August
22,
2000
­
DRAFT
Page
1­
1
1.
Introduction
and
Summary
EPA's
Office
of
Solid
Waste
is
proposing
a
rule
affecting
solvent
contaminated
wipes,
rags,
and
shop
towels,
collectively
defined
as
industrial
wipers
(
new
proposed
Subpart
E
at
40
CFR
261.50
et.
seq.).
The
regulation
would
codify
current
state
policies
regarding
reusable
shop
towels
and
would
provide
generators
who
properly
manage
disposables
(
wipes
and
rags)
with
an
exemption
from
RCRA
Subtitle
C
provided
that
they
manage
rags
and
wipes
in
accordance
with
certain
criteria.
This
report
analyzes
the
economic
impact
that
this
regulatory
change
would
have
on
all
entities
involved.
The
investigation
focuses
on
businesses
that
use
wipes,
rags,
and
towels
with
solvents
that
are
hazardous
wastes
when
spent,
and
the
industrial
laundries
that
wash
solvent
contaminated
shop
towels.

The
report
is
divided
into
two
main
sections,
the
first
addresses
disposable
wipes
and
rags,
and
the
second
addresses
reusable
towels.
In
both
sections
the
approach
is
similar:
first
we
describe
the
current
regulatory
environment
and
current
practices
at
facilities
handling
the
wipers
(
i.
e.,
the
baseline);
second,
we
estimate
the
number
of
wipers
used
and
the
number
of
generators;
third,
we
assess
the
regulatory
status
of
these
generators
(
large
quantity,
small
quantity,
or
conditionally
exempt);
fourth
we
examine
the
regulatory
options;
and
finally
we
estimate
the
economic
impacts
of
each
option
relative
to
the
baseline.

The
report
continues
with
a
summary
chapter
combining
the
costs
and
savings
estimates
for
disposables
and
reusables
to
measure
the
aggregate
impact
of
the
proposal.
The
proposal
would
result
in
net
savings
of
between
$
9
million
and
$
61
million
per
year.
Generators
of
both
disposables
and
reusable
wipers
incur
modest
incremental
compliance
costs,
but
disposal
savings
for
generators
of
disposable
wipes
and
rags
more
than
offset
these
incremental
costs.
Even
if
we
focus
on
those
generators
facing
the
highest
costs,
no
generator
facility
would
bear
an
incremental
cost
greater
than
$
100
per
year.
Therefore
the
proposal
would
not
impose
a
significant
economic
impact
on
any
generators,
small
business
or
otherwise.

The
proposal
also
provides
industrial
laundries
with
significant
relief
from
existing
federal
RCRA
regulations.
This
relief
enables
the
laundries
to
continue
to
benefit
from
the
savings
they
currently
enjoy
as
a
result
of
state
policies
that
exempt
them
from
full
RCRA
regulation.
August
22,
2000
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2.
Disposable
Wipes
and
Rags
2.1
Current
Regulations
and
Practices
Our
analysis
of
economic
impacts
resulting
from
the
proposed
rule
began
with
a
review
of
the
existing
regulatory
situation
for
disposable
wipers.
However,
the
absence
of
a
clear
federal
regulatory
program
governing
the
management
of
solvent
contaminated
wipers
made
it
difficult
to
identify
an
obvious
baseline
from
which
we
should
measure
the
potential
impacts
of
regulatory
changes.

Regulatory
jurisdiction
over
solvent
contaminated
wipes
and
rags
depends
on
the
solvents
used.
Wipes
and
rags
contaminated
with
solvents
that
when
spent
are
listed
hazardous
wastes
(
i.
e.,
hazardous
waste
codes
F001­
F005)
are
also
considered
to
be
listed
hazardous
wastes
and
must
be
managed
in
accordance
with
all
applicable
hazardous
waste
management
requirements
(
e.
g.,
storage
standards,
recordkeeping,
a
hazardous
waste
manifest
for
shipments).
Wipes
and
rags
contaminated
with
spent
solvents,
where
the
solvents
are
hazardous
wastes
because
they
exhibit
one
or
more
of
the
characteristics
of
hazardous
waste,
are
hazardous
wastes
if
the
resultant
mixture
(
the
solvent
contaminated
wipe
or
rag)
exhibits
one
or
more
of
the
characteristics
of
hazardous
waste
(
e.
g.,
is
ignitable).
Again,
characteristically
hazardous
wipers
must
be
managed
in
accordance
with
all
applicable
RCRA
hazardous
waste
management
standards.
An
entity
that
stores,
treats,
recycles,
and/
or
disposes
of
solvent
contaminated
wipers
is
subject
to
the
RCRA
permitting
requirements
of
40
CFR
Part
270,
absent
any
state
regulatory
provision
providing
a
regulatory
exemption
for
these
activities.

A
review
of
state
and
federal
RCRA
compliance
requirements
for
regulated
entities
(
i.
e.,
small
quantity
generators
or
SQGs
and
large
quantity
generators
or
LQGs)
helped
establish
the
baseline
from
which
we
measured
the
incremental
costs
and
savings
associated
with
the
proposal.
Regulated
generators
who
generate
and
dispose
of
hazardous
waste
wipes
and
rags
must:


Store
hazardous
waste
(
including
wipes
and
rags)
in
containers
that
comply
with
RCRA
Subtitle
C
storage
requirements
(
40
CFR
265,
Subpart
I)


Complete
a
hazardous
waste
manifest
for
off­
site
shipments
of
hazardous
waste

Use
licensed
hazardous
waste
transporters
to
pick
up
hazardous
waste
shipments
and
ensure
that
the
waste
is
managed
at
a
permitted
treatment,
storage,
and
disposal
facility
(
TSD).

No
provisions
of
the
proposed
rule
affecting
disposable
wipes
and
rags
are
more
stringent
than
those
required
under
RCRA
Subtitle
C.
While
some
individual
management
requirements
described
below
may
impose
costs
on
generators,
the
total
costs
are
less
than
are
incurred
in
the
current
regulatory
regime.
Therefore,
the
proposal
would
result
in
net
savings
to
generators.
1
To
protect
the
CBI,
we
have
omitted
discussion
of
certain
intermediate
steps
in
the
calculations.

August
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2000
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Before
estimating
these
savings,
however,
Section
2.2
describes
the
universe
of
generators
affected
by
the
proposed
rule.

2.2
Characterizing
the
Universe
of
Disposable
Wipes
and
Rags
Our
general
approach
was
to
use
aggregate,
national
information
about
the
sales
and
uses
of
disposable
wipes
and
rags
and
combine
it
with
usage
information
provided
by
individual
industries
and
from
site
visits.
The
resulting
characterization
of
the
regulated
universe
is
less
precise
than
if
we
had
developed
data
on
each
generator
industry
from
surveys
or
other
studies,
but
collecting
this
detailed
information
would
have
been
much
more
burdensome
and
resource
intensive.

