of
copper
by
electrolytic
methods
or
other
processes.
28
6.1.4.1.1
Production
and
Shipment
Values
Table
6­
15
shows
the
estimated
US
total
value
of
shipments
for
primary
smelting
an
refining
of
copper
products
for
1997.

Table
6­
15.
Estimated
United
States
Total
Value
of
Shipments
of
Primary
Smelting
and
Refining
of
Copper
Products:
1997
YEAR
TOTAL
VALUE
OF
SHIPMENTS
($
1,000)

1997
6,540,441
Source:
1997
Census
of
Manufacturers,
USDC.

6.1.4.1.2
Industry
Size
and
Market
Share
29
1997
Census
of
Manufacturers,
USDC
30
U.
S.
Department
of
Commerce,
US
Census
Bureau,
1997
Economic
Census:
Bridge
Between
NAICS
and
SIC
6­
14
Data
used
to
characterize
this
industry
are
from
the
1997
Census
of
Manufacturers.
The
1997
Census
data
indicate
that
there
are
16
facilities
located
in
the
U.
S.,
owned
by
9
companies.
A
distribution
of
facilities
by
number
of
employees,
and
their
respective
share
of
the
total
value
of
shipments
is
provided
in
Table
6­
16.29
Table
6­
16.
Distribution
of
Facilities
by
Employment
for
the
Primary
Smelting
and
Refining
of
Copper
Industry
Employees
Per
Facility
Number
of
Facilities
Percent
of
Facilities
Percent
of
Total
Shipments
Value
1­
19
1
6.2%
N/
A
20
­
49
1
6.2%
N/
A
50
­
99
0
0.0%
N/
A
100
­
249
3
18.8%
N/
A
250
­
499
11
68.8%
81.8%

Total
16
100.0%
100.0%

Source:
1997
Census
of
Manufacturers,
USDC.

6.1.4.1.3
Typical
Products
Establishments
in
this
industry
primarily
make
primary
copper
and
copper
based
alloys,
such
as
brass
and
bronze,
from
ore
or
concentrates.
30
6.1.4.1.4
Average
Facility
Size
Annual
sales
for
the
average
facility
was
estimated
assuming
that
the
largest
facilities
in
the
industry
were
reporting
BRS
waste
quantities.
Using
this
assumption,
we
estimated
average
annual
sales,
based
on
1997
Census
data,
updated
to
2001
dollars
using
the
GNP
Implicit
Price
Deflator
to
be
$
521,876,000.
31
U.
S.
Department
of
Commerce,
US
Census
Bureau,
1997
Economic
Census:
Bridge
Between
NAICS
and
SIC
32
1997
Census
of
Manufacturers,
USDC
6­
15
6.1.4.2
Other
Nonferrous
Metal
Primary
Smelting
and
Refining
Industry
Profile
This
industry
is
listed
under
the
NAICS
code
331419
(
SIC
3339).
This
industry
is
a
subsector
of
the
primary
metal
industry
(
NAICS
331).
This
industry
comprises
establishments
primarily
engaged
in
(
1)
making
(
i.
e.,
the
primary
production)
nonferrous
metals
by
smelting
ore
and/
or
(
2)
the
primary
refining
of
nonferrous
metals
by
electrolytic
methods
or
other
processes.
31
6.1.4.2.1
Production
and
Shipment
Values
Table
6­
17
shows
the
estimated
US
total
value
of
shipments
for
other
nonferrous
metal
primary
smelting
and
refining
products
for
1997.

Table
6­
17.
Estimated
United
States
Total
Value
of
Shipments
of
Other
Nonferrous
Metal
Primary
Smelting
and
Refining
Products:
1997
YEAR
TOTAL
VALUE
OF
SHIPMENTS
($
1,000)

1997
3,538,056
Source:
1997
Census
of
Manufacturers,
USDC.

6.1.4.2.2
Industry
Size
and
Market
Share
Data
used
to
characterize
this
industry
are
from
the
1997
Census
of
Manufacturers.
The
1997
Census
data
indicate
that
there
are
141
facilities
located
in
the
U.
S.,
owned
by
128
companies.
A
distribution
of
facilities
by
number
of
employees,
and
their
respective
share
of
the
total
value
of
shipments
is
provided
in
Table
6­
18.32
Table
6­
18.
Distribution
of
Facilities
by
Employment
for
the
Other
Nonferrous
Metal
Primary
Smelting
and
Refining
Industry
Employees
Per
Facility
Number
of
Facilities
Percent
of
Facilities
Percent
of
Total
Shipments
Value
1­
19
76
53.9%
3.2%

20
­
49
21
14.9%
10.2%

50
­
99
18
12.8%
11.6%

100
­
249
13
9.2%
19.3%
Table
6­
18.
Distribution
of
Facilities
by
Employment
for
the
Other
Nonferrous
Metal
Primary
Smelting
and
Refining
Industry
Employees
Per
Facility
Number
of
Facilities
Percent
of
Facilities
Percent
of
Total
Shipments
Value
33
U.
S.
Department
of
Commerce,
US
Census
Bureau,
1997
Economic
Census:
Bridge
Between
NAICS
and
SIC
34
1997
Census
of
Manufacturers,
USDC.
35
EPA.
1995.
EPA
Office
of
Compliance
Sector
Notebook
Project:
Profile
of
the
Nonferrous
Metal
Industry
EPA/
310­
R­
95­
010.

6­
16
250
­
499
13
9.2%
55.7%

Total
141
100.0%
100.0%

Source:
1997
Census
of
Manufacturers,
USDC.

6.1.4.2.3
Average
Facility
Size
Annual
sales
for
the
average
facility
was
estimated
assuming
that
the
largest
facilities
in
the
industry
were
reporting
BRS
waste
quantities.
Using
this
assumption,
we
estimated
average
annual
sales,
based
on
1997
Census
data,
updated
to
2001
dollars
using
the
GNP
Implicit
Price
Deflator
to
be
$
74,719,000.

6.1.4.3
The
Secondary
Smelting,
Refining
and
Alloying
of
Copper
Industry
Profile
The
secondary
smelting,
refining
and
alloying
of
copper
are
listed
under
the
NAICS
code
331423.
This
industry
is
a
subsector
of
the
primary
metal
industry
(
NAICS
331).
This
industry
comprises
establishments
primarily
engaged
in
recovering
copper
and
copper
alloys
from
scrap
and/
or
alloying
purchased
copper.
33
6.1.4.3.1
Production
and
Shipment
Values
The
secondary
smelting,
refining,
and
alloying
of
copper
manufacturers
industry
produces
primary
forms,
such
as
ingot,
wire
bar,
cake,
and
slab
from
copper
or
copper
alloys,
such
as
brass
and
bronze.
34
According
to
the
Bureau
of
Mines,
U.
S.
consumption
of
copper
in
1992
was
about
2.2
million
tons.
Consumption
rose
sharply
in
1993
and
1994
to
almost
2.7
million
tons
and
is
expected
to
continue
to
increase
throughout
the
1990s
due
to
a
growing
foreign
market.
However,
in
1991,
the
consumption
of
refined
copper
in
the
U.
S.
decreased
by
four
percent
from
1990
levels.
35
Table
6­
19
shows
the
estimated
US
total
value
of
shipments
for
the
products
in
this
industry
for
1997.
36
1997
Census
of
Manufacturers,
USDC.
37
EPA.
1995.
EPA
Office
of
Compliance
Sector
Notebook
Project:
Profile
of
the
Nonferrous
Metal
Industry
EPA/
310­
R­
95­
010.

6­
17
Table
6­
19.
Estimated
United
States
Total
Value
of
Shipments
of
Secondary
Smelting,
Refining,
and
Alloying
of
Copper
Products:
1997
YEAR
TOTAL
VALUE
OF
SHIPMENTS
($
1,000)

1997
1,269,088
Source:
1997
Census
of
Manufacturers,
USDC.

6.1.4.3.2
Industry
Size
and
Market
Share
Data
used
to
characterize
this
industry
are
from
the
1997
Census
of
Manufacturers.
The
1997
Census
data
indicate
that
there
are
35
facilities
located
in
the
U.
S.,
owned
by
34
companies.
Over
75
percent
of
all
facilities
employ
fewer
than
100
people.
36
A
distribution
of
facilities
by
number
of
employees,
and
their
respective
share
of
the
total
value
of
shipments
is
provided
in
Table
6­
20.
The
secondary
copper
industry
is
concentrated
in
South
Carolina,
Georgia,
Illinois,
and
Missouri.
37
Table
6­
20.
Distribution
of
Facilities
by
Employment
for
the
Secondary
Smelting,
Refining
and
Alloying
of
Copper
Industry
Employees
Per
Facility
Number
of
Facilities
Percent
of
Facilities
Percent
of
Total
Shipments
Value
1­
19
6
17.1%
N/
A
20
­
49
12
34.3%
12.3%

50
­
99
9
25.7%
31.0%

100
­
249
8
22.9%
54.9%

Total
35
100.0%
100.0%

Source:
1997
Census
of
Manufacturers,
USDC.

6.1.4.3.3
Typical
Products
The
secondary
smelting,
refining,
and
alloying
of
copper
manufacturers
industry
produces
primary
forms,
such
as
ingot,
wire
bar,
cake,
and
slab
from
copper
or
copper
alloys,
such
as
brass
and
38
EPA.
1995.
EPA
Office
of
Compliance
Sector
Notebook
Project:
Profile
of
the
Nonferrous
Metal
Industry
EPA/
310­
R­
95­
010.
39
U.
S.
Department
of
Commerce,
US
Census
Bureau,
1997
Economic
Census:
Bridge
Between
NAICS
and
SIC
40
1997
Census
of
Manufacturers,
USDC.

6­
18
bronze.
In
the
secondary
production
of
copper,
scrap
metal
goes
through
pretreatment
and
smelting.
Pretreatment
can
be
accomplished
through
several
different
methods,
two
of
which
are
the
hydrometallurgical
method
and
the
pyrometallurgical
method.
Hydrometallurgical
technologies
differ
from
pyrometallurgical
processes
in
that
the
desired
metals
are
separated
from
undesirable
metals
using
techniques
that
capitalize
on
differences
between
constituent
solubilities
and/
or
electrochemical
properties
while
in
aqueous
solutions.
After
pretreatment
the
scrap
goes
through
the
smelting
process.
Within
the
United
States,
the
leading
end
users
of
copper
and
copper
alloy
are
the
construction
and
electronic
products
industry.
Transportation
equipment
also
accounts
for
a
fair
amount
of
copper
end­
usage
at
11.6
percent.
38
6.1.4.3.4
Average
Facility
Size
Annual
sales
for
the
average
facility
was
estimated
assuming
that
the
largest
facilities
in
the
industry
were
reporting
BRS
waste
quantities.
Using
this
assumption,
we
estimated
average
annual
sales,
based
on
1997
Census
data,
updated
to
2001
dollars
using
the
GNP
Implicit
Price
Deflator
to
be
$
68,807,000.

6.1.4.4
Other
Nonferrous
Metal
Secondary
Smelting,
Refining,
Alloying
Manufacturing
Industry
Profile
The
other
nonferrous
metal
secondary
smelting,
refining,
and
alloying
manufacturers
are
listed
under
the
NAICS
code
331492
(
SIC
3341).
This
industry
is
a
subsector
of
the
primary
metal
industry
(
NAICS
331).
This
industry
comprises
establishments
primarily
engaged
in
alloying
purchased
nonferrous
metals
and/
or
recovering
nonferrous
metals
from
scrap.
39
6.1.4.4.1
Production
and
Shipment
Values
The
secondary
smelting,
refining,
and
alloying
of
nonferrous
metal
manufacturers
industry
produces
primary
forms
(
e.
g.,
bar,
billet,
bloom,
cake,
ingot,
slab,
slug,
wire)
using
smelting
or
refining
processes.
40
Table
6­
21
shows
the
estimated
US
total
value
of
product
shipments.
41
1997
Census
of
Manufacturers,
USDC.

6­
19
Table
6­
21.
Estimated
United
States
Total
Value
of
Shipments
of
Other
Nonferrous
Metal
Secondary
Smelting,
Refining,
Alloying
Products:
1997
YEAR
TOTAL
VALUE
OF
SHIPMENTS
($
1,000)

1997
3,750,387
Source:
1997
Census
of
Manufacturers,
USDC.

6.1.4.4.2
Industry
Size
and
Market
Share
Data
used
to
characterize
this
industry
are
from
the
1997
Census
of
Manufacturers.
The
Census
data
indicate
that
there
are
252
facilities
located
in
the
U.
S.,
owned
by
236
companies.
Over
85
percent
of
all
facilities
employ
fewer
than
100
people.
41
A
distribution
of
facilities
by
number
of
employees,
and
their
respective
share
of
the
total
value
of
shipments
is
provided
in
Table
6­
22.

Table
6­
22.
Distribution
of
Facilities
by
Employment
of
the
Other
Nonferrous
Metal
Secondary
Smelting,
Refining,
Alloying
Industry
Employees
Per
Facility
Number
of
Facilities
Percent
of
Facilities
Percent
of
Total
Shipments
Value
1­
19
148
58.7%
8.2%

20
­
49
48
19.0%
13.5%

50
­
99
25
9.9%
14.9%

100
­
249
23
9.1%
46.3%

250
­
500
6
2.4%
N/
A
500
&
above
2
0.9%
N/
A
Total
252
100.0%
100.0%

Source:
1997
Census
of
Manufacturers,
USDC.

6.1.4.4.3
Typical
Products
The
secondary
smelting,
refining,
and
alloying
of
nonferrous
metal
manufacturers
industry
produce
primary
forms
(
e.
g.,
bar,
billet,
bloom,
cake,
ingot,
slab,
slug,
wire)
using
smelting
or
refining
processes.
In
the
secondary
production
of
nonferrous
metals,
metals
are
produced
from
scrap
and
waste.
Two
metal
recovery
technologies
are
used
to
make
refined
metals,
pyrometallurgical
technology
and
the
hydrometallurgical
technology.
The
four
most
widely
used
nonferrous
metals
in
the
United
States
are
aluminum,
copper,
lead,
and
zinc.
Within
the
United
42
EPA.
1995.
EPA
Office
of
Compliance
Sector
Notebook
Project:
Profile
of
the
Nonferrous
Metal
Industry
EPA/
310­
R­
95­
010.
43
U.
S.
Department
of
Commerce,
US
Census
Bureau,
1997
Economic
Census:
Bridge
Between
NAICS
and
SIC.

6­
20
States,
the
leading
end
users
of
nonferrous
metals
include
the
automotive
industry,
the
construction
industry,
the
power
storage
battery
industry,
and
the
electrical
and
machinery
industry.
42
6.1.4.4.4
Average
Facility
Size
Annual
sales
for
the
average
facility
was
estimated
assuming
that
the
largest
facilities
in
the
industry
were
reporting
BRS
waste
quantities.
Using
this
assumption,
we
estimated
average
annual
sales,
based
on
1997
Census
data,
updated
to
2001
dollars
using
the
GNP
Implicit
Price
Deflator
to
be
$
56,266,000.

6.1.5
Coating,
Engraving,
Heat
Treating,
and
Allied
Activities
The
Coating,
Engraving,
Heat
Treating
and
Allied
Activities
Industry
(
NAICS
3328)
contains
a
broad
range
of
industries.
For
the
purpose
of
this
analysis,
The
Plating
and
Polishing
Industry
will
be
profiled.

6.1.5.1
Plating
and
Polishing
Industry
Profile
The
plating
and
polishing
industry
is
listed
under
the
NAICS
code
for
Paints
and
Coatings
as
332813
(
SIC
3471).
This
industry
is
a
sub­
sector
of
the
fabricated
metal
product
manufacturing
industry
(
NAICS
332).
The
plating
and
polishing
industry
is
primarily
engaged
in
all
types
of
electroplating,
plating,
anodizing,
coloring,
and
finishing
of
metals
and
formed
products
for
the
trade.
Also
included
in
this
industry
are
establishments
which
perform
these
types
of
activities,
on
their
own
account,
on
purchased
metals
or
formed
products.
43
6.1.5.1.1
Production
and
Shipment
Values
Table
6­
23
shows
the
estimated
US
total
value
of
shipments
for
plating
and
polishing
products.

Table
6­
23.
Estimated
United
States
Total
Value
of
Shipments
of
Plating
and
Polishing
Products:
1997
YEAR
TOTAL
VALUE
OF
SHIPMENTS
($
1,000)

1997
5,940,626
Source:
1997
Census
of
Manufacturers,
USDC.
6­
21
6.1.5.1.2
Industry
Size
and
Market
Share
Data
used
to
characterize
the
plating
and
polishing
industry
are
from
the
1997
Census
of
Manufacturers.
The
1997
Census
data
indicate
that
there
are
3,399
facilities
located
in
the
U.
S.,
owned
by
3,282
companies.
Over
95
percent
of
all
facilities
employ
fewer
than
100
people.
A
distribution
of
facilities
by
number
of
employees,
and
their
respective
share
of
the
total
value
of
shipments
is
provided
in
Table
6­
24.

Table
6­
24.
Distribution
of
Facilities
by
Employment
for
the
Plating
and
Polishing
Industry
Employees
Per
Facility
Number
of
Facilities
Percent
of
Facilities
Percent
of
Total
Shipments
Value
36178
2349
69.1%
19.0%

20­
49
674
19.8%
25.6%

50­
99
268
7.9%
27.3%

100­
249
94
2.8%
20.2%

250
&
above
14
0.4%
7.9%

Total
3399
100.0%
100.0%

Source:
1997
Census
of
Manufacturers,
USDC.

6.1.5.1.3
Average
Facility
Size
Annual
sales
for
the
average
facility
was
estimated
assuming
that
the
largest
facilities
in
the
industry
were
reporting
BRS
waste
quantities.
Using
this
assumption,
we
estimated
average
annual
sales,
based
on
1997
Census
data,
updated
to
2001
dollars
using
the
GNP
Implicit
Price
Deflator
to
be
$
9,392,000.

6.1.6
Semiconductor
and
Other
Electronic
Component
Manufacturing
The
Semiconductor
and
Other
Electronic
Component
Manufacturing
Industry
(
NAICS
3344)
contains
a
broad
range
of
industries.
For
the
purpose
of
this
analysis,
The
Printed
Circuit
Board
Industry
will
be
examined.

6.1.6.1
Printed
Circuit
Board
Industry
Profile
The
printed
circuit
board
industry
is
listed
under
the
NAICS
code
as
334412
(
and
SIC
3672).
The
printed
circuit
board
industry
is
a
part
of
the
computer
and
electronic
product
manufacturing
industry
(
NAICS
334).
This
industry
comprises
establishments
primarily
engaged
in
manufacturing
bare
(
i.
e.,
rigid
or
flexible)
printed
circuit
boards
without
mounted
electronic
44
U.
S.
Department
of
Commerce,
US
Census
Bureau,
1997
Economic
Census:
Bridge
Between
NAICS
and
SIC.

6­
22
components.
These
establishments
print,
perforate,
plate,
screen,
etch,
or
photoprint
interconnecting
pathways
for
electric
current
on
laminates.
44
6.1.6.1.1
Production
and
Shipment
Values
Table
6­
25
shows
the
estimated
US
total
value
of
shipments
for
printed
circuit
wire
boards.

Table
6­
25.
Value
of
Shipments
of
Printed
Circuit
Boards:
1995
­
2000
(
Value
in
millions
of
dollars)

YEAR
TOTAL
VALUE
OF
SHIPMENTS
2000
11,129
1999
9,150
1998
8,473
1997
8,702
1996
8,217
1995
8,367
Source:
U.
S.
Department
of
Commerce,
Bureau
of
the
Census,
Current
Industrial
Reports,
Inorganic
Chemicals
1998,
MA
334Q(
00)­
1,
September,
2001
6.1.6.1.2
Industry
Size
and
Market
Share
Data
used
to
characterize
the
printed
circuit
board
industry
are
from
the
1997
Census
of
Manufacturers
and
the
2000
Census
Current
Industrial
Report.
The
1997
Census
data
indicate
that
there
are
1,389
facilities
located
in
the
U.
S.,
owned
by
1,315
companies.
Close
to
90
percent
of
all
facilities
employ
fewer
than
100
people.
A
distribution
of
facilities
by
number
of
employees,
and
their
respective
share
of
the
total
value
of
shipments
is
provided
in
Table
6­
26.
6­
23
Table
6­
26.
Distribution
of
Facilities
by
Employment
for
the
Printed
Circuit
Board
Industry
Employees
Per
Facility
Number
of
Facilities
Percent
of
Facilities
Percent
of
Total
Shipments
Value
1­
19
801
57.7%
5.2%

20­
49
268
19.3%
8.3%

50­
99
144
10.4%
11.5%

100­
249
114
8.2%
22.6%

250
&
above
62
4.4%
52.4%

Total
1,389
100.0%
100.0%

Source:
1997
Census
of
Manufacturers,
USDC.

6.1.6.1.3
Average
Facility
Size
Annual
sales
for
the
average
facility
was
estimated
assuming
that
the
largest
facilities
in
the
industry
were
reporting
BRS
waste
quantities.
Using
this
assumption,
we
estimated
average
annual
sales,
based
on
1997
Census
data,
updated
to
2001
dollars
using
the
GNP
Implicit
Price
Deflator
to
be
$
25,240,000.

6.2
Facility
Level
Impacts
In
this
section
an
overview
of
facility
level
impacts
is
presented.
Impacts
are
presented
for
average
size
facilities
profiled
in
the
previous
section
which
reported
waste
generation
in
the
1999
Biennial
Report
database.

Facility
revenues
were
estimated
using
Census
of
Commerce
data
from
1997,
updated
to
2002
dollars
using
the
GDP
Implicit
Price
Deflator.
In
order
to
approximate
facility
level
revenues
the
assumption
was
made
that
only
the
largest
facilities
(
in
terms
of
revenue
generation)
would
report
waste
in
the
BRS
database.

Profitability
for
these
facilities
was
estimated
using
data
from
Robert
Morris
Associates.
Financial
data
were
averaged
over
a
3­
year
period
(
1999­
2001)
for
various
sizes
of
facilities
in
terms
of
annual
sales.
All
financial
data
were
updated
to
a
2002
basis
using
the
GDP
Implicit
Price
Deflator.
Profitability
estimates
were
developed
for
various
sizes
of
facilities,
expressed
as
profit
before
taxes
as
a
percent
of
sales.
With
average
sales
data
developed
using
Census
data
(
described
above),
profits
before
taxes
were
estimated
for
average
size
facilities.

Table
6­
27
presents
impacts
from
excluding
reclaimed
wastes
from
RCRA
jurisdiction
if
reclaimed
on­
site
or
reclaimed
off­
site
within
the
same
Industry
Group
(
4­
digit
NAICS).
Impacts
6­
24
for
each
of
the
major
industries
presented
are
typically
less
than
0.1
percent
of
sales.
Impacts
on
profitability
are
significantly
larger,
with
profitability
increasing
by
as
much
as
2.9
percent
in
NAICS
3252
(
Resin,
Synthetic
Rubber,
and
Artificial
and
Synthetic
Fibers
and
Filaments
Manufacturing).

Table
6­
27.
Facility
Impacts
for
Major
Industry
Groups
(
NAICS)
1/

NAICS
Number
of
Facilities
Affected
Estimated
Annual
Average
Sales
2/
Estimated
Annual
Profit
Before
Taxes
3/
Estimated
Annual
Average
Cost
Savings
4/
Cost
Savings
as
a
Percent
of
Sales
5/
Cost
Savings
as
a
Percent
of
Profits
6/

3251
302
$
186,090,000
$
11,537,000
$
53,230
0.03%
0.46%

3252
112
$
179,369,000
$
6,458,000
$
185,520
0.10%
2.87%

3254
124
$
271,863,000
$
31,264,000
$
57,330
0.02%
0.18%

3312
152
$
447,372,000
$
16,085,000
$
258,580
0.06%
1.61%

3314
105
$
119,793,000
$
4,911,000
$
29,120
0.02%
0.59%

3328
431
$
9,882,000
$
514,000
$
1,440
0.01%
0.28%

3344
464
$
26,558,000
$
1,062,000
$
24,860
0.09%
2.34%

Other
1038
­
­
$
40,770
­
­

NA
165
­
­
$
165,900
­
­

NA­
Not
available
from
BRS
1/
Includes
both
1999
and
1997
generators
who
recycled
some
portion
of
their
waste.
For
off­
site
recovery,
wastes
recovered
at
facilities
in
the
same
Industry
Group
(
4­
digit
NAICS)
as
the
generator
and
off­
site
outside­
generatorindustry
recycled
wastes
which
are
economical
to
recover
on­
site
are
included.
2/
Estimated
average
sales
per
large
quantity
generator
reporting
waste
generation
in
BRS.
Calculated
as
the
average
value
of
shipments
for
the
facilities
with
more
than
50
employees
as
reported
in
1997
Census
(
updated
to
2002
$).
3/
Average
3­
year
profits
in
2002
$
based
on
Robert
Morris
Associates
data
(
1998­
2000)
4/
Based
on
cost
calculations
presented
in
Chapter
5
5/
Annual
average
cost
savings
divided
by
annual
average
sales
6/
Annual
average
cost
savings
divided
by
annual
average
profits
In
addition
to
these
cost
savings
there
will
likely
be
additional
savings
as
facilities
in
other
industries
which
were
not
explicitly
considered
will
recycle
wastes
which
are
currently
disposed.
The
volume
of
additional
waste
which
will
be
recycled
will
depend
on
the
quality
of
the
waste,
6­
25
especially
the
value/
concentration
of
the
recovered
component.
Accordingly
the
above
estimates
likely
understate
the
total
cost­
reducing
impacts.

6.3
Distributional
Impacts
In
addition
to
the
impacts
presented
in
the
previous
sections
there
will
also
be
certain
distributional
impacts,
especially
resulting
from
changes
in
taxes
levied
on
the
generation
of
hazardous
waste.
State
imposed
hazardous
waste
generation
taxes
and
fees
have
been
identified
for
facilities
located
in
27
states.
These
state
taxes
and
fees
are
listed
in
Appendix
F.

Table
6­
28
presents
a
summary
of
the
estimated
decreases
in
tax
revenue
resulting
from
the
hazardous
waste
generation
taxes.
In
total,
waste
generation
taxes
will
decline
by
approximately
$
12.2
million
for
the
27
states
analyzed.
In
addition
to
the
waste
generation
distributional
impacts
there
will
be
other
distributional
impacts
stemming
from
increased
corporate
income
taxes
which
have
not
been
quantified.
No
tax
effect
is
included
for
wastes
that
are
currently
being
disposed
but
may
be
recovered
post­
rule
due
to
the
uncertainties
about
the
quality
of
waste
and
the
total
amount
which
would
be
recovered.

Table
6­
28.
Estimated
Changes
in
Hazardous
Waste
Generation
Tax
Revenues
State
1/
Total
Decrease
in
State
Tax
Revenue
($/
yr)
Number
Facilities
with
Tax
Decrease
Average
Savings
per
Facility
($/
yr)
AR
1,000
1
626
AZ
13,835
21
5,879
CA
2,046,553
47
7,516
CO
19,696
16
1,231
CT
4,678
12
390
GA
29,520
29
1,018
ID
18,152
3
6,051
KS
13,142
9
1,460
KY
104,775
37
2,832
ME
30,051
11
2,732
MN
2,560,691
47
54,483
MO
65,444
23
2,845
MS
2,500
1
2,500
MT
1,800
3
600
Table
6­
28.
Estimated
Changes
in
Hazardous
Waste
Generation
Tax
Revenues
State
1/
Total
Decrease
in
State
Tax
Revenue
($/
yr)
Number
Facilities
with
Tax
Decrease
Average
Savings
per
Facility
($/
yr)

6­
26
NC
10,603
37
287
NH
60,674
6
10,112
NJ
21,071
36
585
NM
23,070
2
11,535
NY
648,752
16
40,547
OK
11,754
6
1,959
OR
507,636
31
16,375
SC
538,023
19
28,317
TN
4,500
4
1,125
TX
229,288
61
3,759
VA
9,021
4
2,255
WA
678
15
45
WI
10,707
23
466
6,987,614
520
13,438
1/
Estimates
are
not
included
for
DE,
IL,
NE,
NV,
OH,
and
WV
where
further
analysis
needs
to
be
conducted
to
determine
tax
rates.
In
addition,
all
potential
taxes
are
not
included
in
the
estimates
for
NY
and
TX
where
further
analysis
is
needed
to
determine
tax
rates.
45
U.
S.
EPA,
Office
of
Solid
Waste
and
Emergency
Response,
"
RCRA:
Reducing
Risk
From
Waste
OSWER,"
EPA530­
K­
97­
004,
September
1997,
pp
14­
15.
46
U.
S.
Geological
Survey
 
Minerals
Information,
"
Recycling
 
Metals,"
1996,
p.
1.
47
Ibid.

7­
1
7.0
BENEFITS
Providing
exclusions
from
the
RCRA
Definition
of
Solid
Waste
to
generators
of
metal­
bearing,
solvent,
and
other
wastes
(
e.
g.,
acid)
that
recover
wastes
either
on­
site
or
within
the
same
industry,
provides
an
economic
incentive
for
more
generators
to
recover
metals,
solvents,
and
acids
from
wastes
instead
of
placing
it
in
a
landfill,
reusing
it
as
fuel,
or
neutralizing
the
acid
and
discharging
it
as
wastewater,
respectively.
In
addition,
it
provides
an
incentive
to
generators
recovering
wastes
to
continue
the
practice
in
markets
with
fluctuating
product
values
(
e.
g.,
metal
prices).
Also,
depending
on
the
recovery
technology
implemented,
such
as,
ion
exchange,
it
may
promote
recycling
treated
wastewater
back
into
process
units.
Increased
recovery
of
metals,
solvents
and
other
values,
such
as
acid,
and
treated
wastewater
may
result
in
a
net
benefit
to
both
society
and
the
environment.

7.1
Qualitative
Benefits
Some
of
the
expected
benefits
include
the
following:

°
Landfill
Capacity:
Approximately
23
million
tons
of
hazardous
waste
are
land
disposed
annually.
In
1995,
1
million
tons
of
the
land
disposed
hazardous
waste
were
disposed
in
landfills
along
with
208
million
tons
of
municipal
waste.
45
Available
landfill
space
is
limited
and
as
overcapacity
issues
are
eminent,
any
increase
in
recycling
will
lessen
the
future
burden
on
landfills.

°
Resource
Conservation:
The
supply
of
metals
used
in
processes
such
as
electroplating
are
ultimately
fixed
by
nature.
Many
metals
are
easily
recycled
and
today
recycled
metals
make
up
a
large
portion
of
the
available
metals
supply.
For
instance,
the
U.
S.
Geological
Survey
reported
that
in
1996,
78
million
metric
tons
of
metals
were
recycled
in
the
U.
S.
The
value
of
these
recycled
metals
was
estimated
to
be
approximately
$
18
billion.
46
As
the
U.
S.
Geological
Survey
states,
"
Recycling,
a
significant
factor
in
the
supply
of
many
of
the
key
metals
used
in
our
society,
provides
environmental
benefits
in
terms
of
energy
savings,
reduced
volumes
of
waste,
and
reduced
emissions.
These
reductions,
in
turn,
result
in
reduced
disturbance
to
land,
reduced
pollution,
and
reduced
energy
use."
47
°
Resource
Conservation:
In
some
portions
of
the
United
States
water
is
scarce.
Technologies
such
as
ion
exchange
remove
metal
and
other
ions
from
wastewater
to
concentrations
below
levels
typically
achieved
by
metals
precipitation
technologies.
Treated
wastewater
from
ion
exchange
technologies
can
be
reused
in
the
electroplating
process
reducing
demand
on
scarce
water
resources.
48
Based
on
the
difference
between
imports
and
exports
of
each
commodity
as
reported
in
Jacqueline
A.
McClaskey
and
Stephen
D.
Smith,
"
Survey
Methods
and
Statistical
Summary
of
Nonfuel
Minerals,"
U.
S.
Department
of
the
Interior,
Bureau
of
Mines,
1991.
As
reported,
supra,
Note
38,
USEPA,
p.
134.
49
A
strategic
metal
is
a
metal
which
is
required
for
critical
military
and/
or
civilian
use
and
for
which
the
United
States
is
dependent
upon
from
vulnerable
sources
of
supply.
As
reported,
Borst,
Paul
A.,
"
Recycling
of
Wastewater
Treatment
Sludges
From
Electroplating
Operations,
F006,"
USEPA,
OSW.
50
Supra,
Note
38,
pp.
138­
139.
51
Borst,
Paul
A.,
"
Recycling
of
Wastewater
Treatment
Sludges
From
Electroplating
Operations,
F006,"
USEPA,
OSW.

7­
2
°
Metal
Recovery:
An
increase
in
recycling
of
domestic
metals
will
lessen
the
dependance
of
the
United
States
on
foreign
metal
supplies.
In
1991,
the
United
States
ran
a
$
9.8
billion
balance
of
trade
deficit
for
metal
commodities.
48
Copper,
nickel,
and
zinc,
three
of
the
most
common
metals
recovered
from
electroplating
waste,
accounted
for
more
than
$
2
billion
of
this
total.
Additionally,
several
metal
recyclers
of
F006
waste,
which
is
one
of
many
potential
wastes
affected
by
the
proposed
rule,
reported
that
metal
recovery
of
nickel,
chromium
and
zinc
bearing
secondary
materials
was
more
efficient
in
terms
of
conserving
energy,
and
reducing
solid
waste
residuals
associated
with
primary
metal/
mineral
production.
Finally,
in
its
Report
to
Congress
on
Metal
Recovery,
Environmental
Regulation
and
Hazardous
Waste,
EPA
reported
that
chromium,
a
strategic
metal,
49
is
found
in
sources
of
secondary
materials
such
as
electroplating
waste.
The
report
also
indicates
that
these
secondary
materials
are
underutilized
as
a
potential
source
of
secondary
chromium
to
reduce
U.
S.
dependence
on
foreign
primary
sources.
50
51
°
Solvent/
Acid
Recovery:
An
increase
in
the
recovery
of
solvents/
acids
on
site
will
reduce
the
amount
of
energy
used
and
feedstock
material
used
to
produce
and
transport
virgin
solvents
and
acids.

7.2
Quantitative
Benefits
The
following
salvage
value
estimates
were
derived
only
considering
waste
currently
recovered
in
1999
and
waste
previously
recovered
in
1997.
These
salvage
values
(
revenues)
are
included
in
the
cost
estimates
in
Section
5.
The
estimates
do
not
take
into
consideration
that
there
will
be
additional
benefits
beyond
those
quantified
as
generators
recycle
more
and
more
of
their
waste
as
a
result
of
the
rule.

°
Value
of
Recovered
Metal
Products:
In
1999,
plants
affected
by
this
rulemaking
reported
recovering
409,315
tons
of
metal­
bearing
waste
on
site
and
18,647
tons
off
site
within
the
same
Industry
Group.
In
addition
an
estimated
168,695
tons
of
metal­
bearing
waste
are
recovered
off­
site
in
other
industries,
which
may
be
recovered
on­
site
due
to
the
potential
rule
change
if
it
is
economically
feasible
to
construct
on­
site
recovery
facilities.
In
the
analysis,
it
is
assumed
that
these
recovered
wastes
contain
20
percent
recoverable
metals.
At
a
$
4,770
per
ton
average
market
price
(
assuming
a
90
percent
assay
value)
for
copper,
chromium,
and
7­
3
nickel,
the
estimated
metal
value
is
$
569
million.
This
proposed
rule
encourages
these
plants
to
continue
recovering
these
metals
and
maintaining
these
benefits.

Plants
that
reported
recovering
wastes
in
1997
and
not
in
1999
recovered
2,778
tons
of
metalbearing
waste
on
site
and
229
tons
off
site
within
the
same
Industry
Group.
The
estimated
metal
value
is
$
2.9
million.
In
addition,
facilities
that
dispose
two
waste
types
(
48,235
tons
of
emission
control
dust
­
K061,
19,108
tons
of
metal­
containing
liquids
from
the
printed
circuit
board
industry,
and
10,869
tons
of
spent
catalyst
from
the
petroleum
refining
industry
­
K171/
K172)
are
estimated
to
switch
over
to
on­
site
recovery.
In
the
analysis,
it
is
assumed
that
these
recovered
emission
control
dust
wastes
contain
15
percent
recoverable
zinc
at
$
643
per
ton
(
assuming
a
90
percent
assay
value),
the
metal­
containing
liquids
contain
0.02
percent
copper
at
$
1,397
per
ton
(
assuming
a
90
percent
assay
value),
and
the
spent
catalyst
contains
five
percent
molybdenum
at
$
23,940
per
ton
(
assuming
a
90
percent
assay
value).
The
estimated
metal
value
from
these
disposed
wastes
is
$
17.7
million.
This
proposed
rule
may
encourage
these
new
benefits.

The
total
estimated
recovered
metal
value
is
$
590
million.

°
Value
of
Recovered
Solvent
Products:
In
1999,
plants
affected
by
this
rulemaking
reported
recovering
160,119
tons
of
solvent
waste
on
site
and
35,585
tons
off
site
within
the
same
Industry
Group.
In
addition
an
estimated
72,040
tons
of
solvent­
bearing
waste
are
recovered
off­
site
in
other
industries,
which
may
be
recovered
on­
site
due
to
the
potential
rule
change
if
it
is
economically
feasible
to
construct
on­
site
facilities.
In
the
analysis,
it
is
assumed
that
these
recovered
wastes
contain
67
percent
of
recoverable
solvents.
At
a
$
1,542
per
ton
average
market
price
for
solvents,
assuming
90
percent
effectiveness,
the
estimated
solvent
value
is
nearly
$
277
million.
This
proposed
rule
encourages
these
plants
to
continue
recovering
these
solvents
and
maintaining
these
benefits.

Plants
that
reported
recovering
wastes
in
1997
and
not
in
1999
recovered
8,448
tons
of
solvent
waste
on
site
and
4,031
tons
off
site
within
the
same
Industry
Group.
The
estimated
solvent
value
is
$
12.9
million
if
these
facilities
choose
to
switch
back
to
solvent
recovery
instead
of
off­
site
energy
recovery.
This
proposed
rule
may
encourage
these
new
benefits.

The
total
estimated
recovered
solvent
value
is
$
290
million.

°
Value
of
Other
Recovered
Products
(
Acids
and
Fluoride):
In
1999,
plants
affected
by
this
rulemaking
reported
recovering
248,914
tons
of
"
other"
waste
on
site
and
5,205
tons
off
site
within
the
same
Industry
Group.
In
addition
an
estimated
15,952
tons
of
other
waste
are
recovered
off­
site
in
other
industries,
which
may
be
recovered
on­
site
due
to
the
potential
rule
change.
In
the
analysis,
it
is
assumed
that
these
recovered
wastes
contain
74
percent
recoverable
acids.
At
a
$
298
per
ton
average
market
price
for
acid,
assuming
90
percent
effectiveness,
the
estimated
acid
value
is
over
$
60
million.
Other
wastes
were
primarily
acids.
52
Note,
characteristic
sludges
and
byproducts
from
recycling
processes
that
are
themselves
recycled
are
not
solid
wastes
or
hazardous
wastes
currently
(
40
CFR
§
261.2(
c)(
3)
and
would
not
be
under
today's
proposal.

7­
4
This
proposed
rule
encourages
these
plants
to
continue
recovering
these
acids
and
maintaining
these
benefits.

Plants
that
reported
recovering
wastes
in
1997
and
not
in
1999
recovered
16,318
tons
of
other
(
acid)
waste
on
site
and
245
tons
off
site
within
the
same
Industry
Group.
The
estimated
acid
value
is
$
3.7
million
if
these
facilities
choose
to
switch
back
to
acid
recovery
instead
of
on­
site
acid
neutralization.
In
addition,
facilities
that
dispose
two
waste
types
(
71,698
tons
of
spent
aluminum
potliner,
K088,
and
254,109
tons
of
spent
pickle
liquor
from
the
steel
works
industry)
are
estimated
to
switch
over
to
on­
site
recovery.
In
the
analysis,
it
is
assumed
that
these
recovered
spent
aluminum
potliner
wastes
contain
two
percent
recoverable
fluoride
at
$
1,240
per
ton
and
the
spent
pickle
liquor
contains
74
percent
recoverable
acids
at
$
298
per
ton
(
assuming
a
90
percent
assay
value).
The
estimated
metal
value
from
these
disposed
wastes
is
$
57.8
million.
This
proposed
rule
may
encourage
these
new
benefits.

The
total
estimated
recovered
acid
and
fluoride
value
is
$
122
million.

7.3
Qualitative
Discussion
of
Potential
Risk
of
Hazardous
Secondary
Materials
The
Agency
acknowledges
that
some
1.4
million
tons
of
hazardous
secondary
materials
would
be
no
longer
subject
to
regulation
as
hazardous
waste
under
subtitle
C
of
RCRA
under
this
proposal.
As
part
of
this
rulemaking,
EPA
has
not
evaluated
any
potential
for
changes
resulting
in
either
higher
or
lower
releases
to
the
environment
of
hazardous
constituents
from
different
handling
methods
for
affected
secondary
materials.
The
Agency
notes
that
most
hazardous
waste
that
is
currently
recycled
is
stored
in
tanks,
containers
or
buildings
prior
to
the
reclamation
process.
And
this
practice
is
likely
to
continue
post­
rule
both
because
most
affected
entities
have
already
purchased
these
storage
units
and
as
a
means
of
avoiding
legal
liability
for
releases
to
groundwater
from
land
based
units
(
materials
excluded
from
RCRA
subtitle
C
regulation
if
recycled
under
this
proposal
would
still
be
considered
hazardous
wastes
if
released
to
the
environment
and
then
abandoned).
Also,
residuals
from
excluded
recycling
processes
would
still
be
considered
hazardous
wastes
if
they
exhibit
a
hazardous
characteristic
and
are
discarded.
52
However,
residuals
from
formerly
listed
hazardous
wastes
would
not
be
considered
hazardous
wastes
under
the
derived­
from
rule
if
recycled
under
this
proposal.
In
such
cases,
these
residuals
could
be
land
disposed
in
units
other
than
hazardous
waste
landfills.
The
Agency
has
not
evaluated
the
potential
for
such
management
of
these
materials
to
result
in
a
change
in
releases
to
the
environment.