The
analysis
depends
on
several
pieces
of
information
about
disposable
wipes
and
rags.
The
first
is
the
number
of
wipes
and
rags
used
each
year
in
conjunction
with
solvents.
Other
parameters
are
also
important
such
as
the
weight
of
the
wipes
and
rags,
the
amount
of
solvent
on
the
wipe
or
rag
as
it
is
disposed,
the
regulatory
status
of
the
spent
solvents
(
hazardous
or
not),
and
how
the
wipes
and
rags
are
stored
and
transported.
This
information
was
compiled
from
a
number
of
different
sources,
ranging
from
confidential
industry
data
to
our
own
professional
judgement.

2.2.1
Approach
EPA
requested
information
on
the
use
of
disposable
wipes
from
the
Association
of
the
Nonwoven
Fabric
Industry
(
INDA).
INDA
compiled
a
confidential
survey
and
distributed
it
to
its
members.
The
results
were
provided
to
EPA
as
confidential
business
information
(
CBI)
and
will
not
be
disclosed.
We
were
able,
however,
to
use
these
estimates
as
a
starting
point
for
our
analysis
and
still
protect
the
confidentiality
of
the
data.
1
The
INDA
data
provided
estimates
of
the
number
of
disposable
wipes
sold
by
INDA
members
to
industries
where
solvent
use
is
prevalent.
This
assessment
was
made
by
INDA
and
the
data
were
reported
separately
for
the
printing,
automotive,
and
general
manufacturing
sectors.
According
to
INDA,
its
members
account
for
approximately
95
percent
of
the
market
for
these
nonwoven
disposable
wipes,
so
we
scaled
the
survey
results
accordingly.

The
second
adjustment
we
made
to
the
INDA
data
was
to
include
single
use
cloth
rags
in
the
total.
These
rags
are
manufactured
from
discarded
and
recycled
textiles.
Based
on
data
provided
by
the
Secondary
Materials
and
Recycled
Textiles
Association
(
SMART),
we
increased
the
estimate
of
total
disposables
to
include
the
share
of
the
market
attributed
to
cloth
rags.
2
Ralph
Solarski,
Kimberly­
Clark
Corporation,
letter
to
Jim
O'Leary,
EPA,
December
15,
1997.

August
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2000
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DRAFT
Page
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Our
estimate
of
disposable
wipes
and
rags
potentially
used
with
solvents
is
still
too
large
for
our
purposes
because
it
assumes
that
all
wipe
and
rag
uses
in
these
industries
are
associated
with
solvents
and
that
members
of
the
"
solvent­
using
industries"
use
RCRA­
regulated
solvents.
Our
third
and
fourth
tasks,
therefore,
adjusted
the
total
for
these
factors.

The
third
step
was
to
determine
the
fraction
of
wiper
uses
associated
with
solvents,
as
opposed
to
other
materials.
Kimberly­
Clark
Corporation,
a
major
manufacturer
of
wipes,
provided
EPA
with
estimates
of
the
percentage
of
uses
associated
with
solvents
in
the
printing
industry
and
in
all
other
sectors.
2
We
applied
these
percentages
to
the
data
and
derived
an
estimate
of
the
number
of
disposable
wipes
and
rags
used
each
year
in
conjunction
with
solvents.

Finally,
we
investigated
the
types
of
solvents
used
by
generators
of
disposable
wipes
and
rags.
Some
common
solvents,
such
as
mineral
spirits
with
high
flash
points,
are
not
RCRA­
regulated
because
they
are
not
listed
as
hazardous
wastes
and
do
not
exhibit
a
hazardous
waste
characteristic.
In
addition,
some
wipes
and
rags
contaminated
with
solvents
that
are
hazardous
because
they
exhibit
one
or
more
characteristics
of
hazardous
waste
may
no
longer
exhibit
those
characteristics
after
use.
Also,
it
is
possible
that
wipes
and
rags
contaminated
with
characteristic
solvents
are
not
tested
after
use
but
are
presumed
by
the
generator
to
be
nonhazardous.
All
of
these
scenarios
reduce
the
number
of
solvent
contaminated
wipes
and
rags
that
are
ultimately
managed
as
hazardous
waste.

Unfortunately,
data
on
the
types
of
solvents
used
in
these
industries
are
scarce
and
highly
variable.
For
this
analysis,
we
applied
information
obtained
by
EPA
about
the
use
of
solvents
in
the
printing
industry
which
identified
10
percent
of
solvents
used
in
the
industry
as
nonhazardous,
80
percent
as
characteristic
hazardous
when
spent,
and
10
percent
as
listed
hazardous
wastes.
We
applied
our
judgement
to
assess
the
ultimate
regulatory
status
of
the
large
portion
of
spent
rags
and
wipes
that
are
contaminated
with
solvents
that
are
characteristic
waste
and
assumed
that
half
of
the
wipes
and
rags
used
in
conjunction
with
characteristic
solvents
ultimately
would
not
be
managed
as
hazardous
waste,
either
because
the
solvent
contaminated
wipes
and
rags
no
longer
exhibit
a
characteristic,
or
because
the
generator
does
not
test
the
mixture
after
use
and
assumes
the
materials
are
nonhazardous.

Our
final
adjustment
to
the
data,
therefore,
was
that
50
percent
of
disposable
wipes
and
rags
used
in
conjunction
with
solvents
(
10
percent
which
are
listed
hazardous
wastes
plus
half
of
the
80
percent
that
exhibit
a
hazardous
waste
characteristic)
are
ultimately
managed
as
hazardous
waste,
if
they
are
generated
in
sufficient
quantity
or
by
an
entity
that
otherwise
is
a
regulated
generator
of
hazardous
waste.
(
We
address
the
regulatory
status
of
the
facilities
in
Section
2.3
below.)

We
should
also
note
that
many
individuals
we
spoke
with
about
this
issue
told
us
that
generators,
especially
larger
ones,
avoid
using
disposable
wipes
and
rags
with
hazardous
waste.
Knowing
that
hazardous
waste
disposal
adds
significantly
to
the
effective
cost
of
using
disposables,
many
August
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2000
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DRAFT
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4
firms
opt
for
reusable
towels
instead
for
applications
involving
solvents
that
are
hazardous
wastes
when
spent.
It
may
be
that
the
overall
use
of
disposables
with
solvents
that
are
hazardous
wastes
are
less
than
we
have
estimated.

2.2.2
Results
We
estimate
that
166
million
disposable
wipes
and
rags
are
used
in
conjunction
with
RCRAregulated
solvents
each
year.
Related
findings
from
this
research
are:


Solvent
contaminated
wipes
and
rags
are
typically
stored
and
transported
in
55­
gallon
containers.


Using
the
weight
and
dimensions
of
commonly­
used
wipes
and
rags,
we
estimate
that
3,700
wipes
and
rags
will
fill
a
55­
gallon
container.


The
weight
of
disposables
and
solvents
in
a
filled
container
is
approximately
200
pounds.
The
weight
of
the
waste
in
the
container
is
roughly
evenly
split
between
the
wipes
and
rags
and
the
solvent.

2.3
Characterizing
the
Generator
Universe
Wipes
and
rags
used
at
facilities
that
are
exempt
from
RCRA
regulation
(
conditionally­
exempt
SQGs
or
CESQGs)
would
be
unaffected
by
the
proposal.
Further,
the
potential
savings
for
SQGs
and
LQGs
associated
with
the
proposed
regulatory
changes
would
differ
because
of
different
baseline
regulatory
requirements
and
different
quantities
of
wipes
and
rags
used.
The
purpose
of
this
step
of
the
analysis
was
to
estimate
the
fraction
of
disposables
used
by
each
category
of
generators
(
i.
e.,
CESQGs,
SQGs,
LQGs).
We
also
estimated
typical
quantities
of
wipes
and
rags
used
by
each
type
of
generator.

The
information
compiled
by
INDA
and
described
earlier
provides
a
general
indication
of
the
level
of
disposables
used
with
solvents
for
several
broad
industry
groups.
It
does
not
provide
any
indication
of
the
RCRA
regulatory
status
of
facilities
within
those
industries.
We
examined
various
sources
such
as
the
biennial
reporting
system,
RCRIS,
and
generator
surveys
and
were
unable
to
find
any
existing
information
that
would
directly
answer
this
question.
Instead,
we
relied
on
indirect
analysis
using
data
compiled
from
the
generator
industries
and
from
EPA
databases.
3
"
Demographics
of
Solvent
Contaminated
Wipes/
Shop
Towel
Users,"
prepared
by
Jim
O'Leary,
EPA/
OSW,
June
20,
1999.

4
"
Revised
Facility
Estimates
for
Towel/
Wipe
Analysis,"
prepared
for
Mary
Wolfe,
SAIC
and
Jim
O'Leary,
EPA
by
Kevin
Dietly,
Northbridge
Environmental,
April
11,
2000.

August
22,
2000
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DRAFT
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5
2.3.1
Facilities
Using
Disposables
With
Solvents
EPA
has
collected
facility
data
from
site
visits
and
meetings
with
stakeholders
over
several
years.
By
supplementing
these
data
with
information
from
the
Office
of
Enforcement
and
from
RCRIS,
EPA
was
able
to
identify
the
industries
where
these
wipes
are
used
and
describe
general
characteristics
of
wiper
usage.
3
Northbridge
integrated
EPA's
analysis
into
the
data
already
compiled
on
the
universe
of
disposables
to
develop
the
information
summarized
below.
4
Based
on
the
industries
where
cloths
and
wipes
are
used,
EPA
used
Census
data
to
estimate
the
number
of
facilities
in
each
industry
group
(
by
SIC
code).
Within
each
group,
the
number
of
LQGs
was
derived
from
the
1995
Biennial
Reporting
System.
The
remaining
establishments
were
apportioned
between
SQG
and
CESQG
status
based
on
employment:
those
with
fewer
than
20
employees
were
assumed
to
be
CESQGs
and
the
remainder
were
SQGs.

EPA
then
characterized
the
prevalence
of
disposables
and
reusables
by
industry
group.
From
these
assessments
we
were
able
to
calculate
the
number
of
facilities
by
industry
group
and
in
total
that
use
disposables
in
conjunction
with
RCRA­
regulated
solvents.
Exhibit
2­
1
shows
that
81,003
facilities
are
assumed
to
use
these
solvents
with
disposable
wipes
or
rags.
Only
1,337
or
1.7
percent
of
these
generators
are
LQGs,
12,090
(
14.9
percent)
are
SQGs,
and
the
remaining
67,576
are
assumed
to
be
CESQGs.
Therefore,
this
proposed
rule
will
have
no
impact
on
83
percent
of
the
facilities
where
disposables
are
used
in
conjunction
with
RCRA­
regulated
solvents.

2.3.2
Usage
per
Facility
INDA's
survey
provided
us
with
estimates
of
typical
wiper
usage
per
facility.
We
supplemented
this
with
anecdotal
information
compiled
by
EPA
from
its
site
visits
and
meetings
with
stakeholders.
We
also
considered
the
regulatory
status
of
the
facilities
and
the
allowable
accumulation
times
for
SQGs
and
LQGs
to
store
these
wipes
onsite.


SQGs
are
allowed
a
180­
day
accumulation
limit
for
hazardous
waste.
We
assumed
they
would
ship
containers
of
hazardous
wipes
and
rags
off­
site
twice
each
year
and
would
send
one
container
with
each
shipment.
The
wiper
use
associated
with
this
schedule
is
7,400
wipes
and
rags
per
year,
or
about
142
per
week.
This
level
of
use
is
consistent
with
INDA
data
for
generators
at
the
lower
end
of
the
usage
range.
August
22,
2000
­
DRAFT
Page
2­
6

LQGs
are
allowed
a
90­
day
accumulation
limit
(
before
having
to
obtain
a
RCRA
permit
for
the
storage
activities).
We
assumed
shipments
of
used
wipes
and
rags
four
times
per
year
and
two
containers
per
shipment.
This
implies
wiper
usage
of
29,600
per
year
or
569
per
week.
This
level
of
use
is
consistent
with
INDA
averages
for
industries
at
the
upper
end
of
the
usage
range.

From
our
estimates
of
the
number
of
LQGs
and
the
usage
per
LQG,
we
computed
the
total
disposables
generated
by
LQGs
at
nearly
40
million
or
about
one­
quarter
of
all
disposables
used
in
conjunction
with
RCRA­
regulated
solvents
(
Exhibit
2­
1).
Similarly,
the
disposables
generated
by
SQGs
total
about
90
million
per
year,
leaving
36
million
for
the
CESQGs.
Therefore,
78
percent
of
all
disposables
used
in
conjunction
with
RCRA­
regulated
solvents
would
be
affected
by
this
proposed
rule.
In
short,
our
analysis
suggests
that
17
percent
of
facilities
generate
78
percent
of
the
solvent
contaminated
disposable
rags
and
wipes.