The
Agency
notes
that
there
is
the
potential
for
hazardous
wastes
to
be
released
over
time
from
land
based
units
(
that
may
or
may
not
result
in
a
risk
to
human
health
or
the
environment).
EPA
also
notes
that
there
is
potential
risk
from
extracting
natural
resources
and
processing
them
into
goods
for
public
consumption.
It
is
difficult
to
assess
the
net
7­
5
effects
of
this
proposal
on
the
probability
of
releases
of
toxic
constituents
to
the
environment.
The
Agency
solicits
comment
on
this
question.
8­
1
8.0
REFERENCES
Anonymous,
1999,
Personal
Communication,
Sun­
Glo
Plating,
Florida.

Anonymous,
1999,
Personal
Communication,
Dearborn
Brass,
Texas.

Bagsarian,
Tom,
"
Cashing
in
on
Steelmaking
Byproducts,"
New
Steel
Web
Extra,
March
1999,
http://
www.
newsteel.
com/
features/
NS9903f2.
htm
Bates,
Peter,
and
Muir,
Adrian,
"
HIsmelt­
Low
Cost
Iron
Making",
Gorham
conference
June
2000,
Commercializing
New
Hot
Metal
Process
­
Beyond
the
Blast
Furnace.

Borst,
Paul
A.,
U.
S.
EPA,
Office
of
Solid
Waste,
Economic,
Methods
and
Risk
Analysis
Division,
"
Recycling
of
Wastewater
Treatment
Sludges
from
Electroplating
Operations,"
F006,
18th
AESF/
EPA
Pollution
Prevention
and
Control
Conference,
January
27­
29,
1997.

Coplan,
Myron
J,
C.
E.,
"
Comments
on
the
Relative
Cost
of
Fluoride
from
NAF
and
FSA",
http://
www.
dartmouth.
edu/~
rmasters/
AHABS/
Costof.
html
Cushnie,
George
C.,
CAI
Engineering,
"
Pollution
Prevention
and
Control
Technology
for
Plating
Operations,"
prepared
for
NCMS/
NAMF.

Environmental
Cost
Handling
Options
and
Solutions
(
ECHOS),
Environmental
Remediation
Cost
Data­
Unit
Price,
4th
Annual
Edition,
published
by
R.
S.
Means
and
Delta
Technologies
Group,
Inc.,
1998.

Envirosource
Technologies
corporate
webpage,
"
Summary
of
Envirosource
and
the
Super
Detox
Technology
for
Treatment
of
Electric
Arc
Furnace
Dust,"
http://
www.
enso.
net/
detox.
html
Finnder,
Earl
,
October
2001,
Personal
Communication,
U.
S.
Filter.

Furukawa,
Tsukasa,
"
Recovering
Zinc
and
Iron
from
EAF
Dust
at
Chiba
Works,"
New
Steel,
June
1997,
http://
www.
newsteel.
com/
features/
NS9706F4.
htm
Griscom,
Frank,
"
FastMelt!
Your
Waste
to
Profit,"
Midrex
4th
Quarter,
1998,
www.
midrex.
com
Hazardous
Waste
Resource
Center,
January
2002
Landfill
Cost
Data,
www.
etc.
org.

HIsmelt
corporate
webpage,
http://
www.
hismelt.
com
Hoffman,
Glenn
E.,
"
Waste
Recycling
with
FastMet
and
FastMelt,"
Midrex
4th
Quarter,
2000,
www.
midrex.
com
8­
2
International
Zinc
Association­
ZincWorld
organization
website,
"
Concentration,
e.
g.
Waelz
Process,"
http://
www.
zincworld.
org/
zwo_
org/
Applications/
Zinc/
031204­
pdf.
pdf
Jarvis,
1999,
Personal
Communication,
Eritech,
North
Carolina.

Lamancusa,
James
P.,
P.
E.,
CEF,
"
Strategies
at
a
Decorative
Chromium
Electroplating
Facility:
On­
line
vs.
Off­
line
Recycling,"
Plating
and
Surface
Finishing,
April
1995.

Logistics
Management
Institute,
Hazardous
Waste
Manifest
Cost
Benefit
Analysis,
dated
October
2000.

Minnesota
Pollution
Control
Agency,
Small
and
Large
Quantity
Generator
License
Fees
and
Generator
(
Superfund)
Tax,
Waste/
Hazardous
Waste
#
1.03b,
March
2002.

MR3
Systems
Incorporated,
http://
www.
mr3systems.
com
Remedial
Action
Cost
Engineering
and
Requirements
(
RACER)
cost
estimating
software,
2002
Robert
Morris
Associates.
Annual
Statement
Studies.
Various
years
including
1999,
2000,
and
2001.
RMA,
One
Liberty
Place,
Philadelphia,
PA.

Shields,
1999,
Personal
Communication,
American
Nickeloid,
Illinois.

Toon,
Hohn,
"
The
Cost
of
Cleaning
the
Air:
Study
Shows
Permit
Application
Costs
Lower
Than
Expected
­
With
Key
Benefits
to
Industry",
Georgia
Tech
Research
News,
September
21,
1999.

Warski,
Kristine.
SIC
vs.
NAICS:
Understanding
the
Difference,
Miller
Brooks
Inc.

U.
S.
Army
Corp
of
Engineers,
Public
Works
Technical
Bulletin
200­
01­
04,
dated
August
31,
1999
(
USACE
Tech
Bulletin).

U.
S.
Army
Corps
of
Engineers,
HTRW
Center
of
Expertise
Information
­
TDSF,
Section
8.2,
obtained
from
http://
www.
environmental.
usace.
army.
mil/
library/
pubs/
tsdf/
sec8­
2/
sec8­
2.
html
on
September
11,
2002.

U.
S.
Department
of
Commerce,
US
Census
Bureau,
Development
of
NAICS,
http://
www.
census.
gov/
epcd/
www/
naicsdev.
htm..

U.
S.
Department
of
Commerce,
Census
of
Manufacturers,
Cyclic
Crudes
and
Intermediates,
EC97M­
3251I,
August
1999.

U.
S.
Department
of
Commerce,
Census
of
Manufacturers,
Alkalies
and
Chlorine
Manufacturing,
EC97M­
3251I,
September
1999.
8­
3
U.
S.
Department
of
Commerce,
Census
of
Manufacturers,
All
Other
Basic
Inorganic
Chemical
Manufacturing,
EC97M­
3251G,
October
1999.

U.
S.
Department
of
Commerce,
Census
of
Manufacturers,
All
Other
Basic
Organic
Chemical
Manufacturing,
EC97M­
3251K,
November
1999.

U.
S.
Department
of
Commerce,
1997
Census
of
Manufacturers,
1999.

U.
S.
EPA
1999
and
1997
Hazardous
Waste
Report
(
Biennial
Reports).

U.
S.
EPA,
Office
of
Regulatory
Enforcement,
Estimating
Costs
for
the
Economic
Benefits
of
RCRA
Noncompliance,
dated
September
1994.

U.
S.
EPA,
Economic
Assessment
of
the
Revised
LDR
Treatment
Standards
for
Spent
Aluminum
Potliner
(
K088),
prepared
by
DPRA
Incorporated,
March
1,
2000.

U.
S.
EPA,
Office
of
Management
and
Budget,
"
Economic
Analysis
of
Federal
Regulations
under
Executive
Order
12866"
(
OMB
Circular
A­
94),
dated
January
11,
1996.

U.
S.
EPA,
Regulatory
Impact
Analysis
of
the
Final
Rule
for
a
180­
Day
Accumulation
Time
for
F006
Wastewater
Treatment
Sludges,
November
10,
1999
(
F006
180­
Day
Accumulation
Rule).

U.
S.
EPA,
Office
of
Solid
Waste,
Economics,
Methods
and
Risk
Analysis
Division,
Unit
Cost
Compendium
(
UCC),
prepared
by
DPRA
Incorporated,
September
30,
2000.

U.
S.
EPA
­
New
England,
Pilot
of
the
Pollution
Prevention
Technology
Application
Analysis
Template
Utilizing
Acid
Recovery
System
prepared
by
Zero
Discharge
Technologies,
Inc,
dated
October
1999.
A­
1
Appendix
A
Co­
Proposal
Option
for
the
Regulatory
Modifications
to
the
Definition
of
Solid
Waste
for
the
Association
of
Battery
Recyclers
Notice
of
Proposed
Rulemaking
This
appendix
presents
the
estimated
cost
savings
(
economic
benefits)
for
a
regulatory
option
referred
to
as
the
Co­
Proposal
Option.
Under
the
(
approximately
$
63
million)
(
approximately
$
81
million).
If
facilities
construct
on­
site
recovery
units
they
qualify
for
the
exclusion
under
the
Co­
Proposal
Option.

Co­
Proposal
Option
Incremental
Costs
(
2002
$)

Quantity
(
tons)
Total
Costs
($/
year)

On­
Site
Recovery
­
1999
818,348
($
10,962,000)

On­
Site
Recovery
­
1997
27,544
($
16,151,000)

Off­
Site
Recovery
Within
Industry
Group
­
1999
26,069
($
419,000)

Off­
Site
Recovery
Within
Industry
Group
­
1997
1,059
($
905,000)
Co­
Proposal
Option
Incremental
Costs
(
2002
$)

Quantity
(
tons)
Total
Costs
($/
year)

A­
2
Off­
Site
Recovery
Outside
Industry
Group
Switch
to
On­
site
Recovery
­
1999
257,743
($
63,346,000)

On­
Site/
Off­
Site
Disposal
Switch
to
On­
Site
Recovery
for
Four
Waste
Types
(
K061,
K062,
K088,
and
metal­
containing
liquids
from
printed
circuit
board
industry)
404,019
($
80,827,000)

Total
1,534,782
($
172,610,000)

Note:
Numbers
in
parentheses,
"(
)",
represent
negative
costs
that
reflect
revenues
or
cost
savings.

1999
Off­
site
Recovery
Quantity
NAICS
3254,
pharmaceutical
and
medicine
NAICS
3312,
steel
product
manufacturing
from
purchased
steel,
recovered
6,700
tons
(
25.8
percent)
of
the
total
off­
site
recovery
quantity.
All
of
this
quantity
was
managed
by
metals
recovery.

NAICS
3252,
resin,
synthetic
rubber,
and
artificial
synthetic
fibers
and
filaments
manufacturing,
recovered
2,400
tons
(
9.3
percent)
of
the
total
off­
site
recovery
quantity.
All
of
this
quantity
was
managed
by
other
recovery.

.
A­
3
the
total
off­
site
recovery
quantity.
Nearly
all
of
this
quantity
was
managed
by
metals
recovery.

The
remaining
10
NAICS
codes
that
recover
less
than
30
tons
off­
site
in
1999
account
for
95
tons
(
0.36
percent)
of
the
total
off­
site
recovery
quantity.

Potential
Additional
Recovery
Approximately
1,000
tons
of
hazardous
waste
were
recovered
off­
site
in
1997
but
not
in
1999
within
the
same
Industry
Group
(
4­
digit
NAICS)
by
8
plants
within
4
NAICS
codes.
Facilities
that
recovered
their
waste
in
1997
and
not
in
1999
potentially
waste
under
the
proposed
rule.

One
NAICS
code
recovered
950
tons
in
1997
off­
site
but
not
in
1999.
This
NAICS
code
accounts
for
90
percent
of
the
total
quantity
recovered
off
site.
Metals
recovery,
solvents
recovery,
and
other
recovery
account
for
16
tons,
819
tons,
and
225
tons
of
the
total,
respectively.
Table
A­
2
presents
the
quantity
of
hazardous
waste
managed
off­
site
by
NAICS
code
and
.
This
quantity
was
managed
by
metals
recovery.

Summary
of
Potential
Cost
Savings
Incremental
cost
savings
(
post­
rule
costs
minus
pre­
rule
costs)
were
estimated
for
the
total
number
of
plants
currently
recovering
wastes
in
1999
or
recovered
wastes
in
1997.
These
plants
reclaim
metal,
solvent
and
other
values
from
873,000
tons
of
waste.
The
sum
of
the
pre­
rule
costs,
post­
rule
costs,
and
incremental
cost
savings
for
all
plants
are
presented
in
Table
A­
3
by
individual
unit
cost
item.
A­
4
The
potential
incremental
annual
cost
savings
range
from
$
12
million
if
only
1999
plants
benefit
to
$
28
million
if
the
plants
that
recovered
wastes
in
1997
and
not
in
1999
switch
back
to
recovery.

For
the
1999
on­
site
recovery
plants,
the
total
estimated
annual
cost
savings
is
$
11
million.
This
total
includes
one­
time
(
first
year)
contingency
planning
cost
savings
of
$
0.8
million
that
likely
are
sunk
and
one­
time
notification
of
exclusion
costs
of
$
0.5
million.
The
greatest
annual
savings
result
from
a
portion
of
the
residual
quantity
generated
by
the
recovery
processes
being
classified
as
nonhazardous
($
5.3
million
in
residual
hazardous
waste
landfill
cost
savings
­
$
3.0
million
in
new
non­
hazardous
waste
landfill
costs
+
$
2.3
million
in
nonhazardous
transportation
cost
savings
=
$
4.6
million
in
cost
savings).
The
second
largest
annual
cost
savings
is
from
a
reduction
in
hazardous
materials
training
costs
($
2.8
million
in
cost
savings).
The
third
largest
annual
cost
savings
is
from
a
reduction
in
waste
characterization
testing
costs
($
2.1
million).

For
the
1997
on­
site
recovery
plants,
the
total
estimated
annual
cost
savings
is
$
16.2
million.
This
total
includes
one­
time
(
first
year)
contingency
planning
cost
savings
of
$
0.2
million
that
likely
are
not
sunk
because
plants
are
switching
management
technologies
and
one­
time
notification
of
exclusion
costs
of
$
0.2
million.
The
greatest
annual
savings
result
from
a
portion
of
the
residual
quantity
generated
by
the
recovery
processes
being
classified
as
nonhazardous
($
4.3
million
in
pre­
rule
baseline
management
costs
­
$
1.5
million
in
post­
rule
residual
hazardous
waste
landfill
costs
­
$
0.2
million
in
post­
rule
non­
hazardous
waste
landfill
costs
­
$
8.0
million
in
post­
rule
recovery
system
costs
+
$
2.0
million
in
nonhazardous
transportation
cost
savings
+
$
16.9
million
in
value
from
the
recovered
products
=
$
13.5
million
in
cost
savings).
The
second
largest
annual
cost
savings
is
from
a
reduction
in
waste
characterization
testing
costs
($
1.7
million).
The
third
largest
annual
cost
savings
is
from
a
reduction
in
hazardous
materials
training
costs
($
0.6
million).

For
those
1999
plants
that
recovered
wastes
off­
site
within
the
same
4­
digit
NAICS,
the
total
estimated
annual
cost
savings
is
$
0.4
million.
The
largest
annual
cost
savings
is
from
a
reduction
in
the
cost
to
transport
wastes
for
recovery
because
of
fewer
shipments,
i.
e.,
longer
storage
times
($
0.15
million
in
cost
savings).
The
second
largest
annual
savings
result
from
a
portion
of
the
residual
quantity
generated
by
the
recovery
processes
being
classified
as
nonhazardous
($
0.28
million
in
residual
hazardous
waste
landfill
cost
savings
­
$
0.21
million
in
post­
rule
non­
hazardous
waste
landfill
costs
+
$
0.06
million
in
nonhazardous
transportation
cost
savings
=
$
0.13
million
in
cost
savings).
The
third
largest
annual
cost
savings
is
from
a
reduction
in
hazardous
materials
training
costs
($
0.07
million).

For
those
1997
plants
that
recovered
wastes
off­
site
within
the
same
4­
digit
NAICS,
the
total
estimated
annual
cost
savings
is
$
0.9
million.
The
greatest
annual
cost
savings
is
from
a
portion
of
the
residual
quantity
generated
by
the
recovery
processes
being
classified
as
nonhazardous
($
0.32
million
in
pre­
rule
hazardous
waste
management
costs
­
$
0.11
million
in
post­
rule
residual
hazardous
waste
landfill
costs
­
$
0.01
million
in
post­
rule
non­
hazardous
waste
landfill
costs
­
$
0.22
million
in
post­
rule
recovery
system
costs
+
$
0.04
million
in
post­
rule
nonhazardous
transportation
cost
savings
­
$
0.09
million
in
post­
rule
off­
site
recovery
transport
costs
+
$
0.9
million
in
value
from
the
recovered
products
=
$
0.83
million
in
cost
savings).
The
second
largest
A­
5
annual
savings
result
from
a
reduction
in
waste
characterization
testing
costs
($
0.06
million
in
cost
savings).
There
were
no
cost
savings
predicted
that
would
result
from
a
change
in
generator
status
from
LQG
to
SQG,
etc.
(
e.
g.,
decreased
training,
BRS/
general
administrative
duty,
contingency
planning,
and
initial
characterization
costs).
A­
6
Table
A­
1
Co­
Proposal
Option:
1999
Offsite
Recovery
Within
Same
Industry
Group
(
4­
digit
NAICS
Code)
(
Tons)

NAICS
METALS
RECOVERY
Total
Metals
SOLVENTS
RECOVERY
Total
Solvents
OTHER
RECOVERY
Total
Other
TOTALS
Code
M011
M012
M013
M014
M019
Recovery
M021
M022
M023
M024
M029
Recovery
M031
M032
M039
Recovery
Quantity
%
Cumulative
%

3254
0
14,467
14,467
0
14,467
55.495
55.495
3312
6,734
6,734
0
0
6,734
25.832
81.327
3252
0
0
2,429
2,429
2,429
9.319
90.646
3314
489
242
730
0
0
730
2.802
93.448
3363
0
688
688
0
688
2.638
96.086
3251
0
389
389
121
121
510
1.957
98.043
6113
16
398
414
1
1
0
415
1.591
99.634
3372
0
29
29
0
29
0.111
99.745
3344
12
16
28
0
0
0
28
0.107
99.852
8129
17
17
0
0
17
0.064
99.916
3255
0
15
15
0
15
0.059
99.975
5622
0
0
4
4
4
0.016
99.991
9281
1
1
1
0
0
1
0.005
99.997
3399
0
0
0
0
0
0.002
99.998
3325
0
0
0
0
0
0.001
99.999
9241
0
0
0
0
0
0.001
100.000
3231
0
0
0
0
0
0.000
100.000
TOTAL6,735
0
489
45
657
7,925
15,589
0
0
0
0
15,589
2,429
4
121
2,555
26,069
100.000
 
A­
7
Table
A­
2
Co­
Proposal
Option:
1997
Offsite
Recovery
Within
Same
Industry
Group
(
4­
digit
NAICS
Code)
(
Tons)

NAICS
METALS
RECOVERY
Total
Metals
SOLVENTS
RECOVERY
Total
Solvents
OTHER
RECOVERY
Total
Other
TOTALS
Code
M011
M012
M013
M014
M019
Recovery
M021
M022
M023
M024
M029
Recovery
M031
M032
M039
Recovery
Quantity
%
Cumulative
%

3251
16
16
803
15
818
116
116
950
89.680
89.680
3312
0
0
94
94
94
8.873
98.552
5417
0
0
0
15
15
15
1.437
99.990
3314
0
0
0
0
0
0.010
100.000
TOTAL
0
16
0
0
0
16
804
0
0
0
15
819
94
0
131
225
1,059
100.000
 
A­
8
Table
A­
3.
Co­
Proposal
Option:
Summary
of
Pre­
and
Post­
Rule
Costs
and
Incremental
Costs
Cost
Item
1999
Plants
1997
Plants
Total
Costs
($/
yr)

Pre­
Rule
Costs
($/
yr)
Post­
Rule
Costs
($/
yr)
Incremental
Costs
($/
yr)
Pre­
Rule
Costs
($/
yr)
Post­
Rule
Costs
($/
yr)
Incremental
Costs
($/
yr)

On­
site
Recovery
Residual
Hazardous
Landfill
Disposal
$
60,719,000
$
55,431,000
($
5,288,000)
$
0
$
1,525,000
$
1,525,000
($
3,763,000)

Residual
Non­

Hazardous
Landfill
Disposal
$
0
$
2,976,000
$
2,976,000
$
0
$
165,000
$
165,000
$
3,141,000
1997
Pre­
Rule
Management
(
Hazardous
Landfill,

Energy
Recovery,

on­
site
Acid
Neutralization)
$
0
$
0
$
0
$
4,257,000
$
0
($
4,257,000)
($
4,257,000)

Pre­
Rule
and
Post­

Rule
Metal/

Solvent/
Acid
Recovery
$
167,814,000
$
167,814,000
$
0
$
0
$
7,953,000
$
7,953,000
$
7,953,000
Waste
Characterization
Testing
$
24,026,000
$
21,961,000
($
2,065,000)
$
3,245,000
$
1,581,000
($
1,664,000)
($
3,729,000)

Manifesting
$
3,701,000
$
3,383,000
($
318,000)
$
500,000
$
243,000
($
257,000)
($
575,000)

Loading
$
4,371,000
$
4,371,000
$
0
$
71,000
$
224,000
$
153,000
$
153,000
Waste
Transportation
$
23,184,000
$
20,903,000
($
2,281,000)
$
3,749,000
$
1,734,000
($
2,015,000)
($
4,296,000)
Table
A­
3.
Co­
Proposal
Option:
Summary
of
Pre­
and
Post­
Rule
Costs
and
Incremental
Costs
Cost
Item
1999
Plants
1997
Plants
Total
Costs
($/
yr)

Pre­
Rule
Costs
($/
yr)
Post­
Rule
Costs
($/
yr)
Incremental
Costs
($/
yr)
Pre­
Rule
Costs
($/
yr)
Post­
Rule
Costs
($/
yr)
Incremental
Costs
($/
yr)

A­
9
Recovery
Transportation
$
0
$
0
$
0
$
0
$
0
$
0
$
0
Salvage
Revenue
($
610,881,000)
($
610,881,000)
$
0
$
0
($
16,898,000)
($
16,898,000)
($
16,898,000)

Hazardous
Materials
Training
$
7,479,000
$
4,719,000
($
2,760,000)
$
2,291,000
$
1,659,000
($
632,000)
($
3,392,000)

Manifest
Training
$
1,539,000
$
1,095,000
($
444,000)
$
459,000
$
382,000
($
77,000)
($
521,000)

BRS/
General
Administrative
Duties
$
1,927,000
$
1,423,000
($
504,000)
$
584,000
$
473,000
($
111,000)
($
615,000)

One­
Time
Contingency
Planning
$
2,072,000
$
1,252,000
($
820,000)
$
640,000
$
442,000
($
198,000)
($
1,018,000)

Initial
Characterization
$
7,066,000
$
7,066,000
$
0
$
1,805,000
$
1,805,000
$
0
$
0
One­
Time
Notification
of
Exclusion
$
0
$
542,000
$
542,000
$
0
$
162,000
$
162,000
$
704,000
On­
site
Recovery
Subtotal
($
306,983,000)
($
317,945,000)
($
10,962,000)
$
17,601,000
$
1,450,000
($
16,151,000)
($
27,113,000)

Off­
site
Recovery
Within
the
Same
Industry
Group
(
4­
Digit
NAICS
Code)
and
Recovery
Facilities
Do
Not
Receive
Shipments
From
Multiple
NAICS
Codes
Table
A­
3.
Co­
Proposal
Option:
Summary
of
Pre­
and
Post­
Rule
Costs
and
Incremental
Costs
Cost
Item
1999
Plants
1997
Plants
Total
Costs
($/
yr)

Pre­
Rule
Costs
($/
yr)
Post­
Rule
Costs
($/
yr)
Incremental
Costs
($/
yr)
Pre­
Rule
Costs
($/
yr)
Post­
Rule
Costs
($/
yr)
Incremental
Costs
($/
yr)

A­
10
Table
A­
3.
Co­
Proposal
Option:
Summary
of
Pre­
and
Post­
Rule
Costs
and
Incremental
Costs
Cost
Item
1999
Plants
1997
Plants
Total
Costs
($/
yr)

Pre­
Rule
Costs
($/
yr)
Post­
Rule
Costs
($/
yr)
Incremental
Costs
($/
yr)
Pre­
Rule
Costs
($/
yr)
Post­
Rule
Costs
($/
yr)
Incremental
Costs
($/
yr)

A­
11
Table
A­
3.
Co­
Proposal
Option:
Summary
of
Pre­
and
Post­
Rule
Costs
and
Incremental
Costs
Cost
Item
1999
Plants
1997
Plants
Total
Costs
($/
yr)

Pre­
Rule
Costs
($/
yr)
Post­
Rule
Costs
($/
yr)
Incremental
Costs
($/
yr)
Pre­
Rule
Costs
($/
yr)
Post­
Rule
Costs
($/
yr)
Incremental
Costs
($/
yr)

A­
12
($
372,000)
[$
470,000
pre­
rule
and
$
98,000
($
166,000)
[$
191,000
pre­
rule
and
$
25,000
($
1,552,000)
[$
3,364,000
pre­
rule
and
$
1,812,000
$
29,000)
[$
393,000
pre­
rule
and
$
364,000
$
1,581,000).
B­
1
Appendix
B
Review
of
Recycled
Waste
Quantities
by
Manufacturing
Industries
One
option
considered
in
the
ABR­
related
rulemaking
was
the
limitation
that
only
waste
generated
by
manufacturing
industries
(
NAICS
31­
33)
would
be
excluded
as
solid
waste.
This
appendix
presents
a
review
of
the
generators
of
waste,
in
manufacturing
and
other
industries,
so
that
the
impacts
of
this
limitation
can
be
more
readily
identified.

The
following
is
a
summary
of
findings
relating
to
the
waste
currently
being
recycled
within
the
same
NAICS
code
from
the
1999
BRS
as
well
as
the
waste
recycled
within
an
industry
in
1997,
but
not
recycled
in
1999.
Given
the
amount
of
waste
generated
in
1997
and
1999,
the
manufacturing
industry,
defined
by
NAICS
codes
31
through
33,
represents
the
industry
which
would
be
most
affected
by
the
ruling.
According
to
the
data
in
Table
1,
the
manufacturing
industry
generated
97.5
percent
of
the
total
waste
generated
in
1999
and
88.4
percent
of
the
total
waste
generated
was
in
1997.

Table
B­
1.
Total
Waste
Generation
for
1999
and
1997,
including
Waste
Generated
by
the
Manufacturing
Industry
1/

Generation
Year
Total
Onsite
and
Offsite
Managed
Waste
(
tons)
Total
Onsite
and
Offsite
Managed
Waste
with
NAICS
Identified
(
tons)
Total
Waste
Generated
by
the
Manufacturing
Industry
(
tons)
Waste
Generated
by
Manufacturers
(%)
3/

1999
884,648
678,463
661,180
97.5
1997
2/
31,957
28,993
25,624
88.4
Total
916,605
707,456
686,804
97.1
1/
Waste
quantities
recycled
(
BRS
management
codes
M011­
M039)
within
the
generating
industry
NAICS.
2/
Waste
quantities
recycled
within
an
industry
in
1997
but
not
in
1999.
3/
Manufacturers
defined
by
NAICS
codes
31
through
33.

Based
on
the
1999
and
1997
biennial
report
data,
limiting
the
waste
that
would
be
excluded
as
solid
waste
would
be
a
relatively
minor
limitation.
Less
than
three
percent
of
all
waste
generated
would
be
affected
by
this
limitation.
C­
1
Appendix
C
Limitation
on
Use
of
Reclaimed
Product
One
option
considered
in
the
ABR­
related
rulemaking
is
the
limitation
that
any
reclaimed
material
will
have
to
be
consumed
by
the
same
industry
(
or
facility)
that
generated
the
waste.
This
appendix
presents
a
preliminary
review
of
the
potential
implications
of
this
option,
so
that
the
impacts
of
this
limitation
can
be
more
readily
identified.

There
are
broad
classes
of
materials
being
recovered
through
recycling
that
will
be
affected
by
any
rule
revising
the
definition
of
solid
waste.
Products
recovered
through
recycling
primarily
consist
of
solvents,
metals
and
acids.
This
discussion
is
limited
to
current
on­
site
and
off­
site
(
within
the
same
industry)
recovery,
and
wastes
recycled
off­
site
in
industries
different
from
the
generator
which
may
be
recovered
on­
site
as
a
result
of
the
rule.

It
is
not
expected
that
waste
currently
being
recycled
will
be
affected
by
this
potential
limitation.
Waste
currently
being
recovered
will
likely
continue
to
be
recovered.
It
is
expected
that
without
the
limitation
additional
waste
will
be
recovered.
The
quantity
of
waste
added
as
a
result
of
the
rule
will
be
some
component
of
the
waste
highlighted
in
Table
4­
7,
nearly
700,000
tons.
If
generators
can
only
take
advantage
of
the
revised
definition
of
solid
waste
if
the
recovered
material
is
used
by
the
generator,
the
amount
of
waste
recovered
will
be
less
than
the
amount
without
the
limitation.
Unfortunately
the
total
amount
of
waste
which
will
be
recovered
with
and
without
the
limitation
cannot
be
determined
at
this
time.
D­
1
Appendix
D
MEMORANDUM
Date:
February
4,
2003
To:
Paul
Borst,
EPA/
OSW/
EMRAD
Tom
Walker,
IEc
From:
Dave
Gustafson
and
Shauna
Lehmann,
DPRA
Re:
Recoverable
Waste
Type
Analysis
for
the
Economic
Assessment
of
the
Association
of
Battery
Recyclers
Proposed
Rulemaking;
EPA
Contract
No.
68­
W­
02­
007,
WA
1­
05
____________________________________________________________________________

This
memorandum
presents
the
results
of
DPRA's
review
of
the
waste
stream
types
reported
being
recovered
in
the
1999
BRS.
DPRA
assumes
that
based
on
these
recoverable
waste
types
we
can
search
the
list
of
waste
streams
currently
not
recovered
(
i.
e.,
land
disposed
or
thermally
destroyed)
that
may
be
recovered
under
post
rule
conditions.
DPRA
limited
its
initial
review
of
waste
streams
to
those
SIC
codes
that
reported
recovering
more
than
30,000
tons
either
on
site
or
off
site
in
1999.
A
more
detailed
summary
of
this
review
is
presented
in
the
two
sections
below.
The
following
table
presents
a
summary
of
DPRA's
recommendations
for
each
SIC
reviewed.
Based
on
the
waste
type
commonalities
identified
from
this
review
we
may
wish
to
expand
the
search
for
potentially
recoverable
wastes
to
include
all
SIC
codes
rather
than
limiting
it
to
the
SIC
reviewed.

Summary
of
DPRA
Recommendations
SIC
Code
On­
site
Recovery
Off­
Site
Recovery
3341
Secondary
Smelting
Lead
Battery
Wastes
(
D008
waste
code)
Lead
Battery
Wastes
(
D008
waste
code)

2869
Organic
Chemicals
Organic
Liquids
(
B201
­
B219
form
codes,
except
B205
(
oil­
water
emulsion
or
mixture),
B206
(
waste
oil),
B207
(
concentrated
aqueous
solution
of
other
organics),
B210
(
adhesives
or
epoxies),
and
B212
(
reactive
or
polymerizable
organic
liquid).
Organic
Liquids
(
B201
­
B219
form
codes,
except
B205
(
oil­
water
emulsion
or
mixture),
B206
(
waste
oil),
B207
(
concentrated
aqueous
solution
of
other
organics),
B210
(
adhesives
or
epoxies),
and
B212
(
reactive
or
polymerizable
organic
liquid);
and
Spent
Carbon
(
B404
form
code)

2819
Inorganic
Chemicals
No
Recommendations.
Not
Reviewed
(<
30,000
tons).
Summary
of
DPRA
Recommendations
SIC
Code
On­
site
Recovery
Off­
Site
Recovery
D­
2
2491
Wood
Preserving
Chlorophenolic
Liquid
Wastes
(
F032
EPA
waste
code).
Exclude
any
waste
streams
with
solid
or
sludge
waste
form
codes.
Not
Reviewed
(<
30,000
tons).

2851
Paints
&
Allied
Products
Organic
Liquids
(
B201
­
B219
form
codes,
except
B205
(
oil­
water
emulsion
or
mixture),
B206
(
waste
oil),
B207
(
concentrated
aqueous
solution
of
other
organics),
B210
(
adhesives
or
epoxies),
and
B212
(
reactive
or
polymerizable
organic
liquid).
Not
Reviewed
(<
30,000
tons).

2834
Pharmaceutical
Preparations
Organic
Liquids
(
B201
­
B219
form
codes,
except
B205
(
oil­
water
emulsion
or
mixture),
B206
(
waste
oil),
B207
(
concentrated
aqueous
solution
of
other
organics),
B210
(
adhesives
or
epoxies),
and
B212
(
reactive
or
polymerizable
organic
liquid).
Not
Reviewed
(<
30,000
tons)

3312
Steel
Works
Spent
pickle
liquor
wastes
(
K062
waste
code).
Note
that
only
one
waste
stream
is
reported
recovered
on
site.
Approximately
five
waste
streams
are
shipped
off
site
for
recovery.
DPRA
tentatively
recommends
pulling
nonrecovered
waste
streams
with
EPA
waste
code
K062
for
evaluation
as
potentially
recoverable
waste
streams
post
rule.
If
neutralization
is
the
common
management
practice
it
may
not
be
cost
effective
to
recover
this
waste.
Emission
control
dust
(
K061
waste
code).

3672
Printed
Circuit
Boards
Not
Reviewed
(<
30,000
tons).
a.)
Metal­
containing
liquid
wastes
(
B103,
B106,
or
B107
form
codes);
b.)
Lead
solder
dross
waste
(
D008
waste
code
with
form
codes
B304,
B307,
and
B319);
c.)
electroplating
wastewater
treatment
sludges
(
F006
waste
code);
d.)
Solutions
containing
gold
(
F007
waste
code);
or
e.)
Solutions
containing
silver
(
D011
waste
code).

2911
Petroleum
Refining
Not
Reviewed
(<
30,000
tons).
Oily
Sludges
(
B603
form
code;
may
already
be
exempt
if
recovered);
Spent
Carbon
(
B404
form
code);
and
Spent
Catalysts
(
K171
and
K172
waste
codes)

3691
Storage
Batteries
Not
Reviewed
(<
30,000
tons).
Lead
Battery
Wastes
(
D008
waste
code)
Summary
of
DPRA
Recommendations
SIC
Code
On­
site
Recovery
Off­
Site
Recovery
D­
3
2821
Plastic
Materials
&
Resins
Not
Reviewed
(<
30,000
tons).
Organic
Liquids
(
B201
­
B219
form
codes,
except
B205
(
oil­
water
emulsion
or
mixture),
B206
(
waste
oil),
B207
(
concentrated
aqueous
solution
of
other
organics),
B210
(
adhesives
or
epoxies),
and
B212
(
reactive
or
polymerizable
organic
liquid).

On­
Site
Recovery:
SIC
codes
recovering
greater
than
30,000
tons
on
site
SIC
Code
3341:
Secondary
Smelting
and
Refining
of
Nonferrous
Metals
98%
of
the
managed
quantity
has
a
system
type
of
M011­
M019
(
metals
recovery).
Four
waste
streams
contribute
to
approximately
88%
of
the
quantity
for
this
system
type
and
are
as
follows:


Filter
Press
Cake
from
Wastewater
Treatment
System
o
EPA
Code:
D008
­
Lead
o
Form
Code:
B319
­
Other
Waste
Inorganic
Solids
o
Quantity
Managed:
42,972
tons

Battery
Components
from
Lead
Acid
Storage
Batteries
o
EPA
Code:
D008
­
Lead
o
Form
Code:
B309
­
Batteries
or
battery
parts,
casings,
cores
o
Quantity
Managed:
26,347
tons

Lead
Groups
from
Battery
Breaking/
Desulfurization
Operation
o
EPA
Code:
D008
­
Lead
o
Form
Code:
B309
­
Batteries
or
battery
parts,
casings,
cores
o
Quantity
Managed:
21,851
tons

Slag
Furnace
By­
Product
Solid
Originating
from
Recycling
Operations
o
EPA
Code:
D008
­
Lead
o
Form
Code:
B304
­
Other
dry
ash,
slag,
or
thermal
residue
o
Quantity
Managed:
10,645
tons
Of
the
32
waste
streams
with
metals
being
recovered
on
site
22
(
69%)
are
reported
containing
lead
(
D008
EPA
waste
code).
Recommend
pulling
non­
recovered
waste
streams
within
SIC
3341
that
potentially
contain
recoverable
amounts
of
lead
(
EPA
waste
code
D008)
post
rule.

SIC
Code
2869:
Industrial
Organic
Chemicals,
nec
75%
of
the
managed
quantity
has
a
system
type
of
M031­
M039
(
other
recovery).
Three
waste
streams
contribute
to
approximately
61%
of
the
quantity
for
this
system
type
and
are
as
follows:


Acidic
Process
Water
D­
4
o
EPA
Code:
D002
­
Corrosive
Waste
o
Form
Code:
B105
­
Acidic
Aqueous
Waste
o
Quantity
Managed:
43,542
tons

EDC
Heavy
Ends
from
Ethylene
Dichloride
Manufacturing
o
EPA
Codes:
D028
­
1,2­
Dichloroethane
D034
­
Hexachloroethane
D039
­
Tetrachloroethylene
K019
­
Heavy
Ends
from
the
Distillation
of
Ethylene
Dichloride
in
Ethylene
Dichloride
Production
o
Form
Code:
B219
­
Other
Organic
Liquids
o
Quantity
Managed:
13,623
tons

Acid
By­
Product
from
Production
o
EPA
Code:
D002
­
Corrosive
Waste
o
Form
Code:
B105
­
Acidic
Aqueous
Waste
o
Quantity
Managed:
10,610
tons
Even
though
two
of
the
three
largest
waste
streams
are
wastewater
most
waste
streams
have
organic
liquid
waste
form
codes
(
B201
­
B219).
For
waste
streams
being
recovered
by
other
methods
on
site
13
out
of
18
(
72%)
have
an
organic
liquid
form
code.
For
waste
steams
being
recovered
for
solvents
on
site
12
of
15
(
80%)
have
an
organic
liquid
form
code.
Recommend
pulling
non­
recovered
waste
streams
within
SIC
2869
that
are
organic
liquid
form
codes
as
potentially
recoverable
post
rule.
Include
all
waste
streams
with
B200
form
codes
except
B205
(
oil­
water
emulsion
or
mixture),
B206
(
waste
oil),
B207
(
concentrated
aqueous
solution
of
other
organics),
B210
(
adhesives
or
epoxies),
and
B212
(
reactive
or
polymerizable
organic
liquid)
which
are
unlikely
to
be
recoverable.

SIC
Code
2819:
Industrial
Inorganic
Chemicals,
nec
Virtually
100%
of
the
managed
quantity
has
a
system
type
of
M011­
M019
(
metals
recovery).
One
waste
stream
contributes
to
approximately
96%
of
the
quantity
for
this
system
type
and
is
as
follows:


Rinse
Waters,
Process
Wash
Waters,
and
Rain
Water
o
EPA
Codes:
D002
­
Corrosive
Waste
D008
­
Lead
o
Form
Code:
B106
­
Caustic
Solution
with
Metals
but
no
Cyanides
o
Quantity
Managed:
68,462
tons
No
clear
search
pattern
could
be
determined
to
identify
potential
waste
streams
that
may
be
recovered
post
rule.
DPRA
recommends
conducting
no
additional
searches
for
this
SIC
code.
D­
5
SIC
Code
2491:
Wood
Preserving
100%
of
the
managed
quantity
has
a
system
type
of
M031­
M039
(
other
recovery).
One
waste
stream
contributes
to
approximately
96%
of
the
quantity
for
this
system
type
and
is
as
follows:


Wastewater
From
Wood
Preserving
Process,
Containing
Creosote
o
EPA
Codes:
F032
­
Wastewaters,
Process
Residuals,
Preservative
Drippage,
and
Spent
Formulations
from
Wood
Preserving
Processes
Generated
at
Plants
that
Currently
Use,
or
Have
Previously
Used
Chlorophenolic
Formulations
F034
­
Wastewaters,
Process
Residuals,
Preservative
Drippage,
and
Spent
Formulations
from
Wood
Preserving
Processes
Generated
at
Plants
that
Use
Creosote
Formulations
o
Form
Code:
B102
­
Aqueous
Waste
with
Low
Other
Toxic
Organics
o
Quantity
Managed:
31,067
tons
Two
of
the
three
waste
streams
are
reported
under
the
F032
EPA
waste
code.
Recommend
pulling
non­
recovered
waste
streams
within
SIC
2491
that
contain
the
F032
EPA
waste
code.
Exclude
any
waste
streams
with
solid
or
sludge
waste
forms.