Exhibit
2­
1
Disposable
Wiper
Generation
and
Regulated
Facility
Assumptions
LQGs
SQGs
CESQGs
Totals
Generators
of
Hazardous
Wipes
and
Rags
(%
of
Total)
1,337
(
1.7%)
12,090
(
14.9%)
67,576
(
83.4%)
81,003
(
100%)

Solvent
Contaminated
Wipes
and
Rags
Generated
Annually
(%
of
Total)
39.6
million
(
24%)
89.5
million
(
54%)
36.5
million
(
22%)
165.6
million
(
100%)

Weekly
Generation
per
Facility
569
142
10
2.3.3
Potential
Shifts
in
RCRA
Regulatory
Status
A
final
issue
related
to
the
generator
universe
is
whether
some
generators
might
be
able
to
avoid
Subtitle
C
regulation
entirely
if
their
wipes
and
rags
were
declared
exempt
from
RCRA
hazardous
waste
regulation.
Given
the
relatively
small
quantity
of
wipes
and
rags
relative
to
total
hazardous
waste
generation,
we
assumed
it
would
be
very
unlikely
for
a
large
quantity
generator
to
become
a
small
quantity
generator
based
on
deregulation
of
disposable
wipes
and
rags.
The
switch
is
somewhat
more
plausible
for
small
quantity
generators
becoming
CESQGs
as
a
result
of
the
exemption,
but
we
believe
it
would
affect
only
a
small
fraction
of
SQGs.
August
22,
2000
­
DRAFT
Page
2­
7
We
analyzed
this
issue
by
comparing
the
typical
quantity
of
solvent
contaminated
wipes
and
rags
at
SQGs
to
other
wastes
generated.
Given
our
assumption
of
two
waste
containers
of
wipes
and
rags
per
year,
the
solvent
and
wiper
waste
generated
by
a
typical
SQG
would
equal
roughly
400
pounds
of
hazardous
waste
per
year
or
33
pounds
per
month.
SQGs
can
generate
between
220
pounds
(
100
kg)
and
2,200
pounds
(
1,000
kg)
of
hazardous
waste
per
month
and
remain
regulated
as
SQGs,
so
a
reduction
of
33
pounds
would
exempt
from
SQG
status
only
those
generators
who
generated
between
220
pounds
and
253
pounds.
Intuitively,
we
expect
that
generators
that
close
to
the
regulated
limit
would
take
measures
to
stay
below
the
220
pound
threshold.
Therefore,
we
believe
relatively
few
generators
would
shift
out
of
the
SQG
category
as
a
result
of
a
regulatory
exemption
for
wipes
and
rags.

To
estimate
the
percentage
of
the
SQG
universe
that
might
become
conditionally
exempt
from
RCRA
regulation
under
the
proposed
rule,
we
assumed
that
SQGs
are
distributed
uniformly
across
the
waste
generation
range
of
220
pounds
to
2,200
pounds
per
month.
A
reduction
of
33
pounds
for
SQGs
with
disposable
wipes
and
rags
would
shift
less
than
2
percent
of
the
generators
to
CESQG
status
(
33
pound
reduction
divided
by
the
1,980
pound
range
for
all
SQGs
(
2,200
pounds
­
220
pounds).
We
estimated
that
roughly
1.7
percent
of
SQGs
might
be
able
to
avoid
SQG
status
(
i.
e.,
become
CESQGs),
which
equals
about
200
facilities.

2.4
Overview
of
the
Proposed
Rule
EPA
is
proposing
to
amend
its
hazardous
waste
management
regulations
under
RCRA
to
provide
a
conditional
exemption
from
the
definition
of
hazardous
waste
for
certain
industrial
wipers.
The
Agency
is
proposing
to
provide
an
exemption
for
these
materials
on
two
basic
conditions:
(
1)
generators
accumulate,
store,
and
transport
solvent
contaminated
shop
towels,
rags
and
wipes
in
covered
containers;
and
(
2)
generators
ensure
that
no
liquid
drips
from
the
wipers
when
they
are
hand­
wrung
and
that
any
released
solvent
is
contained.
Wipers
sent
offsite
must
be
labeled
"
Solvent
Contaminated
Wipers"
and
must
be
packaged
either
in
containers
that
comply
with
existing
DOT
requirements
(
49
CFR
171­
180)
or
that
will
contain
the
solvents.
Wipers
that
meet
these
requirements
may
be
disposed
of
in
a
non­
hazardous
waste
management
facility
except
a
landfill.

Recipients
of
these
non­
landfilled
wipers
must
store
the
wipers
in
a
closed
container
until
they
are
disposed
of.
If
any
liquid
solvent
arrives
with
the
wipers,
the
recipient
must
return
the
shipment
to
the
generator
or
recover
and
properly
manage
the
liquid
solvent.

In
order
to
be
disposed
in
a
landfill,
the
wipers
must
be
"
dry,"
(
i.
e.,
contain
less
than
five
grams
of
solvent
on
average).
Dry
wipers
may
result
from
removing
excess
solvent
from
the
wipers
using
mechanical
extraction
equipment
such
as
a
wringer
or
centrifuge,
or
from
low
use
rates
of
solvent
on
the
wiper
initially.
In
any
event,
these
wipers
may
be
disposed
in
a
Subtitle
D
landfill
including
municipal
landfills.
Dry
wipers
are
also
exempt
from
any
generator,
transport,
or
handling
conditions
once
they
are
dry.
5
Generators
of
solvent
contaminated
wipes
and
rags
will
retain
the
option
of
managing
their
disposables
in
full
compliance
with
Subtitle
C
management
requirements
in
lieu
of
in
compliance
with
the
proposed
exemption.

August
22,
2000
­
DRAFT
Page
2­
8
The
proposal
contains
two
additional
restrictions
on
disposal
for
wipers
used
with
certain
F­
listed
solvents.
Wipers
used
in
conjunction
with
the
following
solvents
may
not
be
disposed
of
in
a
landfill,
regardless
of
how
they
are
managed:
2­
nitropropane,
nitrobenzene,
methyl
ethyl
ketone
(
MEK),
methyl
isobutyl
ketone
(
MIK),
methylene
chloride,
pyridine,
benzene,
cresol
(
o,
m,
p),
carbon
tetrachloride,
chlorobenzene,
1,1,2­
trichloroethane,
tetrachloroethylene,
and
trichloroethylene.
These
wipers
may
be
disposed
of
in
a
municipal
waste
combustor
or
other
nonhazardous
non­
landfill
facility.
Wipers
used
in
conjunction
with
2­
nitropropane
are
not
eligible
for
the
exemption
in
any
case;
they
remain
as
hazardous
waste.

2.5
Unit
Costs/
Savings
for
Generators
EPA's
proposed
rule
offers
generators
significant
savings
over
the
current
regulations
because
many
wipes
and
rags
would
be
exempt
from
Subtitle
C
regulation.
Savings
result
from
avoided
manifesting
requirements
and
lower
costs
associated
with
non­
hazardous
disposal
alternatives.
Some
offsetting
costs
are
incurred
to
comply
with
the
conditions
for
the
exemption,
but
because
the
costs
are
modest
compared
to
the
potential
savings,
we
assumed
generators
would
take
advantage
of
the
proposed
exemption.
5
Incremental
costs
that
may
be
incurred
to
comply
with
the
conditions
include
labeling
of
containers
and
management
of
the
solvent
wrung
out
of
wipes
and
rags.
Even
in
cases
where
a
generator
uses
a
disposable
wipe
in
conjunction
with
one
of
the
F­
listed
solvents,
the
generator
would
be
no
worse
off
than
he
is
under
the
current
regulatory
regime.

It
is
important
to
note
the
prerequisites
for
the
conditional
exemption.
First,
wipes
and
rags
must
be
dry
enough
that
no
liquid
drips
from
them
when
hand
wrung.
Second,
the
wipes
and
rags
must
be
stored
and
transported
in
covered
containers.
Note
that
because
these
generators
must
already
comply
with
RCRA
storage
and
transportation
requirements,
we
assumed
that
meeting
the
latter
condition
would
impose
no
new
costs
on
generators
(
i.
e.,
the
condition
is
less
restrictive
than
current
practice).

2.5.1
Components
of
the
Proposal
2.5.1.1
No
Liquid
Drips
from
the
Wipers
Compliance
with
this
standard
is
assumed
to
be
through
hand
wringing
of
disposables
at
the
point
of
use.
Costs
associated
with
hand
wringing
were
assumed
to
be
negligible
because
the
time
required
would
be
very
small
(
only
one
or
two
seconds)
and
the
closed
receptacles
for
storing
the
wastes
are
already
available
at
the
facility.
6
Pricing
information
compiled
by
DPRA
and
provided
in
a
personal
communication
with
Patricia
Overmeyer,
SAIC
March
20,
1998.

7
Backup
for
these
and
other
cost
estimates
are
found
in
the
Appendix.

8
"
Use
and
Management
Practices
of
Solvent
Contaminated
Shop
Towels
and
Wipes,"
Interim
Report,
December
27,
1997.

9
Based
on
the
price
for
6"
X
6"
pre­
printed,
vinyl,
adhesive
labels,
Lab
Safety
Supply,
August
1998.

10
"
Supporting
Statement
for
Information
Collection
Request
Number
801,
`
Requirements
for
Generators,
Transporters,
and
Waste
Management
Facilities
Under
the
RCRA
Hazardous
Waste
Management
System,'"
pp.
7,
21,
and
24,
July
31,
1996.

August
22,
2000
­
DRAFT
Page
2­
9
Once
solvents
are
wrung
out
of
the
wipes
and
rags,
the
liquids
must
be
managed
according
to
RCRA
regulation.
This
would
represent
an
incremental
cost
because
solvents
are
currently
managed
with
the
wipes
and
rags.
We
assumed
that
all
generators
would
send
their
solvents
to
a
fuel
blender,
which
is
a
relatively
inexpensive
and
common
management
technique,
especially
for
larger
volumes
of
solvent.
This
costs
about
11
¢
per
pound
of
solvent.
6
7
This
estimate
would
overstate
costs
for
a
facility
that
had
a
reuse
or
tolling
program
in
place
for
solvents,
which
would
be
more
typical
of
smaller
facilities.
To
determine
the
amount
of
solvent
each
facility
would
have
to
manage,
we
multiplied
the
amount
of
solvent
extracted
from
each
wipe
or
rag
by
the
number
of
wipes
and
rags
each
facility
uses.
The
removal
efficiency
of
hand
wringing
was
determined
based
on
site
visits
and
research
conducted
by
EPA
and
SAIC
staff.
8
2.5.1.2
Covered
Containers
While
the
covered
container
requirement
itself
imposes
no
new
cost
on
SQGs
and
LQGs,
the
proposal
requires
a
uniform
label
to
be
placed
on
containers
of
exempt
wipers
and
rags
sent
offsite.
Because
the
wording
is
included
in
the
regulation,
generators
would
be
required
to
purchase
appropriately
worded
labels
and
apply
them
to
containers.
The
cost
of
the
labels
is
about
$
0.33
each.
9
Rather
than
developing
an
uncertain
estimate
for
the
fraction
of
wipers
managed
on
and
offsite,
we
simply
assumed
that
all
containers
would
be
labeled.

2.5.1.3
Waste
Management
Savings
Generators
meeting
the
conditions
for
the
exemption
would
save
on
the
shipment
and
management
costs
for
their
wipes
and
rags.
First,
shipments
of
wipes
and
rags
would
no
longer
require
manifest
preparation
and
retention
of
records.
Manifests
must
accompany
every
hazardous
waste
shipment,
so
these
costs
were
determined
on
a
per
shipment
basis,
and
then
multiplied
by
the
number
of
shipments
sent
by
each
LQG
or
SQG.
The
savings
per
shipment
is
$
16.93
for
LQGs
and
$
16.22
for
SQGs.
10
11
"
Environmental
Fact
Sheet:
Municipal
Solid
Waste
Generation,
Recycling
and
Disposal
in
the
United
States:
Fact
and
Figures
for
1998,"
prepared
by
Franklin
Associates
for
EPA
Office
of
Solid
Waste,
April
2000.

12
Northbridge
conducted
a
survey
of
New
England
waste
management
companies
to
estimate
pickup,
transportation,
and
disposal
cost
under
the
baseline
and
regulatory
options.
A
summary
of
our
findings
is
included
in
the
Appendix.