SIC
Code
2851:
Paints
and
Allied
Products
71%
of
the
managed
quantity
has
a
system
type
of
M021­
M029
(
solvents
recovery).
Two
waste
streams
contribute
to
approximately
46%
of
the
quantity
for
this
system
type
and
are
as
follows:


Spent
Solvent
o
EPA
Codes:
D001
­
Ignitable
Waste
D005
­
Barium
D007
­
Chromium
D008
­
Lead
D035
­
Methyl
ethyl
ketone
F003
­
Select
List
of
Spent
Non­
Halogenated
Solvents
(
see
list)
F005
­
Select
List
of
Spent
Non­
Halogenated
Solvents
(
see
list)
o
Form
Code:
B201
­
Concentrated
Solvent­
Water
Solution
o
Quantity
Managed:
9,792
tons

Spent
Organic
Non­
Halogenated
Solvents
o
EPA
Codes:
(
same
as
above)
o
Form
Code:
B203
­
Nonhalogenated
Solvent
o
Quantity
Managed:
4,892
tons
Most
waste
streams
have
organic
liquid
waste
form
codes
(
B201
­
B219).
For
waste
streams
being
recovered
for
solvents
on
site
48
out
of
53
(
91%)
have
an
organic
liquid
form
code.
Most
D­
6
waste
streams
contain
F003
or
F005
EPA
waste
codes.
Recommend
pulling
non­
recovered
waste
streams
within
SIC
2851
that
are
organic
liquid
form
codes
as
potentially
recoverable
post
rule.
Include
all
waste
streams
with
B200
form
codes
except
B205
(
oil­
water
emulsion
or
mixture),
B206
(
waste
oil),
B207
(
concentrated
aqueous
solution
of
other
organics),
B210
(
adhesives
or
epoxies),
and
B212
(
reactive
or
polymerizable
organic
liquid)
which
are
unlikely
to
be
recoverable.

SIC
Code
2834:
Pharmaceutical
Preparations
100%
of
the
managed
quantity
has
a
system
type
of
M021­
M029
(
solvents
recovery).
Four
waste
streams
contribute
to
approximately
95%
of
the
quantity
for
this
system
type
and
are
as
follows:


(
No
Waste
Description
Listed)
o
EPA
Code:
D001
­
Ignitable
Waste
o
Form
Code:
B203
­
Nonhalogenated
Solvent
o
Quantity
Managed:
10,548
tons

Ignitable
Spent
Solvent
from
Pharmaceutical
Manufacturing
Process
o
EPA
Codes:
D001
­
Ignitable
Waste
F003
­
Select
List
of
Spent
Non­
Halogenated
Solvents
(
see
list)
o
Form
Code:
B201
­
Concentrated
Solvent­
Water
Solution
o
Quantity
Managed:
8,061
tons

(
No
Waste
Description
Listed)
o
EPA
Code:
D001
­
Ignitable
Waste
o
Form
Code:
B203
­
Nonhalogenated
Solvent
o
Quantity
Managed:
5,742
tons

Ignitable
Spent
Solvent
from
Pharmaceutical
Manufacturing
Process
o
EPA
Codes:
D001
­
Ignitable
Waste
D038
­
Pyridine
F005
­
Select
List
of
Spent
Non­
Halogenated
Solvents
(
see
list)
o
Form
Code:
B201
­
Concentrated
Solvent­
Water
Solution
o
Quantity
Managed:
8,061
tons
Most
waste
streams
have
organic
liquid
waste
form
codes
(
B201
­
B219).
For
waste
streams
being
recovered
by
other
methods
on
site
13
out
of
18
(
72%)
have
an
organic
liquid
form
code.
All
12
waste
steams
being
recovered
for
solvents
have
an
organic
liquid
form
code.
Recommend
pulling
non­
recovered
waste
streams
within
SIC
2851
that
are
organic
liquid
form
codes
as
potentially
recoverable
post
rule.
Include
all
waste
streams
with
B200
form
codes
except
B205
(
oil­
water
emulsion
or
mixture),
B206
(
waste
oil),
B207
(
concentrated
aqueous
solution
of
other
organics),
B210
(
adhesives
or
epoxies),
and
B212
(
reactive
or
polymerizable
organic
liquid)
which
are
unlikely
to
be
recoverable.

SIC
Code
3312:
Steel
Works,
Blast
Furnaces,
and
Rolling
Mills
D­
7
100%
of
the
managed
quantity
has
a
system
type
of
M031­
M039
(
other
recovery).
One
waste
stream
contributes
100%
of
the
quantity
for
this
system
type
and
is
as
follows:


Spent
Pickle
Liquor
HCl
from
Steel
Processing
o
EPA
Codes:
D002
­
Corrosive
Waste
K062
­
Spent
Pickle
Liquor
from
Steel
Finishing
Operations
of
Plants
that
Produce
Iron
or
Steel
o
Form
Code:
B103
­
Spent
Acid
with
Metals
o
Quantity
Managed:
30,222
tons
Recommend
pulling
non­
recovered
waste
streams
within
SIC
3312
that
contain
the
EPA
waste
code
K062.
Note
that
only
one
waste
stream
is
reported
recovered
on
site.
Approximately
five
waste
streams
are
shipped
off
site
for
recovery.
DPRA
tentatively
recommends
pulling
non­
recovered
waste
streams
with
EPA
waste
code
K062
for
evaluation
as
potentially
recoverable
waste
streams
post
rule.
If
neutralization
is
the
common
management
practice
it
may
not
be
cost
effective
to
recover
this
waste.

Off­
Site
Recovery:
SIC
codes
recovering
greater
than
30,000
tons
off
site
SIC
Code
3312:
Steel
Works,
Blast
Furnaces,
and
Rolling
Mills
96%
of
the
shipped
quantity
has
a
system
type
of
M011­
M019
(
metals
recovery).
The
fifteen
highest­
quantity
waste
streams
contribute
to
approximately
53%
of
the
total
quantity
for
this
system
type,
and
can
be
summarized
by
the
following:


Emission
Control
Dust
from
the
Production
of
Steel
in
an
Electric
Arc
Furnace
o
EPA
Codes:
D006
­
Cadmium
D008
­
Lead
K061
­
Emission
Control
Dust/
Sludge
from
the
Primary
Production
of
Steel
in
Electric
Furnaces
o
Form
Codes:
B303
­
Ash,
slag,
or
other
residue
from
incineration
of
wastes
B304
­
Other
dry
ash,
slag,
or
thermal
residue
B306
­
Dry
lime
or
metal
hydroxide
solids
not
fixed
B319
­
Other
waste
inorganic
solids
B511
­
Air
pollution
control
device
sludge
o
Sum
of
Shipped
Quantities:
251,441
tons
Most
waste
streams
recovered
off
site
contain
the
EPA
waste
code
K061.
87
of
the
143
(
61%)
of
the
waste
streams
contain
the
K061
waste
code.
Recommend
pulling
non­
recovered
waste
streams
within
SIC
3312
that
contain
the
K061
EPA
waste
code.
D­
8
SIC
Code
3672:
Printed
Circuit
Boards
90%
of
the
shipped
quantity
has
a
system
type
of
M011­
M019
(
metals
recovery).
NOTE:
there
are
not
many
high­
quantity
waste
streams
for
this
system
type,
so
it
is
difficult
to
determine
the
major
contributing
waste
streams.

Most
waste
streams
either
contain
either:
a.)
form
codes
B103,
B106,
or
B107;
b.)
D008
waste
code
used
for
solder
dross
waste
with
form
codes
B304,
B307,
and
B319;
c.)
F006;
d.)
F007
(
gold
solutions);
or
e.)
D011
(
silver
solutions).
Recommend
pulling
non­
recovered
waste
streams
within
SIC
3672
that
contain
one
or
more
of
the
above
codes.

SIC
Code
2911:
Petroleum
Refining
78%
of
the
shipped
quantity
has
a
system
type
of
M031­
M039
(
other
recovery).
NOTE:
there
are
not
many
high­
quantity
waste
streams
for
this
system
type,
so
it
is
difficult
to
determine
the
major
contributing
waste
streams.

Waste
streams
recovered
off
site
by
other
recovery
methods
are
identified
as
either
oily
sludge
(
form
code
B603)
or
spent
carbon
(
form
code
B404).
Note,
recovery
of
oily
sludge
(
form
code
B603)
may
already
be
exempt
under
prior
RCRA
regulations.
Records
were
removed
in
the
November,
2002,
Economic
Assessment
if
the
system
type
code
was
M032
(
which
includes
waste
oil
recovery).
The
records
remaining
on
the
list
have
different
system
type
codes
(
e.
g.,
M039,
other
recovery
­
type
unknown).
We
may
wish
to
remove
these
records
from
the
analysis
given
their
oily
sludge
form
code
(
B603).
In
addition
catalysts
are
being
recovered
(
EPA
waste
codes
K171
and
K172).
Recommend
pulling
non­
recovered
waste
streams
within
SIC
2911
that
are
oily
sludges
(
form
code
B603)
or
spent
carbon
form
code
B404)
as
potentially
recoverable
post
rule.
In
addition
pull
non­
recovered
waste
streams
containing
EPA
waste
codes
K171
and
K172.

SIC
Code
2869:
Industrial
Organic
Chemicals,
nec
62%
of
the
shipped
quantity
has
a
system
type
of
M021­
M029
(
solvents
recovery).
NOTE:
there
are
not
many
high­
quantity
waste
streams
for
this
system
type,
so
it
is
difficult
to
determine
the
major
contributing
waste
streams.

Most
waste
streams
have
organic
liquid
waste
form
codes
(
B201
­
B219).
Recommend
pulling
non­
recovered
waste
streams
within
SIC
2869
that
are
organic
liquid
form
codes
as
potentially
recoverable
post
rule.
Include
all
waste
streams
with
B200
form
codes
except
B205
(
oil­
water
emulsion
or
mixture),
B206
(
waste
oil),
B207
(
concentrated
aqueous
solution
of
other
organics),
B210
(
adhesives
or
epoxies),
and
B212
(
reactive
or
polymerizable
organic
liquid)
which
are
unlikely
to
be
recoverable.
In
addition
pull
all
non­
recovered
waste
streams
that
are
spent
carbon
(
form
code
B404).
D­
9
SIC
Code
3341:
Secondary
Smelting
and
Refining
of
Nonferrous
Metals
53%
of
the
shipped
quantity
has
a
system
type
of
M031­
M039
(
other
recovery).
Three
waste
streams
contribute
to
approximately
98%
of
the
quantity
for
this
system
type
and
can
be
summarized
by
the
following:


Plastic
from
Lead
Acid
Battery
Cases
Recovered
from
Battery
Breaking
Operations
o
EPA
Code:
D008
­
Lead
o
Form
Code:
B309
­
Batteries
or
battery
parts,
casings,
cores
o
Sum
of
Shipped
Quantities:
18,251
tons
Of
the
53
waste
streams
with
metals
being
recovered
off
site
27
(
51%)
are
reported
containing
lead
(
D008
EPA
waste
code)
primarily
from
batteries.
Recommend
pulling
non­
recovered
waste
streams
within
SIC
3341
that
potentially
contain
recoverable
amounts
of
lead
(
EPA
waste
code
D008)
post
rule.

SIC
Code
3691:
Storage
Batteries
99%
of
the
shipped
quantity
has
a
system
type
of
M011­
M019
(
metals
recovery).
NOTE:
there
are
not
many
high­
quantity
waste
streams
for
this
system
type,
so
it
is
difficult
to
determine
the
major
contributing
waste
streams.

Of
the
142
waste
streams
with
metals
being
recovered
off
site
116
(
82%)
are
reported
containing
lead
(
D008
EPA
waste
code)
primarily
from
batteries.
Recommend
pulling
non­
recovered
waste
streams
within
SIC
3691
that
potentially
contain
recoverable
amounts
of
lead
(
EPA
waste
code
D008)
post
rule.

SIC
Code
2821:
Plastic
Materials
and
Resins
82%
of
the
shipped
quantity
has
a
system
type
of
M021­
M029
(
solvents
recovery).
NOTE:
there
are
not
many
high­
quantity
waste
streams
for
this
system
type,
so
it
is
difficult
to
determine
the
major
contributing
waste
streams.

Most
waste
streams
have
organic
liquid
waste
form
codes
(
B201
­
B219).
Recommend
pulling
non­
recovered
waste
streams
within
SIC
2821
that
are
organic
liquid
form
codes
as
potentially
recoverable
post
rule.
Include
all
waste
streams
with
B200
form
codes
except
B205
(
oil­
water
emulsion
or
mixture),
B206
(
waste
oil),
B207
(
concentrated
aqueous
solution
of
other
organics),
B210
(
adhesives
or
epoxies),
and
B212
(
reactive
or
polymerizable
organic
liquid)
which
are
unlikely
to
be
recoverable.
53
Sippel,
1999,
Personal
Communication,
Noranda,
Ontario,
Canada.
54
Jarvis,
1999,
Personal
Communication,
Eritech,
North
Carolina
55
Average
distances
to
landfills
and
recyclers
were
previously
estimated
at
200
and
600
miles,
respectively,
based
on
a
review
of
BRS
data
(
DPRA,
1999.
Regulatory
Impact
Analysis
of
the
Proposed
Rule
for
F006
Wastewater
Treatment
Sludges).
The
assumed
incremental
charge
of
$
50
per
ton
is
a
proxy
for
this
cost;
actual
costs
would
E­
1
Appendix
E
MEMORANDUM
Date:
November
14,
2002
To:
Paul
Borst,
EPA/
OSW/
EMRAD,
Tom
Walker,
IEc
From:
Dave
Gustafson,
and
Craig
Simons,
DPRA
Re:
Analysis
of
Market
Changes
between
1997
and
1999
This
memo
presents
a
differential
cost
analysis
between
Subtitle
C
metals
recovery
and
Subtitle
C
landfill
for
generators,
comparing
cost
experiences
in
1997
versus
1999.
Also
presented
is
an
overview
of
the
potential
market
affects
regarding
decisions
to
recycle
solvent
based
waste
versus
sending
the
wastes
to
fuel
blending.

Within
the
market
things
are
changing.
Currently
we
assume
that
since
they
recycled
in
the
past
they
will
do
it
in
the
future.
Table
1
presents
pricing
charts
for
four
key
metals,
as
well
as
prices
for
landfilling,
price
indices
for
industrial
chemicals,
and
petroleum.
With
landfill
prices
increasing,,
metals
prices
decreasing,
and
solvent
prices
decreasing,
at
least
between
1997
and
1999,
the
Agency
needs
to
know
what
the
overall
affect
is
on
generators'
decision
to
recycle
versus
dispose
of
the
wastes
generated.
The
wastes
considered
are
those
wastes
which
may
be
affected
by
EPA
exclusions,
brought
about
by
the
ABR
court
decision.
In
short,
we
want
to
determine
how
to
change
the
analytical
framework
for
what
wastes
will
be
recycled.
For
example,
should
the
Agency
maintain
the
current
assumption
that
100
percent
of
1997
metal
and
solvent
recovery
quantities
will
switch
back
to
recycling
or
use
some
alternative
assumption?

During
the
period
from
1997
through
1999
key
recyclable
metals
copper,
chromium
and
nickel
experienced
price
declines
ranging
from
15
to
almost
30
percent,
making
them
less
attractive
to
recycle.
However,
at
least
partially
offsetting
the
effect
of
the
metal
price
declines,
landfilling
prices
increased
approximately
25
percent.

To
identify
how
changes
in
costs
may
affect
recycling
versus
landfilling
decisions
we
look
to
the
recycling
of
copper­
bearing
waste,
the
arrangements
for
which
we
know
the
most
about.
When
this
material
is
sent
directly
to
the
smelter,
which
only
happens
on
a
limited
basis,
the
smelter
would
typically
charge
a
processing
fee,
which
has
been
reported
to
range
from
approximately
$
200
per
ton53
to
$
300
per
ton.
54
For
purposes
of
this
assessment
a
processing
charge
of
$
300
per
ton
is
assumed,
with
an
additional
charge
of
$
50
per
ton
associated
with
increased
transportation
costs.
55
56
Then,
depending
on
the
practice
of
the
smelter,
payment
would
be
made
depend
on
load
sizes,
pickup
arrangements
and
other
factors.
56
1999
dollar
basis,
adjusted
for
1997
calculations
using
GDP
IPD
57
Sippel,
1999,
Personal
Communication,
Noranda,
Ontario,
Canada.
58
USGS
Mineral
Commodity
Summaries:
Copper,
January
2002
59
Environmental
Cost
Handling
Options
and
Solutions
(
ECHOS),
Environmental
Remediation
Cost
Data­
Unit
Price,
4th
Annual
Edition,
published
by
R.
S.
Means
and
Delta
Technologies
Group,
Inc.,
various
years.

E­
2
to
the
generator
based
on
the
assay
value
of
the
copper,
which
may
be
approximately
90
percent
of
the
total
value.
57
With
this
construct
the
breakeven
point,
above
which
the
material
may
be
attractive
from
a
monetary
standpoint,
depends
heavily
on
the
copper
content
of
the
waste,
the
market
price
for
copper,
and
the
cost
for
landfilling.
As
indicated
in
Table
1,
the
average
price
for
copper,
based
on
USGS
data58
was
estimated
to
be
$
2,140
per
ton
in
1997
and
$
1,518
per
ton
in
1999.
Subtitle
C
landfill
disposal
costs
(
with
stabilization)
are
estimated
at
$
241
and
$
304
per
ton
in
1997
and
1999,
respectively.
59
The
breakeven
point
for
copper­
bearing
sludge,
below
which
the
material
would
be
more
economical
to
landfill
would
be
calculated
as:

CC
=
(
R
­
L)
/(
C
*
0.9)

Where:
CC
is
the
copper
content
of
the
waste
considered
for
recycling,
expressed
as
a
decimal;
R
is
the
per
ton
processing
fee
charged
by
the
recycler
($
300)
plus
incremental
transportation
costs,
assumed
to
be
$
50,
1999
basis;
L
is
the
landfill
cost
per
ton
(
Subtitle
C
with
stabilization);
C
is
the
price
of
copper,
and
0.9
is
the
portion
of
the
assay
value
of
the
copper
in
the
sludge
which
is
assumed
to
be
paid
to
the
generator.

Given
the
assumptions
presented
previously,
the
breakeven
copper
content
would
be
approximately
5.2
percent
in
1997.
In
1999
the
breakeven
copper
content
actually
falls
to
3.4
percent
because
the
affect
of
the
increased
cost
for
landfilling
outweighs
the
decreased
price
for
copper.
At
least
for
copper
waste,
it
appears
that
recycling
was
more
attractive
from
a
monetary
standpoint
in
1999.

Unfortunately
we
have
not
been
able
to
make
similar
calculations
for
other
metals,
most
notably
nickel,
chromium
and
lead
due
to
a
lack
of
information
on
recycling
arrangements.
However
we
note
that
the
decline
in
copper
prices
was
far
greater,
in
percentage
terms,
than
for
the
other
metals.
Based
on
this
observation
it
would
not
seem
that
the
changes
in
metals
prices,
when
considered
in
concert
with
landfill
prices,
would
adversely
affect
generators
decisions
regarding
recycling
their
metal
bearing
wastes.
E­
3
To
examine
the
cost
implications
for
nickel,
chromium
and
lead
generators
we
use
the
same
general
construct
as
for
copper.
That
is,
generators
are
assumed
to
pay
a
fee
for
recycling
and
in
return
are
reimbursed
for
90
percent
of
the
assay
value
of
the
metal
in
the
waste.
This
is
for
illustrative
purposes
only,
to
show
the
relative
attractiveness
of
recycling
in
1999
versus
1997.

The
breakeven
recycling
charge
for
these
metal
bearing
wastes,
below
which
the
material
would
be
more
economical
to
landfill
would
be
calculated
as:

R
=
L
+
(
MC
*
(
M
*
0.9))

Where:
R
is
the
per
ton
processing
fee
charged
by
the
recycler
plus
incremental
transportation
costs;
L
is
the
landfill
cost
per
ton
(
Subtitle
C
with
stabilization);
MC
is
the
metal
content
of
the
waste
considered
for
recycling,
expressed
as
a
decimal;
M
is
the
price
of
the
metal,
and
0.9
is
the
portion
of
the
assay
value
of
the
metal
in
the
waste
which
is
assumed
to
be
paid
to
the
generator.

For
purposes
of
illustration
we
consider
wastes
which
have
a
three
percent
metal
content.
Given
these
assumptions,
the
results
are
presented
in
Table
2.
What
is
notable
is
that
for
all
of
the
metals
the
"
breakeven"
recycling
fee
in
1999
would
have
to
be
from
4
to
23
percent
higher
in
1999
versus
1997
for
the
generator
to
be
more
likely
to
dispose
of
the
waste
in
a
landfill.
Stated
differently,
for
nickel
wastes,
in
1997
the
generator
would
be
indifferent
between
recycling
and
disposal
given
a
recycling
fee
of
$
411
per
ton.
In
1999
this
breakpoint
would
actually
increase
to
a
fee
of
$
451
per
ton.
Recycling
fees
are
not
at
this
level
and
consequently
price
variations
cannot
explain
the
switch
in
waste
management
from
recycling
in
1997
to
disposal
in
1999.

For
solvent
bearing
wastes
the
decision
to
recycle
or
dispose
depends
on
both
the
value
of
the
solvents
and
their
value
to
cement
kilns
as
fuel.
As
shown
in
Table
2,
industrial
chemicals,
as
measured
by
the
producer
price
index,
declined
in
value
by
approximately
6
percent
between
1997
and
1999.
However
residual
fuel
prices
also
declined
by
approximately
8
percent.
Consequently
the
change
in
prices
would
not
seem
to
affect
generators'
decisions
to
dispose
through
fuel
blending.

In
conclusion
we
recommend
that
the
Agency
continue
to
use
the
assumption
that
100
percent
of
the
1997
waste
streams
which
went
to
recycling
(
but
did
not
in
1999)
would
again
be
sent
to
recycling
as
a
result
of
the
change
in
regulatory
status
for
these
wastes.
We
believe
it
is
more
likely
that
additional
wastes
(
beyond
these
1997
wastes)
will
be
recycled
because
of
any
regulatory
exclusions.
In
short,
the
above
assumption
serves
as
a
conservative
proxy.
E­
4
Table
1.
Overview
of
Prices
for
Major
Recycled
Metals,
Industrial
Chemicals
and
Land
Disposal
Commodity
Price/
Unit
Year
1996
1997
1998
1999
2000
Copper
($/
ton)
2,180
2,140
1,572
1,518
1,764
Nickel
($/
ton)
6,804
6,284
4,200
5,454
7,836
Chromium
($/
ton)
9,500
10,400
9,460
8,860
8,860
Lead
($/
ton)
976
930
906
874
872
Industrial
Chemicals
(
PPI)
127
126
121
119
129
Subtitle
C
Landfill
(
w.
stabilization)
($/
ton)
241
241
304
318
Residual
Fuel
#
6
($/
bl)
19
18
13
16
26
Recycling
Fee
($/
ton)
350
350
350
350
GDP
IPD
0.956
0.974
0.986
1.000
1.023
Sources:
Metals
Prices
form
USGS;
Industrial
Chemicals
PPI
from
Bureau
of
Econ
Analysis;
Landfill
prices
from
R.
S.
Means.
E­
5
Table
2.
Analysis
of
Breakeven
Points
for
Recycling,
1997
versus
1999
1997
1999
Copper
recycling
(%
cu
for
breakeven)
5.2%
3.4%

Nickel
recycling
breakeven
fee
(
3%
Ni
waste)
($/
ton)
411
451
Chromium
recycling
breakeven
fee
(
3%
Cr
waste)
($/
ton)
522
543
Lead
recycling
breakeven
fee
(
3%
Pb
waste)
($/
ton)
266
328
F­
1
Appendix
F
State
Hazardous
Waste
Generation
Taxes
and
Fees
State
imposed
hazardous
waste
generation
taxes
and
fees
have
been
identified
for
facilities
located
in
27
states.
These
state
taxes
and
fees
are
listed
in
Table
F­
1.
Further
analysis
needs
to
be
conducted
for
eight
states
identified
in
the
Table
F­
1
to
determine
if
"
recovery"
is
included
under
their
regulatory
definition
of
"
treatment."
F­
2
Table
F­
1.
State
Hazardous
Waste
Generator
Taxes
and
Fees
State
Non­
size
Specific
Tax
or
Fee
Tax
or
Fee
Size­
specific
Taxes
and
Fees*

Description
LQG
>
2,000
tons/
yr
LQG
1,000
­

2,000
tons/
yr
LQG
500
­
1,000
tons/
yr
LQG
250
­
500
tons/
yr
LQG
50
­
250
tons/
yr
LQG
13.2
50
tons/
yr
SQG
1.3
­
13.2
tons/
yr
CESQG
<
1.3
tons/
yr
AZ
Generators
of
waste
that
retain
the
waste
on­
site
for
disposal
or
who
ship
it
off­
site
to
a
facility
owned
or
operated
by
that
generator
$
4.00/
ton
AR
Monitoring/
inspe
ction
fees
$
500/
yr
$
500/
yr
$
500/
yr
$
500/
yr
$
500/
yr
$
500/
yr
$
150/
yr
$
0/
yr
CA
Generator
fee
and
generator
waste
reporting
surcharge
$
71,432/
yr
$
53,573/
yr
$
35,717/
yr
$
17,858/
yr
$
3,572/
yr
$
1,429/
yr
$
177/
yr
$
0/
yr
CO
Hazardous
waste
TSDF
annual
operating
fee
(
assumed
off­
site
passed
on
to
generator):
Class
III
(
resource
recovery)
$
2.50/
ton
CT
Hazardous
waste
generator
tax
$
9.59/
ton
DE
Fee
for
off­
site
treatment.
Unclear
if
treatment
equals
recovery
in
this
state?

($
16/
ton)
Further
Analysis
Needed
GA
Hazardous
waste
management
fee
$
1/
ton
$
1/
ton
$
1/
ton
$
1/
ton
$
1/
ton
$
1/
ton
$
100/
yr
$
0/
yr
ID
Hazardous
waste
fee
$
30.00/
ton
Table
F­
1.
State
Hazardous
Waste
Generator
Taxes
and
Fees
State
Non­
size
Specific
Tax
or
Fee
Tax
or
Fee
Size­
specific
Taxes
and
Fees*

Description
LQG
>
2,000
tons/
yr
LQG
1,000
­

2,000
tons/
yr
LQG
500
­
1,000
tons/
yr
LQG
250
­
500
tons/
yr
LQG
50
­
250
tons/
yr
LQG
13.2
50
tons/
yr
SQG
1.3
­
13.2
tons/
yr
CESQG
<
1.3
tons/
yr
F­
3
IL
Fee
for
on­
or
off­
site
treatment.
Unclear
if
treatment
equals
recovery
in
this
state?

($
7.19/
ton)
Further
Analysis
Needed
KS
Generator
annual
monitoring
fee
$
5,000/
yr
$
5,000/
yr
$
5,000/
yr
$
1,000/
yr
$
1,000/
yr
$
500/
yr
$
500/
yr
$
100/
yr
KY
Generator
hazardous
waste
assessment
$
2.00/
ton
(
on
site)

$
4.00/
ton
(
off
site)

ME
Off
site
"
handling"
fee
(
assume
handling
=

recovery)
$
30.00/
ton
MN
Quantity
fee
and
tax
and
statewide
program
fee
$
3,290/
yr
$
3,290/
yr
$
3,290/
yr
$
3,290/
yr
$
13.50/
ton
$
52.20/
ton
$
115.41/

ton
$
274.72/

ton
MS
Pollution
prevention
fee
for
generators
$
2,500/
yr
$
2,500/
yr
$
1,500/
yr
$
1,500/
yr
$
1,500/
yr
$
500/
yr
$
250/
yr
$
250/
yr
MO
Hazardous
waste
fee.

For
category
tax,

unclear
if
treatment
equals
recovery
in
this
state?
[$
0.7
(
ton)
2
+

$
20/
yr]
$
1.00/
ton
MT
Generator
fee.
Did
not
have
"
Class"

definition.
Assumed
middle
class/
fee.
$
600.00/
yr
Table
F­
1.
State
Hazardous
Waste
Generator
Taxes
and
Fees
State
Non­
size
Specific
Tax
or
Fee
Tax
or
Fee
Size­
specific
Taxes
and
Fees*

Description
LQG
>
2,000
tons/
yr
LQG
1,000
­

2,000
tons/
yr
LQG
500
­
1,000
tons/
yr
LQG
250
­
500
tons/
yr
LQG
50
­
250
tons/
yr
LQG
13.2
50
tons/
yr
SQG
1.3
­
13.2
tons/
yr
CESQG
<
1.3
tons/
yr
F­
4
NE
TSDF
fee
assessment.

Unclear
if
treatment
equals
recovery
in
this
state?
($
1.92/
ton)
Further
Analysis
Needed
NV
Fee
for
off­
site
treatment.
Unclear
if
treatment
equals
recovery
in
this
state?

($
40.20/
ton)
Further
Analysis
Needed
NH
Hazardous
waste
fee
$
60/
ton
$
60/
ton
$
60/
ton
$
60/
ton
$
60/
ton
$
60/
ton
$
60/
ton
$
0/
ton
NJ
Manifest
processing
fee
(
assumed
18
tons
shipped
per
manifest)
$
0.50/
ton
Hazardous
waste
generator
biennial
reporting
fee
and
inspection
and
compliance
review
fee
$
2,981/
yr
$
2,981/
yr
$
2,981/
yr
$
2,981/
yr
$
2,681/
yr
$
2,428/
yr
$
651/
yr
$
67/
yr
NM
Generation
fee
and
business
fee
$
20/
ton
$
2,500/
yr
$
20/
ton
$
2,500/
yr
$
20/
ton
$
2,500/
yr
$
20/
ton
$
2,500/
yr
$
20/
ton
$
2,500/
yr
$
20/
ton
$
2,500/
yr
$
250/
yr
$
200/
yr
$
100/
yr
$
0/
yr
NY
Special
assessment
on
off­
site
generation,

treatment
or
disposal.

Unclear
if
treatment
equals
recovery
in
this
state?
($
16/
ton)
Further
Analysis
Needed
Hazardous
waste
program
fees
for
generators
$
40,000/
yr
$
40,000/
yr
$
20,000/
yr
$
6,000/
yr
$
6,000/
yr
$
1,000/
yr
$
0/
yr
$
0/
yr
NC
Generator
fee
$
0.50/
ton
$
0.50/
ton
$
0.50/
ton
$
0.50/
ton
$
0.50/
ton
$
0.50/
ton
$
25/
yr
$
0/
yr
Table
F­
1.
State
Hazardous
Waste
Generator
Taxes
and
Fees
State
Non­
size
Specific
Tax
or
Fee
Tax
or
Fee
Size­
specific
Taxes
and
Fees*

Description
LQG
>
2,000
tons/
yr
LQG
1,000
­

2,000
tons/
yr
LQG
500
­
1,000
tons/
yr
LQG
250
­
500
tons/
yr
LQG
50
­
250
tons/
yr
LQG
13.2
50
tons/
yr
SQG
1.3
­
13.2
tons/
yr
CESQG
<
1.3
tons/
yr
F­
5
OH
Hazardous
waste
treatment
and
disposal
fee.
Unclear
if
treatment
equals
recovery
in
this
state?

($
24/
ton)
Further
Analysis
Needed
OK
Annual
fee
for
off­
site
recycling
$
4.00/
ton
Generator
fee
$
100/
yr
$
100/
yr
$
100/
yr
$
100/
yr
$
100/
yr
$
100/
yr
$
25/
yr
$
0/
yr
OR
Annual
hazardous
waste
generation
fee
$
45.00/
ton
Annual
activity
verification
fee
$
525/
yr
$
525/
yr
$
525/
yr
$
525/
yr
$
525/
yr
$
525/
yr
$
300/
yr
$
0/
yr
SC
Annual
hazardous
waste
fee
Annual
nonhazardous
waste
fee
$
34.00/
ton
$
13.70/
t
TN
Annual
generator
fee
$
900/
yr
$
900/
yr
$
900/
yr
$
900/
yr
$
900/
yr
$
900/
yr
$
550/
yr
$
0/
yr
TX
Facility
fee
assessment.

Unclear
if
treatment
equals
recovery
in
this
state?
($
4.80/
ton)
Further
Analysis
Needed
Generation
fee
assessment
$
2/
ton
$
2/
ton
$
2/
ton
$
2/
ton
$
2/
ton
$
2/
ton
$
100/
yr
$
100/
yr
$
0/
yr
VT
Hazardous
waste
generation
fees
$
28.00/
ton
WA
Hazardous
waste
education
fee
$
35.00/
yr
WV
Generator
fee.
Unclear
if
treatment
equals
recovery
in
this
state?
Further
Analysis
Needed
Table
F­
1.
State
Hazardous
Waste
Generator
Taxes
and
Fees
State
Non­
size
Specific
Tax
or
Fee
Tax
or
Fee
Size­
specific
Taxes
and
Fees*

Description
LQG
>
2,000
tons/
yr
LQG
1,000
­

2,000
tons/
yr
LQG
500
­
1,000
tons/
yr
LQG
250
­
500
tons/
yr
LQG
50
­
250
tons/
yr
LQG
13.2
50
tons/
yr
SQG
1.3
­
13.2
tons/
yr
CESQG
<
1.3
tons/
yr
F­
6
WI
Tonnage
fee
and
manifest
fee
(
assumed
18
tons
shipped
per
manifest)
$
0.26/
ton
References:
U.
S.
Army
Corps
of
Engineers,
HTRW
Center
of
Expertise
Information
­
TDSF,
Section
8.2,
obtained
from
http://
www.
environmental.
usace.
army.
mil/
library/
pubs/
tsdf/
sec8­
2/
sec8­
2.
html
on
September
11,
2002.

Minnesota
Pollution
Control
Agency,
Small
and
Large
Quantity
Generator
License
Fees
and
Generator
(
Superfund)
Tax,
Waste/
Hazardous
Waste
#
1.03b,
March
2002.

*
These
size
categories
do
not
fit
for
all
states.
For
cost
modeling
purposes,
taxes
and
fees
for
states
with
different
size
categories
are
approximate
for
certain
size
categories.
G­
1
Appendix
G
Example
Cost
Calculation:
1999
On­
site
Metals
Recovery
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
Cost
Inputs
Total
Quantity
of
Hazardous
Waste
Generated
25
tons
hazardous
waste/
yr
Total
Quantity
of
Hazardous
Waste
Generated
(
25
tons
hazardous
waste/
yr)
­
(
25
tons
recovered
waste/
yr)+
(
25
tons
recovered
waste/
yr*
0.32
fraction
as
residuals
*
0.95
fraction
characteristically
hazardous)
=
7.6
tons
hazardous
waste/
yr
(
recovered
waste
quantity
no
longer
hazardous
by
definition)

Generator
Status
If
(
tons
hazardous
waste/
yr
>
13.2
tons/
yr)
then
LQG
Generator
Status
If
(
1.3
tons/
yr
<
tons
hazardous
waste/
yr
<
13.2
tons/
yr)
then
SQG
Quantity
of
Waste
Recovered
On
Site
25
tons
recovered
waste/
yr
Quantity
of
Waste
Recovered
On
Site
25
tons
recovered
waste/
yr
Estimated
Residual
Quantity
32%
of
recovered
waste
quantity
will
be
residual
(
0.32)
*
(
25
tons
recovered
waste/
yr)
=
8
tons
residual/
yr
Estimated
Residual
Quantity
32%
of
recovered
waste
quantity
will
be
residual
(
0.32)
*
(
25
tons
recovered
waste/
yr)
=
8
tons
residual/
yr
Estimated
Hazardous
Residual
Quantity
100%
residual
is
listed
&
characteristically
hazardous;

(
1.00)
*
(
8
tons
residual/
yr)
=
8
tons
hazardous
residual/
yr
Estimated
Hazardous
Residual
Quantity
95%
residual
is
characteristically
hazardous;

(
0.95)
*
(
8
tons
residual/
yr)
=
7.6
tons
hazardous
residual/
yr
Estimated
Nonhazardous
Residual
Quantity
0%
residual
is
nonhazardous;

(
0)
*
(
8
tons
residual/
yr)
=
0
tons
nonhazardous
residual/
yr
Estimated
Nonhazardous
Residual
Quantity
5%
residual
is
nonhazardous;

(
0.05)
*
(
8
tons
residual/
yr)
=
0.4
tons
nonhazardous
residual/
yr
Appendix
G
Example
Cost
Calculation:
1999
On­
site
Metals
Recovery
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
G­
2
Estimated
Recovered
Product
Quantity
20%
of
recovered
waste
quantity
will
be
recovered
metals
product
(
0.20)
*
(
25
tons
recovered
waste)
=
5
tons
recovered
metal
Estimated
Recovered
Product
Quantity
20%
of
recovered
waste
quantity
will
be
recovered
metals
product
(
0.20)
*
(
25
tons
recovered
waste)
=
5
tons
recovered
metal
Number
of
Off­
site
Hazardous
Waste
Residual
Shipments
per
Year
Given
LQG
then
maximum
of
(
4
shipments
or
8
tons
hazardous
residual/
18
tons
per
truck)
=
4
hazardous
waste
shipments
per
year
Number
of
Off­
site
Hazardous
Waste
Residual
Shipments
per
Year
Given
SQG
and
>
200
miles
then
maximum
of
(
1.33
shipments
or
7.6
tons
hazardous
residual/
18
tons
per
truck)
=
1.33
hazardous
waste
shipments
per
year
Number
of
Off­
site
Nonhazardous
Waste
Residual
Shipments
per
Year
(
0
tons
nonhazardous
residual/
18
tons
per
truck)
=
0
nonhazardous
waste
shipments
per
year
Number
of
Off­
site
Non­
Hazardous
Waste
Residual
Shipments
per
Year
(
0.4
tons
nonhazardous
residual/
18
tons
per
truck)
=
0.02
nonhazardous
waste
shipments
per
year
Distance
to
Nearest
Offsite
Hazardous
Waste
Landfill
338
miles
Distance
to
Nearest
Offsite
Hazardous
Waste
Landfill
338
miles
Distance
to
Nearest
Offsite
Non­
hazardous
Waste
Landfill
50
miles
Distance
to
Nearest
Offsite
Non­
hazardous
Waste
Landfill
50
miles
Location
of
Generator
Oregon
Location
of
Generator
Oregon
Cost
Calculations
(
costs
are
positive
and
revenues
are
negative)

On­
site
Metals
Recovery
Cost
($
308/
ton)
*
(
25
tons
recovered
waste/
yr)
=
$
7,700/
yr
On­
site
Metals
Recovery
Cost
($
308/
ton)
*
(
25
tons
recovered
waste/
yr)
=
$
7,700/
yr
Residual
Off­
site
Hazardous
Landfill
Cost
maximum(
($
312/
ton)
*
(
8
tons
hazardous
residual
per
yr)
or
($
2,246/
load)
*
(
4
Hazardous
Waste
Shipments)
=
$
8,984/
yr
Residual
Off­
site
Hazardous
Landfill
Cost
maximum
(
($
312/
ton)
*
(
7.6
tons
hazardous
residual
per
yr)
or
(
($
2,246/
load)
*
(
1.33
Hazardous
Waste
Shipments)
=
$
2,987/
yr
Residual
Off­
site
Nonhazardous
Landfill
Cost
($
111/
ton)
*
(
0
tons
nonhazardous
residual
per
yr)
=
$
0/
yr
Residual
Off­
site
Nonhazardous
Landfill
Cost
($
111/
ton)
*
(
0.4
tons
non­
hazardous
residual
per
yr)
=
$
44/
yr
Appendix
G
Example
Cost
Calculation:
1999
On­
site
Metals
Recovery
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
G­
3
Waste
Characterization
Testing
Cost
($
1,410/
load)
*
(
4
Hazardous
Loads
+
0
Non­
Hazardous
Load)
=
$
5,640/
yr
Waste
Characterization
Testing
Cost
($
1,410/
load)
*
(
1.33
Hazardous
Loads
+
0.02
Non­
Hazardous
Load)
=
$
1,903/
yr
Manifesting
Costs
($
236/
shipment)
*
(
4
shipments/
yr)
=
$
944/
yr
Manifesting
Costs
($
89/
shipment)
*
(
1.35
shipments/
yr)
=
$
120/
yr
Loading
Costs
($
2.57/
ton)
*
(
8
tons
residual)
=
$
21/
yr
Loading
Costs
($
2.57/
ton)
*
(
8
tons
residual)
=
$
21/
yr
Residual
Waste
Transportation
Costs
($
3.73/
mile)*(
4
hazardous
waste
landfill
shipments/
yr)*(
338
miles
to
hazardous
landfill/
hazardous
waste
shipment)
+
($
2.16/
mile)*(
0
nonhazardous
waste
landfill
shipments/
yr)*(
50
miles
to
nonhazardous
landfill/
nonhazardous
waste
shipment)
=
$
5,047/
yr
Transportation
Costs
($
3.73/
mile)*(
1.33
hazardous
waste
landfill
shipments/
yr)*(
338
miles
to
hazardous
landfill/
hazardous
waste
shipment)
+
($
2.16/
mile)*(
0.02
nonhazardous
waste
landfill
shipments/
yr)*(
50
miles
to
nonhazardous
landfill/
nonhazardous
waste
shipment)
=
$
1,676/
yr
Salvage
(
Recovered
Product)
Value
($
4,770/
ton
metal)
*
(
5
tons
recovered
metal/
yr)
=
­$
23,850/
yr
Salvage
(
Recovered
Product)
Value
($
4,770/
ton
metal)
*
(
5
tons
recovered
metal/
yr)
=
­$
23,850/
yr
Hazardous
Material
Training
Cost
Given
LQG
then
$
9,794/
yr
Hazardous
Material
Training
Cost
Given
SQG
then
$
2,191/
yr
Manifest
Training
Cost
Given
LQG
then
$
1,828/
yr
Manifest
Training
Cost
Given
SQG
then
$
1,828/
yr
Biennial
Report/
General
Administrative
Duties
Cost
Given
LQG
then
$
2,430/
yr
Biennial
Report/
General
Administrative
Duties
Cost
Given
SQG
then
$
1,215/
yr
Contingency
Planning
Cost
Given
LQG
then
$
2,796
Contingency
Planning
Cost
Given
SQG
then
$
0
Initial
Waste
Characterization
Cost
$
6,160
Initial
Waste
Characterization
Cost
$
6,160
Exclusion
Filing
Fee
(
One
time
Expenditure)
$
0
Exclusion
Filing
Fee
(
One
time
Expenditure)
$
639
Appendix
G
Example
Cost
Calculation:
1999
On­
site
Metals
Recovery
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
G­
4
State
Facility
Tax/
Fee
Given
Oregon
and
LQG
then:
$
525
activity
verification
fee/
yr
State
Facility
Tax/
Fee
Given
Oregon
and
SQG
then:
$
300
activity
verification
fee/
yr
State
Generation
Tax/
Fee
Given
Oregon
then:
($
45
generation
fee/
ton)*(
25
tons
recovered
waste/
yr)
=
$
1,125/
yr
State
Generation
Tax/
Fee
Given
Oregon
then:
($
45
generation
fee/
ton)*(
7.6
tons
residual/
yr)
=
$
342/
yr
Total
$
29,144/
yr
$
3,276/
yr
Incremental
Costs
­$
25,868/
yr
H­
1
Appendix
H
Example
Cost
Calculation:
1999
On­
site
Solvents
Recovery
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
Cost
Inputs
Total
Quantity
of
Hazardous
Waste
Generated
25
tons
hazardous
waste/
yr
Total
Quantity
of
Hazardous
Waste
Generated
(
25
tons
hazardous
waste/
yr)
­
(
25
tons
recovered
waste/
yr)+
(
25
tons
recovered
waste/
yr*
0.33
fraction
as
residuals
*
0.85
fraction
characteristically
hazardous)
=
7.0
tons
hazardous
waste/
yr
(
recovered
waste
quantity
no
longer
hazardous
by
definition)

Generator
Status
If
(
tons
hazardous
waste/
yr
>
13.2
tons/
yr)
then
LQG
Generator
Status
If
(
1.3
tons/
yr
<
tons
hazardous
waste/
yr
<
13.2
tons/
yr)
then
SQG
Quantity
of
Waste
Recovered
On
Site
25
tons
recovered
waste/
yr
Quantity
of
Waste
Recovered
On
Site
25
tons
recovered
waste/
yr
Estimated
Residual
Quantity
33%
of
recovered
waste
quantity
will
be
residual
(
0.33)
*
(
25
tons
recovered
waste/
yr)
=
8.2
tons
residual/
yr
Estimated
Residual
Quantity
33%
of
recovered
waste
quantity
will
be
residual
(
0.33)
*
(
25
tons
recovered
waste/
yr)
=
8.2
tons
residual/
yr
Estimated
Hazardous
Residual
Quantity
100%
residual
is
listed
&
characteristically
hazardous;

(
1.00)
*
(
8.2
tons
residual/
yr)
=
8.2
tons
hazardous
residual/
yr
Estimated
Hazardous
Residual
Quantity
85%
residual
is
characteristically
hazardous;

(
0.85)
*
(
8.2
tons
residual/
yr)
=
7.0
tons
hazardous
residual/
yr
Estimated
Nonhazardous
Residual
Quantity
0%
residual
is
nonhazardous;

(
0)
*
(
8.2
tons
residual/
yr)
=
0
tons
nonhazardous
residual/
yr
Estimated
Nonhazardous
Residual
Quantity
15%
residual
is
nonhazardous;

(
0.15)
*
(
8.2
tons
residual/
yr)
=
1.2
tons
nonhazardous
residual/
yr
Appendix
H
Example
Cost
Calculation:
1999
On­
site
Solvents
Recovery
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
H­
2
Estimated
Recovered
Product
Quantity
67%
of
recovered
waste
quantity
will
be
recovered
solvent
product
(
0.67)
*
(
25
tons
recovered
waste)
=
16.8
tons
recovered
solvent
Estimated
Recovered
Product
Quantity
67%
of
recovered
waste
quantity
will
be
recovered
solvent
product
(
0.67)
*
(
25
tons
recovered
waste)
=
16.8
tons
recovered
solvent
Number
of
Off­
site
Hazardous
Waste
Residual
Shipments
per
Year
Given
LQG
then
maximum
of
(
4
shipments
or
8.2
tons
hazardous
residual/
18
tons
per
truck)
=
4
hazardous
waste
shipments
per
year
Number
of
Off­
site
Hazardous
Waste
Residual
Shipments
per
Year
Given
SQG
and
>
200
miles
then
maximum
of
(
1.33
shipments
or
7
tons
hazardous
residual/
18
tons
per
truck)
=
1.33
hazardous
waste
shipments
per
year
Number
of
Off­
site
Nonhazardous
Waste
Residual
Shipments
per
Year
(
0
tons
nonhazardous
residual/
18
tons
per
truck)
=
0
nonhazardous
waste
shipments
per
year
Number
of
Off­
site
Non­
Hazardous
Waste
Residual
Shipments
per
Year
(
1.2
tons
nonhazardous
residual/
18
tons
per
truck)
=
0.07
nonhazardous
waste
shipments
per
year
Distance
to
Nearest
Offsite
Energy
Recovery
Facility
577
miles
Distance
to
Nearest
Offsite
Energy
Recovery
Facility
577
miles
Distance
to
Nearest
Offsite
Non­
hazardous
Waste
Landfill
50
miles
Distance
to
Nearest
Offsite
Non­
hazardous
Waste
Landfill
50
miles
Location
of
Generator
Oregon
Location
of
Generator
Oregon
Cost
Calculations
(
costs
are
positive
and
revenues
are
negative)

On­
site
Solvent
Recovery
Cost
$
43.49
*
(
25
tons
recovered
waste/
yr)
+
$
1,615
=
$
2,703/
yr
On­
site
Solvent
Recovery
Cost
$
43.49
*
(
25
tons
recovered
waste/
yr)
+
$
1,615
=
$
2,703/
yr
Residual
Off­
site
Energy
Recovery
Cost
maximum(($
291/
ton)
*
(
8.2
tons
hazardous
residual
per
yr)
or
($
338/
load)
*
(
4
Hazardous
Waste
Shipments)
=
$
2,386/
yr
Residual
Off­
site
Energy
Recovery
Cost
maximum
(
($
291/
ton)
*
(
7
tons
hazardous
residual
per
yr)
or
(
($
338/
load)
*
(
1.33
Hazardous
Waste
Shipments)
=
$
2,037/
yr
Appendix
H
Example
Cost
Calculation:
1999
On­
site
Solvents
Recovery
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
H­
3
Residual
Off­
site
Nonhazardous
Energy
Recovery
Cost
($
291/
ton)
*
(
0
tons
nonhazardous
residual
per
yr)
=
$
0/
yr
Residual
Off­
site
Non­
Hazardous
Energy
Recovery
Cost
($
291/
ton)
*
(
1.2
tons
non­
hazardous
residual
per
yr)
=
$
350/
yr
Waste
Characterization
Testing
Cost
($
1,410/
load)
*
(
4
Hazardous
Loads
+
0
Non­
Hazardous
Load)
=
$
5,640/
yr
Waste
Characterization
Testing
Cost
($
1,410/
load)
*
(
1.33
Hazardous
Loads
+
0.07
Non­
Hazardous
Load)
=
$
1,974/
yr
Manifesting
Costs
($
236/
shipment)
*
(
4
shipments/
yr)
=
$
944/
yr
Manifesting
Costs
($
89/
shipment)
*
(
1.40
shipments/
yr)
=
$
125/
yr
Loading
Costs
($
2.57/
ton)
*
(
8.2
tons
residual)
=
$
21/
yr
Loading
Costs
($
2.57/
ton)
*
(
8.2
tons
residual)
=
$
21/
yr
Residual
Waste
Transportation
Costs
($
2.94/
mile)*(
4
hazardous
waste
shipments/
yr)*(
577
miles
to
hazardous
energy
recovery/
hazardous
waste
shipment)
+
($
2.94/
mile)*(
0
nonhazardous
waste
shipments/
yr)*(
577
miles
to
nonhazardous
energy
recovery/
nonhazardous
waste
shipment)
=
$
6,786/
yr
Residual
Waste
Transportation
Costs
($
2.94/
mile)*(
1.33
hazardous
waste
shipments/
yr)*(
577
miles
to
hazardous
energy
recovery/
hazardous
waste
shipment)
+
($
2.94/
mile)*(
0.07
nonhazardous
waste
shipments/
yr)*(
577
miles
to
nonhazardous
energy
recovery/
nonhazardous
waste
shipment)
=
$
2,375/
yr
Salvage
(
Recovered
Product)
Value
($
1,543/
ton
solvent)
*
(
16.8
tons
recovered
solvent/
yr)
=
­$
25,922/
yr
Salvage
(
Recovered
Product)
Value
($
1,543/
ton
solvent)
*
(
16.8
tons
recovered
solvent/
yr)
=
­$
25,922/
yr
Hazardous
Material
Training
Cost
Given
LQG
then
$
9,794/
yr
Hazardous
Material
Training
Cost
Given
SQG
then
$
2,191/
yr
Manifest
Training
Cost
Given
LQG
then
$
1,828/
yr
Manifest
Training
Cost
Given
SQG
then
$
1,828/
yr
Biennial
Report/
General
Administrative
Duties
Cost
Given
LQG
then
$
2,430/
yr
Biennial
Report/
General
Administrative
Duties
Cost
Given
SQG
then
$
1,215/
yr
Contingency
Planning
Cost
Given
LQG
then
$
2,796
Contingency
Planning
Cost
Given
SQG
then
$
0
Initial
Waste
Characterization
Cost
$
6,160
Initial
Waste
Characterization
Cost
$
6,160
Appendix
H
Example
Cost
Calculation:
1999
On­
site
Solvents
Recovery
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
H­
4
Exclusion
Filing
Fee
(
One
time
Expenditure)
$
0
Exclusion
Filing
Fee
(
One
time
Expenditure)
$
639
State
Facility
Tax/
Fee
Given
Oregon
and
LQG
then:
$
525
activity
verification
fee/
yr
Given
Oregon
and
SQG
then:
$
300
activity
verification
fee/
yr
State
Generation
Tax/
Fee
Given
Oregon
then:
($
45
generation
fee/
ton)*(
25
tons
recovered
waste/
yr)
=
$
1,125/
yr
State
Generation
Tax/
Fee
Given
Oregon
then:
($
45
generation
fee/
ton)*(
7
tons
residual/
yr)
=
$
315/
yr
Total
$
22,213/
yr
$
1,308/
yr
Incremental
Costs
­$
20,905/
yr
E­
1
I­
2
Appendix
I
Example
Cost
Calculation:
1999
On­
site
Acid
Recovery
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
Cost
Inputs
Total
Quantity
of
Hazardous
Waste
Generated
30
tons
hazardous
waste/
yr
Total
Quantity
of
Hazardous
Waste
Generated
(
30
tons
hazardous
waste/
yr)
­
(
30
tons
recovered
waste/
yr)+
(
30
tons
recovered
waste/
yr*
0.26
fraction
as
residuals
*
0.75
fraction
characteristically
hazardous)
=
5.8
tons
hazardous
waste/
yr
(
recovered
waste
quantity
no
longer
hazardous
by
definition)

Generator
Status
If
(
tons
hazardous
waste/
yr
>
13.2
tons/
yr)
then
LQG
Generator
Status
If
(
1.3
tons/
yr
<
tons
hazardous
waste/
yr
<
13.2
tons/
yr)
then
SQG
Quantity
of
Waste
Recovered
On
Site
30
tons
recovered
waste/
yr
Quantity
of
Waste
Recovered
On
Site
30
tons
recovered
waste/
yr
Estimated
Residual
Quantity
26%
of
recovered
waste
quantity
will
be
residual
(
0.26)
*
(
30
tons
recovered
waste/
yr)
=
7.8
tons
residual/
yr
Estimated
Residual
Quantity
26%
of
recovered
waste
quantity
will
be
residual
(
0.26)
*
(
30
tons
recovered
waste/
yr)
=
7.8
tons
residual/
yr
Estimated
Hazardous
Residual
Quantity
100%
residual
is
listed
&
characteristically
hazardous;

(
1.00)
*
(
7.8
tons
residual/
yr)
=
7.8
tons
hazardous
residual/
yr
Estimated
Hazardous
Residual
Quantity
75%
residual
is
characteristically
hazardous;

(
0.75)
*
(
7.8
tons
residual/
yr)
=
5.9
tons
hazardous
residual/
yr
Estimated
Nonhazardous
Residual
Quantity
0%
residual
is
nonhazardous;

(
0)
*
(
7.8
tons
residual/
yr)
=
0
tons
nonhazardous
residual/
yr
Estimated
Nonhazardous
Residual
Quantity
25%
residual
is
nonhazardous;

(
0.25)
*
(
7.8
tons
residual/
yr)
=
2.0
tons
nonhazardous
residual/
yr
Appendix
I
Example
Cost
Calculation:
1999
On­
site
Acid
Recovery
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
I­
3
Estimated
Recovered
Product
Quantity
74%
of
recovered
waste
quantity
will
be
recovered
metals
product
(
0.74)
*
(
30
tons
recovered
waste)
=
22.2
tons
recovered
acid
Estimated
Recovered
Product
Quantity
74%
of
recovered
waste
quantity
will
be
recovered
metals
product
(
0.74)
*
(
30
tons
recovered
waste)
=
22.2
tons
recovered
acid
Number
of
Off­
site
Hazardous
Waste
Residual
Shipments
per
Year
Given
LQG
then
maximum
of
(
4
shipments
or
7.8
tons
hazardous
residual/
18
tons
per
truck)
=
4
hazardous
waste
shipments
per
year
Number
of
Off­
site
Hazardous
Waste
Residual
Shipments
per
Year
Given
SQG
and
>
200
miles
then
maximum
of
(
1.33
shipments
or
7.8
tons
hazardous
residual/
18
tons
per
truck)
=
1.33
hazardous
waste
shipments
per
year
Number
of
Off­
site
Nonhazardous
Waste
Residual
Shipments
per
Year
(
0
tons
nonhazardous
residual/
18
tons
per
truck)
=
0
nonhazardous
waste
shipments
per
year
Number
of
Off­
site
Non­
Hazardous
Waste
Residual
Shipments
per
Year
(
2.0
tons
nonhazardous
residual/
18
tons
per
truck)
=
0.11
nonhazardous
waste
shipments
per
year
Distance
to
Nearest
Offsite
Acid
Neutralization,
Stabilization,
Landfill
Facility
405
miles
Distance
to
Nearest
Offsite
Acid
Neutralization,
Stabilization,
Landfill
Facility
405
miles
Distance
to
Nearest
Offsite
Non­
hazardous
Waste
Landfill
50
miles
Distance
to
Nearest
Offsite
Non­
hazardous
Waste
Landfill
50
miles
Location
of
Generator
Oregon
Location
of
Generator
Oregon
Cost
Calculations
(
costs
are
positive
and
revenues
are
negative)

On­
site
Acid
Recovery
Cost
$
79.50
*
(
30
tons
recovered
waste/
yr)
+
$
1,804
=
$
4,189/
yr
On­
site
Acid
Recovery
Cost
$
79.50
*
(
30
tons
recovered
waste/
yr)
+
$
1,804
=
$
4,189/
yr
Residual
Off­
site
Acid
Neutralization,
Stabilization,
Landfill
Facility
Cost
maximum(($
38/
ton)
*
(
7.8
tons
hazardous
residual
per
yr)
or
($
316/
load)
*
(
4
Hazardous
Waste
Shipments)
=
$
1,264/
yr
Residual
Off­
site
Acid
Neutralization,
Stabilization,
Landfill
Facility
Cost
maximum
(($
38/
ton)
*
(
5.9
tons
hazardous
residual
per
yr)
or
(
($
316/
load)
*
(
1.33
Hazardous
Waste
Shipments)
=
$
1,264/
yr
Appendix
I
Example
Cost
Calculation:
1999
On­
site
Acid
Recovery
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
I­
4
Residual
Off­
site
Nonhazardous
Acid
Neutralization,
Stabilization,
Landfill
Facility
Cost
($
38/
ton)
*
(
0
tons
nonhazardous
residual
per
yr)
=
$
0/
yr
Residual
Off­
site
Nonhazardous
Acid
Neutralization,
Stabilization,
Landfill
Facility
Cost
($
38/
ton)
*
(
2.0
tons
nonhazardous
residual
per
yr)
=
$
76/
yr
Waste
Characterization
Testing
Cost
($
1,410/
load)
*
(
4
Hazardous
Loads
+
0
Non­
Hazardous
Load)
=
$
5,640/
yr
Waste
Characterization
Testing
Cost
($
1,410/
load)
*
(
1.33
Hazardous
Loads
+
0.11
Non­
Hazardous
Load)
=
$
2,045/
yr
Manifesting
Costs
($
236/
shipment)
*
(
4
shipments/
yr)
=
$
944/
yr
Manifesting
Costs
($
89/
shipment)
*
(
1.44
shipments/
yr)
=
$
128/
yr
Loading
Costs
($
2.57/
ton)
*
(
7.8
tons
residual)
=
$
20/
yr
Loading
Costs
($
2.57/
ton)
*
(
7.8
tons
residual)
=
$
20/
yr
Residual
Waste
Transportation
Costs
($
3.50/
mile)*(
4
hazardous
waste
landfill
shipments/
yr)*(
405
miles
to
hazardous
acid
neutralization,
stabilization,
landfill/
hazardous
waste
shipment)
+
($
3.50/
mile)*(
0
nonhazardous
waste
landfill
shipments/
yr)*(
405
miles
to
nonhazardous
acid
neutralization,
stabilization
landfill/
nonhazardous
waste
shipment)
=
$
5,670/
yr
Transportation
Costs
($
3.50/
mile)*(
1.33
hazardous
waste
landfill
shipments/
yr)*(
405
miles
to
hazardous
acid
neutralization,
stabilization/
hazardous
waste
shipment)
+
($
3.50/
mile)*(
0.11
nonhazardous
waste
landfill
shipments/
yr)*(
405
miles
to
nonhazardous
acid
neutralization,
stabilization/
nonhazardo
us
waste
shipment)
=
$
2,055/
yr
Salvage
(
Recovered
Product)
Value
($
298.12/
ton
acid)
*
(
22.2
tons
recovered
acid/
yr)
=
­$
6,618/
yr
Salvage
(
Recovered
Product)
Value
($
298.12/
ton
acid)
*
(
22.2
tons
recovered
acid/
yr)
=
­$
6,618/
yr
Hazardous
Material
Training
Cost
Given
LQG
then
$
9,794/
yr
Hazardous
Material
Training
Cost
Given
SQG
then
$
2,191/
yr
Manifest
Training
Cost
Given
LQG
then
$
1,828/
yr
Manifest
Training
Cost
Given
SQG
then
$
1,828/
yr
Appendix
I
Example
Cost
Calculation:
1999
On­
site
Acid
Recovery
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
I­
5
Biennial
Report/
General
Administrative
Duties
Cost
Given
LQG
then
$
2,430/
yr
Biennial
Report/
General
Administrative
Duties
Cost
Given
SQG
then
$
1,215/
yr
Contingency
Planning
Cost
Given
LQG
then
$
2,796
Contingency
Planning
Cost
Given
SQG
then
$
0
Initial
Waste
Characterization
Cost
$
6,160
Initial
Waste
Characterization
Cost
$
6,160
Exclusion
Filing
Fee
(
One
time
Expenditure)
$
0
Exclusion
Filing
Fee
(
One
time
Expenditure)
$
639
State
Facility
Tax/
Fee
Given
Oregon
and
LQG
then:
$
525
activity
verification
fee/
yr
State
Facility
Tax/
Fee
Given
Oregon
and
SQG
then:
$
300
activity
verification
fee/
yr
State
Generation
Tax/
Fee
Given
Oregon
then:
($
45
generation
fee/
ton)*(
30
tons
recovered
waste/
yr)
=
$
1,575/
yr
State
Generation
Tax/
Fee
Given
Oregon
then:
($
45
generation
fee/
ton)*(
5.9
tons
residual/
yr)
=
$
266/
yr
Total
$
36,217/
yr
$
15,743/
yr
Incremental
Costs
­$
20,474
J­
1
Appendix
J
Example
Cost
Calculation:
1997
On­
site
Metals
Recovery
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
Cost
Inputs
Total
Quantity
of
Hazardous
Waste
Generated
25
tons
hazardous
waste/
yr
Total
Quantity
of
Hazardous
Waste
Generated
(
25
tons
hazardous
waste/
yr)
­
(
25
tons
recovered
waste/
yr)+
(
25
tons
recovered
waste/
yr*
0.32
fraction
as
residuals
*
0.95
fraction
characteristically
hazardous)
=
7.6
tons
hazardous
waste/
yr
(
recovered
waste
quantity
no
longer
hazardous
by
definition)

Generator
Status
If
(
tons
hazardous
waste/
yr
>
13.2
tons/
yr)
then
LQG
Generator
Status
If
(
1.3
tons/
yr
<
tons
hazardous
waste/
yr
<
13.2
tons/
yr)
then
SQG
Quantity
of
Waste
Recovered
On
Site
0
tons
recovered
waste/
yr
Quantity
of
Waste
Recovered
On
Site
25
tons
recovered
waste/
yr
Estimated
Hazardous
Waste
Quantity
100%
of
waste
quantity
will
be
disposed
(
1)
*
(
25
tons
recovered
waste/
yr)
=
25
tons
waste/
yr
Estimated
Residual
Quantity
32%
of
recovered
waste
quantity
will
be
residual
(
0.32)
*
(
25
tons
recovered
waste/
yr)
=
8
tons
residual/
yr
Estimated
Hazardous
Residual
Quantity
100%
residual
is
listed
&
characteristically
hazardous;

(
1.00)
*
(
0
tons
residual/
yr)
=
0
tons
hazardous
residual/
yr
Estimated
Hazardous
Residual
Quantity
95%
residual
is
characteristically
hazardous;

(
0.95)
*
(
8
tons
residual/
yr)
=
7.6
tons
hazardous
residual/
yr
Estimated
Nonhazardous
Residual
Quantity
0%
residual
is
nonhazardous;

(
0)
*
(
0
tons
residual/
yr)
=
0
tons
nonhazardous
residual/
yr
Estimated
Nonhazardous
Residual
Quantity
5%
residual
is
nonhazardous;

(
0.05)
*
(
8
tons
residual/
yr)
=
0.4
tons
nonhazardous
residual/
yr
Appendix
J
Example
Cost
Calculation:
1997
On­
site
Metals
Recovery
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
J­
2
Estimated
Recovered
Product
Quantity
20%
of
recovered
waste
quantity
will
be
recovered
metals
product
(
0.20)
*
(
0
tons
recovered
waste)
=
0
tons
recovered
metal
Estimated
Recovered
Product
Quantity
20%
of
recovered
waste
quantity
will
be
recovered
metals
product
(
0.20)
*
(
25
tons
recovered
waste)
=
5
tons
recovered
metal
Number
of
Off­
site
Hazardous
Waste
Shipments
per
Year
Given
LQG
then
maximum
of
(
4
shipments
or
25
tons
hazardous
residual/
18
tons
per
truck)
=
4
hazardous
waste
shipments
per
year
Number
of
Off­
site
Hazardous
Waste
Shipments
per
Year
Given
SQG
and
>
200
miles
then
maximum
of
(
1.33
shipments
or
7.6
tons
hazardous
residual/
18
tons
per
truck)
=
1.33
hazardous
waste
shipments
per
year
Number
of
Off­
site
Nonhazardous
Waste
Shipments
per
Year
(
0
tons
nonhazardous
residual/
18
tons
per
truck)
=
0
nonhazardous
waste
shipments
per
year
Number
of
Off­
site
Nonhazardous
Waste
Shipments
per
Year
(
0.4
tons
nonhazardous
residual/
18
tons
per
truck)
=
0.02
nonhazardous
waste
shipments
per
year
Distance
to
Nearest
Offsite
Hazardous
Waste
Landfill
338
miles
Distance
to
Nearest
Offsite
Hazardous
Waste
Landfill
338
miles
Distance
to
Nearest
Offsite
Non­
hazardous
Waste
Landfill
50
miles
Distance
to
Nearest
Offsite
Non­
hazardous
Waste
Landfill
50
miles
Location
of
Generator
Oregon
Location
of
Generator
Oregon
Cost
Calculations
(
costs
are
positive
and
revenues
are
negative)

On­
site
Metals
Recovery
Cost
($
308/
ton)
*
(
0
tons
recovered
waste/
yr)
=
$
0/
yr
On­
site
Metals
Recovery
Cost
($
308/
ton)
*
(
25
tons
recovered
waste/
yr)
=
$
7,700/
yr
Off­
site
Disposal
Cost
at
Hazardous
Landfill
(
baseline)
maximum(
($
312/
ton)
*
(
25
tons
hazardous
residual
per
yr)
or
($
2,246/
load)
*
(
4
Hazardous
Waste
Shipments)
=
$
8,984/
yr
Residual
Off­
site
Hazardous
Landfill
Cost
maximum
(
($
312/
ton)
*
(
7.6
tons
hazardous
residual
per
yr)
or
(
($
2,246/
load)
*
(
1.33
Hazardous
Waste
Shipments)
=
$
2,987/
yr
Residual
Off­
site
Nonhazardous
Landfill
Cost
($
111/
ton)
*
(
0
tons
nonhazardous
residual
per
yr)
=
$
0/
yr
Residual
Off­
site
Nonhazardous
Landfill
Cost
($
111/
ton)
*
(
0.4
tons
non­
hazardous
residual
per
yr)
=
$
44/
yr
Appendix
J
Example
Cost
Calculation:
1997
On­
site
Metals
Recovery
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
J­
3
Waste
Characterization
Testing
Cost
($
1,410/
load)
*
(
4
Hazardous
Loads
+
0
Non­
Hazardous
Load)
=
$
5,640/
yr
Waste
Characterization
Testing
Cost
($
1,410/
load)
*
(
1.33
Hazardous
Loads
+
0.02
Non­
Hazardous
Load)
=
$
1,903/
yr
Manifesting
Costs
($
236/
shipment)
*
(
4
shipments/
yr)
=
$
944/
yr
Manifesting
Costs
($
89/
shipment)
*
(
1.35
shipments/
yr)
=
$
120/
yr
Loading
Costs
($
2.57/
ton)
*
(
25
tons
waste)
=
$
64/
yr
Loading
Costs
($
2.57/
ton)
*
(
8
tons
residual)
=
$
21/
yr
Residual
Waste
Transportation
Costs
($
3.73/
mile)*(
4
hazardous
waste
landfill
shipments/
yr)*(
338
miles
to
hazardous
landfill/
hazardous
waste
shipment)
+
($
2.16/
mile)*(
0
nonhazardous
waste
landfill
shipments/
yr)*(
50
miles
to
nonhazardous
landfill/
nonhazardous
waste
shipment)
=
$
5,047/
yr
Residual
Waste
Transportation
Costs
($
3.73/
mile)*(
1.33
hazardous
waste
landfill
shipments/
yr)*(
338
miles
to
hazardous
landfill/
hazardous
waste
shipment)
+
($
2.16/
mile)*(
0.02
nonhazardous
waste
landfill
shipments/
yr)*(
50
miles
to
nonhazardous
landfill/
nonhazardous
waste
shipment)
=
$
1,668/
yr
Salvage
(
Recovered
Product)
Value
($
4,770/
ton
metal)
*
(
0
tons
recovered
metal/
yr)
=
­$
0/
yr
Salvage
(
Recovered
Product)
Value
($
4,770/
ton
metal)
*
(
5
tons
recovered
metal/
yr)
=
­$
23,850/
yr
Hazardous
Material
Training
Cost
Given
LQG
then
$
9,794/
yr
Hazardous
Material
Training
Cost
Given
SQG
then
$
2,191/
yr
Manifest
Training
Cost
Given
LQG
then
$
1,828/
yr
Manifest
Training
Cost
Given
SQG
then
$
1,828/
yr
Biennial
Report/
General
Administrative
Duties
Cost
Given
LQG
then
$
2,430/
yr
Biennial
Report/
General
Administrative
Duties
Cost
Given
SQG
then
$
1,215/
yr
Contingency
Planning
Cost
Given
LQG
then
$
2,796
Contingency
Planning
Cost
Given
SQG
then
$
0
Initial
Waste
Characterization
Cost
$
6,160
Initial
Waste
Characterization
Cost
$
6,160
Exclusion
Filing
Fee
(
One
time
Expenditure)
$
0
Exclusion
Filing
Fee
(
One
time
Expenditure)
$
639
Appendix
J
Example
Cost
Calculation:
1997
On­
site
Metals
Recovery
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
J­
4
State
Facility
Tax/
Fee
Given
Oregon
and
LQG
then:
$
525
activity
verification
fee/
yr
State
Facility
Tax/
Fee
Given
Oregon
and
SQG
then:
$
300
activity
verification
fee/
yr
State
Generation
Tax/
Fee
Given
Oregon
then:
($
45
generation
fee/
ton)*(
25
tons
waste/
yr)
=
$
1,125/
yr
State
Generation
Tax/
Fee
Given
Oregon
then:
($
45
generation
fee/
ton)*(
7.6
tons
residual/
yr)
=
$
342/
yr
Total
$
45,337/
yr
$
3,268/
yr
Incremental
Costs
­$
42,069/
yr
K­
1
Appendix
K
Example
Cost
Calculation:
1997
On­
site
Solvents
Recovery
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
Cost
Inputs
Total
Quantity
of
Hazardous
Waste
Generated
25
tons
hazardous
waste/
yr
Total
Quantity
of
Hazardous
Waste
Generated
(
25
tons
hazardous
waste/
yr)
­
(
25
tons
recovered
waste/
yr)+
(
25
tons
recovered
waste/
yr*
0.33
fraction
as
residuals
*
0.85
fraction
characteristically
hazardous)
=
7
tons
hazardous
waste/
yr
(
recovered
waste
quantity
no
longer
hazardous
by
definition)

Generator
Status
If
(
tons
hazardous
waste/
yr
>
13.2
tons/
yr)
then
LQG
Generator
Status
If
(
1.3
tons/
yr
<
tons
hazardous
waste/
yr
<
13.2
tons/
yr)
then
SQG
Quantity
of
Waste
Recovered
On
Site
0
tons
recovered
waste/
yr
Quantity
of
Waste
Recovered
On
Site
25
tons
recovered
waste/
yr
Estimated
Hazardous
Waste
Quantity
100%
of
waste
quantity
will
be
disposed
(
1)
*
(
25
tons
recovered
waste/
yr)
=
25
tons
waste/
yr
Estimated
Residual
Quantity
33%
of
recovered
waste
quantity
will
be
residual
(
0.33)
*
(
25
tons
recovered
waste/
yr)
=
8.2
tons
residual/
yr
Estimated
Hazardous
Residual
Quantity
100%
residual
is
listed
&
characteristically
hazardous;

(
1.00)
*
(
0
tons
residual/
yr)
=
0
tons
hazardous
residual/
yr
Estimated
Hazardous
Residual
Quantity
85%
residual
is
characteristically
hazardous;

(
0.85)
*
(
8.2
tons
residual/
yr)
=
7.0
tons
hazardous
residual/
yr
Estimated
Nonhazardous
Residual
Quantity
0%
residual
is
nonhazardous;

(
0)
*
(
0
tons
residual/
yr)
=
0
tons
nonhazardous
residual/
yr
Estimated
Nonhazardous
Residual
Quantity
15%
residual
is
nonhazardous;

(
0.15)
*
(
8.2
tons
residual/
yr)
=
1.2
tons
nonhazardous
residual/
yr
Appendix
K
Example
Cost
Calculation:
1997
On­
site
Solvents
Recovery
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
K­
2
Estimated
Recovered
Product
Quantity
67%
of
recovered
waste
quantity
will
be
recovered
solvent
product
(
0.67)
*
(
0
tons
recovered
waste)
=
0
tons
recovered
solvent
Estimated
Recovered
Product
Quantity
67%
of
recovered
waste
quantity
will
be
recovered
solvent
product
(
0.67)
*
(
25
tons
recovered
waste)
=
16.8
tons
recovered
solvent
Number
of
Off­
site
Hazardous
Waste
Shipments
per
Year
Given
LQG
then
maximum
of
(
4
shipments
or
50
tons
hazardous
waste/
18
tons
per
truck)
=
4
hazardous
waste
shipments
per
year
Number
of
Off­
site
Hazardous
Waste
Shipments
per
Year
Given
SQG
and
>
200
miles
then
maximum
of
(
1.33
shipments
or
7
tons
hazardous
residual/
18
tons
per
truck)
=
1.33
hazardous
waste
shipments
per
year
Number
of
Off­
site
Nonhazardous
Waste
Shipments
per
Year
(
0
tons
nonhazardous
residual/
18
tons
per
truck)
=
0
nonhazardous
waste
shipments
per
year
Number
of
Off­
site
Non­
Hazardous
Waste
Residual
Shipments
per
Year
(
1.2
tons
nonhazardous
residual/
18
tons
per
truck)
=
0.07
nonhazardous
waste
shipments
per
year
Distance
to
Nearest
Offsite
Hazardous
Waste
Energy
Recovery
Facility
577
miles
Distance
to
Nearest
Offsite
Hazardous
Waste
Energy
Recovery
Facility
577
miles
Distance
to
Nearest
Offsite
Non­
hazardous
Waste
Landfill
50
miles
Distance
to
Nearest
Offsite
Non­
hazardous
Waste
Landfill
50
miles
Location
of
Generator
Oregon
Location
of
Generator
Oregon
Cost
Calculations
(
costs
are
positive
and
revenues
are
negative)

On­
site
Solvent
Recovery
Cost
$
43.49
*
(
0
tons
recovered
waste/
yr)
+
$
1,615
=
$
0/
yr
On­
site
Solvent
Recovery
Cost
$
43.49
*
(
25
tons
recovered
waste/
yr)
+
$
1,615
=
$
2,703/
yr
Off­
site
Disposal
Cost
at
Energy
Recovery
Facility/
Cement
Kiln
(
baseline)
($
291/
ton)
*
(
25
tons
hazardous
residual
per
yr)
=
$
7,275/
yr
Residual
Off­
site
Hazardous
Energy
Recovery
Cost
maximum
(
($
291/
ton)
*
(
7
tons
hazardous
residual
per
yr)
or
(
($
338/
load)
*
(
1.33
Hazardous
Waste
Shipments)
=
$
2,037/
yr
Appendix
K
Example
Cost
Calculation:
1997
On­
site
Solvents
Recovery
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
K­
3
Residual
Off­
site
Nonhazardous
Landfill
Cost
($
111/
ton)
*
(
0
tons
nonhazardous
residual
per
yr)
=
$
0/
yr
Residual
Off­
site
Nonhazardous
Energy
Recovery
Cost
($
291/
ton)
*
(
1.2
tons
non­
hazardous
residual
per
yr)
=
$
349/
yr
Waste
Characterization
Testing
Cost
($
1,410/
load)
*
(
4
Hazardous
Loads
+
0
Non­
Hazardous
Load)
=
$
5,640/
yr
Waste
Characterization
Testing
Cost
($
1,410/
load)
*
(
1.33
Hazardous
Loads
+
0.07
Non­
Hazardous
Load)
=
$
1,974/
yr
Manifesting
Costs
($
236/
shipment)
*
(
4
shipments/
yr)
=
$
944/
yr
Manifesting
Costs
($
89/
shipment)
*
(
1.40
shipments/
yr)
=
$
125/
yr
Loading
Costs
($
2.57/
ton)
*
(
25
tons
waste)
=
$
64/
yr
Loading
Costs
($
2.57/
ton)
*
(
8.2
tons
residual)
=
$
21/
yr
Hazardous
Waste
Transportation
Costs
($
2.94/
mile)*(
4
hazardous
waste
energy
recovery
shipments/
yr)*(
577
miles
to
hazardous
energy
recovery
facility/
hazardous
waste
shipment)
+
($
2.94/
mile)*(
0
nonhazardous
waste
energy
recovery
shipments/
yr)*(
577
miles
to
nonhazardous
energy
recovery/
nonhazardous
waste
shipment)
=
$
6,786/
yr
Residual
Waste
Transportation
Costs
($
2.94/
mile)*(
1.33
hazardous
waste
energy
recovery
shipments/
yr)*(
577
miles
to
hazardous
energy
recovery/
hazardous
waste
shipment)
+
($
2.97/
mile)*(
0.07
nonhazardous
waste
energy
recovery
shipments/
yr)*(
577
miles
to
nonhazardous
energy
recovery/
nonhazardous
waste
shipment)
=
$
2,375/
yr
Salvage
(
Recovered
Product)
Value
($
1,543/
ton
solvent)
*
(
0
tons
recovered
solvent/
yr)
=
­$
0/
yr
Salvage
(
Recovered
Product)
Value
($
1,543/
ton
solvent)
*
(
16.8
tons
recovered
solvent/
yr)
=
­$
25,922/
yr
Hazardous
Material
Training
Cost
Given
LQG
then
$
9,794/
yr
Hazardous
Material
Training
Cost
Given
SQG
then
$
2,191/
yr
Manifest
Training
Cost
Given
LQG
then
$
1,828/
yr
Manifest
Training
Cost
Given
SQG
then
$
1,828/
yr
Biennial
Report/
General
Administrative
Duties
Cost
Given
LQG
then
$
2,430/
yr
Biennial
Report/
General
Administrative
Duties
Cost
Given
SQG
then
$
1,215/
yr
Contingency
Planning
Cost
Given
LQG
then
$
2,796
Contingency
Planning
Cost
Given
SQG
then
$
0
Appendix
K
Example
Cost
Calculation:
1997
On­
site
Solvents
Recovery
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
K­
4
Initial
Waste
Characterization
Cost
$
6,160
Initial
Waste
Characterization
Cost
$
6,160
Exclusion
Filing
Fee
(
One
time
Expenditure)
$
0
Exclusion
Filing
Fee
(
One
time
Expenditure)
$
639
State
Facility
Tax/
Fee
Given
Oregon
and
LQG
then:
$
525
activity
verification
fee/
yr
State
Facility
Tax/
Fee
Given
Oregon
and
SQG
then:
$
300
activity
verification
fee/
yr
State
Generation
Tax/
Fee
Given
Oregon
then:
($
45
generation
fee/
ton)*(
25
tons
recovered
waste/
yr)
=
$
1,125/
yr
State
Generation
Tax/
Fee
Given
Oregon
then:
($
45
generation
fee/
ton)*(
7
tons
residual/
yr)
=
$
315/
yr
Total
$
45,367/
yr
­$
3,690/
yr
Incremental
Costs
­$
49,057/
yr
L­
1
Appendix
L
Example
Cost
Calculation:
1997
On­
site
Acid
Recovery
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
Cost
Inputs
Total
Quantity
of
Hazardous
Waste
Generated
30
tons
hazardous
waste/
yr
Total
Quantity
of
Hazardous
Waste
Generated
(
30
tons
hazardous
waste/
yr)
­
(
30
tons
recovered
waste/
yr)+
(
30
tons
recovered
waste/
yr*
0.26
fraction
as
residuals
*
0.75
fraction
characteristically
hazardous)
=
5.8
tons
hazardous
waste/
yr
(
recovered
waste
quantity
no
longer
hazardous
by
definition)

Generator
Status
If
(
tons
hazardous
waste/
yr
>
13.2
tons/
yr)
then
LQG
Generator
Status
If
(
1.3
tons/
yr
<
tons
hazardous
waste/
yr
<
13.2
tons/
yr)
then
SQG
Quantity
of
Waste
Recovered
On
Site
0
tons
recovered
waste/
yr
Quantity
of
Waste
Recovered
On
Site
30
tons
recovered
waste/
yr
Estimated
Hazardous
Waste
Quantity
100%
of
waste
quantity
will
be
disposed
(
1)
*
(
30
tons
disposed
waste/
yr)
=
30
tons
waste/
yr
Estimated
Residual
Quantity
26%
of
recovered
waste
quantity
will
be
residual
(
0.26)
*
(
30
tons
recovered
waste/
yr)
=
7.8
tons
residual/
yr
Estimated
Hazardous
Residual
Quantity
100%
residual
is
listed
&
characteristically
hazardous;

(
1.00)
*
(
0
tons
residual/
yr)
=
0
tons
hazardous
residual/
yr
Estimated
Hazardous
Residual
Quantity
75%
residual
is
characteristically
hazardous;

(
0.75)
*
(
7.8
tons
residual/
yr)
=
5.8
tons
hazardous
residual/
yr
Estimated
Nonhazardous
Residual
Quantity
0%
residual
is
nonhazardous;

(
0)
*
(
0
tons
residual/
yr)
=
0
tons
nonhazardous
residual/
yr
Estimated
Nonhazardous
Residual
Quantity
25%
residual
is
nonhazardous;