August
22,
2000
­
DRAFT
Page
2­
10
If
containers
of
solvent
contaminated
wipes
and
rags
are
no
longer
required
to
be
managed
as
hazardous
waste,
generators
will
also
save
on
transportation
and
disposal
charges
levied
by
offsite
waste
managers.
The
proposal
permits
disposal
in
municipal
waste
combustors
and,
if
dry,
municipal
waste
landfills.
These
are
the
least
expensive
options
available
for
generators
and
haulers.
We
did
not
have
information
on
the
fraction
of
disposables
generated
in
areas
with
municipal
waste
combustion,
so
we
simply
assumed
that
it
would
follow
the
distribution
of
all
municipal
wastes.
EPA
estimates
that
23
percent
of
all
municipal
waste
disposed
goes
to
combustors,
with
the
remaining
77
percent
going
to
landfills.
11
We
assumed
that
23
percent
of
exempt
wipes
and
rags
would
be
shipped
to
municipal
waste
combustors
at
a
savings
of
nearly
$
400
per
drum
of
waste
shipped.
12
The
remaining
77
percent
of
the
exempt
wipes
and
rags
could
be
shipped
to
a
municipal
landfill
(
if
they
are
"
dry"
as
defined
in
the
proposal)
at
a
savings
of
about
$
400
per
drum
(
see
the
Appendix).
Alternatively,
these
wipers
could
be
handled
as
nonhazardous
waste
at
a
permitted
facility
such
as
a
fuel
blender,
incinerator,
or
industrial
furnace.
This
latter
option
would
be
more
costly
than
landfilling,
but
substantially
cheaper
than
management
as
a
hazardous
waste.
Based
on
the
survey
data
described
in
the
Appendix,
the
expected
savings
would
be
about
$
230
per
drum
of
waste.
This
range
in
disposal
cost
savings
is
reflected
in
our
results
 
both
on
a
per­
facility
basis
and
for
the
national
totals.

Note
that
generators
using
disposable
wipes
with
the
F­
listed
solvents
identified
in
the
proposal
would
not
be
able
to
use
the
landfill
option,
but
could
still
save
on
their
disposal
costs
by
using
municipal
waste
combustors
or
managing
the
wipers
as
non­
hazardous
wastes.

Finally,
generators
that
choose
to
manage
exempt
wipes
in
permitted
facilities
as
nonhazardous
wastes
might
be
able
to
increase
their
savings
by
rendering
their
wipes
"
dry"
and
disposing
of
them
in
a
municipal
landfill.
The
most
likely
way
to
achieve
the
five­
gram
standard
is
to
centrifuge
the
wipers.
We
analyzed
the
cost
of
centrifuging
and
found
that
SQGs
and
LQGs
could,
in
fact,
save
additional
waste
management
costs
by
paying
to
have
their
wipers
centrifuged
(
assuming
the
service
is
available
in
their
area).
This
option
is
discussed
further
in
the
results
section.

2.5.2
Impact
of
the
Exemption
on
Regulatory
Status
Generators
qualifying
for
the
exemption
would
not
have
to
include
the
weight
of
exempt
wipes
and
rags
when
calculating
their
monthly
waste
generation
quantity.
SQGs
who
would
become
August
22,
2000
­
DRAFT
Page
2­
11
CESQGs
as
a
result
of
the
exemption
would
realize
substantial
savings.
These
generators
would
not
only
save
manifesting
costs
($
16.22
per
shipment),
but
they
would
realize
additional
savings
associated
with
other
Subtitle
C
regulatory
requirements:


Recordkeeping
and
waste
analysis
($
6,958/
facility/
year)

°
Store,
file
and
maintain
records
of
any
test
results,
waste
analyses,
or
other
determinations
($
4.80/
facility/
year)
°
Conduct
waste
analysis,
document
and
maintain
information
($
6,455.47/
facility/
year)
°
Prepare
and
maintain
contingency
plan
($
497.52/
facility/
year)


Waste
pickup,
transportation,
and
disposal
($
400.46/
shipment)

The
total
savings
for
each
SQG
becoming
conditionally
exempt
would
equal
$
7,791
per
year
(
see
Appendix).

2.6
Results
2.6.1
Savings
per
Facility
Exhibit
2­
2
summarizes
the
savings
estimates
per
facility.
The
exhibit
aggregates
the
costs
and
savings
for
each
type
of
generator
and
each
component
of
the
proposal.
The
savings
are
significant,
especially
for
the
few
SQGs
that
would
change
regulatory
status
to
conditionally
exempt
SQGs
as
a
result
of
not
counting
solvent
contaminated
wipes
and
rags
in
their
hazardous
waste
total.

For
the
remaining
generators,
the
exemption
from
Subtitle
C
management
of
the
wipers
provides
a
significant
savings
minimally
offset
by
the
solvent
management
and
labeling
costs.
Net
savings
range
from
$
1,869
to
$
3,259
per
year
for
LQGs
and
$
475
to
$
817
per
year
for
SQGs.
As
noted
in
Section
2.5.1.3,
the
range
in
the
savings
estimates
results
from
the
different
options
generators
have
to
manage
the
exempt
wipers.
Those
with
access
to
municipal
waste
combustors
are
assumed
to
dispose
of
their
exempt
wipers
at
those
facilities.
For
other
generators,
those
with
"
dry"
wipes
would
save
the
most,
since
they
could
use
municipal
landfills
for
disposal;
their
savings
define
the
upper
bound
of
the
savings
estimates
shown.
The
facilities
with
smaller
savings
are
those
that
are
assumed
to
manage
the
wipers
as
nonhazardous
wastes
at
permitted
facilities.
13
Given
the
cost
of
centrifuging,
only
those
generators
without
access
to
municipal
waste
combustors
would
be
likely
to
centrifuge
their
wipers.
Those
that
could
send
their
wastes
to
combustors
without
centrifuging
would
already
capture
the
vast
majority
of
the
disposal
savings
and
would
not
have
to
incur
centrifuging
costs.

August
22,
2000
­
DRAFT
Page
2­
12
Exhibit
2­
2
Annual
Costs
and
(
Savings)
per
Generator
Regulatory
Element
LQGs
SQGs
No
Liquids
Hand
wringing
Solvent
management
Negligible
$
9.88
Negligible
$
2.47
Covered
Containers
Containers
Labeling
$
0.00
$
2.64
$
0.00
$
0.66
Waste
Management
Manifesting
Transport
and
disposal
($
67.72)
($
1,814
­
$
3,204)
($
32.44)
($
446
­
$
788)

Totals
($
1,869
­
$
3,259)
($
475
­
$
817)

Note:
SQGs
that
become
conditionally
exempt
save
($
7,791)
per
year.
Source:
see
Appendix
One
other
issue
we
examined
is
whether
generators
might
find
it
worthwhile
to
render
their
wipes
"
dry"
in
order
to
dispose
of
them
in
municipal
landfills.
The
most
likely
way
to
achieve
the
fivegram
standard
is
to
centrifuge
the
wipers.
The
economic
advantage
of
lower
disposal
costs
is
offset
by
the
cost
of
the
centrifuging
service
(
assuming
the
service
is
available).
Those
who
elect
to
manage
the
wipers
as
non­
hazardous
wastes
at
a
fuel
blender
or
other
permitted
facility
could
save
additional
money
by
centrifuging
the
wipers
and
landfilling
them.
13
Per­
facility
savings
would
increase
from
$
475
per
year
to
$
511
per
year
for
SQGs
and
from
$
1,869
per
year
to
$
2,311
for
LQGs.
These
savings
are
conditional
on
the
availability
of
centrifuging
service
and
are
not
reflected
in
Exhibit
2­
2
or
in
the
national
totals
reported
below.