(
0.25)
*
(
7.8
tons
residual/
yr)
=
2
tons
nonhazardous
residual/
yr
Appendix
L
Example
Cost
Calculation:
1997
On­
site
Acid
Recovery
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
L­
2
Estimated
Recovered
Product
Quantity
74%
of
recovered
waste
quantity
will
be
recovered
acid
product
(
0.74)
*
(
0
tons
recovered
waste)
=
0
tons
recovered
acid
Estimated
Recovered
Product
Quantity
74%
of
recovered
waste
quantity
will
be
recovered
acid
product
(
0.74)
*
(
30
tons
recovered
waste)
=
22
tons
recovered
acid
Number
of
Off­
site
Hazardous
Waste
Shipments
per
Year
Given
LQG
then
maximum
of
(
4
shipments
or
30
tons
hazardous
waste/
18
tons
per
truck)
=
4
hazardous
waste
shipments
per
year
Number
of
Off­
site
Hazardous
Waste
Residual
Shipments
per
Year
Given
SQG
and
>
200
miles
then
maximum
of
(
1.33
shipments
or
7.8
tons
hazardous
residual/
18
tons
per
truck)
=
1.33
hazardous
waste
shipments
per
year
Number
of
Off­
site
Nonhazardous
Waste
Shipments
per
Year
(
0
tons
nonhazardous
residual/
18
tons
per
truck)
=
0
nonhazardous
waste
shipments
per
year
Number
of
Off­
site
Non­
Hazardous
Waste
Residual
Shipments
per
Year
(
2
tons
nonhazardous
residual/
18
tons
per
truck)
=
0.11
nonhazardous
waste
shipments
per
year
Distance
to
Nearest
Offsite
Hazardous
Waste
Acid
Neutralization,
Stabilization,
Landfill
Facility
405
miles
Distance
to
Nearest
Offsite
Hazardous
Waste
Acid
Neutralization,
Stabilization,
Landfill
Facility
405
miles
Distance
to
Nearest
Offsite
Non­
hazardous
Waste
Landfill
50
miles
Distance
to
Nearest
Offsite
Non­
hazardous
Waste
Landfill
50
miles
Location
of
Generator
Oregon
Location
of
Generator
Oregon
Cost
Calculations
(
costs
are
positive
and
revenues
are
negative)

On­
site
Acid
Recovery
Cost
$
79.50
*
(
0
tons
recovered
waste/
yr)
+
$
1,809
=
$
0/
yr
On­
site
Acid
Recovery
Cost
$
79.50
*
(
30
tons
recovered
waste/
yr)
+
$
1,809
=
$
4,194/
yr
On­
site
Treatment
Cost
by
Acid
Neutralization
(
baseline)
($
3.26/
ton
+
$
18,830)
*
(
30
tons
hazardous
waste
per
yr)
=
$
18,928/
yr
Residual
Off­
site
Hazardous
Acid
Neutralization,
Stabilization,
Landfill
Cost
maximum
(($
38/
ton)
*
(
5.8
tons
hazardous
residual
per
yr)
or
(
($
316/
load)
*
(
1.33
Hazardous
Waste
Shipments)
=
$
420/
yr
Appendix
L
Example
Cost
Calculation:
1997
On­
site
Acid
Recovery
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
L­
3
Residual
Off­
site
Nonhazardous
Acid
Neutralization,
Stabilization,
Landfill
Cost
($
38/
ton)
*
(
0
tons
nonhazardous
residual
per
yr)
=
$
0/
yr
Residual
Off­
site
Nonhazardous
Acid
Neutralization,
Stabilization,
Landfill
Cost
($
38/
ton)
*
(
2
tons
nonhazardous
residual
per
yr)
=
$
76/
yr
Waste
Characterization
Testing
Cost
($
1,410/
load)
*
(
0
Hazardous
Loads
+
0
Non­
Hazardous
Load)
=
$
0/
yr
Waste
Characterization
Testing
Cost
($
1,410/
load)
*
(
1.33
Hazardous
Loads
+
0.11
Non­
Hazardous
Load)
=
$
2,030/
yr
Manifesting
Costs
($
236/
shipment)
*
(
0
shipments/
yr)
=
$
0/
yr
Manifesting
Costs
($
89/
shipment)
*
(
1.44
shipments/
yr)
=
$
128/
yr
Loading
Costs
($
2.57/
ton)
*
(
0
tons
residual)
=
$
0/
yr
Loading
Costs
($
2.57/
ton)
*
(
7.8
tons
residual)
=
$
20/
yr
Residual
Waste
Transportation
Costs
($
3.50/
mile)*(
0
hazardous
waste
shipments/
yr)*(
405
miles
to
hazardous
acid
neutralization,
stabilization,
landfill/
hazardous
waste
shipment)
+
($
3.50/
mile)*(
0
nonhazardous
waste
shipments/
yr)*(
405
miles
to
nonhazardous
acid
neutralization,
stabilization,
landfill/
nonhazardous
waste
shipment)
=
$
0/
yr
Residual
Waste
Transportation
Costs
($
3.50/
mile)*(
1.33
hazardous
waste
shipments/
yr)*(
405
miles
to
hazardous
acid
neutralization,
stabilization,
landfill/
hazardous
waste
shipment)
+
($
3.50/
mile)*(
0.11
nonhazardous
waste
shipments/
yr)*(
405
miles
to
nonhazardous
acid
neutralization,
stabilization,
landfill/
nonhazardous
waste
shipment)
=
$
2,055/
yr
Salvage
(
Recovered
Product)
Value
($
298.12/
ton
acid)
*
(
0
tons
recovered
acid/
yr)
=
­$
0/
yr
Salvage
(
Recovered
Product)
Value
($
298.12/
ton
acid)
*
(
22
tons
recovered
acid/
yr)
=
­$
6,559/
yr
Hazardous
Material
Training
Cost
Given
LQG
then
$
9,794/
yr
Hazardous
Material
Training
Cost
Given
SQG
then
$
2,191/
yr
Manifest
Training
Cost
Given
LQG
then
$
0/
yr
Manifest
Training
Cost
Given
SQG
then
$
1,828/
yr
Biennial
Report/
General
Administrative
Duties
Cost
Given
LQG
then
$
2,430/
yr
Biennial
Report/
General
Administrative
Duties
Cost
Given
SQG
then
$
1,215/
yr
Appendix
L
Example
Cost
Calculation:
1997
On­
site
Acid
Recovery
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
L­
4
Contingency
Planning
Cost
Given
LQG
then
$
2,796
Contingency
Planning
Cost
Given
SQG
then
$
0
Initial
Waste
Characterization
Cost
$
6,160
Initial
Waste
Characterization
Cost
$
6,160
Exclusion
Filing
Fee
(
One
time
Expenditure)
$
0
Exclusion
Filing
Fee
(
One
time
Expenditure)
$
639
State
Facility
Tax/
Fee
Given
Oregon
and
LQG
then:
$
525
activity
verification
fee/
yr
State
Facility
Tax/
Fee
Given
Oregon
and
SQG
then:
$
300
activity
verification
fee/
yr
State
Generation
Tax/
Fee
Given
Oregon
then:
($
45
generation
fee/
ton)*(
30
tons
neutralized
waste/
yr)
=
$
1,350/
yr
State
Generation
Tax/
Fee
Given
Oregon
then:
($
45
generation
fee/
ton)*(
5.8
tons
residual
waste/
yr)
=
$
261/
yr
Total
$
41,983/
yr
$
14,958/
yr
Incremental
Costs
­$
27,025/
yr
M­
1
Appendix
M
Example
Cost
Calculation:
1999
Off­
site
Metals
Recovery
Within
Same
NAICS
(
2001$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
Cost
Inputs
Total
Quantity
of
Hazardous
Waste
Generated
25
tons
hazardous
waste/
yr
Total
Quantity
of
Hazardous
Waste
Generated
(
25
tons
hazardous
waste/
yr)
­
(
25
tons
recovered
waste/
yr)+
(
25
tons
recovered
waste/
yr*
0.32
fraction
as
residuals
*
0.95
fraction
characteristically
hazardous)
=
7.6
tons
hazardous
waste/
yr
(
recovered
waste
quantity
no
longer
hazardous
by
definition)

Generator
Status
If
(
tons
hazardous
waste/
yr
>
13.2
tons/
yr)
then
LQG
Generator
Status
If
(
1.3
tons/
yr
<
tons
hazardous
waste/
yr
<
13.2
tons/
yr)
then
SQG
Quantity
of
Waste
Recovered
Off
Site
25
tons
recovered
waste/
yr
Quantity
of
Waste
Recovered
Off
Site
25
tons/
yr
Estimated
Residual
Quantity
for
Recovery
Facility*
32%
of
recovered
waste
quantity
will
be
residual
(
0.32)
*
(
25
tons
recovered
waste/
yr)
=
8
tons
residual/
yr
Estimated
Residual
Quantity
for
Recovery
Facility*
32%
of
recovered
waste
quantity
will
be
residual
(
0.32)
*
(
25
tons
recovered
waste/
yr)
=
8
tons
residual/
yr
Estimated
Hazardous
Residual
Quantity
for
Recovery
Facility*
100%
residual
is
listed
&
characteristically
hazardous;

(
1.00)
*
(
8
tons
residual/
yr)
=
8
tons
hazardous
residual/
yr
Estimated
Hazardous
Residual
Quantity
for
Recovery
Facility*
95%
residual
is
characteristically
hazardous;

(
0.95)
*
(
8
tons
residual/
yr)
=
7.6
tons
hazardous
residual/
yr
Estimated
Nonhazardous
Residual
Quantity
for
Recovery
Facility*
0%
residual
is
nonhazardous;

(
0)
*
(
8
tons
residual/
yr)
=
0
tons
nonhazardous
residual/
yr
Estimated
Nonhazardous
Residual
Quantity
for
Recovery
Facility*
5%
residual
is
nonhazardous;

(
0.05)
*
(
8
tons
residual/
yr)
=
0.4
tons
nonhazardous
residual/
yr
Appendix
M
Example
Cost
Calculation:
1999
Off­
site
Metals
Recovery
Within
Same
NAICS
(
2001$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
M­
2
Estimated
Recovered
Product
Quantity
20%
of
recovered
waste
quantity
will
be
recovered
metals
product
(
0.20)
*
(
25
tons
recovered
waste)
=
5
tons
recovered
metal
Estimated
Recovered
Product
Quantity
20%
of
recovered
waste
quantity
will
be
recovered
metals
product
(
0.20)
*
(
25
tons
recovered
waste)
=
5
tons
recovered
metal
Number
of
Off­
site
Metals
Recovery
Shipments
per
Year
by
Generator
25
tons
recovered
waste
/
18
tons
per
truck)
=
1.4
recovery
shipments
per
year
Number
of
Off­
site
Metals
Recovery
Shipments
per
Year
by
Generator
25
tons
recovered
waste
/
18
tons
per
truck)
=
1.4
recovery
shipments
per
year
Number
of
Off­
site
Hazardous
Waste
Residual
Shipments
per
Year
for
Recovery
Facility*
Given
LQG
then
maximum
of
(
4
shipments
or
8
tons
hazardous
residual/
18
tons
per
truck)
=
4
hazardous
waste
shipments
per
year
Number
of
Off­
site
Hazardous
Waste
Residual
Shipments
per
Year
for
Recovery
Facility*
Given
SQG
and
>
200
miles
then
maximum
of
(
1.33
shipments
or
7.6
tons
hazardous
residual/
18
tons
per
truck)
=
1.33
hazardous
waste
shipments
per
year
Number
of
Off­
site
Nonhazardous
Waste
Residual
Shipments
per
Year
for
Recovery
Facility*
(
0
tons
nonhazardous
residual/
18
tons
per
truck)
=
0
nonhazardous
waste
shipments
per
year
Number
of
Off­
site
Non­
Hazardous
Waste
Residual
Shipments
per
Year
for
Recovery
Facility*
(
0.4
tons
nonhazardous
residual/
18
tons
per
truck)
=
0.02
nonhazardous
waste
shipments
per
year
Distance
to
Nearest
Offsite
Hazardous
Waste
Landfill
338
miles
Distance
to
Nearest
Offsite
Hazardous
Waste
Landfill
338
miles
Distance
to
Off­
site
Recovery
Facility
521
miles
Distance
to
Off­
site
Recovery
Facility
521
miles
Distance
to
Nearest
Offsite
Non­
hazardous
Waste
Landfill
50
miles
Distance
to
Nearest
Offsite
Non­
hazardous
Waste
Landfill
50
miles
Location
of
Generator
Oregon
Location
of
Generator
Oregon
Cost
Calculations
(
costs
are
positive
and
revenues
are
negative)

Off­
site
Metals
Recovery
Cost
for
Generator
($
308/
ton)
*
(
25
tons
recovered
waste/
yr)
=
$
7,700/
yr
Off­
site
Metals
Recovery
Cost
for
Generator
($
308/
ton)
*
(
25
tons
recovered
waste/
yr)
=
$
7,700/
yr
Appendix
M
Example
Cost
Calculation:
1999
Off­
site
Metals
Recovery
Within
Same
NAICS
(
2001$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
M­
3
Residual
Off­
site
Hazardous
Landfill
Cost
for
Recovery
Facility*
maximum(
($
312/
ton)
*
(
8
tons
hazardous
residual
per
yr)
or
($
2,246/
load)
*
(
4
Hazardous
Waste
Shipments)
=
$
8,984/
yr
Residual
Off­
site
Hazardous
Landfill
Cost
for
Recovery
Facility*
maximum
(
($
312/
ton)
*
(
7.6
tons
hazardous
residual
per
yr)
or
(
($
2,246/
load)
*
(
1.33
Hazardous
Waste
Shipments)
=
$
2,987/
yr
Residual
Off­
site
Nonhazardous
Landfill
Cost
for
Recovery
Facility*
($
111/
ton)
*
(
0
tons
nonhazardous
residual
per
yr)
=
$
0/
yr
Residual
Off­
site
Nonhazardous
Landfill
Cost
for
Recovery
Facility*
($
111/
ton)
*
(
0.4
tons
non­
hazardous
residual
per
yr)
=
$
44/
yr
Waste
Characterization
Testing
Cost
for
Recovery
Facility*
($
1,410/
load)
*
(
4
Hazardous
Loads
+
0
Non­
Hazardous
Load)
=
$
5,640/
yr
Waste
Characterization
Testing
Cost
for
Recovery
Facility*
($
1,410/
load)
*
(
1.33
Hazardous
Loads
+
0.02
Non­
Hazardous
Load)
=
$
1,903/
yr
Manifesting
Costs
for
Generator
and
Recovery
Facility
($
236/
shipment)
*
(
1.4
Recovery
shipments/
yr
+
4
Hazardous
residual
shipments)
=
$
1,274/
yr
Manifesting
Costs
for
Generator
and
Recovery
Facility
($
89/
shipment)
*
(
1.33
residual
shipments/
yr
+
1.4
recovery
shipments/
yr)
=
$
243/
yr
Loading
Costs
for
Generator
and
Recovery
Facility
($
2.57/
ton)
*
(
8
tons
residual
+
25
tons
recovered
waste)
=
$
85/
yr
Loading
Costs
for
Generator
and
Recovery
Facility
($
2.57/
ton)
*
(
8
tons
residual
+
25
tons
recovered
waste)
=
$
85/
yr
Residual
Waste
Transportation
Costs
for
Recovery
Facility*
($
3.73/
mile)*(
4
hazardous
waste
landfill
shipments/
yr)*(
338
miles
to
hazardous
landfill/
hazardous
waste
shipment)
+
($
2.16/
mile)*(
0
nonhazardous
waste
landfill
shipments/
yr)*(
50
miles
to
nonhazardous
landfill/
nonhazardous
waste
shipment)
=
$
5,047/
yr
Residual
Transportation
Costs
for
Recovery
Facility*
($
3.73/
mile)*(
1.33
hazardous
waste
landfill
shipments/
yr)*(
338
miles
to
hazardous
landfill/
hazardous
waste
shipment)
+
($
2.16/
mile)*(
0.02
nonhazardous
waste
landfill
shipments/
yr)*(
50
miles
to
nonhazardous
landfill/
nonhazardous
waste
shipment)
=
$
1,668/
yr
Recovered
Waste
Transportation
Cost
for
Generator
($
6.20/
mile)*(
1.4
recovered
waste
shipments/
yr)*(
521
miles
to
recovery
facility/
hazardous
waste
shipment)
=
$
4,522/
yr
Recovered
Waste
Transportation
Cost
for
Generator
($
6.20/
mile)*(
1.4
recovered
waste
shipments/
yr)*(
521
miles
to
recovery
facility/
hazardous
waste
shipment)
=
$
4,522/
yr
Appendix
M
Example
Cost
Calculation:
1999
Off­
site
Metals
Recovery
Within
Same
NAICS
(
2001$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
J­
1
Salvage
(
Recovered
Product)
Value
($
4,770/
ton
metal)
*
(
5
tons
recovered
metal/
yr)
=
­$
23,850/
yr
Salvage
(
Recovered
Product)
Value
($
4,770/
ton
metal)
*
(
5
tons
recovered
metal/
yr)
=
­$
23,850/
yr
Hazardous
Material
Training
Cost
Given
LQG
then
$
9,794/
yr
Hazardous
Material
Training
Cost
Given
SQG
then
$
2,191/
yr
Manifest
Training
Cost
Given
LQG
then
$
1,828/
yr
Manifest
Training
Cost
Given
SQG
then
$
1,828/
yr
Biennial
Report/
General
Administrative
Duties
Cost
Given
LQG
then
$
2,430/
yr
Biennial
Report/
General
Administrative
Duties
Cost
Given
SQG
then
$
1,215/
yr
Contingency
Planning
Cost
Given
LQG
then
$
2,796
Contingency
Planning
Cost
Given
SQG
then
$
0
Initial
Waste
Characterization
Cost
$
6,160
Initial
Waste
Characterization
Cost
$
6,160
Exclusion
Filing
Fee
(
One
time
Expenditure)
$
0
Exclusion
Filing
Fee
(
One
time
Expenditure)
$
639
State
Facility
Tax/
Fee
Given
Oregon
and
LQG
then:
$
525
activity
verification
fee/
yr
State
Facility
Tax/
Fee
Given
Oregon
and
SQG
then:
$
300
activity
verification
fee/
yr
State
Generation
Tax/
Fee
for
Generator
Given
Oregon
then:
($
45
generation
fee/
ton)*(
25
tons
recovered
waste/
yr)
=
$
1,125/
yr
State
Generation
Tax/
Fee
for
Recovery
Facility*
Given
Oregon
then:
($
45
generation
fee/
ton)*(
7.6
tons
recovered
waste/
yr)
=
$
342/
yr
Total
$
34,060/
yr
$
25,077/
yr
Incremental
Costs
­$
8,983/
yr
*
Given
wastes
are
transferred
within
the
same
NAICS,
it
is
assumed
that
the
recovery
facility
in
most
cases
is
owned
by
the
same
company
that
owns
the
generator
facility.
Costs
for
the
recovery
facility
are
added
to
the
generator's
costs
because
the
same
company
carrying
the
burden
of
the
added
cost.
N­
2
Appendix
N
Example
Cost
Calculation:
1999
Off­
site
Solvents
Recovery
Within
Same
NAICS
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
Cost
Inputs
Total
Quantity
of
Hazardous
Waste
Generated
25
tons
hazardous
waste/
yr
Total
Quantity
of
Hazardous
Waste
Generated
(
25
tons
hazardous
waste/
yr)
­
(
25
tons
recovered
waste/
yr)+
(
25
tons
recovered
waste/
yr*
0.33
fraction
as
residuals
*
0.85
fraction
characteristically
hazardous)
=
7
tons
hazardous
waste/
yr
(
recovered
waste
quantity
no
longer
hazardous
by
definition)

Generator
Status
If
(
tons
hazardous
waste/
yr
>
13.2
tons/
yr)
then
LQG
Generator
Status
If
(
1.3
tons/
yr
<
tons
hazardous
waste/
yr
<
13.2
tons/
yr)
then
SQG
Quantity
of
Waste
Recovered
Off
Site
25
tons
recovered
waste/
yr
Quantity
of
Waste
Recovered
Off
Site
25
tons
recovered
waste
/
yr
Estimated
Residual
Quantity
for
Recovery
Facility*
33%
of
recovered
waste
quantity
will
be
residual
(
0.33)
*
(
25
tons
recovered
waste/
yr)
=
8.2
tons
residual/
yr
Estimated
Residual
Quantity
for
Recovery
Facility
*
33%
of
recovered
waste
quantity
will
be
residual
(
0.33)
*
(
25
tons
recovered
waste/
yr)
=
8.2
tons
residual/
yr
Estimated
Hazardous
Residual
Quantity
for
Recovery
Facility*
100%
residual
is
listed
&
characteristically
hazardous;

(
1.00)
*
(
8.2
tons
residual/
yr)
=
8.2
tons
hazardous
residual/
yr
Estimated
Hazardous
Residual
Quantity
for
Recovery
Facility*
85%
residual
is
characteristically
hazardous;

(
0.85)
*
(
8.2
tons
residual/
yr)
=
7
tons
hazardous
residual/
yr
Estimated
Nonhazardous
Residual
Quantity
for
Recovery
Facility*
0%
residual
is
nonhazardous;

(
0)
*
(
8.2
tons
residual/
yr)
=
0
tons
nonhazardous
residual/
yr
Estimated
Nonhazardous
Residual
Quantity
for
Recovery
Facility*
15%
residual
is
nonhazardous;

(
0.15)
*
(
8.2
tons
residual/
yr)
=
1.2
tons
nonhazardous
residual/
yr
Appendix
N
Example
Cost
Calculation:
1999
Off­
site
Solvents
Recovery
Within
Same
NAICS
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
N­
3
Estimated
Recovered
Product
Quantity
67%
of
recovered
waste
quantity
will
be
recovered
solvent
product
(
0.67)
*
(
25
tons
recovered
waste)
=
16.8
tons
recovered
solvent
Estimated
Recovered
Product
Quantity
67%
of
recovered
waste
quantity
will
be
recovered
solvent
product
(
0.67)
*
(
25
tons
recovered
waste)
=
16.8
tons
recovered
solvent
Number
of
Off­
site
Solvent
Recovery
Shipments
per
Year
25
tons
recovered
waste
/
18
tons
per
truck)
=
1.4
recovery
shipments
per
year
Number
of
Off­
site
Solvent
Recovery
Shipments
per
Year
25
tons
recovered
waste
/
18
tons
per
truck)
=
1.4
recovery
shipments
per
year
Number
of
Off­
site
Hazardous
Waste
Residual
Shipments
per
Year
for
Recovery
Facility*
Given
LQG
then
maximum
of
(
4
shipments
or
8.2
tons
hazardous
residual/
18
tons
per
truck)
=
4
hazardous
waste
shipments
per
year
Number
of
Off­
site
Hazardous
Waste
Residual
Shipments
per
Year
for
Recovery
Facility*
Given
SQG
and
>
200
miles
then
maximum
of
(
1.33
shipments
or
7
tons
hazardous
residual/
18
tons
per
truck)
=
1.33
hazardous
waste
shipments
per
year
Number
of
Off­
site
Nonhazardous
Waste
Residual
Shipments
per
Year
for
Recovery
Facility*
(
0
tons
nonhazardous
residual/
18
tons
per
truck)
=
0
nonhazardous
waste
shipments
per
year
Number
of
Off­
site
Non­
Hazardous
Waste
Residual
Shipments
per
Year
for
Recovery
Facility*
(
1.2
tons
nonhazardous
residual/
18
tons
per
truck)
=
0.07
nonhazardous
waste
shipments
per
year
Distance
to
Nearest
Offsite
Hazardous
Waste
Energy
Recovery
577
miles
Distance
to
Nearest
Offsite
Hazardous
Waste
Energy
Recovery
Facility
577
miles
Distance
to
Off­
site
Recovery
Facility
521
miles
Distance
to
Off­
site
Recovery
Facility
521
miles
Distance
to
Nearest
Offsite
Non­
hazardous
Waste
Landfill
50
miles
Distance
to
Nearest
Offsite
Non­
hazardous
Waste
Landfill
50
miles
Location
of
Generator
Oregon
Location
of
Generator
Oregon
Cost
Calculations
(
costs
are
positive
and
revenues
are
negative)

Off­
site
Solvent
Recovery
Cost
($
1,066/
ton)
*
(
25
tons
recovered
waste/
yr)
=
$
26,650/
yr
Off­
site
Solvent
Recovery
Cost
($
1,066/
ton)
*
(
25
tons
recovered
waste/
yr)
=
$
26,650/
yr
Appendix
N
Example
Cost
Calculation:
1999
Off­
site
Solvents
Recovery
Within
Same
NAICS
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
N­
4
Residual
Off­
site
Hazardous
Energy
Recovery
Cost
for
Recovery
Facility*
maximum(($
291/
ton)
*
(
8.2
tons
hazardous
residual
per
yr)
or
($
338/
load)
*
(
4
Hazardous
Waste
Shipments)
=
$
2,386/
yr
Residual
Off­
site
Hazardous
Energy
Recovery
Cost
for
Recovery
Facility*
maximum
(
($
291/
ton)
*
(
7
tons
hazardous
residual
per
yr)
or
(
($
338/
load)
*
(
1.33
Hazardous
Waste
Shipments)
=
$
2,037/
yr
Residual
Off­
site
Non­
Hazardous
Energy
Recovery
Cost
($
291/
ton)
*
(
0
tons
nonhazardous
residual
per
yr)
=
$
0/
yr
Residual
Off­
site
Non­
Hazardous
Energy
Recovery
Cost
($
291/
ton)
*
(
1.2
tons
non­
hazardous
residual
per
yr)
=
$
349/
yr
Waste
Characterization
Testing
Cost
for
Recovery
Facility*
($
1,410/
load)
*
(
4
Hazardous
Loads
+
0
Non­
Hazardous
Load)
=
$
5,640/
yr
Waste
Characterization
Testing
Cost
for
Recovery
Facility*
($
1,410/
load)
*
(
1.33
Hazardous
Loads
+
0.07
Non­
Hazardous
Load)
=
$
1,974/
yr
Manifesting
Costs
for
Generator
&
Recovery
Facility*
($
236/
shipment)
*
(
1.4
Recovery
shipments/
yr
+
4
Hazardous
residual
shipments)
=
$
1,274/
yr
Manifesting
Costs
for
Generator
&
Recovery
Facility*
($
89/
shipment)
*
(
1.33
residual
shipments/
yr
+
1.4
recovery
shipments/
yr)
=
$
243/
yr
Loading
Costs
for
Generator
&
Recovery
Facility*
($
2.57/
ton)
*
(
8.2
tons
residual
+
25
tons
recovered
waste)
=
$
85/
yr
Loading
Costs
for
Generator
&
Recovery
Facility*
($
2.57/
ton)
*
(
8.2
tons
residual
+
25
tons
recovered
waste)
=
$
85/
yr
Residual
Waste
Transportation
Costs
for
Recovery
Facility*
($
2.94/
mile)*(
4
hazardous
waste
shipments/
yr)*(
577
miles
to
hazardous
energy
recovery/
hazardous
waste
shipment)
+
($
2.94/
mile)*(
0
nonhazardous
waste
energy
recovery
shipments/
yr)*(
577
miles
to
nonhazardous
energy
recovery/
nonhazardous
waste
shipment)
=
$
6,786/
yr
Residual
Waste
Transportation
Costs
for
Recovery
Facility*
($
2.94/
mile)*(
1.33
hazardous
waste
shipments/
yr)*(
577
miles
to
hazardous
energy
recovery/
hazardous
waste
shipment)
+
($
2.94/
mile)*(
0.07
nonhazardous
waste
shipments/
yr)*(
577
miles
to
nonhazardous
energy
recovery/
nonhazardous
waste
shipment)
=
$
2,375/
yr
Recovered
Waste
Transportation
Cost
for
Generator
($
6.20/
mile)*(
1.4
recovered
waste
shipments/
yr)*(
521
miles
to
recovery
facility/
hazardous
waste
shipment)
=
$
4,522/
yr
Recovered
Waste
Transportation
Cost
for
Generator
($
6.20/
mile)*(
1.4
recovered
waste
shipments/
yr)*(
521
miles
to
hazardous
recovery
facility/
hazardous
waste
shipment)
=
$
4,522/
yr
Appendix
N
Example
Cost
Calculation:
1999
Off­
site
Solvents
Recovery
Within
Same
NAICS
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
K­
1
Salvage
(
Recovered
Product)
Value
($
1,543/
ton
solvent)
*
(
16.8
tons
recovered
solvent/
yr)
=
­$
25,922/
yr
Salvage
(
Recovered
Product)
Value
($
1,543/
ton
solvent)
*
(
16.8
tons
recovered
solvent/
yr)
=
­$
25,922/
yr
Hazardous
Material
Training
Cost
Given
LQG
then
$
9,794/
yr
Hazardous
Material
Training
Cost
Given
SQG
then
$
2,191/
yr
Manifest
Training
Cost
Given
LQG
then
$
1,828/
yr
Manifest
Training
Cost
Given
SQG
then
$
1,828/
yr
Biennial
Report/
General
Administrative
Duties
Cost
Given
LQG
then
$
2,430/
yr
Biennial
Report/
General
Administrative
Duties
Cost
Given
SQG
then
$
1,215/
yr
Contingency
Planning
Cost
Given
LQG
then
$
2,796
Contingency
Planning
Cost
Given
SQG
then
$
0
Initial
Waste
Characterization
Cost
$
6,160
Initial
Waste
Characterization
Cost
$
6,160
Exclusion
Filing
Fee
(
One
time
Expenditure)
$
0
Exclusion
Filing
Fee
(
One
time
Expenditure)
$
639
State
Facility
Tax/
Fee
for
Generator
Given
Oregon
and
LQG
then:
$
525
activity
verification
fee/
yr
State
Facility
Tax/
Fee
for
Recovery
Facility*
Given
Oregon
and
SQG
then:
$
300
activity
verification
fee/
yr
State
Generation
Tax/
Fee
for
Generator
Given
Oregon
then:
($
45
generation
fee/
ton)*(
25
tons
recovered
waste/
yr)
=
$
1,125/
yr
State
Generation
Tax/
Fee
for
Recovery
Facility*
Given
Oregon
then:
($
45
generation
fee/
ton)*(
7
tons
recovered
waste/
yr)
=
$
315/
yr
Total
$
46,079/
yr
­$
24,961/
yr
Incremental
Costs
­$
21,118/
yr
*
Given
wastes
are
transferred
within
the
same
NAICS,
it
is
assumed
that
the
recovery
facility
in
most
cases
is
owned
by
the
same
company
that
owns
the
generator
facility.
Costs
for
the
recovery
facility
are
added
to
the
generator's
costs
because
the
same
company
carrying
the
burden
of
the
added
cost.
O­
2
Appendix
O
Example
Cost
Calculation:
1999
Off­
site
Acid
Recovery
Within
Same
NAICS
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
Cost
Inputs
Total
Quantity
of
Hazardous
Waste
Generated
30
tons
hazardous
waste/
yr
Total
Quantity
of
Hazardous
Waste
Generated
(
30
tons
hazardous
waste/
yr)
­
(
30
tons
recovered
waste/
yr)+
(
30
tons
recovered
waste/
yr*
0.26
fraction
as
residuals
*
0.75
fraction
characteristically
hazardous)
=
5.8
tons
hazardous
waste/
yr
(
recovered
waste
quantity
no
longer
hazardous
by
definition)

Generator
Status
If
(
tons
hazardous
waste/
yr
>
13.2
tons/
yr)
then
LQG
Generator
Status
If
(
1.3
tons/
yr
<
tons
hazardous
waste/
yr
<
13.2
tons/
yr)
then
SQG
Quantity
of
Waste
Recovered
Off
Site
30
tons
recovered
waste/
yr
Quantity
of
Waste
Recovered
Off
Site
30
tons
recovered
waste/
yr
Estimated
Residual
Quantity
for
Recovery
Facility*
26%
of
recovered
waste
quantity
will
be
residual
(
0.26)
*
(
30
tons
recovered
waste/
yr)
=
7.8
tons
residual/
yr
Estimated
Residual
Quantity
for
Recovery
Facility*
26%
of
recovered
waste
quantity
will
be
residual
(
0.26)
*
(
30
tons
recovered
waste/
yr)
=
7.8
tons
residual/
yr
Estimated
Hazardous
Residual
Quantity
for
Recovery
Facility*
100%
residual
is
listed
&
characteristically
hazardous;

(
1.00)
*
(
7.8
tons
residual/
yr)
=
7.8
tons
hazardous
residual/
yr
Estimated
Hazardous
Residual
Quantity
for
Recovery
Facility*
75%
residual
is
characteristically
hazardous;

(
0.75)
*
(
7.8
tons
residual/
yr)
=
5.8
tons
hazardous
residual/
yr
Estimated
Nonhazardous
Residual
Quantity
for
Recovery
Facility*
0%
residual
is
nonhazardous;

(
0)
*
(
7.8
tons
residual/
yr)
=
0
tons
nonhazardous
residual/
yr
Estimated
Nonhazardous
Residual
Quantity
for
Recovery
Facility*
25%
residual
is
nonhazardous;

(
0.25)
*
(
7.8
tons
residual/
yr)
=
2
tons
nonhazardous
residual/
yr
Appendix
O
Example
Cost
Calculation:
1999
Off­
site
Acid
Recovery
Within
Same
NAICS
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
O­
3
Estimated
Recovered
Product
Quantity
74%
of
recovered
waste
quantity
will
be
recovered
metals
product
(
0.74)
*
(
30
tons
recovered
waste)
=
21.2
tons
recovered
acid
Estimated
Recovered
Product
Quantity
74%
of
recovered
waste
quantity
will
be
recovered
metals
product
(
0.74)
*
(
30
tons
recovered
waste)
=
22.2
tons
recovered
acid
Number
of
Off­
site
Acid
Recovery
Shipments
per
Year
30
tons
recovered
waste/
18
tons
per
truck
=
1.7
recovery
shipments
per
year
Number
of
Off­
site
Acid
Recovery
Shipments
per
Year
30
tons
recovered
waste/
18
tons
per
truck
=
1.7
recovery
shipments
per
year
Number
of
Off­
site
Hazardous
Waste
Residual
Shipments
per
Year
for
Recovery
Facility*
Given
LQG
then
maximum
of
(
4
shipments
or
7.8
tons
hazardous
residual/
18
tons
per
truck)
=
4
hazardous
waste
shipments
per
year
Number
of
Off­
site
Hazardous
Waste
Residual
Shipments
per
Year
for
Recovery
Facility*
Given
SQG
and
>
200
miles
then
maximum
of
(
1.33
shipments
or
7.8
tons
hazardous
residual/
18
tons
per
truck)
=
1.33
hazardous
waste
shipments
per
year
Number
of
Off­
site
Nonhazardous
Waste
Residual
Shipments
per
Year
for
Recovery
Facility*
(
0
tons
nonhazardous
residual/
18
tons
per
truck)
=
0
nonhazardous
waste
shipments
per
year
Number
of
Off­
site
Non­
Hazardous
Waste
Residual
Shipments
per
Year
for
Recovery
Facility*
(
2
tons
nonhazardous
residual/
18
tons
per
truck)
=
0.11
nonhazardous
waste
shipments
per
year
Distance
to
Nearest
Offsite
Hazardous
Waste
Acid
Neutralization,
Stabilization,
Landfill
405
miles
Distance
to
Nearest
Offsite
Hazardous
Waste
Acid
Neutralization,
Stabilization,
Landfill
405
miles
Distance
to
Off­
site
Recovery
Facility
521
miles
Distance
to
Off­
site
Recovery
Facility
521
miles
Distance
to
Nearest
Offsite
Non­
hazardous
Waste
Landfill
50
miles
Distance
to
Nearest
Offsite
Non­
hazardous
Waste
Landfill
50
miles
Location
of
Generator
Oregon
Location
of
Generator
Oregon
Cost
Calculations
(
costs
are
positive
and
revenues
are
negative)

Off­
site
Acid
Recovery
Cost
($
170/
ton)
*
(
30
tons
recovered
waste/
yr)
=
$
5,100/
yr
Off­
site
Acid
Recovery
Cost
($
170/
ton)
*
(
30
tons
recovered
waste/
yr)
=
$
5,100/
yr
Appendix
O
Example
Cost
Calculation:
1999
Off­
site
Acid
Recovery
Within
Same
NAICS
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
O­
4
Residual
Off­
site
Hazardous
Acid
Neutralization,
Stabilization,
Landfill
Cost
for
Recovery
Facility*
maximum(($
38/
ton)
*
(
7.8
tons
hazardous
residual
per
yr)
or
($
316/
load)
*
(
4
Hazardous
Waste
Shipments)
=
$
1,264/
yr
Residual
Off­
site
Hazardous
Acid
Neutralization,
Stabilization,
Landfill
Cost
for
Recovery
Facility*
maximum
(($
38/
ton)
*
(
5.8
tons
hazardous
residual
per
yr)
or
(
($
316/
load)
*
(
1.33
Hazardous
Waste
Shipments)
=
$
1,264/
yr
Residual
Off­
site
Non­
Hazardous
Acid
Neutralization,
Stabilization,
Landfill
Cost
for
Recovery
Facility*
($
38/
ton)
*
(
0
tons
nonhazardous
residual
per
yr)
=
$
0/
yr
Residual
Off­
site
Non­
Hazardous
Acid
Neutralization,
Stabilization,
Landfill
Cost
for
Recovery
Facility*
($
38/
ton)
*
(
2
tons
nonhazardous
residual
per
yr)
=
$
76/
yr
Waste
Characterization
Testing
Cost
($
1,410/
load)
*
(
4
Hazardous
Loads
+
0
Non­
Hazardous
Load)
=
$
5,640/
yr
Waste
Characterization
Testing
Cost
($
1,410/
load)
*
(
1.33
Hazardous
Loads
+
0.11
Non­
Hazardous
Load)
=
$
2,030/
yr
Manifesting
Costs
($
236/
shipment)
*
(
1.7
recovery
shipments/
yr
+
4
residual
shipments/
yr)
=
$
1,345/
yr
Manifesting
Costs
($
89/
shipment)
*
(
1.7
recovery
shipments/
yr
+
1.44
residual
shipments/
yr)
=
$
279/
yr
Loading
Costs
($
2.57/
ton)
*
(
7.8
tons
residual
+
50
tons
recovered
waste
)
=
$
149/
yr
Loading
Costs
($
2.57/
ton)
*
(
7.8
tons
residual
+
50
tons
recovered
waste
)
=
$
149/
yr
Residual
Waste
Transportation
Costs
for
Recovery
Facility*
($
3.50/
mile)*(
4
hazardous
waste
shipments/
yr)*(
405
miles
to
hazardous
acid
neutralization,
stab.,
landfill/
hazardous
waste
shipment)
+
($
3.50/
mile)*(
0
nonhazardous
waste
shipments/
yr)*(
405
miles
to
nonhazardous
neutralization,
stab.,
landfill/
nonhazardous
waste
shipment)
=
$
5,670/
yr
Residual
Waste
Transportation
Costs
for
Recovery
Facility*
($
3.50/
mile)*(
1.33
hazardous
waste
shipments/
yr)*(
405
miles
to
hazardous
acid
neutralization,
stab.,
landfill/
hazardous
waste
shipment)
+
($
3.50/
mile)*(
0.11
nonhazardous
waste
shipments/
yr)*(
405
miles
to
nonhazardous
acid
neutralization,
stab.,
landfill/
nonhazardous
waste
shipment)
=
$
2,055/
yr
Appendix
O
Example
Cost
Calculation:
1999
Off­
site
Acid
Recovery
Within
Same
NAICS
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
L­
1
Recovered
Waste
Transportation
Cost
for
Generator
($
6.20/
mile)*(
1.7
recovered
waste
shipments/
yr)*(
521
miles
to
hazardous
acid
regeneration/
hazardous
waste
shipment)
=
$
5,491/
yr
Recovered
Waste
Transportation
Cost
for
Generator
($
6.20/
mile)*(
1.7
recovered
waste
shipments/
yr)*(
521
miles
to
acid
regeneration/
hazardous
waste
shipment)
=
$
5,491/
yr
Salvage
(
Recovered
Product)
Value
($
298.12/
ton
acid)
*
(
22.2
tons
recovered
acid/
yr)
=
­$
6,618/
yr
Salvage
(
Recovered
Product)
Value
($
298.12/
ton
acid)
*
(
22.2
tons
recovered
acid/
yr)
=
­$
6,618/
yr
Hazardous
Material
Training
Cost
Given
LQG
then
$
9,794/
yr
Hazardous
Material
Training
Cost
Given
SQG
then
$
2,191/
yr
Manifest
Training
Cost
Given
LQG
then
$
1,828/
yr
Manifest
Training
Cost
Given
SQG
then
$
1,828/
yr
Biennial
Report/
General
Administrative
Duties
Cost
Given
LQG
then
$
2,430/
yr
Biennial
Report/
General
Administrative
Duties
Cost
Given
SQG
then
$
1,215/
yr
Contingency
Planning
Cost
Given
LQG
then
$
2,796
Contingency
Planning
Cost
Given
SQG
then
$
0
Initial
Waste
Characterization
Cost
$
6,160
Initial
Waste
Characterization
Cost
$
6,160
Exclusion
Filing
Fee
(
One
time
Expenditure)
$
0
Exclusion
Filing
Fee
(
One
time
Expenditure)
$
639
State
Facility
Tax/
Fee
for
Generator
Given
Oregon
and
LQG
then:
$
525
activity
verification
fee/
yr
State
Facility
Tax/
Fee
for
Recovery
Facility*
Given
Oregon
and
SQG
then:
$
300
activity
verification
fee/
yr
State
Generation
Tax/
Fee
for
Generator
Given
Oregon
then:
($
45
generation
fee/
ton)*(
30
tons
recovered
waste/
yr)
=
$
1,575/
yr
State
Generation
Tax/
Fee
for
Recovery
Facility*
Given
Oregon
then:
($
45
generation
fee/
ton)*(
6.5
tons
recovered
waste/
yr)
=
$
293/
yr
Total
$
43,149/
yr
$
22,420/
yr
Incremental
Costs
­$
20,729/
yr
L­
2
*
Given
wastes
are
transferred
within
the
same
NAICS,
it
is
assumed
that
the
recovery
facility
in
most
cases
is
owned
by
the
same
company
that
owns
the
generator
facility.
Costs
for
the
recovery
facility
are
added
to
the
generator's
costs
because
the
same
company
carrying
the
burden
of
the
added
cost.
P­
3
Appendix
P
Example
Cost
Calculation:
1997
Off­
site
Metals
Recovery
Within
Same
NAICS
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
Cost
Inputs
Total
Quantity
of
Hazardous
Waste
Generated
25
tons
hazardous
waste/
yr
Total
Quantity
of
Hazardous
Waste
Generated
(
25
tons
hazardous
waste/
yr)
­
(
25
tons
recovered
waste/
yr)+
(
25
tons
recovered
waste/
yr*
0.32
fraction
as
residuals
*
0.95
fraction
characteristically
hazardous)
=
7.6
tons
hazardous
waste/
yr
(
recovered
waste
quantity
no
longer
hazardous
by
definition)

Generator
Status
If
(
tons
hazardous
waste/
yr
>
13.2
tons/
yr)
then
LQG
Generator
Status
If
(
1.3
tons/
yr
<
tons
hazardous
waste/
yr
<
13.2
tons/
yr)
then
SQG
Quantity
of
Waste
Recovered
Off
Site
0
tons
recovered
waste/
yr
Quantity
of
Waste
Recovered
Off
Site
25
tons
recovered
waste/
yr
Estimated
Hazardous
Waste
Quantity
for
Generator
100%
of
waste
quantity
will
be
disposed
(
1)
*
(
50
tons
recovered
waste/
yr)
=
50
tons
waste/
yr
Estimated
Residual
Quantity
for
Recovery
Facility*
32%
of
recovered
waste
quantity
will
be
residual
(
0.06)
*
(
50
tons
recovered
waste/
yr)
=
3
tons
residual/
yr
Estimated
Hazardous
Residual
Quantity
100%
residual
is
listed
&
characteristically
hazardous;

(
1.00)
*
(
0
tons
residual/
yr)
=
0
tons
hazardous
residual/
yr
Estimated
Hazardous
Residual
Quantity
for
Recovery
Facility*
95%
residual
is
characteristically
hazardous;

(
0.95)
*
(
8
tons
residual/
yr)
=
7.6
tons
hazardous
residual/
yr
Estimated
Nonhazardous
Residual
Quantity
0%
residual
is
nonhazardous;

(
0)
*
(
0
tons
residual/
yr)
=
0
tons
nonhazardous
residual/
yr
Estimated
Nonhazardous
Residual
Quantity
for
Recovery
Facility*
5%
residual
is
nonhazardous;

(
0.05)
*
(
8
tons
residual/
yr)
=
0.4
tons
nonhazardous
residual/
yr
Appendix
P
Example
Cost
Calculation:
1997
Off­
site
Metals
Recovery
Within
Same
NAICS
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
P­
4
Estimated
Recovered
Product
Quantity
20%
of
recovered
waste
quantity
will
be
recovered
metals
product
(
0.20)
*
(
0
tons
recovered
waste)
=
0
tons
recovered
metal
Estimated
Recovered
Product
Quantity
20%
of
recovered
waste
quantity
will
be
recovered
metals
product
(
0.20)
*
(
25
tons
recovered
waste)
=
5
tons
recovered
metal
Number
of
Off­
site
Metals
Recovery
Shipments
per
Year
0
tons
recovered
waste
/
18
tons
per
truck)
=
0
recovery
shipments
per
year
Number
of
Off­
site
Metals
Recovery
Shipments
per
Year
25
tons
recovered
waste
/
18
tons
per
truck)
=
1.4
recovery
shipments
per
year
Number
of
Off­
site
Hazardous
Waste
Shipments
per
Year
by
Generator
Given
LQG
then
maximum
of
(
4
shipments
or
25
tons
hazardous
residual/
18
tons
per
truck)
=
4
hazardous
waste
shipments
per
year
Number
of
Off­
site
Hazardous
Waste
Residual
Shipments
per
Year
for
Recovery
Facility*
Given
SQG
and
>
200
miles
then
maximum
of
(
1.33
shipments
or
7.6
tons
hazardous
residual/
18
tons
per
truck)
=
1.33
hazardous
waste
shipments
per
year
Number
of
Off­
site
Nonhazardous
Waste
Shipments
per
Year
by
Generator
(
0
tons
nonhazardous
residual/
18
tons
per
truck)
=
0
nonhazardous
waste
shipments
per
year
Number
of
Off­
site
Non­
Hazardous
Waste
Residual
Shipments
per
Year
for
Recovery
Facility*
(
0.4
tons
nonhazardous
residual/
18
tons
per
truck)
=
0.02
nonhazardous
waste
shipments
per
year
Distance
to
Nearest
Offsite
Hazardous
Waste
Landfill
338
miles
Distance
to
Nearest
Offsite
Hazardous
Waste
Landfill
338
miles
Distance
to
Off­
site
Recovery
Facility
521
miles
Distance
to
Off­
site
Recovery
Facility
521
miles
Distance
to
Nearest
Offsite
Non­
hazardous
Waste
Landfill
50
miles
Distance
to
Nearest
Offsite
Non­
hazardous
Waste
Landfill
50
miles
Location
of
Generator
Oregon
Location
of
Generator
Oregon
Cost
Calculations
(
costs
are
positive
and
revenues
are
negative)

Off­
site
Metals
Recovery
Cost
($
308/
ton)
*
(
0
tons
recovered
waste/
yr)
=
$
0/
yr
Off­
site
Metals
Recovery
Cost
for
Generator
($
308/
ton)
*
(
25
tons
recovered
waste/
yr)
=
$
7,700/
yr
Appendix
P
Example
Cost
Calculation:
1997
Off­
site
Metals
Recovery
Within
Same
NAICS
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
P­
5
Off­
site
Disposal
Cost
at
Hazardous
Landfill
(
baseline)
for
Generator
maximum(
($
312/
ton)
*
(
25
tons
hazardous
residual
per
yr)
or
($
2,246/
load)
*
(
4
Hazardous
Waste
Shipments)
=
$
8,984/
yr
Residual
Off­
site
Hazardous
Landfill
Cost
for
Recovery
Facility*
maximum
(
($
312/
ton)
*
(
7.6
tons
hazardous
residual
per
yr)
or
(
($
2,246/
load)
*
(
1.33
Hazardous
Waste
Shipments)
=
$
2,987/
yr
Residual
Off­
site
Non­
Hazardous
Landfill
Cost
($
111/
ton)
*
(
0
tons
nonhazardous
residual
per
yr)
=
$
0/
yr
Residual
Off­
site
Non­
Hazardous
Landfill
Cost
for
Recovery
Facility*
($
111/
ton)
*
(
0.4
tons
non­
hazardous
residual
per
yr)
=
$
44/
yr
Waste
Characterization
Testing
Cost
for
Generator
($
1,410/
load)
*
(
4
Hazardous
Loads
+
0
Non­
Hazardous
Load)
=
$
5,640/
yr
Waste
Characterization
Testing
Cost
for
Recovery
Facility*
($
1,410/
load)
*
(
1.33
Hazardous
Loads
+
0.02
Non­
Hazardous
Load)
=
$
1,903/
yr
Manifesting
Costs
for
Generator
($
236/
shipment)
*
(
4
shipments/
yr)
=
$
944/
yr
Manifesting
Costs
for
Generator
&
Recovery
Facility*
($
89/
shipment)
*
(
1.35
shipments/
yr
+
1.4
recovery
loads)
=
$
85/
yr
Loading
Costs
for
Generator
($
2.57/
ton)
*
(
25
tons
waste)
=
$
64/
yr
Loading
Costs
for
Generator
&
Recovery
Facility*
($
2.57/
ton)
*
(
8
tons
residual
+
25
tons
recovered
waste)
=
$
85/
yr
Hazardous
Waste
Transportation
Costs
for
Generator
($
3.73/
mile)*(
4
hazardous
waste
landfill
shipments/
yr)*(
338
miles
to
hazardous
landfill/
hazardous
waste
shipment)
+
($
2.16/
mile)*(
0
nonhazardous
waste
landfill
shipments/
yr)*(
50
miles
to
nonhazardous
landfill/
nonhazardous
waste
shipment)
=
$
5,047/
yr
Residual
Waste
Transportation
Costs
for
Recovery
Facility*
($
3.73/
mile)*(
1.33
hazardous
waste
landfill
shipments/
yr)*(
338
miles
to
hazardous
landfill/
hazardous
waste
shipment)
+
($
2.16/
mile)*(
0.02
nonhazardous
waste
landfill
shipments/
yr)*(
50
miles
to
nonhazardous
landfill/
nonhazardous
waste
shipment)
=
$
1,668/
yr
Recovered
Waste
Transportation
Cost
($
6.20/
mile)*(
0
recovered
waste
shipments/
yr)*(
521
miles
to
metals
recovery/
hazardous
waste
shipment)
=
$
0/
yr
Recovered
Waste
Transportation
Cost
for
Generator
($
6.20/
mile)*(
1.4
recovered
waste
shipments/
yr)*(
521
miles
to
hazardous
metals
recovery/
hazardous
waste
shipment)
=
$
4,522/
yr
Appendix
P
Example
Cost
Calculation:
1997
Off­
site
Metals
Recovery
Within
Same
NAICS
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
P­
6
Salvage
(
Recovered
Product)
Value
($
4,770/
ton
metal)
*
(
0
tons
recovered
metal/
yr)
=
­$
0/
yr
Salvage
(
Recovered
Product)
Value
($
4,770/
ton
metal)
*
(
5
tons
recovered
metal/
yr)
=
­$
23,850/
yr
Hazardous
Material
Training
Cost
Given
LQG
then
$
9,794/
yr
Hazardous
Material
Training
Cost
Given
SQG
then
$
2,191/
yr
Manifest
Training
Cost
Given
LQG
then
$
1,828/
yr
Manifest
Training
Cost
Given
SQG
then
$
1,828/
yr
Biennial
Report/
General
Administrative
Duties
Cost
Given
LQG
then
$
2,430/
yr
Biennial
Report/
General
Administrative
Duties
Cost
Given
SQG
then
$
1,215/
yr
Contingency
Planning
Cost
Given
LQG
then
$
2,796
Contingency
Planning
Cost
Given
SQG
then
$
0
Initial
Waste
Characterization
Cost
$
6,160
Initial
Waste
Characterization
Cost
$
6,160
Exclusion
Filing
Fee
(
One
time
Expenditure)
$
0
Exclusion
Filing
Fee
(
One
time
Expenditure)
$
639
State
Facility
Tax/
Fee
for
Generator
Given
Oregon
and
LQG
then:
$
525
activity
verification
fee/
yr
State
Facility
Tax/
Fee
for
Recovery
Facility*
Given
Oregon
and
SQG
then:
$
300
activity
verification
fee/
yr
State
Generation
Tax/
Fee
for
Generator
Given
Oregon
then:
($
45
generation
fee/
ton)*(
25
tons
waste/
yr)
=
$
1,125/
yr
State
Generation
Tax/
Fee
for
Recovery
Facility*
Given
Oregon
then:
($
45
generation
fee/
ton)*(
7.6
tons
recovered
waste/
yr)
=
$
342/
yr
Total
$
45,337/
yr
$
7,978/
yr
Incremental
Costs
­$
37,359/
yr
*
Given
wastes
are
transferred
within
the
same
NAICS,
it
is
assumed
that
the
recovery
facility
in
most
cases
is
owned
by
the
same
company
that
owns
the
generator
facility.
Costs
for
the
recovery
facility
are
added
to
the
generator's
costs
because
the
same
company
carrying
the
burden
of
the
added
cost.
Q­
1
Appendix
Q
Example
Cost
Calculation:
1997
Off­
site
Solvents
Recovery
Within
Same
NAICS
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
Cost
Inputs
Total
Quantity
of
Hazardous
Waste
Generated
25
tons
hazardous
waste/
yr
Total
Quantity
of
Hazardous
Waste
Generated
(
25
tons
hazardous
waste/
yr)
­
(
25
tons
recovered
waste/
yr)+
(
25
tons
recovered
waste/
yr*
0.33
fraction
as
residuals
*
0.85
fraction
characteristically
hazardous)
=
7
tons
hazardous
waste/
yr
(
recovered
waste
quantity
no
longer
hazardous
by
definition)

Generator
Status
If
(
tons
hazardous
waste/
yr
>
13.2
tons/
yr)
then
LQG
Generator
Status
If
(
1.3
tons/
yr
<
tons
hazardous
waste/
yr
<
13.2
tons/
yr)
then
SQG
Quantity
of
Waste
Recovered
Off
Site
0
tons
recovered
waste/
yr
Quantity
of
Waste
Recovered
Off
Site
25
tons
recovered
waste/
yr
Estimated
Hazardous
Waste
Quantity
for
Generator
100%
of
waste
quantity
will
be
disposed
(
1)
*
(
25
tons
recovered
waste/
yr)
=
25
tons
waste/
yr
Estimated
Residual
Quantity
for
Recovery
Facility*
33%
of
recovered
waste
quantity
will
be
residual
(
0.33)
*
(
25
tons
recovered
waste/
yr)
=
8.2
tons
residual/
yr
Estimated
Hazardous
Residual
Quantity
100%
residual
is
listed
&
characteristically
hazardous;

(
1.00)
*
(
0
tons
residual/
yr)
=
0
tons
hazardous
residual/
yr
Estimated
Hazardous
Residual
Quantity
for
Recovery
Facility*
85%
residual
is
characteristically
hazardous;

(
0.85)
*
(
8.2
tons
residual/
yr)
=
7
tons
hazardous
residual/
yr
Estimated
Nonhazardous
Residual
Quantity
0%
residual
is
nonhazardous;

(
0)
*
(
0
tons
residual/
yr)
=
0
tons
nonhazardous
residual/
yr
Estimated
Nonhazardous
Residual
Quantity
for
Recovery
Facility*
15%
residual
is
nonhazardous;

(
0.15)
*
(
8.2
tons
residual/
yr)
=
1.2
tons
nonhazardous
residual/
yr
Appendix
Q
Example
Cost
Calculation:
1997
Off­
site
Solvents
Recovery
Within
Same
NAICS
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
Q­
2
Estimated
Recovered
Product
Quantity
67%
of
recovered
waste
quantity
will
be
recovered
solvent
product
(
0.67)
*
(
0
tons
recovered
waste)
=
0
tons
recovered
solvent
Estimated
Recovered
Product
Quantity
67%
of
recovered
waste
quantity
will
be
recovered
solvent
product
(
0.67)
*
(
25
tons
recovered
waste)
=
16.8
tons
recovered
solvent
Number
of
Off­
site
Solvent
Recovery
Shipments
per
Year
by
Generator
0
tons
recovered
waste
/
18
tons
per
truck)
=
0
recovery
shipments
per
year
Number
of
Off­
site
Solvent
Recovery
Shipments
per
Year
25
tons
recovered
waste
/
18
tons
per
truck)
=
1.4
recovery
shipments
per
year
Number
of
Off­
site
Hazardous
Waste
Shipments
per
Year
by
Generator
Given
LQG
then
maximum
of
(
4
shipments
or
25
tons
hazardous
waste/
18
tons
per
truck)
=
4
hazardous
waste
shipments
per
year
Number
of
Off­
site
Hazardous
Waste
Residual
Shipments
per
Year
for
Recovery
Facility*
Given
SQG
and
>
200
miles
then
maximum
of
(
1.33
shipments
or
7
tons
hazardous
residual/
18
tons
per
truck)
=
1.33
hazardous
waste
shipments
per
year
Number
of
Off­
site
Nonhazardous
Waste
Shipments
per
Year
by
Generator
(
0
tons
nonhazardous
residual/
18
tons
per
truck)
=
0
nonhazardous
waste
shipments
per
year
Number
of
Off­
site
Non­
Hazardous
Waste
Residual
Shipments
per
Year
for
Recovery
Facility*
(
1.2
tons
nonhazardous
residual/
18
tons
per
truck)
=
0.07
nonhazardous
waste
shipments
per
year
Distance
to
Nearest
Offsite
Hazardous
Waste
Energy
Recovery
Facility
577
miles
Distance
to
Nearest
Offsite
Hazardous
Waste
Energy
Recovery
Facility
577
miles
Distance
to
Off­
site
Recovery
Facility
521
miles
Distance
to
Off­
site
Recovery
Facility
521
miles
Distance
to
Nearest
Offsite
Non­
hazardous
Waste
Landfill
50
miles
Distance
to
Nearest
Offsite
Non­
hazardous
Waste
Landfill
50
miles
Location
of
Generator
Oregon
Location
of
Generator
Oregon
Cost
Calculations
(
costs
are
positive
and
revenues
are
negative)

Off­
site
Solvent
Recovery
Cost
($
1,066/
ton)
*
(
0
tons
recovered
waste/
yr)
=
$
0/
yr
Off­
site
Solvent
Recovery
Cost
($
1,066/
ton)
*
(
25
tons
recovered
waste/
yr)
=
$
26,650/
yr
Appendix
Q
Example
Cost
Calculation:
1997
Off­
site
Solvents
Recovery
Within
Same
NAICS
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
Q­
3
Off­
site
Disposal
Cost
at
Energy
Recovery
Facility/
Cement
Kiln
(
baseline)
maximum(($
291/
ton)
*
(
25
tons
hazardous
residual
per
yr)
=
$
7,275/
yr
Residual
Off­
site
Hazardous
Energy
Recovery
Cost
for
Recovery
Facility*
maximum
(
($
291/
ton)
*
(
7
tons
hazardous
residual
per
yr)
or
(
($
338/
load)
*
(
1.33
Hazardous
Waste
Shipments)
=
$
2,037/
yr
Residual
Off­
site
Nonhazardous
Landfill
Cost
($
111/
ton)
*
(
0
tons
nonhazardous
residual
per
yr)
=
$
0/
yr
Residual
Off­
site
Non­
Hazardous
Energy
Recovery
Cost
($
291/
ton)
*
(
1.2
tons
non­
hazardous
residual
per
yr)
=
$
349/
yr
Waste
Characterization
Testing
Cost
for
Generator
($
1,410/
load)
*
(
4
Hazardous
Loads
+
0
Non­
Hazardous
Load)
=
$
5,640/
yr
Waste
Characterization
Testing
Cost
for
Recovery
Facility*
($
1,410/
load)
*
(
1.33
Hazardous
Loads
+
0.07
Non­
Hazardous
Load)
=
$
1,974/
yr
Manifesting
Costs
for
Generator
($
236/
shipment)
*
(
4
shipments/
yr)
=
$
944/
yr
Manifesting
Costs
for
Generator
&
Recovery
Facility*
($
89/
shipment)
*
(
1.40
shipments/
yr
+
1.4
recovery
loads)
=
$
249/
yr
Loading
Costs
for
Generator
($
2.57/
ton)
*
(
25
tons
waste)
=
$
64/
yr
Loading
Costs
for
Generator
&
Recovery
Facility*
($
2.57/
ton)
*
(
8.2
tons
residual
+
25
tons
recovered
waste)
=
$
85/
yr
Hazardous
Waste
Transportation
Costs
for
Generator
($
2.94/
mile)*(
4
hazardous
waste
shipments/
yr)*(
577
miles
to
hazardous
energy
recovery/
hazardous
waste
shipment)
+
($
2.94/
mile)*(
0
nonhazardous
waste
shipments/
yr)*(
577
miles
to
nonhazardous
energy
recovery/
nonhazardous
waste
shipment)
=
$
6,786/
yr
Residual
Waste
Transportation
Costs
for
Recovery
Facility*
($
2.94/
mile)*(
1.33
hazardous
waste
shipments/
yr)*(
577
miles
to
hazardous
energy
recovery/
hazardous
waste
shipment)
+
($
2.94/
mile)*(
0.07
nonhazardous
waste
shipments/
yr)*(
577
miles
to
nonhazardous
energy
recovery/
nonhazardous
waste
shipment)
=
$
2,375/
yr
Recovered
Waste
Transportation
Cost
($
6.20/
mile)*(
0
recovered
waste
shipments/
yr)*(
521
miles
to
hazardous
landfill/
hazardous
waste
shipment)
=
$
0/
yr
Recovered
Waste
Transportation
Cost
for
Generator
($
6.20/
mile)*(
7
recovered
waste
shipments/
yr)*(
521
miles
to
hazardous
landfill/
hazardous
waste
shipment)
=
$
22,611/
yr
Appendix
Q
Example
Cost
Calculation:
1997
Off­
site
Solvents
Recovery
Within
Same
NAICS
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
Q­
4
Salvage
(
Recovered
Product)
Value
($
1,543/
ton
solvent)
*
(
0
tons
recovered
solvent/
yr)
=
­$
0/
yr
Salvage
(
Recovered
Product)
Value
($
1,543/
ton
solvent)
*
(
16.8
tons
recovered
solvent/
yr)
=
­$
25,922/
yr
Hazardous
Material
Training
Cost
Given
LQG
then
$
9,794/
yr
Hazardous
Material
Training
Cost
Given
SQG
then
$
2,191/
yr
Manifest
Training
Cost
Given
LQG
then
$
1,828/
yr
Manifest
Training
Cost
Given
SQG
then
$
1,828/
yr
Biennial
Report/
General
Administrative
Duties
Cost
Given
LQG
then
$
2,430/
yr
Biennial
Report/
General
Administrative
Duties
Cost
Given
SQG
then
$
1,215/
yr
Contingency
Planning
Cost
Given
LQG
then
$
2,796
Contingency
Planning
Cost
Given
SQG
then
$
0
Initial
Waste
Characterization
Cost
$
6,160
Initial
Waste
Characterization
Cost
$
6,160
Exclusion
Filing
Fee
(
One
time
Expenditure)
$
0
Exclusion
Filing
Fee
(
One
time
Expenditure)
$
639
State
Facility
Tax/
Fee
for
Generator
Given
Oregon
and
LQG
then:
$
525
activity
verification
fee/
yr
State
Facility
Tax/
Fee
for
Recovery
Facility*
Given
Oregon
and
SQG
then:
$
300
activity
verification
fee/
yr
State
Generation
Tax/
Fee
for
Generator
Given
Oregon
then:
($
45
generation
fee/
ton)*(
25
tons
recovered
waste/
yr)
=
$
1,125/
yr
State
Generation
Tax/
Fee
for
Recovery
Facility*
Given
Oregon
then:
($
45
generation
fee/
ton)*(
7
tons
recovered
waste/
yr)
=
$
315/
yr
Total
$
45,367/
yr
$
43,056/
yr
Incremental
Costs
­$
2,311/
yr
*
Given
wastes
are
transferred
within
the
same
NAICS,
it
is
assumed
that
the
recovery
facility
in
most
cases
is
owned
by
the
same
company
that
owns
the
generator
facility.
Costs
for
the
recovery
facility
are
added
to
the
generator's
costs
because
the
same
company
carrying
the
burden
of
the
added
cost.
R­
1
Appendix
R
Example
Cost
Calculation:
1997
Off­
site
Acid
Recovery
Within
Same
NAICS
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
Cost
Inputs
Total
Quantity
of
Hazardous
Waste
Generated
30
tons
hazardous
waste/
yr
Total
Quantity
of
Hazardous
Waste
Generated
(
30
tons
hazardous
waste/
yr)
­
(
30
tons
recovered
waste/
yr)+
(
30
tons
recovered
waste/
yr*
0.26
fraction
as
residuals
*
0.75
fraction
characteristically
hazardous)
=
5.8
tons
hazardous
waste/
yr
(
recovered
waste
quantity
no
longer
hazardous
by
definition)

Generator
Status
If
(
tons
hazardous
waste/
yr
>
13.2
tons/
yr)
then
LQG
Generator
Status
If
(
1.3
tons/
yr
<
tons
hazardous
waste/
yr
<
13.2
tons/
yr)
then
SQG
Quantity
of
Waste
Recovered
Off
Site
0
tons
recovered
waste/
yr
Quantity
of
Waste
Recovered
Off
Site
30
tons
recovered
waste/
yr
Estimated
Hazardous
Waste
Quantity
by
Generator
100%
of
recovered
waste
quantity
will
be
disposed
(
1)
*
(
30
tons
recovered
waste/
yr)
=
30
tons
residual/
yr
Estimated
Residual
Quantity
by
Recovery
Facility*
26%
of
recovered
waste
quantity
will
be
residual
(
0.26)
*
(
30
tons
recovered
waste/
yr)
=
7.8
tons
residual/
yr
Estimated
Hazardous
Residual
Quantity
100%
residual
is
listed
&
characteristically
hazardous;

(
1.00)
*
(
0
tons
residual/
yr)
=
0
tons
hazardous
residual/
yr
Estimated
Hazardous
Residual
Quantity
by
Recovery
Facility*
75%
residual
is
characteristically
hazardous;

(
0.75)
*
(
7.8
tons
residual/
yr)
=
5.8
tons
hazardous
residual/
yr
Estimated
Nonhazardous
Residual
Quantity
0%
residual
is
nonhazardous;

(
0)
*
(
0
tons
residual/
yr)
=
0
tons
nonhazardous
residual/
yr
Estimated
Nonhazardous
Residual
Quantity
by
Recovery
Facility*
25%
residual
is
nonhazardous;

(
0.25)
*
(
7.8
tons
residual/
yr)
=
2
tons
nonhazardous
residual/
yr
Appendix
R
Example
Cost
Calculation:
1997
Off­
site
Acid
Recovery
Within
Same
NAICS
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
R­
2
Estimated
Recovered
Product
Quantity
74%
of
recovered
waste
quantity
will
be
recovered
acid
product
(
0.74)
*
(
0
tons
recovered
waste)
=
0
tons
recovered
acid
Estimated
Recovered
Product
Quantity
74%
of
recovered
waste
quantity
will
be
recovered
acid
product
(
0.74)
*
(
30
tons
recovered
waste)
=
22.2
tons
recovered
acid
Number
of
Off­
site
Acid
Recovery
Shipments
per
Year
0
tons
recovered
waste
/
18
tons
per
truck)
=
0
recovery
shipments
per
year
Number
of
Off­
site
Acid
Recovery
Shipments
per
Year
by
Generator
30
tons
recovered
waste
/
18
tons
per
truck)
=
1.7
recovery
shipments
per
year
Number
of
Off­
site
Hazardous
Waste
Shipments
per
Year
by
Generator
Given
LQG
then
maximum
of
(
4
shipments
or
30
tons
hazardous
residual/
18
tons
per
truck)
=
4
hazardous
waste
shipments
per
year
Number
of
Off­
site
Hazardous
Waste
Residual
Shipments
per
Year
by
Recovery
Facility*
Given
SQG
and
>
200
miles
then
maximum
of
(
1.33
shipments
or
7.8
tons
hazardous
residual/
18
tons
per
truck)
=
1.33
hazardous
waste
shipments
per
year
Number
of
Off­
site
Nonhazardous
Waste
Shipments
per
Year
(
0
tons
nonhazardous
residual/
18
tons
per
truck)
=
0
nonhazardous
waste
shipments
per
year
Number
of
Off­
site
Nonhazardous
Waste
Shipments
per
Year
by
Recovery
Facility*
(
2
tons
nonhazardous
residual/
18
tons
per
truck)
=
0.11
nonhazardous
waste
shipments
per
year
Distance
to
Nearest
Offsite
Hazardous
Waste
Acid
Neutralization,
Stabilization,
Landfill
405
miles
Distance
to
Nearest
Offsite
Hazardous
Waste
Acid
Neutralization,
Stabilization,
Landfill
405
miles
Distance
to
Off­
site
Recovery
Facility
521
miles
Distance
to
Off­
site
Recovery
Facility
521
miles
Distance
to
Nearest
Offsite
Non­
hazardous
Waste
Landfill
50
miles
Distance
to
Nearest
Offsite
Non­
hazardous
Waste
Landfill
50
miles
Location
of
Generator
Oregon
Location
of
Generator
Oregon
Cost
Calculations
(
costs
are
positive
and
revenues
are
negative)

Of­
site
Acid
Recovery
Cost
for
Generator
($
170/
ton)
*
(
0
tons
recovered
waste/
yr)
=
$
0/
yr
Off­
site
Acid
Recovery
Cost
for
Generator
($
170/
ton)
*
(
30
tons
recovered
waste/
yr)
=
$
5,100/
yr
Appendix
R
Example
Cost
Calculation:
1997
Off­
site
Acid
Recovery
Within
Same
NAICS
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
R­
3
On­
site
Treatment
Cost
by
Acid
Neutralization
(
baseline)
maximum(($
3.26/
ton
+
$
18,830)
*
(
30
tons
hazardous
residual
per
yr)
=
$
18,928/
yr
Residual
Off­
site
Hazardous
Neutralization,
Stabilization,
Landfill
Cost
by
Recovery
Facility*
maximum
(($
38/
ton)
*
(
5.8
tons
hazardous
residual
per
yr)
or
(
($
316/
load)
*
(
1.33
Hazardous
Waste
Shipments)
=
$
420/
yr
Residual
Off­
site
Nonhazardous
Landfill
Cost
($
111/
ton)
*
(
0
tons
nonhazardous
residual
per
yr)
=
$
0/
yr
Residual
Off­
site
Non­
Hazardous
Neutralization,
Stabilization,
Landfill
Cost
by
Recovery
Facility*
($
38/
ton)
*
(
2
tons
nonhazardous
residual
per
yr)
=
$
76/
yr
Waste
Characterization
Testing
Cost
($
1,410/
load)
*
(
0
Hazardous
Loads
+
0
Non­
Hazardous
Load)
=
$
0/
yr
Waste
Characterization
Testing
Cost
by
Recovery
Facility*
($
1,410/
load)
*
(
1.33
Hazardous
Loads
+
0.11
Non­
Hazardous
Load)
=
$
2,044/
yr
Manifesting
Costs
($
236/
shipment)
*
(
0
shipments/
yr)
=
$
0/
yr
Manifesting
Costs
for
Generator
&
Recovery
Facility*
($
89/
shipment)
*
(
1.44
shipments/
yr
+
1.7
recovery
loads)
=
$
279/
yr
Loading
Costs
($
2.57/
ton)
*
(
0
tons
residual)
=
$
0/
yr
Loading
Costs
for
Generator
&
by
Recovery
Facility*
($
2.57/
ton)
*
(
7.8
tons
residual
+
30
tons
recovered
waste)
=
$
97/
yr
Residual
Waste
Transportation
Costs
($
3.50/
mile)*(
0
hazardous
waste
shipments/
yr)*(
405
miles
to
hazardous
neutralization,
stab.,
landfill/
hazardous
waste
shipment)
+
($
3.50/
mile)*(
0
nonhazardous
waste
shipments/
yr)*(
405
miles
to
nonhazardous
neutralization,
stab.,
landfill/
nonhazardous
waste
shipment)
=
$
0/
yr
Residual
Waste
Transportation
Costs
by
Recovery
Facility*
($
3.50/
mile)*(
1.33
hazardous
waste
shipments/
yr)*(
405
miles
to
hazardous
neutralization,
stab.,
landfill/
hazardous
waste
shipment)
+
($
3.50/
mile)*(
0.11
nonhazardous
waste
shipments/
yr)*(
405
miles
to
nonhazardous
neutralization,
stab.,
landfill/
nonhazardous
waste
shipment)
=
$
2,055/
yr
Appendix
R
Example
Cost
Calculation:
1997
Off­
site
Acid
Recovery
Within
Same
NAICS
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
R­
4
Recovered
Waste
Transportation
Cost
($
6.20/
mile)*(
0
recovered
waste
shipments/
yr)*(
521
miles
to
hazardous
landfill/
hazardous
waste
shipment)
=
$
0/
yr
Recovered
Waste
Transportation
Cost
for
Generator
($
6.20/
mile)*(
1.7
recovered
waste
shipments/
yr)*(
521
miles
to
hazardous
acid
regeneration/
hazardous
waste
shipment)
=
$
5,491/
yr
Salvage
(
Recovered
Product)
Value
($
298.12/
ton
acid)
*
(
0
tons
recovered
acid/
yr)
=
­$
0/
yr
Salvage
(
Recovered
Product)
Value
($
298.12/
ton
acid)
*
(
22.2
tons
recovered
acid/
yr)
=
­$
6,618/
yr
Hazardous
Material
Training
Cost
Given
LQG
then
$
9,794/
yr
Hazardous
Material
Training
Cost
Given
SQG
then
$
2,191/
yr
Manifest
Training
Cost
Given
LQG
then
$
0/
yr
Manifest
Training
Cost
Given
SQG
then
$
1,828/
yr
Biennial
Report/
General
Administrative
Duties
Cost
Given
LQG
then
$
2,430/
yr
Biennial
Report/
General
Administrative
Duties
Cost
Given
SQG
then
$
1,215/
yr
Contingency
Planning
Cost
Given
LQG
then
$
2,796
Contingency
Planning
Cost
Given
SQG
then
$
0
Initial
Waste
Characterization
Cost
$
6,160
Initial
Waste
Characterization
Cost
$
6,160
Exclusion
Filing
Fee
(
One
time
Expenditure)
$
0
Exclusion
Filing
Fee
(
One
time
Expenditure)
$
639
State
Facility
Tax/
Fee
for
Generator
Given
Oregon
and
LQG
then:
$
525
activity
verification
fee/
yr
State
Facility
Tax/
Fee
for
Recovery
Facility*
Given
Oregon
and
SQG
then:
$
300
activity
verification
fee/
yr
State
Generation
Tax/
Fee
for
Generator
Given
Oregon
then:
($
45
generation
fee/
ton)*(
30
tons
recovered
waste/
yr)
=
$
1,350/
yr
State
Generation
Tax/
Fee
for
Recovery
Facility*
Given
Oregon
then:
($
45
generation
fee/
ton)*(
5.8
tons
recovered
waste/
yr)
=
$
261/
yr
Total
$
41,983/
yr
$
21,538/
yr
Incremental
Costs
­$
20,445/
yr
*
Given
wastes
are
transferred
within
the
same
NAICS,
it
is
assumed
that
the
recovery
facility
in
most
cases
is
owned
by
the
same
company
that
owns
the
generator
facility.
Costs
for
the
recovery
facility
are
added
to
the
generator's
costs
because
the
same
company
carrying
the
burden
of
the
added
cost.
S­
1
Appendix
S
Example
Cost
Calculation:
1999
Off­
site
Solvents
Recovery
Outside
Industry
Group
Shifting
to
On­
Site
Solvent
Recovery
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
Cost
Inputs
Total
Quantity
of
Hazardous
Waste
Generated
140
tons
hazardous
waste/
yr
Total
Quantity
of
Hazardous
Waste
Generated
(
140
tons
hazardous
waste/
yr)
­
(
140
tons
recovered
waste/
yr)+
(
140
tons
recovered
waste/
yr*
0.33
fraction
as
residuals
*
0.85
fraction
characteristically
hazardous)
=
39
tons
hazardous
waste/
yr
(
recovered
waste
quantity
no
longer
hazardous
by
definition)

Generator
Status
If
(
tons
hazardous
waste/
yr
>
13.2
tons/
yr)
then
LQG
Generator
Status
If
(
tons
hazardous
waste/
yr
>
13.2
tons/
yr)
then
LQG
Quantity
of
Waste
Recovered
On
Site
0
tons
recovered
waste/
yr
Quantity
of
Waste
Recovered
On
Site
140
tons
recovered
waste/
yr
Quantity
of
Waste
Recovered
Off
Site
140
tons
recovered
waste/
yr
Quantity
of
Waste
Recovered
Off
Site
0
tons
recovered
waste/
yr
Estimated
Residual
Quantity*
33%
of
recovered
waste
quantity
will
be
residual
(
0.33)
*
(
0
tons
recovered
waste/
yr)
=
0
tons
residual/
yr
Estimated
Residual
Quantity
33%
of
recovered
waste
quantity
will
be
residual
(
0.33)
*
(
140
tons
recovered
waste/
yr)
=
46
tons
residual/
yr
Estimated
Hazardous
Residual
Quantity*
85%
residual
is
characteristically
hazardous;
(
0.85)
*
(
0
tons
residual/
yr)
=
0
tons
hazardous
residual/
yr
Estimated
Hazardous
Residual
Quantity
85%
residual
is
characteristically
hazardous;
(
0.85)
*
(
46
tons
residual/
yr)
=
39
tons
hazardous
residual/
yr
Estimated
Nonhazardous
Residual
Quantity*
15%
residual
is
nonhazardous;
(
0.15)
*
(
0
tons
residual/
yr)
=
0
tons
nonhazardous
residual/
yr
Estimated
Nonhazardous
Residual
Quantity
15%
residual
is
nonhazardous;
(
0.15)
*
(
46
tons
residual/
yr)
=
7
tons
nonhazardous
residual/
yr
Appendix
S
Example
Cost
Calculation:
1999
Off­
site
Solvents
Recovery
Outside
Industry
Group
Shifting
to
On­
Site
Solvent
Recovery
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
S­
2
Estimated
Recovered
Product
Quantity
67%
of
recovered
waste
quantity
will
be
recovered
solvent
product
(
0.67)
*
(
140
tons
recovered
waste)
=
94
tons
recovered
solvent
Estimated
Recovered
Product
Quantity
67%
of
recovered
waste
quantity
will
be
recovered
solvent
product
(
0.67)
*
(
140
tons
recovered
waste)
=
94
tons
recovered
solvent
Number
of
Off­
site
Hazardous
Waste
Residual
Shipments
per
Year*
0
hazardous
waste
shipments
per
year
Number
of
Off­
site
Hazardous
Waste
Residual
Shipments
per
Year
Given
LQG
and
>
200
miles
then
maximum
of
(
4
shipments
or
39
tons
recovery
wastes/
18
ton
truck)
=
4
recovery
shipments
per
year
Number
of
Off
Site
Recovery
Shipments
per
Year
Given
LQG
and
>
200
miles
then
maximum
of
(
4
shipments
or
140
tons
recovery
wastes/
18
ton
truck)
=
7.8
recovery
shipments
per
year
Number
of
Off
Site
Recovery
Shipments
per
Year
0
recovery
shipments
per
year
Number
of
Off­
site
Nonhazardous
Waste
Residual
Shipments
per
Year*
(
0
tons
nonhazardous
residual/
18
tons
per
truck)
=
0
nonhazardous
waste
shipments
per
year
Number
of
Off­
site
Non­
Hazardous
Waste
Facility
Residual
Shipments
per
Year
(
7
tons
nonhazardous
residual/
18
tons
per
truck)
=
0.4
nonhazardous
waste
shipments
per
year
Distance
to
Nearest
Offsite
Hazardous
Waste
Energy
Recovery
577
miles
Distance
to
Nearest
Offsite
Hazardous
Waste
Energy
Recovery
577
miles
Distance
to
Nearest
Offsite
Recovery
Facility.
521
miles
Distance
to
Nearest
Offsite
Recovery
Facility.
521
miles
Distance
to
Nearest
Offsite
Non­
hazardous
Waste
Landfill
50
miles
Distance
to
Nearest
Offsite
Non­
hazardous
Waste
Landfill
50
miles
Location
of
Generator
Oregon
Location
of
Generator
Oregon
Cost
Calculations
(
costs
are
positive
and
revenues
are
negative)