2.6.2
Total
Savings
The
total
annual
savings
for
all
generators
range
from
$
11.1
million
to
$
15.6
million
as
shown
in
Exhibit
2­
3.
The
difference
between
these
two
estimates
is
due
to
uncertainty
over
how
many
of
the
generators
would
be
able
to
send
their
exempt
wipers
to
municipal
landfills
(
i.
e.,
how
many
of
August
22,
2000
­
DRAFT
Page
2­
13
the
wipers
used
in
conjunction
with
solvents
are
"
dry").
Based
on
EPA's
characterization
of
solvent
use
at
various
types
of
generators,
we
believe
that
more
than
80
percent
of
disposables
are
used
with
minimal
solvent
and
would
likely
meet
the
five­
gram
standard.
This
suggests
that
the
actual
savings
would
be
nearer
to
the
$
15.6
million
estimate.

Exhibit
2­
3
Total
(
Savings)
and
(
Savings)
per
Wiper
Low
Savings
Estimate
High
Savings
Estimate
Large
Quantity
Generators
($
2,920,000)
($
0.074)
($
4,350,000)
($
0.110)

Small
Quantity
Generators
($
6,570,000)
($
0.075)
($
9,700,000)
($
0.110)

SQGs
becoming
CESQGs*
($
1,560,000)
($
1,560,000)

Total*
($
11,050,000)
($
15,610,000)

Note:
Does
not
assume
any
shift
from
reusables
to
disposables.
*
Savings
per
wiper
not
calculated
Another
way
to
compute
the
savings
is
based
on
the
number
of
wipes
and
rags
used.
Exhibit
2­
3
shows
the
savings
per
disposable
wiper
used
for
SQGs
and
LQGs.
The
savings
per
wiper
provide
the
basis
for
analyzing
potential
market
impacts
of
the
proposal.
Given
the
base
price
of
a
disposable
wiper
and
the
cost
of
a
comparable
reusable
shop
towel,
we
can
at
least
evaluate
whether
the
projected
savings
for
disposables
would
be
large
enough
to
induce
some
users
of
reusable
shop
towels
to
switch
to
disposables.

2.6.3
Market
Impact
Users
pay
approximately
5
¢
to
8
¢
per
disposable
wiper
according
to
our
research.
The
price
of
course
varies
with
the
type
of
wiper
and
the
quantity
purchased.
For
example,
small
quantities
of
wipes
may
cost
as
much
as
10
¢
each.
A
rough
estimate
of
the
price
for
a
reusable
shop
towel
sent
to
a
laundry
is
12
¢
to
15
¢
per
use,
which
includes
leasing
the
towel
and
having
it
cleaned.
14Assumes
about
$
400
per
drum
to
dispose
as
a
hazardous
waste
and
3,700
wipes
and
rags
per
drum.

August
22,
2000
­
DRAFT
Page
2­
14
If
we
look
at
the
base
price
and
the
potential
savings
if
the
wipes
and
rags
could
be
disposed
of
in
a
landfill,
we
can
infer
that
the
effective
cost
of
using
a
disposable
wipe
or
rag
with
hazardous
waste
is
16
¢
to
19
¢
(
5
¢
to
8
¢
to
purchase
+
11
¢
to
dispose
as
a
hazardous
waste14),
which
would
make
it
somewhat
more
expensive
to
use
disposables
with
hazardous
waste
than
reusables.
This
is
consistent
with
the
anecdotal
information
we
collected
indicating
that
establishments
tend
to
avoid
using
disposables
with
hazardous
waste.
Presumably,
companies
that
do
use
disposables
with
hazardous
waste
do
so
because
the
disposables
offer
some
performance
advantages,
only
a
small
number
of
wipes
are
used
with
solvents,
or
they
are
unable
to
find
laundries
able
or
willing
to
handle
solvent
contaminated
towels.

From
this
perspective,
the
proposal
has
the
potential
to
cause
a
significant
shift
in
the
relative
price
of
disposables
and
reusables
used
in
conjunction
with
hazardous
solvents.
We
do
not
have
sufficient
information
to
estimate
the
impact
on
demand
for
the
two
competing
products,
but
this
limited
analysis
does
show
that
the
savings
would
be
sufficient
to
change
behavior.
If
the
savings
averaged
9
¢
per
wipe
or
rag
(
Exhibit
2­
3),
then
the
average
disposable
would
cost
7
¢
to
10
¢
to
purchase
and
dispose
of.
This
is
lower
than
the
cost
per
use
of
the
average
reusable
towel
(
assuming
one
to
one
equivalency
in
use).

In
the
end,
it
is
not
clear
whether
disposables
would
become
more
popular
for
use
with
solvents
as
a
result
of
the
proposal.
The
primary
consideration
for
most
generators
is
the
performance
of
the
wiper
on
the
job.
In
the
applications
where
heavy
solvent
use
is
common
(
such
as
printing),
reusables
are
often
the
wiper
of
choice.
We
do
not
believe
that
the
cost
impact
of
the
proposal
would
be
sufficient
to
change
this.
Given
the
wide
range
of
uses
to
which
generators
put
the
wipes,
it
is
possible
that
disposables
could
become
more
attractive
in
some
applications.
15
"
Treatment
means
any
method,
technique,
or
process,
including
neutralization,
designed
to
change
the
physical,
chemical,
or
biological
character
or
composition
of
any
hazardous
waste
so
as
to
neutralize
such
waste,
or
so
as
to
recover
energy
or
material
resources
from
the
waste,
or
so
as
to
render
such
waste
non­
hazardous,
or
less
hazardous;
safer
to
transport,
store,
or
dispose
of;
or
amendable
for
recovery,
amendable
for
storage,
or
reduced
volume."

August
22,
2000
­
DRAFT
Page
3­
1
3.
Shop
Towels
3.1
Current
Regulations
and
Practices
Current
federal
regulations
require
any
party
that
engages
in
the
"
treatment"
of
solvent
contaminated
shop
towels
that
are
hazardous
wastes
to
obtain
a
RCRA
permit
for
the
treatment
activity.
The
RCRA
definition
of
treatment
provided
in
40
CFR
260.10
includes
the
laundering
of
solvent
contaminated
shop
towels
to
remove
any
solvents
and/
or
other
contaminants
from
the
towels
to
render
them
usable.
15
Such
an
interpretation
of
the
federal
regulatory
program
would
result
in
an
assumption
that
all
industrial
laundries
currently
managing
solvent
contaminated
shop
towels
are
required
to
obtain
a
RCRA
permit
for
this
waste
management
activity.
These
laundries
would
incur
expenses
to
obtain
and
maintain
their
RCRA
permit
as
well
as
ongoing
costs
to
manage
sludges
produced
from
the
process
as
hazardous
wastes.