On­
site
Solvent
Recovery
Cost
($
43.29/
ton)
*
(
0
tons
recovered
waste/
yr)
+
$
1,615
=
$
0/
yr
On­
site
Solvent
Recovery
Cost
($
43.29/
ton)
*
(
140
tons
recovered
waste/
yr)
+
$
1,615
=
$
7,676/
yr
Appendix
S
Example
Cost
Calculation:
1999
Off­
site
Solvents
Recovery
Outside
Industry
Group
Shifting
to
On­
Site
Solvent
Recovery
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
S­
3
Off­
site
Solvent
Recovery
Cost
($
1,066/
ton)
*
(
140
tons
recovered
waste/
yr)
=
$
149,240/
yr
Off­
site
Solvent
Recovery
Cost
Given
small
loads
(
less
than
60%
of
a
full
18
ton
load):
($
1,066/
ton
+
$
160/
ton
surcharge)
*
(
0
tons
recovered
waste/
yr)
=
$
0/
yr
Residual
Off­
site
Hazardous
Energy
Recovery
Cost*
Given
small
loads
(
less
than
60%
of
a
full
18
ton
load):
(
($
291/
ton
+
$
44/
ton
)
*
(
0
Hazardous
Waste
Shipments)
=
$
0/
yr
Residual
Off­
site
Hazardous
Energy
Recovery
Cost
Given
small
loads
(
less
than
60%
of
a
full
18
ton
load):
(
($
291/
ton
+
$
44/
ton
)
*
(
39
tons
hazardous
residual
per
yr)
=
$
13,065/
yr
Residual
Off­
site
Nonhazardous
Energy
Recovery
Cost
($
291/
ton)
*
(
0
tons
nonhazardous
residual
per
yr)
=
$
0/
yr
Residual
Off­
site
Nonhazardous
Energy
Recovery
Cost
($
291/
ton)
*
(
7
tons
nonhazardous
residual
per
yr)
=
$
2,037/
yr
Waste
Characterization
Testing
Cost
($
1,410/
load)
*
(
7.8
Hazardous
Loads
+
0
Non­
Hazardous
Load)
=
$
10,998/
yr
Waste
Characterization
Testing
Cost
($
1,410/
load)
*
(
4
Hazardous
Loads
+
0.4
Non­
Hazardous
Load)
=
$
6,240/
yr
Manifesting
Costs
($
236/
shipment)
*
(
7.8
shipments/
yr)
=
$
1,841/
yr
Manifesting
Costs
($
236/
shipment)
*
(
4
shipments/
yr)
=
$
944/
yr
+
($
89/
shipment)
*
(
0.4
shipments/
yr)
=
$
980/
yr
Loading
Costs
Cost
included
in
Off­
site
Solvent
Recovery
Costs
Loading
Costs
($
2.57/
ton)
*
(
46
tons
residual)
=
$
118/
yr
Residual
Waste
Transportation
Costs
($
2.94/
mile)*(
0
hazardous
waste
shipments/
yr)*(
577
miles
to
hazardous
energy
recovery/
hazardous
waste
shipment)
+
($
2.94/
mile)*(
0
nonhazardous
waste
shipments/
yr)*(
577
miles
to
nonhazardous
Energy
recovery/
nonhazardous
waste
shipment)
=
$
0/
yr
Residual
Waste
Transportation
Costs
($
2.94/
mile)*(
4
hazardous
waste
shipments/
yr)*(
577
miles
to
hazardous
energy
recovery/
hazardous
waste
shipment)
+
($
2.94/
mile)*(
0.4
nonhazardous
waste
shipments/
yr)*(
577
miles
to
nonhazardous
Energy
recovery/
nonhazardous
waste
shipment)
=
$
7,464/
yr
Appendix
S
Example
Cost
Calculation:
1999
Off­
site
Solvents
Recovery
Outside
Industry
Group
Shifting
to
On­
Site
Solvent
Recovery
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
S­
4
Recovered
Waste
Transportation
Cost
Cost
included
in
Management
Recovered
Waste
Transportation
Cost
(
6.20/
mile)*(
0
recovered
waste
shipments/
yr)*(
521
miles
to
recovery
facility/
hazardous
waste
shipments)
=
$
0/
yr
Salvage
(
Recovered
Product)
Value
($
1,543/
ton
solvent)
*
(
94
tons
recovered
solvent/
yr)
=
­
$
145,042/
yr
Salvage
(
Recovered
Product)
Value
($
1,543/
ton
solvent)
*
(
94
tons
recovered
solvent/
yr)
=
­
$
145,042/
yr
Hazardous
Material
Training
Cost
Given
LQG
then
$
9,794/
yr
Hazardous
Material
Training
Cost
Given
LQG
then
$
9,794/
yr
Manifest
Training
Cost
Given
LQG
then
$
1,828/
yr
Manifest
Training
Cost
Given
LQG
then
$
1,828/
yr
Biennial
Report/
General
Administrative
Duties
Cost
Given
LQG
then
$
2,430/
yr
Biennial
Report/
General
Administrative
Duties
Cost
Given
LQG
then
$
2,430/
yr
Contingency
Planning
Cost
Given
LQG
then
$
2,796
Contingency
Planning
Cost
Given
LQG
then
$
2,796
Initial
Waste
Characterization
Cost
$
6,160
Initial
Waste
Characterization
Cost
$
6,160
Exclusion
Filing
Fee
(
One
time
Expenditure)
$
0
Exclusion
Filing
Fee
(
One
time
Expenditure)
$
639
State
Facility
Tax/
Fee
Given
Oregon
and
LQG
then:
$
525
activity
verification
fee/
yr
State
Facility
Tax/
Fee
Given
Oregon
and
LQG
then:
$
525
activity
verification
fee/
yr
State
Generation
Tax/
Fee
Given
Oregon
then:
($
45
generation
fee/
ton)*(
140
tons
recovered
waste/
yr)
=
$
6,300/
yr
State
Generation
Tax/
Fee
Given
Oregon
then:
($
45
generation
fee/
ton)*(
39
tons
residual/
yr)
=
$
1,755/
yr
Total
$
46,870/
yr
­$
81,535/
yr
Incremental
Costs
­$
128,405/
yr
*
Given
wastes
are
transferred
outside
industry
group,
it
is
assumed
that
the
recovery
facility
in
most
cases
is
a
commercial
company
separate
and
distinct
from
the
generator.
Cost
for
the
recovery
facility
are
not
included
in
the
generator
costs
and
are
assumed
to
be
a
portion
of
the
offsite
recovery
facility
unit
cost.
Costs
not
listed
separately
for
off­
site
commercial
recovery
facilities
include
all
costs
associated
with
residual
management,
transportation,
and
disposal.
T­
1
Appendix
T
Example
Cost
Calculation:
1999
Off­
site
Acid
Recovery
Outside
Same
NAICS
Shifting
to
On­
site
Acid
Recovery
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
Cost
Inputs
Total
Quantity
of
Hazardous
Waste
Generated
140
tons
hazardous
waste/
yr
Total
Quantity
of
Hazardous
Waste
Generated
(
140
tons
hazardous
waste/
yr)
­
(
140
tons
recovered
waste/
yr)+
(
140
tons
recovered
waste/
yr*
0.26
fraction
as
residuals
*
0.75
fraction
characteristically
hazardous)
=
27.3
tons
hazardous
waste/
yr
(
recovered
waste
quantity
no
longer
hazardous
by
definition)

Generator
Status
If
(
tons
hazardous
waste/
yr
>
13.2
tons/
yr)
then
LQG
Generator
Status
If
(
tons
hazardous
waste/
yr
>
13.2
tons/
yr)
then
LQG
Quantity
of
Waste
Recovered
On
Site
0
tons
recovered
waste/
yr
Quantity
of
Waste
Recovered
On
Site
140
tons
recovered
waste/
yr
Quantity
of
Waste
Recovered
Off
Site
140
tons
recovered
waste/
yr
Quantity
of
Waste
Recovered
Off
Site
0
tons
recovered
waste/
yr
Estimated
Residual
Quantity*
26%
of
recovered
waste
quantity
will
be
residual
(
0.26)
*
(
0
tons
recovered
waste/
yr)
=
0
tons
residual/
yr
Estimated
Residual
Quantity
26%
of
recovered
waste
quantity
will
be
residual
(
0.26)
*
(
140
tons
recovered
waste/
yr)
=
36.4
tons
residual/
yr
Estimated
Hazardous
Residual
Quantity*
75%
residual
is
characteristically
hazardous;
(
0.75)
*
(
0
tons
residual/
yr)
=
0
tons
hazardous
residual/
yr
Estimated
Hazardous
Residual
Quantity
75%
residual
is
characteristically
hazardous;
(
0.75)
*
(
36.4
tons
residual/
yr)
=
27.3
tons
hazardous
residual/
yr
Estimated
Nonhazardous
Residual
Quantity*
25%
residual
is
nonhazardous;
(
0.25)
*
(
0
tons
residual/
yr)
=
0
tons
nonhazardous
residual/
yr
Estimated
Nonhazardous
Residual
Quantity
25%
residual
is
nonhazardous;
(
0.25)
*
(
36.4
tons
residual/
yr)
=
9.1
tons
nonhazardous
residual/
yr
Appendix
T
Example
Cost
Calculation:
1999
Off­
site
Acid
Recovery
Outside
Same
NAICS
Shifting
to
On­
site
Acid
Recovery
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
T­
2
Estimated
Recovered
Product
Quantity
74%
of
recovered
waste
quantity
will
be
recovered
acid
product
(
0.74)
*
(
140
tons
recovered
waste)
=
103.6
tons
recovered
acid
Estimated
Recovered
Product
Quantity
74%
of
recovered
waste
quantity
will
be
recovered
acid
product
(
0.74)
*
(
140
tons
recovered
waste)
=
103.6
tons
recovered
acid
Number
of
Off­
site
Hazardous
Waste
Residual
Shipments
per
Year*
0
hazardous
waste
shipments
per
year
Number
of
Off­
site
Hazardous
Waste
Residual
Shipments
per
Year
Given
LQG
and
>
200
miles
then
maximum
of
(
4
shipments
or
27.3
tons
recovery
wastes/
18
ton
truck)
=
4
recovery
shipments
per
year
Number
of
Off
Site
Recovery
Shipments
per
Year
Given
LQG
and
>
200
miles
then
maximum
of
(
4
shipments
or
140
tons
recovery
wastes/
18
ton
truck)
=
7.8
recovery
shipments
per
year
Number
of
Off
Site
Recovery
Shipments
per
Year
0
recovery
shipments
per
year
Number
of
Off­
site
Nonhazardous
Waste
Residual
Shipments
per
Year*
(
0
tons
nonhazardous
residual/
18
tons
per
truck)
=
0
nonhazardous
waste
shipments
per
year
Number
of
Off­
site
Non­
Hazardous
Waste
Residual
Shipments
per
Year
(
9.1
tons
nonhazardous
residual/
18
tons
per
truck)
=
0.51
nonhazardous
waste
shipments
per
year
Distance
to
Nearest
Offsite
Hazardous
Waste
Facility
for
Acid
Neutralization,
Stabilization,
and
Landfill
405
miles
Distance
to
Nearest
Offsite
Hazardous
Waste
Facility
for
Acid
Neutralization,
Stabilization,
and
Landfill
405
miles
Distance
to
Nearest
Offsite
Recovery
Facility.
521
miles
Distance
to
Nearest
Offsite
Recovery
Facility.
521miles
Distance
to
Nearest
Offsite
Non­
hazardous
Waste
Landfill
50
miles
Distance
to
Nearest
Offsite
Non­
hazardous
Waste
Landfill
50
miles
Location
of
Generator
Oregon
Location
of
Generator
Oregon
Cost
Calculations
(
costs
are
positive
and
revenues
are
negative)
Appendix
T
Example
Cost
Calculation:
1999
Off­
site
Acid
Recovery
Outside
Same
NAICS
Shifting
to
On­
site
Acid
Recovery
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
T­
3
On­
site
Acid
Recovery
Cost
($
79.50/
ton)
*
(
0
tons
recovered
waste/
yr)
+
$
1,804
=
$
0/
yr
On­
site
Acid
Recovery
Cost
($
79.50/
ton)
*
(
140
tons
recovered
waste/
yr)
+
$
1,804
=
$
12,934/
yr
Off­
site
Acid
Recovery
Cost
($
170/
ton)
*
(
140
tons
recovered
waste/
yr)
=
$
23,800/
yr
Off­
site
Acid
Recovery
Cost
Given
small
loads
(
less
than
60%
of
a
full
18
ton
load):
($
170/
ton)
*
(
0
tons
recovered
waste/
yr)
=
$
0/
yr
Residual
Off­
site
Hazardous
Acid
Neutralization,
Stabilization,
Landfill
Cost*
maximum(
($
38/
ton)
*
(
0
tons
hazardous
residual
per
yr)
or
($
316/
load)
*
(
0
Hazardous
Waste
Shipments)
=
$
0/
yr
Residual
Off­
site
Hazardous
Acid
Neutralization,
Stabilization,
Landfill
Cost
maximum
(
($
38/
ton)
*
(
27.3
tons
hazardous
residual
per
yr)
or
(
($
316/
load)
*
(
4
Hazardous
Waste
Shipments)
=
$
1,037/
yr
Residual
Off­
site
Nonhazardous
Acid
Neutralization,
Stabilization,
Landfill
Cost
($
38/
ton)
*
(
0
tons
nonhazardous
residual
per
yr)
=
$
0/
yr
Residual
Off­
site
Nonhazardous
Acid
Neutralization,
Stabilization,
Landfill
Cost
($
38/
ton)
*
(
9.1
tons
nonhazardous
residual
per
yr)
=
$
346/
yr
Waste
Characterization
Testing
Cost
($
1,410/
load)
*
(
4
Hazardous
Loads
+
0
Non­
Hazardous
Load)
=
$
5,640/
yr
Waste
Characterization
Testing
Cost
($
1,410/
load)
*
(
4
Hazardous
Loads
+
0.51
Non­
Hazardous
Load)
=
$
6,359/
yr
Manifesting
Costs
($
236/
shipment)
*
(
4
shipments/
yr)
=
$
944/
yr
Manifesting
Costs
($
236/
shipment)
*
(
4
shipments/
yr)
+
($
89/
shipment)
*
(
0.51
shipments/
yr)
=
$
989/
yr
Loading
Costs
Cost
included
in
Off­
site
Acid
Recovery
Costs
Loading
Costs
($
2.57/
ton)
*
(
36.4
tons
residual)
=
$
94/
yr
Appendix
T
Example
Cost
Calculation:
1999
Off­
site
Acid
Recovery
Outside
Same
NAICS
Shifting
to
On­
site
Acid
Recovery
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
T­
4
Residual
Waste
Transportation
Costs
($
3.05/
mile)*(
0
hazardous
waste
shipments/
yr)*(
405
miles
to
hazardous
landfill/
hazardous
waste
shipment)
+
($
3.05/
mile)*(
0
nonhazardous
waste
shipments/
yr)*(
405
miles
to
nonhazardous
landfill/
nonhazardous
waste
shipment)
=
$
0/
yr
Residual
Waste
Transportation
Costs
($
3.05/
mile)*(
4
hazardous
waste
shipments/
yr)*(
405
miles
to
hazardous
landfill/
hazardous
waste
shipment)
+
($
3.05/
mile)*(
0.51
nonhazardous
waste
shipments/
yr)*(
405
miles
to
nonhazardous
landfill/
nonhazardous
waste
shipment)
=
$
5,571/
yr
Recovered
Waste
Transportation
Cost
Cost
included
in
Off­
site
Acid
Recovery
Costs
Recovered
Waste
Transportation
Cost
(
6.20/
mile)*(
0
recovered
waste
shipments/
yr)*(
521
miles
to
recovery
facility/
hazardous
waste
shipments)
=
$
0/
yr
Salvage
(
Recovered
Product)
Value
($
298.12/
ton
acid)
*
(
103.6
tons
recovered
acid/
yr)
=
­$
30,885/
yr
Salvage
(
Recovered
Product)
Value
($
298.12/
ton
acid)
*
(
103.6
tons
recovered
acid/
yr)
=
­$
30,885/
yr
Hazardous
Material
Training
Cost
Given
LQG
then
$
9,794/
yr
Hazardous
Material
Training
Cost
Given
LQG
then
$
9,794/
yr
Manifest
Training
Cost
Given
LQG
then
$
1,828/
yr
Manifest
Training
Cost
Given
LQG
then
$
1,828/
yr
Biennial
Report/
General
Administrative
Duties
Cost
Given
LQG
then
$
2,430/
yr
Biennial
Report/
General
Administrative
Duties
Cost
Given
LQG
then
$
2,430/
yr
Contingency
Planning
Cost
Given
LQG
then
$
2,796
Contingency
Planning
Cost
Given
LQG
then
$
2,796
Initial
Waste
Characterization
Cost
$
6,160
Initial
Waste
Characterization
Cost
$
6,160
Exclusion
Filing
Fee
(
One
time
Expenditure)
$
0
Exclusion
Filing
Fee
(
One
time
Expenditure)
$
639
State
Facility
Tax/
Fee
Given
Oregon
and
LQG
then:
$
525
activity
verification
fee/
yr
State
Facility
Tax/
Fee
Given
Oregon
and
SQG
then:
$
300
activity
verification
fee/
yr
Appendix
T
Example
Cost
Calculation:
1999
Off­
site
Acid
Recovery
Outside
Same
NAICS
Shifting
to
On­
site
Acid
Recovery
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
T­
5
State
Generation
Tax/
Fee
Given
Oregon
then:
($
45
generation
fee/
ton)*(
140
tons
recovered
waste/
yr)
=
$
1,800/
yr
State
Generation
Tax/
Fee
Given
Oregon
then:
($
45
generation
fee/
ton)*(
27.3
tons
residual/
yr)
=
$
1,229/
yr
Total
$
24,832/
yr
$
21,621/
yr
Incremental
Costs
­$
3,211/
yr
*
Given
wastes
are
transferred
outside
the
same
NAICS,
it
is
assumed
that
the
recovery
facility
in
most
cases
is
a
commercial
company
separate
and
distinct
from
the
generator.
Cost
for
the
recovery
facility
are
not
included
in
the
generator
costs
and
are
assumed
to
be
a
portion
of
the
offsite
recovery
facility
unit
cost.
Costs
are
not
listed
separately
for
off­
site
commercial
recovery
facilities
include
all
costs
associated
with
residual
management,
transportation,
and
disposal.
U­
1
Appendix
U
Example
Cost
Calculation:
1999
Off­
site
Disposal
of
Emission
Control
Dust
(
K061)
Shifting
to
On­
site
Metals
Recovery
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
Cost
Inputs
Total
Quantity
of
Hazardous
Waste
Generated
32,000
tons
hazardous
waste/
yr
Total
Quantity
of
Hazardous
Waste
Generated
(
32,000
tons
hazardous
waste/
yr)
­
(
32,000
tons
recovered
waste/
yr)+
(
32,000
tons
recovered
waste/
yr*
0.32
fraction
as
residuals
*
0.95
fraction
characteristically
hazardous)
=
9,728
tons
hazardous
waste/
yr
(
recovered
waste
quantity
no
longer
hazardous
by
definition)

Generator
Status
If
(
tons
hazardous
waste/
yr
>
13.2
tons/
yr)
then
LQG
Generator
Status
If
(
tons
hazardous
waste/
yr
>
13.2
tons/
yr)
then
LQG
Quantity
of
Waste
Recovered
On
Site
0
tons
recovered
waste/
yr
Quantity
of
Waste
Recovered
On
Site
32,000
tons
recovered
waste/
yr
Quantity
of
Waste
Disposed
Off
Site
(
Hazardous
Landfill)
32,000
tons
disposed
waste/
yr
Quantity
of
Waste
Disposed
Off
Site
(
Hazardous
Landfill)
0
tons
disposed
waste/
yr
Estimated
Residual
Quantity*
32%
of
recovered
waste
quantity
will
be
residual
(
0.32)
*
(
0
tons
recovered
waste/
yr)
=
0
tons
residual/
yr
Estimated
Residual
Quantity
32%
of
recovered
waste
quantity
will
be
residual
(
0.32)
*
(
32,000
tons
recovered
waste/
yr)
=
10,240
tons
residual/
yr
Estimated
Hazardous
Residual
Quantity*
95%
residual
is
characteristically
hazardous;
(
0.95)
*
(
0
tons
residual/
yr)
=
0
tons
hazardous
residual/
yr
Estimated
Hazardous
Residual
Quantity
95%
residual
is
characteristically
hazardous;
(
0.95)
*
(
10,240
tons
residual/
yr)
=
9,728
tons
hazardous
residual/
yr
Estimated
Nonhazardous
Residual
Quantity*
5%
residual
is
nonhazardous;
(
0.05)
*
(
0
tons
residual/
yr)
=
0
tons
nonhazardous
residual/
yr
Estimated
Nonhazardous
Residual
Quantity
5%
residual
is
nonhazardous;
(
0.05)
*
(
10,240
tons
residual/
yr)
=
512
tons
nonhazardous
residual/
yr
Appendix
U
Example
Cost
Calculation:
1999
Off­
site
Disposal
of
Emission
Control
Dust
(
K061)
Shifting
to
On­
site
Metals
Recovery
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
U­
2
Estimated
Recovered
Product
Quantity
15%
of
recovered
waste
quantity
will
be
recovered
metal
product
(
0.15)
*
(
0
tons
recovered
waste)
=
0
tons
recovered
metal
Estimated
Recovered
Product
Quantity
15%
of
recovered
waste
quantity
will
be
recovered
metal
product
(
0.15)
*
(
32,000
tons
recovered
waste)
=
4,800
tons
recovered
metal
Number
of
Off­
site
Hazardous
Waste
Residual
Shipments
per
Year*
0
hazardous
waste
shipments
per
year
Number
of
Off­
site
Hazardous
Waste
Residual
Shipments
per
Year
Given
LQG
and
>
200
miles
then
maximum
of
(
4
shipments
or
9,728
tons
recovery
wastes/
18
ton
truck)
=
540.4
hazardous
waste
shipments
per
year
Number
of
Off
Site
Disposal
Shipments
per
Year
(
Hazardous
Landfill)
Given
LQG
and
>
200
miles
then
maximum
of
(
4
shipments
or
32,000
tons
disposal
wastes/
18
ton
truck)
=
1,777.8
disposal
shipments
per
year
Number
of
Off
Site
Disposal
Shipments
per
Year
(
Hazardous
Landfill)
0
disposal
shipments
per
year
Number
of
Off­
site
Nonhazardous
Waste
Residual
Shipments
per
Year*
(
0
tons
nonhazardous
residual/
18
tons
per
truck)
=
0
nonhazardous
waste
shipments
per
year
Number
of
Off­
site
Non­
Hazardous
Waste
Residual
Shipments
per
Year
(
512
tons
nonhazardous
residual/
18
tons
per
truck)
=
28.4
nonhazardous
waste
shipments
per
year
Distance
to
Nearest
Offsite
Hazardous
Waste
Landfill
338
miles
Distance
to
Nearest
Offsite
Hazardous
Waste
Landfill
338
miles
Distance
to
Nearest
Offsite
Non­
hazardous
Waste
Landfill
50
miles
Distance
to
Nearest
Offsite
Non­
hazardous
Waste
Landfill
50
miles
Location
of
Generator
Oregon
Location
of
Generator
Oregon
Cost
Calculations
(
costs
are
positive
and
revenues
are
negative)

On­
site
Metal
Recovery
Cost
$
1,933.5
*
(
0
tons
recovered
waste/
yr)^
0.78
+
$
6,744.4
*
(
0
tons
recovered
waste/
yr)^
0.59
+
$
23,685
=
$
0/
yr
On­
site
Metal
Recovery
Cost
$
1,933.5
*
(
32,000
tons
recovered
waste/
yr)^
0.78
+
$
6,744.4
*
(
32,000
tons
recovered
waste/
yr)^
0.59
+
$
23,685
=
$
9,407,401/
yr
Appendix
U
Example
Cost
Calculation:
1999
Off­
site
Disposal
of
Emission
Control
Dust
(
K061)
Shifting
to
On­
site
Metals
Recovery
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
U­
3
Off­
site
Waste
Disposal
(
Hazardous
Waste
Landfill)
Given
full
truck
loads
(
greater
than
60%
full):
($
153.42/
ton)
*
(
32,000
tons
waste
per
yr)=
$
4,909,440/
yr
Off­
site
Waste
Disposal
(
Hazardous
Waste
Landfill)
($
153.42/
ton)
*
(
0
tons
waste
per
yr)=
$
0/
yr
Residual
Off­
site
Hazardous
Landfill
Cost
maximum(
($
320/
ton)
*
(
0
tons
waste
per
yr)
or
($
2,246/
load)
*
(
0
Hazardous
Waste
Shipments)
)=
$
0/
yr
Residual
Off­
site
Hazardous
Landfill
Cost
maximum(
($
320/
ton)
*
(
9,728
tons
waste
per
yr)
or
($
2,246/
load)
*
(
540.4
Hazardous
Waste
Shipments)
)=
$
3,112,960/
yr
Residual
Off­
site
Nonhazardous
Landfill
Cost
($
111/
ton)
*
(
0
tons
nonhazardous
residual
per
yr)
=
$
0/
yr
Residual
Off­
site
Nonhazardous
Landfill
Cost
($
111/
ton)
*
(
512
tons
non­
hazardous
residual
per
yr)
=
$
56,832/
yr
Waste
Characterization
Testing
Cost
($
1,532/
load)
*
(
1,777.8
Hazardous
Loads
+
0
Non­
Hazardous
Load)
=
$
2,723,590/
yr
Waste
Characterization
Testing
Cost
($
1,532/
load)
*
(
540.4
Hazardous
Loads
+
28.4
Non­
Hazardous
Load)
=
$
871,402/
yr
Manifesting
Costs
($
236/
shipment)
*
(
1,777.8
shipments/
yr)
=
$
419,561/
yr
Manifesting
Costs
($
236/
shipment)
*
(
540.4
hazardous
shipments/
yr
)+
($
89/
shipment)
*
(
28.4
shipments/
yr)
=
$
130,062/
yr
Loading
Costs
($
2.57/
ton)
*
(
32,000
tons
recovered
waste)
=
$
82,240/
yr
Loading
Costs
($
2.57/
ton)
*
(
10,240
tons
residual)
=
$
26,317/
yr
Residual
Waste
Transportation
Costs
($
3.73/
mile)*(
0
hazardous
waste
shipments/
yr)*(
338
miles
to
hazardous
landfill/
hazardous
waste
shipment)
+
($
2.16/
mile)*(
0
nonhazardous
waste
shipments/
yr)*(
50
miles
to
nonhazardous
Landfill/
nonhazardous
waste
shipment)
=
$
0/
yr
Residual
Waste
Transportation
Costs
($
3.73/
mile)*(
540.4
hazardous
waste
shipments/
yr)*(
338
miles
to
hazardous
landfill/
hazardous
waste
shipment)
+
($
2.16/
mile)*(
28.4
nonhazardous
waste
shipments/
yr)*(
50
miles
to
nonhazardous
Landfill/
nonhazardous
waste
shipment)
=
$
684,371/
yr
Appendix
U
Example
Cost
Calculation:
1999
Off­
site
Disposal
of
Emission
Control
Dust
(
K061)
Shifting
to
On­
site
Metals
Recovery
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
U­
4
Disposal
Waste
Transportation
Cost
($
3.73/
mile)*(
1,777.8
hazardous
waste
shipments/
yr)*(
338
miles
to
hazardous
landfill/
hazardous
waste
shipment)
=
$
2,241,343/
yr
Disposal
Waste
Transportation
Cost
($
3.73/
mile)*(
0
hazardous
waste
shipments/
yr)*(
338
miles
to
hazardous
landfill/
hazardous
waste
shipment)
=
$
0/
yr
Salvage
(
Recovered
Product)
Value
($
643/
ton
metal)
*
(
0
tons
recovered
metal/
yr)
=
$
0/
yr
Salvage
(
Recovered
Product)
Value
($
643/
ton
metal)
*
(
4,800
recovered
metal/
yr)
=
$
3,086,400/
yr
Hazardous
Material
Training
Cost
Given
LQG
then
$
9,794/
yr
Hazardous
Material
Training
Cost
Given
LQG
then
$
9,794/
yr
Manifest
Training
Cost
Given
LQG
then
$
1,828/
yr
Manifest
Training
Cost
Given
LQG
then
$
1,828/
yr
Biennial
Report/
General
Administrative
Duties
Cost
Given
LQG
then
$
2,430/
yr
Biennial
Report/
General
Administrative
Duties
Cost
Given
LQG
then
$
2,430/
yr
Contingency
Planning
Cost
Given
LQG
then
$
2,796
Contingency
Planning
Cost
Given
LQG
then
$
2,796
Initial
Waste
Characterization
Cost
$
6,160
Initial
Waste
Characterization
Cost
$
6,160
Exclusion
Filing
Fee
(
One
time
Expenditure)
$
0
Exclusion
Filing
Fee
(
One
time
Expenditure)
$
639
State
Facility
Tax/
Fee
Given
Oregon
and
LQG
then:
$
525
activity
verification
fee/
yr
State
Facility
Tax/
Fee
Given
Oregon
and
LQG
then:
$
525
activity
verification
fee/
yr
State
Generation
Tax/
Fee
Given
Oregon
then:
($
45
generation
fee/
ton)
*
(
32,000
tons
disposed
waste/
yr)
=
$
1,440,000/
yr
State
Generation
Tax/
Fee
Given
Oregon
then:
($
45
generation
fee/
ton)
*
(
9,728
tons
residual/
yr)
=
$
437,360/
yr
Total
$
11,839,707/
yr
$
11,664,477/
yr
Incremental
Costs
­$
175,230/
yr
*
Residual
costs
are
included
in
the
cost
for
off­
site
commercial
treatment
and
disposal
V­
1
Appendix
V
Example
Cost
Calculation:
1999
Off­
site
Disposal
of
Spent
Aluminum
Potliner
(
K088)
shifting
to
On­
site
Sodium
Fluoride
Recovery
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
Cost
Inputs
Total
Quantity
of
Hazardous
Waste
Generated
360
tons
hazardous
waste/
yr
Total
Quantity
of
Hazardous
Waste
Generated
(
360
tons
hazardous
waste/
yr)
­
(
360
tons
recovered
waste/
yr)+
(
360
tons
recovered
waste/
yr*
0.32
fraction
as
residuals
*
0
fraction
characteristically
hazardous)
=
0
tons
hazardous
waste/
yr
(
recovered
waste
quantity
no
longer
hazardous
by
definition)

Generator
Status
If
(
tons
hazardous
waste/
yr
>
13.2
tons/
yr)
then
LQG
Generator
Status
If
(
1.3
tons/
yr
>
tons
hazardous
waste/
yr)
then
CESQG
(
Not
a
Generator)

Quantity
of
Waste
Recovered
On
Site
0
tons
recovered
waste/
yr
Quantity
of
Waste
Recovered
On
Site
360
tons
recovered
waste/
yr
Quantity
of
Waste
Disposed
Off
Site
360
tons
recovered
waste/
yr
Quantity
of
Waste
Disposed
Off
Site
0
tons
recovered
waste/
yr
Estimated
Residual
Quantity*
33%
of
recovered
waste
quantity
will
be
residual
(
0)
*
(
0
tons
recovered
waste/
yr)
=
0
tons
residual/
yr
Estimated
Residual
Quantity
32%
of
recovered
waste
quantity
will
be
residual
(
0.32)
*
(
360
tons
recovered
waste/
yr)
=
119
tons
residual/
yr
Estimated
Hazardous
Residual
Quantity*
100%
residual
is
Listed
hazardous;
(
1.00)
*
(
0
tons
residual/
yr)
=
0
tons
hazardous
residual/
yr
Estimated
Hazardous
Residual
Quantity
0%
residual
is
characteristically
hazardous;
(
0)
*
(
119
tons
residual/
yr)
=
0
tons
hazardous
residual/
yr
Estimated
Nonhazardous
Residual
Quantity*
0%
residual
is
nonhazardous;
(
0)
*
(
0
tons
residual/
yr)
=
0
tons
nonhazardous
residual/
yr
Estimated
Nonhazardous
Residual
Quantity
100%
residual
is
nonhazardous;
(
1.0)
*
(
119
tons
residual/
yr)
=
119
tons
nonhazardous
residual/
yr
Appendix
V
Example
Cost
Calculation:
1999
Off­
site
Disposal
of
Spent
Aluminum
Potliner
(
K088)
shifting
to
On­
site
Sodium
Fluoride
Recovery
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
V­
2
Estimated
Recovered
Product
Quantity
2%
of
recovered
waste
quantity
will
be
recovered
sodium
fluoride
product
(
0.02)
*
(
0
tons
recovered
waste)
=
0
tons
recovered
sodium
fluoride
Estimated
Recovered
Product
Quantity
2%
of
recovered
waste
quantity
will
be
recovered
sodium
fluoride
product
(
0.02)
*
(
360
tons
recovered
waste)
=
7.2
tons
recovered
sodium
fluoride
Number
of
Off­
site
Hazardous
Waste
Residual
Shipments
per
Year*
0
hazardous
waste
shipments
per
year
Number
of
Off­
site
Hazardous
Waste
Residual
Shipments
per
Year
0
hazardous
waste
shipments
per
year
Number
of
Off
Site
Disposal
Shipments
per
Year
Given
LQG
and
>
200
miles
then
maximum
of
(
4
shipments
or
360
tons
recovery
wastes/
18
ton
truck)
=
20
recovery
shipments
per
year
Number
of
Off
Site
Recovery
Shipments
per
Year
0
recovery
shipments
per
year
Number
of
Off­
site
Nonhazardous
Waste
Residual
Shipments
per
Year*
(
0
tons
nonhazardous
residual/
18
tons
per
truck)
=
0
nonhazardous
waste
shipments
per
year
Number
of
Off­
site
Non­
Hazardous
Waste
Residual
Shipments
per
Year
(
119
tons
nonhazardous
residual/
18
tons
per
truck)
=
6.6
nonhazardous
waste
shipments
per
year
Distance
to
Nearest
Offsite
Hazardous
Waste
Incineration
Facility
1000
miles
Distance
to
Nearest
Offsite
Hazardous
Waste
Incineration
Facility
1000
miles
Distance
to
Nearest
Offsite
Non­
hazardous
Waste
Landfill
50
miles
Distance
to
Nearest
Offsite
Non­
hazardous
Waste
Landfill
50
miles
Location
of
Generator
Oregon
Location
of
Generator
Oregon
Cost
Calculations
(
costs
are
positive
and
revenues
are
negative)

On­
site
Sodium
Fluoride
Recovery
Cost
($
465/
ton)
*
(
0
tons
recovered
waste/
yr)^
0.9
+
($
4,136/
ton)
*
(
0
tons
recovered
waste/
yr)^
0.6
$
53,603
=
$
0/
yr
On­
site
Sodium
Fluoride
Recovery
Cost
($
465/
ton)
*
(
360
tons
recovered
waste/
yr)^
0.9
+
($
4,136/
ton)
*
(
360
tons
recovered
waste/
yr)^
0.6
$
53,603
=
$
287,898/
yr
Appendix
V
Example
Cost
Calculation:
1999
Off­
site
Disposal
of
Spent
Aluminum
Potliner
(
K088)
shifting
to
On­
site
Sodium
Fluoride
Recovery
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
V­
3
Off­
site
Incineration
Cost
($
551.5/
ton)
*
(
360
tons
incinerated
waste/
yr)
=
$
198,551/
yr
Off­
site
Incineration
Cost
Given
small
loads
(
less
than
60%
of
a
full
18
ton
load):
($
170/
ton
+
$
25.50/
ton
surcharge)
*
(
0
tons
incinerated
waste/
yr)
=
$
0/
yr
Residual
Off­
site
Hazardous
Landfill
Cost
($
320/
ton)
*
(
0
tons
hazardous
residual
per
yr)
=
$
0/
yr
Residual
Off­
site
Hazardous
Landfill
Cost
($
320/
ton)
*
(
0
tons
hazardous
residual
per
yr)
=
$
0/
yr
Residual
Off­
site
Nonhazardous
Landfill
Cost
($
111/
ton)
*
(
0
tons
nonhazardous
residual
per
yr)
=
$
0/
yr
Residual
Off­
site
Nonhazardous
Landfill
Cost
($
111/
ton)
*
(
119
tons
non­
hazardous
residual
per
yr)
=
$
13,209/
yr
Waste
Characterization
Testing
Cost
($
1,410/
load)
*
(
20
Hazardous
Loads
+
0
Non­
Hazardous
Load)
=
$
28,200/
yr
Waste
Characterization
Testing
Cost
($
1,410/
load)
*
(
0
Hazardous
Loads
+
6.6
Non­
Hazardous
Load)
=
$
9,306/
yr
Manifesting
Costs
($
236/
shipment)
*
(
20
shipments/
yr)
=
$
4,720/
yr
Manifesting
Costs
($
89/
shipment)
*
(
6.6
shipments/
yr)
=
$
587/
yr
Loading
Costs
($
2.57/
ton)
*
(
360
tons
recovered
waste)
=
$
925/
yr
Loading
Costs
($
2.57/
ton)
*
(
119
tons
residual)
=
$
306/
yr
Residual
Waste
Transportation
Costs
($
3.73/
mile)*(
0
hazardous
waste
shipments/
yr)*(
1,000
miles
to
hazardous
incineration/
hazardous
waste
shipment)
+
($
2.16/
mile)*(
0
nonhazardous
waste
shipments/
yr)*(
50
miles
to
nonhazardous
landfill/
nonhazardous
waste
shipment)
=
$
0/
yr
Transportation
Costs
($
3.73/
mile)*(
0
hazardous
waste
shipments/
yr)*(
1,000
miles
to
hazardous
incineration/
hazardous
waste
shipment)
+
($
2.16/
mile)*(
6.6
nonhazardous
waste
shipments/
yr)*(
50
miles
to
nonhazardous
landfill/
nonhazardous
waste
shipment)
=
$
713/
yr
Appendix
V
Example
Cost
Calculation:
1999
Off­
site
Disposal
of
Spent
Aluminum
Potliner
(
K088)
shifting
to
On­
site
Sodium
Fluoride
Recovery
(
2001
$)

Pre­
Rule
Cost
Calculation
Post­
Rule
Cost
Calculation
V­
4
Disposed
Waste
Transportation
Cost
($
3.73/
mile)
*
(
20
hazardous
waste
shipments/
yr)*(
1,000
miles
to
hazardous
incineration/
hazardous
waste
shipment)
=
$
74,600/
yr
Disposed
Waste
Transportation
Cost
($
3.73/
mile)
*
(
0
hazardous
waste
shipments/
yr)*(
1,000
miles
to
hazardous
incineration/
hazardous
waste
shipment)
=
$
0/
yr
Salvage
(
Recovered
Product)
Value
($
1,240/
ton
sodium
fluoride)
*
(
0
tons
recovered
acid/
yr)
=
$
0/
yr
Salvage
(
Recovered
Product)
Value
($
1,240/
ton
sodium
fluoride)
*
(
7.2
tons
recovered
acid/
yr)
=
$
8,928/
yr
Hazardous
Material
Training
Cost
Given
LQG
then
$
9,794/
yr
Hazardous
Material
Training
Cost
Given
Not
a
Generator
then
$
0/
yr
Manifest
Training
Cost
Given
LQG
then
$
1,828/
yr
Manifest
Training
Cost
Given
Not
a
Generator
then
$
0/
yr
Biennial
Report/
General
Administrative
Duties
Cost
Given
LQG
then
$
2,430/
yr
Biennial
Report/
General
Administrative
Duties
Cost
Given
Not
a
Generator
then
$
0/
yr
Contingency
Planning
Cost
Given
LQG
then
$
2,796
Contingency
Planning
Cost
Given
Not
a
Generator
then
$
0
Initial
Waste
Characterization
Cost
$
6,160
Initial
Waste
Characterization
Cost
$
6,160
Exclusion
Filing
Fee
(
One
time
Expenditure)
$
0
Exclusion
Filing
Fee
(
One
time
Expenditure)
$
639
State
Facility
Tax/
Fee
Given
Oregon
and
LQG
then:
$
525
activity
verification
fee/
yr
State
Facility
Tax/
Fee
Given
Oregon
and
Not
a
Generator
then:
$
0
activity
verification
fee/
yr
State
Generation
Tax/
Fee
Given
Oregon
then:
($
45
generation
fee/
ton)*(
360
tons
recovered
waste/
yr)
=
$
16,200/
yr
State
Generation
Tax/
Fee
Given
Oregon
then:
($
45
generation
fee/
ton)*(
0
tons
residual/
yr)
=
$
0/
yr
Total
$
346,728/
yr
$
308,842/
yr
Incremental
Costs
­
$
37,887/
yr
*
Residual
costs
are
included
in
the
costs
for
off­
site
commercial
incineration.
W­
5
W­
1
Appendix
W
Methodology
for
Estimating
Residual
Generation
and
Management
This
appendix
presents
the
methodology
used
regarding
metal,
solvent,
and
acid
recovery
residual
generation
and
disposal.

Using
1999
BRS
data,
facilities
reporting
waste
management
with
system
types
M013,
M021,
and
M031
were
reviewed.
Due
to
the
limited
number
of
facilities
reporting
wastes
managed
with
system
types
M013
and
M031,
all
such
facilities
were
reviewed.
Facilities
reporting
management
by
system
type
M021
were
divided
into
5
groups,
approximately
equal
in
number,
based
on
the
mass
of
waste
managed
by
system
type
M021.
Six
facilities
were
selected
from
each
group.
The
groups
were
divided
as
follows:
less
than
1.1
tons
managed,
1.1
to
5
tons
managed,
5
to
13.5
tons
managed,
13.5
to
55
tons
managed,
and
greater
than
55
tons
managed.
The
tables
below
present
the
data
results.

The
following
assumptions
were
made
regarding
the
recovery
processes:

°
Reclamation
systems
for
acid
and
solvents
are
closed
loop.
That
is
no
losses
from
spillage
or
waste
are
assumed.
This
is
a
simplification
of
the
actual
process
as
many
processes
may
include
settlement
tanks
or
other
open­
air
sections
that
may
allow
evaporation
or
spillage.

°
All
ineffective
products
are
removed
with
the
process
residuals.
An
effectiveness
factor
or
assay
value
is
included
to
estimate
the
"
purity"
of
the
recovered
solvent,
acid,
or
metal.

°
Mass
is
assumed
to
be
balanced
in
the
acid
and
solvent
recovery
process.
No
additives
or
precipitants
are
assumed
into
the
process,
or
the
change
in
product/
residual
mass
in
comparison
to
the
total
mass
is
minor.
The
recovery
of
metals
process,
68
percent
of
the
waste
stream
mass
is
assumed
to
contain
the
product
metals
and
components
that
are
volatilized
(
e.
g.,
water
vapor).
Twenty
(
20)
percent
of
the
waste
stream
is
assumed
recovered
as
metals
in
higher
quality
wastes
and
five
percent
in
lower
quality
wastes.
Thirty­
two
(
32)
percent
is
assumed
to
be
residual
waste.
The
mass
recovery
of
products
is
discussed
further
below.

Metals
Recovery
Statistics
No.
Data
Points
7
Range
0.42
to
84
percent
Average
32
percent
Standard
Deviation
33.92
percent
W­
2
DPRA
reviewed
a
total
of
19
facilities
reporting
wastes
managed
by
M013
in
the
1999
BRS.
One
additional
facility,
for
a
total
of
seven
facilities,
was
able
to
be
used
in
a
percent
residual
assumption.
Residual
waste
streams
could
not
be
identified
in
the
remaining
facilities.

The
management
system
type
reported
for
the
residuals
identified
from
M013
system
processes
are
M061,
M111,
M112,
M119,
and
M132.
Five
of
seven
waste
generating
facilities
managed
the
M013
residuals
by
stabilization
(
M111,
M112,
and
M119).
The
likely
final
deposition
of
the
stabilized
wastes
are
in
a
RCRA
Subtitle
C
hazardous
waste
landfill.

Solvent
Recovery
Statistics
No.
Data
Points
23
Range
0.46
to
140
percent
Average
33
percent
Standard
Deviation
32.13
percent
Residuals
generated
by
M021
system
processes
were
reported
managed
by
the
following
system
types;
M042,
M051,
M061,
and
M081.
An
total
of
28
facilities
were
reviewed,
of
which
5
facility
residual
waste
streams
could
not
be
identified.
Fuel
blending
(
M061)
was
reported
by
17
of
22
facilities
for
management
of
M021
residuals.
An
additional
three
facilities
managed
M021
residuals
by
other
co­
burning
or
incineration
systems
(
M042
and
M051).

Acid
Recovery
Statistics
No.
Data
Points
18
Range
0
to
105
percent
Average
26
percent
Standard
Deviation
31.92
percent
Residuals
generated
by
M031
system
processes
were
assumed
to
be
similar
in
form
to
the
spent
acid
waste
stream.
That
is,
the
contaminants
(
generally
metals)
were
concentrated
in
a
smaller
portion
of
the
waste
stream
for
management.
The
disposal
quantities
of
these
residuals
were
identified
by
their
description
and
management
system
type.
An
total
of
23
facilities
were
reviewed,
of
which
5
facility
residual
waste
streams
could
not
be
identified.
Residuals
were
reported
managed
by
M039,
M042,
M043,
M051,
M077,
M104,
M109,
M121,
M134,
M136.
Chemical
precipitation
(
M077)
was
reported
by
seven
of
eighteen
facilities
for
management
of
M031
residuals.
One
additional
facility
reported
management
by
neutralization
only
(
M121),
which
is
similar
to
chemical
precipitation.

The
analysis
should
use
the
average
residual
generation
values
listed
above.
Metal
recovery
residuals
will
be
managed
by
stabilization
and
Subtitle
C
landfill.
Solvent
residuals
are
managed
W­
3
by
energy
recovery.
Acid
recovery
residuals
are
managed
by
chemical
precipitation.
Cost
assumptions
for
management
of
acid
recovery
residuals
will
include
stabilization
and
landfill
disposal
of
precipitates,
and
sewer
discharge
of
neutralized
wastewater.
X­
1
Appendix
X
Analysis
of
Metals
Containing
and
Organic
Liquid
Disposal
Quantities
This
appendix
presents
the
review
of
selected
metals
containing
liquids
and
organic
liquids
waste
streams
to
determine
the
potential
for
or
quantity
of
mis­
categorized
disposed
waste
streams.
Disposed
wastes
streams
1999
BRS
data
was
reviewed
for
the
final
disposition
in
the
case
of
metals
containing
liquids
and
the
description
in
the
case
of
organic
liquids.
Metals
containing
liquids
may
be
classified
as
disposed
based
on
the
reported
1999
Biennial
Report
management
methods,
but
the
waste
may
be
managed
further
and
metals
content
recovered.
The
final
disposal/
management
method
may
not
be
reflected
in
the
reporting
by
the
disposing
facility.
For
example,
metals
containing
liquids
reported
managed
by
chemical
precipitation
(
M077)
may
be
disposed
in
a
landfill
or
shipped
to
a
high
temperature
metals
recovery
facility.
In
which
case,
the
waste
streams
should
be
classified
as
recovered
off­
site
outside
the
same
NAICs.
For
organic
liquid
wastes
disposed,
the
facility
may
recover
solvents
on
site
and
produce
a
waste
stream
with
a
similar
form
as
spent
solvents.
The
screening
process
for
the
1999
BRS
data
did
not
differentiate
between
solvent
recovery
residuals
and
spent
solvents.
A
review
of
the
wastes
descriptions
was
conducted
to
determine
if
the
organic
liquid
wastestreams
were
the
result
of
onsite
recovery
and
should
be
excluded
from
the
analysis.
Examples
of
wastes
that
should
be
removed
from
the
analysis
include
still
bottoms,
distillation
fractions,
column
bottoms.
Other
wastes
streams
with
descriptions
indicating
a
recovery
process
was
employed
were
also
flagged
to
be
removed.

DPRA
reviewed
a
total
of
10
metals
containing
liquids
generating
facilities,
representing
$
1.9
million
of
a
total
of
$
2.9
million
in
incremental
cost
savings
without
taxes
(
66
percent).
Three
facilities
were
identified
that
generate
3,621.5
tons
of
metals
containing
liquid
waste
streams
with
which
the
metals
are
ultimately
recovered.
The
recovery
facilities
represent
a
total
of
$
0.56
million
of
the
incremental
costs
savings
without
taxes,
29
percent
of
the
reviewed
facilities
and
19
percent
of
the
total
incremental
cost
savings
without
taxes.

DPRA
reviewed
a
total
of
35
organic
liquids
generating
facilities,
representing
$
87.9
million
of
a
total
of
$
174.4
million
in
incremental
cost
savings
without
taxes
(
50
percent).
Eight
facilities
were
identified
that
generate
10,610
tons
of
organic
liquid
waste
streams
of
which
the
description
indicates
them
to
be
solvent
recovery
residuals.
These
facilities
represent
a
total
of
$
23.9
million
of
the
incremental
costs
savings
without
taxes,
27
percent
of
the
reviewed
facilities
and
14
percent
of
the
total
incremental
cost
savings
without
taxes.
The
waste
streams
identified
represent
only
a
portion
of
the
organic
liquids
generated
at
seven
of
the
eight
facilities;
therefore,
the
identified
wastes
streams
account
for
less
than
the
facility
totals
of
$
23.9
million
incremental
costs
savings
without
taxes.
DPRA
estimates
the
waste
streams
represent
53
percent
of
the
eight
facilities
incremental
cost
savings
without
taxes
($
46.6
million).
X­
2
Metals
Containing
Liquids
Generating
Facilities
Reviewed
for
Potential
Metal
Recovery
Ultimate
Disposal
Generator
EPA
ID
Total
Offsite
Shipped
Quantity
(
tons)
Offsite
Shipped
Quantity
(
tons)
Management
Method
Receiver
EPA
ID
Receiver
Name
(

Secondary
Receiver
Name)
Management
Method
for
Precipitated
Sludges
Conclusions
NYD002241982
1773.4
169.9
Stabilization
(
M077)
PAD010154045
Envirite
of
Pennsylvania
Inc.
Stabilization/
chemi
cal
fixation
(
M111)
Stabilization/
chemical
fixation
­
likely
landfilled
1603.5
Chemical
precipitation
in
combination
with
biological
treatment
(
M091)
NJD002385730
Dupont
Chambers
Works
(
Unable
to
find
related
waste
stream)

ILD984774513
1233.1
1233.1
Chemical
precipitation
(
M077)
ILD062480850

TXR000000034
Phibro­
Tech
Inc

ECS
Refining
Texas
LLC
No
1999
Biennial
Report
data
for
TXR000000034
WID000711077
1315.2
1315.2
Stabilization/
chemical
fixation
(
M111)
IND093219012
Heritage
Environmental
Svc
­
Indy
Landfill
(
M132)
Landfilled
MND980680540
1514.5
1514.5
Chemical
precipitation/
other
aqueous
inorganic
treatment
(
M077/
M078)
MND981098478
US
Filter
Recovery
Services
Inc
High
temperature
metals
recovery
(
M011)
Remove
facility
from
off­
site
disposal
scenario
to
off­
site
recovery
scenario.

AZD980818330
1105.3
1105.3
Chemical
oxidation
followed
by
chemical
precipitation
(
M074)
CAD008488025
Phibro­
Tech
Inc
Other
metals
recovery
for
reuse
(
M014)
Remove
facility
from
off­
site
disposal
scenario
to
off­
site
recovery
scenario.

NOTE:
WR­
form
says
M014,
not
M074
ILD067464875
1332.9
1288.6
Chemical
precipitation
(
M077)
ILD000666206

(
onsite
M112)


MID000724831
Envirite
of
Illinois
Inc.
Stabilization/
chemi
cal
fixation
(
M111)
Stabilization/
chemical
fixation
­
likely
landfilled
­
NOTE:
GM­
form
says
M112,
not
M077
33.3
Transfer
facility
storage
(
M141)
ILD980502744
Safety­
Kleen
Corp
(
Unable
to
find
related
waste
stream)

11.0
Chemical
precipitation
(
M077)
ILD062480850

TXR000000034
Phibro­
Tech
Inc

ECS
Refining
Texas
LLC
No
1999
Biennial
Report
data
for
TXR000000034
ILD984809905
760.9
760.9
Chemical
precipitation
(
M077)
ILD000666206

(
onsite
M112)


MID000724831
Envirite
of
Illinois
Inc.
Stabilization/
chemi
cal
fixation
(
M111)
Stabilization/
chemical
fixation
­
likely
landfilled
­
NOTE:
GM­
form
says
M112,
not
M077
ILD155126030
687.3
687.3
Chemical
precipitation
(
M077)
ILD000666206

(
onsite
M112)


MID000724831
Envirite
of
Illinois
Inc.
Stabilization/
chemi
cal
fixation
(
M111)
Stabilization/
chemical
fixation
­
likely
landfilled
­
NOTE:
GM­
form
says
M112,
not
M077
Metals
Containing
Liquids
Generating
Facilities
Reviewed
for
Potential
Metal
Recovery
Ultimate
Disposal
X­
3
MND001037639
1001.8
1001.5
Chemical
precipitation/
other
aqueous
inorganic
treatment
(
M077/
M078)
MND981098478
US
Filter
Recovery
Services
Inc
High
temperature
metals
recovery
(
M011)
Remove
facility
from
off­
site
disposal
scenario
to
off­
site
recovery
scenario.

0.2
Chemical
precipitation
(
M077)
MND980996805

MND981098478
Enviro­
Chem
Inc

US
Filter
Recovery
Services
Inc
High
temperature
metals
recovery
(
M011)
Remove
facility
from
off­
site
disposal
scenario
to
off­
site
recovery
scenario.

ILD984844134
601.3
601.3
Chemical
precipitation
(
M077)
ILD000666206

(
onsite
M112)


MID000724831
Envirite
of
Illinois
Inc.
Stabilization/
chemi
cal
fixation
(
M111)
Stabilization/
chemical
fixation
­
likely
landfilled
­
NOTE:
GM­
form
says
M112,
not
M077
X­
4
Organic
Liquids
Generating
Facilities
Reviewed
for
Potential
to
be
Solvent
Recovery
Residuals
Generator
EPA
ID
Total
Offsite
Shipped
Quantity
(
tons)
Offsite
Shipped
Quantity
(
tons)
Waste
Description
Other
Info
Conclusions
NJD002146504
3,760.6
0.1
WASTE
PETROLEUM
NAPTHA,
COMBUSTIBLE
LIQUID,
FROM
PARTS
DEGREASING
3,760.5
FLAMMABLE
LIQUID
FROM
PRODUCTION
OR
SUNSCREENS
WID000808824
3,676.5
3,657.5
(
no
waste
description)
F005,
A34,
B203
19.0
(
no
waste
description)
F005,
A37,
B203
WIR000046276
3,263.2
14.8
(
no
waste
description)
F003,
A09,
B203
3,248.4
(
no
waste
description)
D001,
A09,
B203
0.1
(
no
waste
description)
D038,
A59,
B203
0.1
(
no
waste
description)
D006,
A19,
B203
0.2
(
no
waste
description)
U122,
A58,
B219
TXD980626014
3,224.0
1,711.7
STYRENE
WASTE
OIL.
THIS
WASTE
CONSISTS
OF
BENZENE,
TOLUENE,

534.8
SPENT
XYLENE.
THE
WASTE
IS
A
SPENT
XYLENE
SOLVENT.
IT
IS
A
1.8
FLAMMABLE
ORGANIC
LIQUIDS.
THE
WASTE
CONSISTS
OF
ORGANIC
LI
5.7
PAINT
WASTE,
LIQUID
954.2
NON­
AQUEOUS
LIQUID,
TYPICALLY
AS
FOLLOWSHEPTANE
ISOMERS
48%,

2.2
ANTIOXIDANT.
THE
WASTE
IS
A
CLEAR
LIGHT
YELLOW
LIQUID
WITH
13.6
PARTS
WASHER
SOLVENT
Organic
Liquids
Generating
Facilities
Reviewed
for
Potential
to
be
Solvent
Recovery
Residuals
X­
5
IAD005272398
2,830.7
17.2
DUPONT
WASTE
CODE
=
WFW­
1
OBSOLETE
NON­
SALEABLE
PAINT
AND
PA
INT
RELATED
MATERIAL,
ORGANIC
LIQUID,
FUELS
BLENDING
FOR
CEM
ENT
KILN
1,737.0
DUPONT
WASTE
CODE
=
WOM­
0;
MIXED
WASTE
PAINT
AND
PAINT
RELAT
ED
MATERIALS,

ORGANIC
LIQUIDS,
TFE
STILL
BOTTOMS,
FUELS
FOR
CEMENT
KILN
AND
INCINERATION
Already
a
distillation
byproduct
1,076.6
DUPONT
WASTE
CODE
=
WOM­
16;
OCPSF
PROCESS
WASTEWATER,
RESIN
WATER
OF
REACTION,

LOW
SOLIDS
LIQUID,
SHIPPED
OFF­
SITE
FOR
BIOLOGICAL
WATER
TREATMENT
WVD004325353
3,228.7
3,188.2
IGNITABLE,
LISTED
WASTE
SOLVENTS
FROM
PROCESS
EQUIPMENT
CLEA
NUP;
CONTAINS
TOLUENE,
METHANOL,
ISOPROPANOL,
ETHANOL
AND
SO
LVENT
140.

0.1
IGNITABLE
OFF­
SPEC
RAW
MATERIAL,
ISOPROPYL
ALCOHOL.

1.6
IGNITABLE
OFF­
SPEC
ORGANOFUNCTIONAL
SILANE
PRODUCT.

2.9
IGNITABLE,
SILOXANE
DISTILLATION/
STRIPPING
WASTE
FROM
PRODUC
T
MANUFACTURING.
Already
a
distillation
byproduct
8.1
CORROSIVE
OFF­
SPEC
RAW
MATERIAL,
POLYOXYALKYLENE
BUTYL
EHTER
PHOSPHATE.

0.7
IGNITABLE,
SILOXANE
DISTILLATION/
STRIPPING
RESIDUE
FROM
PROD
UCT
MANUFACTURING
CONTAINING
ETHANOL.
Already
a
distillation
byproduct
0.8
IGNITABLE
WASTE
FROM
PROCESS
EQUIPMENT
CLEANUP
WITH
ETHANOL.

0.1
IGNITABLE,
LISTED
OFF­
SPEC
RAW
MATERIAL,
METHYLENE
CHLORIDE.

0.2
LISTED
OFF­
SPEC
RAW
MATERIAL,
TETRAHYDROFURAN.

0.2
IGNITABLE,
LISTED
WASTE
SOLVENTS
FROM
PROCESS
EQUIPMENT
CLEA
NUP
CONTAINING
TOLUENE
AND
METHANOL.

0.4
IGNITABLE
OFF­
SPEC
RAW
MATERIAL,
DICYCLOPENTADIENE.

1.2
IGNITABLE,
SILOXANE
DISTILLATION/
STRIPPING
RESIDUE
FROM
PROD
UCT
MANUFACTURING.
Already
a
distillation
byproduct
1.3
IGNITABLE
OFF­
SPEC
RAW
MATERIAL,
ETHYLENE
GLYCOL.
Organic
Liquids
Generating
Facilities
Reviewed
for
Potential
to
be
Solvent
Recovery
Residuals
X­
6
2.6
IGNITABLE,
LISTED
PAINT
SOLVENTS
FROM
MAINTENANCE
OPERATIONS
.

20.3
IGNITABLE,
LISTED
WASTE
SOLVENTS
AND
OFF­
SPEC
SURFACTANTS.

NJD981080401
2,682.7
2,682.7
DISTILLATION
FRACTIONS
&
STILL
BOTTOMS
AND
SOLVENTS
USED
Already
a
distillation
byproduct
TXD000461533
2,944.3
13.3
PAINT
RELATED
WASTE
CONSISTS
OF
PAINT,
PAINT
THINNER,
PAINT
597.0
ORGANIC
ACID
RESIDUES
GENERATED
DURING
PRODUCTION
OF
ORGANIC
70.7
SPENT
ACETONE/
MSO
WASTE
GENERATED
AT
OLEFINS
UNIT
FROM
ACETY
982.1
VINYL
ACETATE
POLYMER
IS
VISCOUS
ORGANIC
LIQUID
MATERIAL
RES
928.3
"
A"
DRIPOLENE
IS
STILL
BOTTOMS
GENERATED
AS
PART
OF
OLEFINS
Already
a
distillation
byproduct
6.4
SPENT
SOLVENTS,
HALOGENATED
&
NON­
HALOGENATED
ORGANIC
CHEMIC
0.2
METHANOL
SYNOSOL
WATER
RESULTING
FROM
MIXTURE
OF
METHANOL,
S
346.2
MIXED
VARNISH
WASTE
IS
VISCOUS
LIQUID
ORGANIC
MATERIAL
RESUL
ARD052528809
2,876.3
19.2
TANK
CLEANOUT,
ONE
TIME.
(
15)
FLAMMABLE.
CONTAINS
TOLUENE.
(
13292)

0.7
MIXED
LAB
WASTES.
(
LAB)
FLAMMABLE,
TOXIC.
CONTAINS
ACETONE,
METHANOL.
(
12654)

1.8
MIXED
LAB
WASTES.
(
LAB)
FLAMMABLE,
TOXIC.
CONTAINS
ACETONE,
BENZENE.
(
9433)

5.0
MIXED
LAB
WASTES.
(
LAB)
FLAMMABLE,
TOXIC.
CONTAINS
ACETONE,
DICHLOROMETHANE.

(
9276)

695.5
SPENT
DISTILLATION
CHASER
FLUID,
WASTE
OIL.
(
DE)
FLAMMABLE.
(
CP1374)
Already
a
distillation
byproduct
0.6
DISTILLATION
COLUMN
BOTTOMS
AND
OVERHEADS.
(
AD)
FLAMMABLE.
(
9345)
Already
a
distillation
byproduct
2,145.1
DISTILLATION
BY
PRODUCT
FROM
PRODUCTION.
(
AD
­
PCO)
FLAMMAB
LE.
(
9710­
06333)
Already
a
distillation
byproduct
Organic
Liquids
Generating
Facilities
Reviewed
for
Potential
to
be
Solvent
Recovery
Residuals
X­
7
1.7
PAINT
WASTE.
(
MAINT)
TOXIC,
FLAMMABLE.
CONTAINS
TOLUENE,
XYL
ENE.
(
9278)

6.6
TANK
CLEANOUT,
ONE
TIME.
(
AD)
FLAMMABLE.
CONTAINS
ADMA.
(
137
72)

TXD008092793
2,451.1
2,404.5
MISCELLANEOUS
ORGANIC
LIQUIDS
46.6
HAZARDOUS
NON­
HALOGENATED
SOLVENTS
PRD090036021
2,589.0
60.7
AQUEOUS
PHASE
FROM
PHARMACEUTICAL
MANUFACTURING
PROCESS.

1,968.6
IGNITABLE
SPENT
SOLVENT
MIXTURE
FROM
PHARMACEUTICAL
MANUFACT
URING
PROCESS;

MIXTURE
OF
TOLUENE,
ACETONE,
ETHYL
ACETATE,
M
ETHYLENE
CHLORIDE,
METHANOL,

XYLENE,
METHYL
ISOBUTYL
KETONE
5.8
DISCARDED
SPENT
HALOGENATED
&
NON­
HALOGENATED
SOLVENTS
535.5
IGNITABLE
SPENT
SOLVENT
MIXTURE
FROM
PHARMACEUTICAL
PROCESS;
ACETONE,

METHANOL,
ETHYL
ACETATE
AND
METHYLENE
CHLORIDE.

14.2
DISCARDED
FLAMMABLE
WASTE
FROM
PHARMACEUTICAL
MANUFACTURINGP
ROCESS
4.2
OFF
SPEC
DISCARDED
INTERMEDIATE
ORGANIC
LIQUIDS
OHD076796887
2,766.8
155.1
DRUM
LIQUIDS
FROM
RESIN
MANUFACTURING
0.1
2K
CLEARCOAT
AND
KILLED
ISOCYANATE
WASTE
0.2
AGED
RAW
MATERIAL:
DIMETHYLETHANOLAMINE
5.3
AGED
RAW
MATERIAL:
PHENOTIC
RESIN
SOLUTION
20.8
CLEANING
SOLVENT
BLEND
USED
IN
RESIN
MANUFACTURING
19.7
OFF­
SPEC
WATERBASED
RESIN
2.4
WASTE
MONOMER
MIX
FROM
LABORATORY
TESTING
293.3
OFF­
SPEC
SOLVENT
BASED
RESINS
70.9
WASTE
TOLUENE
AND
METHYL
CARBANATE
SOLUTION
2,198.7
FLAMMABLE
LIQUID
DISTILLATE
FROM
RESIN
MANUFACTURING
Already
a
distillation
byproduct
0.4
KARL
FISCHER
REAGENT
FROM
LABORATORY
TESTING
VAD000019828
2,236.6
PAINT
MANUFACTURER
HAZARDOUS
WASTE
SOLVENT
NJD002191211
2,283.3
15.9
METHYLENE
CHLORIDE
Organic
Liquids
Generating
Facilities
Reviewed
for
Potential
to
be
Solvent
Recovery
Residuals
X­
8
0.2
WASTE
SOLVENTS
2,267.2
BULK
SOLVENTS
BUILDING
30
IAD045372836
2,432.7
1,047.9
BENZENE­
CONTAINING
PYROLYSIS
OIL
FROM
ETHYLENE
PRODUCTION:
MIXTURE
OF
ORGANIC
COMPONENTS.

1,354.5
IGNITABLE
SPENT
SOLVENT
AND
CO­
MONOMER
FROM
LOW
DENSITY
POLYETHYLENE
PRODUCTION:
MIXTURE
OF
MINERAL
SPIRITS
AND
VINYL
ACETATE.

28.0
IGNITABLE
SPENT
SOLVENT
AND
CO­
MONOMER
FROM
LOW
DENSITY
POLYETHYLENE
PRODUCTION:
MIXTURE
OF
MINERAL
SPIRITS
AND
METHYL
ACRYLATE.

0.2
IGNITABLE
SPENT
SOLVENT
FROM
OPERATIONAL
CLEANOUT:
MIXTURE
OF
ALIPHATIC
HYDROCARBONS.

0.2
IGNITABLE
SPENT
SOLVENTS
FROM
QUALITY
CONTROL
LABORATORY
OPERATIONS:
MIXTURE
OF
SOLVENTS,
WITH
MAIN
COMPONENTS
BEING
CYCLOHEXANE
AND
TETRACHLOROETHENE.

1.2
WASTE
PAINT
MATERIALS
AND
MIXTURE
OF
VARIOUS
OIL­
BASED
PAINTS.

0.7
IGNITABLE
SPENT
SOLVENTS
FROM
QUALITY
CONTROL
LABORATORY
OPERATIONS:
MIXTURE
OF
SOLVENTS,
WITH
MAIN
COMPONENTS
BEING
CYCLOHEXANE
AND
TETRACHLOROETHENE.

TXD008090011
2,212.8
2,212.0
BY­
PRODUCT
ORGANICS
FROM
MERCAPTAN
MANUFACTURING.
TOWER
BOT
0.8
WASTE
PAINT
THINNER
AND
PAINT
COLLECTED
IN
55
GALLON
DRUMS
TXR000025809
2,670.4
0.4
PAINT
THINNER
OR
PETROLEUM
DISTILLATES
Already
a
distillation
byproduct
26.6
POLYETHYLENE
AND
POLYVINYLACETATE
WAX
IN
VINYL
ACETATE
FRO
2,319.1
RECOVERED
ORGANICS
­
SPENT
CONTAMINATED
LUBRICATING
OILS,
MI
11.8
SPENT
PARTS
WASHER
SOLVENT
29.5
HEAVY
AROMATIC
HYDROCARBONS
(
ETHYLENE
TARS)

15.2
POLYETHYLENE
ADDITIVE
SLURRY
(
AMINES,
ANTIOXIDENTS
&
AMIDE
4.4
WASTE
PAINT
RELATED
RESIDUES,
EXCESS
PAINT
AND
APPLICATOR
Organic
Liquids
Generating
Facilities
Reviewed
for
Potential
to
be
Solvent
Recovery
Residuals
X­
9
17.7
SPENT
CYCLOHEXANE
WASH
SOLUTION
197.0
SPENT
METHANOL
USED
IN
CLEANING
PROCESS
VESSELS
21.9
RECOVERED,
SPENT
ORGANIC
PEROXIDE
IN
MINERAL
SPIRITS
2.5
OLD/
CONTAMINATED
FUEL
0.2
USED
N­
PROPANOL
PUMP
SEAL
FLUIDS
24.2
SPENT
LABORATORY
SOLVENT
WITH
ANALYTICAL
RESIDUES
MOD985791995
2,158.5
1,437.9
IGNITABLE
SPENT
SOLVENT
FROM
PHARMACEUTICAL
MFG
PROCESS
­
MI
XTURE
OF
METHANOL
AND
TOLUENE
485.6
SPENT
SOLVENT
FROM
PHARMACEUTICAL
MFG
PROCESS
SOLUTION
OF
ME
THYLENE
CHLORIDE
AND
WATER
WITH
ACETONE
234.9
IGNITABLE
SPENT
SOLVENT
FROM
PHARMACEUTICAL
MFG.
PROCESS­
TOL
UENE
KYD082390394
2,002.0
459.5
IGNITABLE,
BARIUM,
CHROMIUM,
LEAD
1,542.5
IGNITABLE,
LEAD,
BARIUM,
MEK,
TOLUENE
MAD980912323
2,947.1
1,111.0
TOXIC
IGNITABLE
SOLVENT
(
ACETONE,
TOLUENE,
BUTANOL,
XYLENE)
GENERATED
FROM
ORGANIC
CHEMICAL
FILTERING
PROCESSING
AND
EQUIPMENT
CLEANING.

3.6
DISTILLATION
STILLBOTTOMS
AND
SPENT
SOLVENT.
CONTAINS
METHYLENE
CHLORIDE
AND
ANILINE.
Already
a
distillation
byproduct
566.1
TOXIC
IGNITABLE
AQUEOUS
SOLUTION
CONTAINS
(
ACETONE,
TOLUENE,
BUTANOL,

METHANOL,
CHLOROBENZENE)
GENERATED
FROM
SITE
AIR
ABATEMENT
EQUIPMENT,

WASTEWATER
CONTROL
EQUIPMENT,
PRODUCT
FILTERING
AND
EQUIPMENT
CLEANOUTS.

783.5
TOXIC
IGNITABLE
AQUEOUS
SOLUTION
CONTAINS
(
ACETONE,
TOLUENE,
BUTANOL,

METHYLENE
CHLORIDE,
METHANOL)
GENERATED
FROM
SITE
AIR
ABATEMENT
EQUIPMENT,

WASTEWATER
CONTROL
EQUIPMENT,
PRODUCT
FILTERING
AND
EQUIPMENT
CLEANOUTS.

48.9
IGNITABLE
SOLVENT
SOLUTION,
BUTANOL
CONTAMINATED
WITH
ETHYL
ACETATE.

150.1
IGNITABLE
AQUEOUS
SOLUTION,
CONTAINS
ISOPROPANOL
GENERATED
FROM
PRODUCT
FILTERING.

20.0
WASTE
SOLVENTS
FROM
DRYER
CONDENSATE
AND
CAPTURED
VENT
OVERHEADS.(
BUTANOL,

ACETONE,
ISOPROPANOL,
CYCLOHEXANE)
GENERATED
FROM
ORGANIC
CHEMICAL
DRYING.

8.7
SPENT
INPROCESS
SOLVENT
WASTE,
(
METHANOL,
TOLUENE,
XYLENE,
ISOPROPANOL,
ETHYL
Organic
Liquids
Generating
Facilities
Reviewed
for
Potential
to
be
Solvent
Recovery
Residuals
X­
10
ACETATE)
GENERATED
FROM
ORGANIC
CHEMICAL
MANUFACTURE.

0.5
WASTE
METHYLENE
CHLORIDE
AND
ISOPROPANOL.
GENERATED
FROM
ORGANIC
CHEMICAL
MANUFACTURING.

0.8
LABORATORY
SOLVENT
WASTE.
GENERATED
IN
QUALITY
AND
RESEARCH
LABORTORIES.

9.4
WASTE
SOLVENTS
FROM
CONTAMINATED
REACTION.
(
BUTANOL,
ETHYL
ACETATE)

GENERATED
WHEN
INPROCESS
REACTION
BECAME
CONTAMINATED
WITH
ETHYL
ACETATE.

0.8
SPENT
IGNITABLE,
CORROSIVE
SOLVENT
USED
IN
VESSEL
CLEANING
(
ACETONE,

HYDROCHLORIC
ACID)
GENERATED
FROM
PROCESS
VESSEL
CLEANING.
Organic
Liquids
Generating
Facilities
Reviewed
for
Potential
to
be
Solvent
Recovery
Residuals
X­
11
0.3
IGNITABLE,
TOXIC
AND
CORROSIVE
CLEANOUT
SOLUTION,
(
ACETONE,
METHYLENE
CHLORIDE,

HYDROCHLORIC
ACID).
GENERATED
FROM
VESSEL
CLEANING.

18.6
SPENT
TOXIC
SOLVENT,
(
METHYLENE
CHLORIDE).
SENT
OFFSITE
FOR
RECOVERY.
GENERATED
FROM
ORGANIC
CHEMICAL
MANUFACTURE.

42.5
DISTILLATION
STILLBOTTOMS
AND
SPENT
SOLVENT.
CONTAINS
ISOPROPANOL
OR
CYCLOHEXANE.
GENERATED
FROM
ONSITE
SOLVENT
RECOVERY.
Already
a
distillation
byproduct
2.4
IGNITABLE
WASTE
OIL,
CONTAMINATED
WITH
CYCLOHEXANE.
GENERATED
FROM
OIL
CHANGES
ON
VACCUM
PUMPS.

1.0
INPROCESS
SOLVENT
SAMPLE
STREAMS
CONTAINING,
METHANOL,
TOLUENE,
ACETONE
OR
ACETIC
ACID.
GENERATED
FROM
SAMPLING
ORGANIC
CHEMICAL
REACTIONS.

6.0
SPENT
SOLVENTS
GENERATED
FROM
PROCESS
CLEANOUTS.
(
METHANOL,
ISOPROPANOL,

BUTANOL)

99.7
DISTILLATION
STILLBOTTOMS
AND
SPENT
SOLVENT.
CONTAINS
METHYLENE
CHLORIDE
AND
PYRIDINE.
Already
a
distillation
byproduct
2.7
SPENT
PROCESS
SOLVENT
(
PROPIONIC
ACID)
GENERATED
IN
ORGANIC
CHEMICAL
MANUFACTURE.

0.2
SPENT
PROCESS
SOLVENT,
(
PROPIONIC
ACID,
M­
CRESOL)
GENERATED
IN
ORGANIC
CHEMICAL
MANUFACTURE.

13.1
SPENT
IGNITABLE,
CORROSIVE,
TOXIC
LIQUID
GENERATED
FROM
DISTILLATION
OF
SOLVENTS
FROM
ORGANIC
CHEMICAL
MANUFACTURING.
CONTAINS
CHLOROBENZENE
AND
HYDROCHLORIC
ACID.
Already
a
distillation
byproduct
57.5
SPENT
IGNITABLE,
TOXIC,
CORROSIVE
LIQUID.
GENERATED
FROM
THE
DISTILLATION
OF
SOLVENTS
IN
ORGANIC
CHEMICAL
MANUFACTURING.
CONTAINS
CHLOROBENZENE,
METHANOL
AND
HYDROCHLORIC
ACID.
Already
a
distillation
byproduct
PAD042259374
1,842.2
1,841.9
WASTE
FLAMMABLE
LIQUID,
HEPTANE/
TOLUENE
SOLUTION
SEPARATED
F
ROM
CAUSTIC
WASH
0.2
WASTE
COMBUSTIBLE
LIQUID,
PETROLEUM
NAPHTHA
USED
AS
A
PARTS
CLEANER
IN
MAINTENANCE
SHOP
TXD980867345
1,804.0
7.1
RESIN
WASTE
­
OFF­
GRADE
NON­
SALABLE
RESIN
USED
IN
FUEL
SUPPL
61.5
MIXED
SOLVENTS
FROM
PROCESS
AID
OF
REACTIONS
­
10,000
GAL.
T
Organic
Liquids
Generating
Facilities
Reviewed
for
Potential
to
be
Solvent
Recovery
Residuals
X­
12
1,735.4
AQUEOUS/
SOLVENT
SOLUTION
­
CHEMICALS/
WASTEWATER
FROM
REACTIO
PAD003008943
1,741.4
9.3
INKS,
DYES,
ALCOHOLS
AND
ADHESIVES
FROM
CONSUMER
HEALTHCARE
PRODUCTS
AND
PHARMAUCEUTICALS
PACKAGING
OPERATIONS
0.8
MIXTURE
CONTAINING
PETROLEUM
NAPHTHA
USED
IN
MACHINERY
PARTS
WASHER
1,695.0
OFF­
SPEC
PRODUCTION
WASTE
CONTAINING
FLAMABLE
LIQUIDS
33.5
ALCOHOLS
MIXTURES
USED
IN
THE
PRODUCTION
OF
CONSUMER
HEALTHC
ARE
PRODUCTS
AND
PHARMACEUTICALS
2.9
OUT­
DATED
OR
EXPIRED
FLAVORINGS
USED
IN
THE
PRODUCTION
OF
CO
NSUMER
HEALTHCARE
PRODUCTS
PRD090346909
1,618.1
IGNITABLE
SPENT
SOLVENT
FROM
THE
PRODUCTION
OF
PHARMACEUTICA
LS
PRODUCT.

LAD003913183
1,491.5
WASTE
FLAMMABLE
LIQUIDS
(
ETHANOL/
PROPANOL)

OHD004282976
1,558.9
1,153.9
WASTE
FLAMMABLE
LIQUID
­
SPENT
SOLVENT
136.3
WASTE
GELLED
ALKYD
RESIN
CONTAINING
NAPHTHA
268.8
WASTE
OFF
SPECIFICATION
SOLVENT
BORNE
PAINT
TXD096037932
1,596.0
956.0
MIXED
ORGANIC
LIQUIDS
WITH
140
F.

637.6
WASTE
ISOBUTANOL
AND
DIOL
0.6
FURFURAL
WASTE
1.8
ISOBUTYRALDEHYDE
WASTE
TXD980625966
1,510.0
1,494.8
RED
OIL
AND
RED
OIL
POLYMER
WITH
HAN
15.1
METHANOL/
PROPANOL
MIXTURE
0.1
DIMETHYL
SULFIDE
GAD075876623
1,569.7
0.0
SPENT
SOLVENT
FROM
QUALITY
CONTROL
TESTING
(
CONTAINS
PYRIDIN
E
AND
DICHLOROMETHANE),
IGNITABLE
AND
TOXIC
6.1
ORGANIC
DEFECTIVE
PAINT,
IGNITABLE,
TOXIC
FOR
METALS
AND
MEK
388.7
DEFECTIVE
SOLVENT
BASED
PAINT
AND
SPENT
SOLVENT
(
IGNITABLE
A
ND
TOXIC­
CONTAINS
METALS
AND
SOLVENT)

1.6
EPOXY
PRIMER,
IGNITABLE
Organic
Liquids
Generating
Facilities
Reviewed
for
Potential
to
be
Solvent
Recovery
Residuals
X­
13
1,173.3
SPENT
SOLVENT
FROM
CLEANING
PAINT
PRODUCTION
EQUIPMENT,
IGNI
TABLE
AND
TOXIC
TXD008088833
1,574.2
0.7
MIXED
LIQUID
LABORATORY
WASTE
FROMTECHNICAL
LABORATORY
ACTIV
37.9
POLYMER
BLOWDOWN
CONAINING
SOLVENT.
INITIAL
GENERATION
1996
1,497.1
SPENT
NON­
HALOGENATED
SOLVENT
FROM
LOW
DENSITY
POLYETHYLENE
0.2
HALOGENATED
LABORATORY
SOLVENT
FROM
QUALITY
CONTROL
LABORATO
0.4
QUALITY
CONTROL
LABORATORY
WASTE.
FIRST
GENERATED
1980.

1.7
PILOT
PLANT
WASTE
SOLVENT
GENERATED
DURING
POLYETHYLENE
5.0
PLANT
DEGREASER,
HAZARDOUS
LIQUID.
MAINTENANCE
PARTS
WASHER
1.3
PAINT
THINNER,
CHLOROBENZENE.

0.5
SP
SOLVENT/
MONOMER/
AND
ADDITIVES
29.4
SPECIALTY
POLYMER
WASTE
INACTIVE
CATALYST.
GENERATED
DURING
0.1
POLYARD,
HAZARDOUS,
LIQUID,
RESIDUE
FROM
LOW
DENSITY
POLYETH
TXD008088247
1,550.6
31.2
BCHLOR
WASH
WATER
18.7
DIOL
WASTE
FROM
THE
MANUFACTURE
AND
PURIFICATION
OF
DIOL
PRO
919.2
DBE
REACTOR
BOTTOMS
/
MANUFACTURE
OF
DIBASIC
ESTERS
562.4
REACTOR
WASH
SOLUTION
/
PROCESS
EQUIPMENT
CLEANING
/
FEB.
19
0.2
OTHER
ORGANIC
LIQUIDS
0.2
LIQUID
WASTE
FROM
THE
MANUFACTURE
OF
SIMA.

0.7
BENZYL
CHLORIDE
WASTES
Organic
Liquids
Generating
Facilities
Reviewed
for
Potential
to
be
Solvent
Recovery
Residuals
X­
14
18.0
AQUEOUS
REACTOR
WASH
SOLUTION
CAD070635669
1,266.5
FLAMMABLE
SPENT
SOLVENT
FROM
THE
MANUFACTURING
OF
BULK
PHARMACEUTICALS
WHICH
INCLUDE
A
MIXTURE
OF
TOLUENE,
METHANOL
ISOPROPYL
ALCOHOL,
ETHYL
ACETATE
AND
ETHANOL
LAD098168206
1,259.0
HEAVY
ENDS/
OFF­
SPEC
PRODUCT
FROM
PRODUCTION
OF
ETHYLENE
DICH
LORIDE
BY
"
DIRECT
CHLORINATION"
PROCESS,
EDC,
1,1,2­
TRICHLOR
OETHYLENE,
BIS­
2
CHLOROETHYL
ETHER
TXD065096273
1,677.9
24.6
OFF
SPECIFICATION
BUTYL
ACRYLATE
0.1
LIGHT
ENDS
FROM
BUTYL
METHACRYLATE/
ISO­
BUTYL
METHACRYLATE
PR
1.9
IMMERSION
SOLVENT
USED
IN
SAFETY
KLEEN
PARTS
WASHERS
3.0
PAINT/
THINNER
MIXTURES.
GENERATED
FROM
PAINTING
AND
MAINTEN
865.5
81R
RESIDUE.
MANUFACTURING
WASTE
FROM
THE
PRODUCTION
OF
81R
49.0
METHYL
METHACRYLATE,
OFF
SPEC
PRODUCT.

455.5
B­
3
LIGHT
ENDS.
MANUFACTURING
BYPRODUCT
OF
MMA
AND
MAA
PROD
11.7
OFF
SPEC
METHACRYLIC
ACID
PRODUCT
17.1
METHYL
METHACRYLATE
TANK
WASHINGS
AND
DISCHARGES.
FROM
CRUD
0.0
SAFETY
KLEEN
SOLVENT,
USED
IN
DEGREASING
OPERATIONS
AND
PART
226.0
BMA
BLEED
STRIPPER
BOTTOMS.
MANUFACTURING
WASTE
FROM
THE
PR
23.3
ACETIC
ACID,
COPRODUCT
OF
ACRYLIC
ACID
PRODUCTION.
DISCARDE
WVD005005483
1,823.8
385.3
IGNITABLE
MATERIAL
FROM
UNIT
PRODUCTION
(
PVA/
IPA
STREAM)

0.2
DISCARDED
RAW
MATERIAL
CYCLOHEXANONE.

440.6
IGNITABLE
RESIDUES
CONTAINING
CHROMIUM
FROM
UNIT
PRODUCTION
(
CBM
RESIDUES).

1.8
MISCELLANEOUS
IGNITABLE
ORGANIC
MATERIALS
FROM
PLANT
LABORAT
ORY.
Organic
Liquids
Generating
Facilities
Reviewed
for
Potential
to
be
Solvent
Recovery
Residuals
X­
15
6.2
PAINT
WASTE
CONTAINING
VARIOUS
SOLVENTS.

368.9
IGNITABLE
MATERIAL
FROM
PRODUCTION
(
PVA
RESIDUES).

2.1
MISCELLANEOUS
IGNITABLE
OUT­
OF­
DATE
PRODUCTS.

49.1
IGNITABLE
RESIDUES
FROM
PRODUCTION
OF
DIENE
299
CONTAINING
A
LCOHOLS.

414.1
IGNITABLE
RESIDUES
CONTAINING
BENZENE
FROM
UNIT
PRODUCTION
(
MVA
RESIDUES).

18.4
IGNITABLE
MATERIAL
FROM
UNIT
PRODUCTION
(
PVA
LA­
1
WASTE).

42.6
IGNITABLE
RESIDUES
CONTAINING
BENZENE
AND
METHYL
ETHYL
KETO
NE
FROM
UNIT
PRODUCTION
(
ACETONE
RECOVERY).

55.0
FLAMMABLE
WASTE
FROM
OVERHEAD
STRIP;
MIXTURE
CONTAINS
ISOPRO
PANOL
AND
VINYL
ETHYL
ETHER.

39.6
IGNITABLE
RESIDUES
CONTAINING
BENZENE
AND
METHYL
ETHYL
KETON
E
FROM
UNIT
PRODUCTION
(
MVA
RESIDUES).