EPA's
policy
with
regard
to
the
regulatory
status
of
solvent
contaminated
shop
towels,
however,
has
been
to
defer
jurisdictional
decisions
to
state
agencies
and/
or
the
EPA
Regions.
The
majority
of
states
and
the
EPA
Regional
offices
have
established
policies
that
provide
an
exemption
from
regulation
as
a
hazardous
waste
for
reusable
shop
towels
that
are
managed
at
industrial
laundries
that
discharge
to
a
POTW.
Forty­
six
states
allow
industrial
laundries
with
NPDES
permits
to
launder
solvent
contaminated
shop
towels
without
a
RCRA
permit.
Many
impose
conditions
on
the
management
of
reusable
shop
towels
that
are
similar
to
the
provisions
in
the
current
rulemaking
being
proposed
by
EPA.
In
particular,
most
states
require
that
no
free
liquids
be
transported
offsite
with
the
shop
towels
from
the
generator
establishment.

3.1.1
Current
Practice
Baseline
We
have
identified
two
baselines
from
which
to
measure
the
economic
impact
of
the
proposed
rule.
The
first
baseline
(
current
practice)
is
defined
by
the
current
policies
and
regulatory
interpretations
established
by
most
state
programs
with
regard
to
reusable
shop
towels
contaminated
with
hazardous
waste
solvents.
Our
assumptions
about
current
management
practices
are
outlined
below:
16
EPA's
Slide
Presentation
on
Categorical
Standards
from
the
March
4,
1997
Industrial
Laundries
Public
Meeting.
The
data,
provided
on
UTSA's
web
site,
were
derived
from
Section
308
questionnaires.

17
[
Need
complete
citation]
EPA's
Information
Collection
Request
Number
XXX
for
permitted
and
interim
status
facilities;
the
average
is
the
total
annual
respondent
cost
(
Exhibit
8)
divided
by
total
facilities
(
Table
1).

August
22,
2000
­
DRAFT
Page
3­
2

Towels
must
not
contain
"
free
liquids"
before
being
sent
to
the
laundry
service.
This
condition
is
common
among
state
programs
and
is
considered
an
existing
practice.
Wringing
or
other
methods
used
to
remove
liquids
from
shop
towels
by
generators
and
washing
by
the
industrial
laundry
are
not
interpreted
as
treatment
of
hazardous
waste.


We
assume
that
most
towels
(
90
percent)
are
transported
in
bags,
although
some
(
10
percent)
currently
are
transported
in
drums.
This
assumption
is
based
on
EPA's
observation
at
site
visits
and
anecdotal
information.


Generators
and
industrial
laundries
do
not
differentiate
between
towels
contaminated
with
listed
solvents
and
those
contaminated
with
characteristic
solvents.
"
Heavily
soiled"
and
"
printer"
towels
are
managed
together,
regardless
of
the
type
of
solvent
used.

To
clarify
our
assumptions
about
current
practices,
we
should
note
that
although
federal
regulations
do
not
explicitly
include
the
exemption
currently
provided
for
solvent
contaminated
shop
towels
in
most
states,
the
exemption
is
widespread.
The
proposed
rule
has
the
principal
effect
of
codifying
this
state­
based
exemption
in
federal
regulation.
Therefore,
the
proposal's
impact
on
generators
and
industrial
laundries
will
be
limited
to
the
incremental
costs
required
to
meet
the
conditions
set
out
in
the
proposal
to
qualify
for
the
exemption.
These
conditions
are
described
in
Section
3.3
below.

3.1.2
Federal
Standards
Baseline
The
second
baseline
we
examined
is
defined
by
the
current
federal
requirements
for
industrial
laundries
managing
solvent
contaminated
shop
towels
that
are
hazardous
wastes.
Though
virtually
all
states
have
granted
exemptions,
the
facilities
would
still
be
subject
to
these
standards
in
the
absence
of
the
exemptions.
Without
the
exemptions,
the
laundries
would
incur
costs
to:


Obtain
and
maintain
a
Subtitle
C
permit
for
treatment
and,
possibly,
storage

Manage
sludge
from
the
laundering
process
as
hazardous
waste
For
this
analysis,
we
assumed
that
these
costs
would
be
incurred
at
least
by
the
480
laundries
managing
printer
towels
and
could
be
incurred
by
as
many
as
1,358
laundries
which
manage
printer
and/
or
shop
towels.
16
The
annual
cost
to
maintain
a
RCRA
Subtitle
C
permit
averages
more
than
$
17,300.17
The
average
annual
sludge
generation
from
the
1,358
laundries
that
manage
18
[
CBI
issue?]
E­
mail
from
John
Vierow,
SAIC
to
Jim
O'Leary,
EPA
on
August
16,
2000.
The
data
were
derived
from
the
Section
308
survey
in
1994.

19
Op.
cit.,
note
16.

August
22,
2000
­
DRAFT
Page
3­
3
printer
or
shop
towels
is
81
tons.
18
Based
on
consultation
with
EPA
we
have
assumed
that
appropriate
hazardous
waste
management
costs
for
these
sludges
would
be
about
$
200
per
ton
for
incineration.
The
annual
cost
of
hazardous
waste
management
for
these
sludges
is
therefore
$
16,200
per
facility.

The
total
annual
cost
of
regulation
under
Subtitle
C
is
estimated
at
$
33,500
per
laundry
or
a
national
total
of
between
$
16.1
million
and
$
45.5
million
depending
on
the
number
of
laundries
that
would
handle
solvent
contaminated
shop
towels
if
they
were
not
exempt
from
Subtitle
C
requirements.
This
estimate
is
conservatively
low
because
it
does
not
include
the
cost
to
acquire
a
permit
initially,
nor
does
it
include
additional
burdens
on
generators
for
storage
and
transportation
of
hazardous
wastes.
It
is
not
clear
what
fraction
of
this
cost
would
be
borne
by
the
laundries
themselves
and
which
would
be
passed
on
to
generators,
but
the
allocation
of
these
costs
is
not
important
for
the
purposes
of
this
analysis.

The
estimate
of
costs
to
comply
with
the
federal
requirements
was
developed
to
quantify
the
significant
benefit
that
the
current,
state­
based
exemptions
confer
on
industrial
laundries
and
their
customers.
Without
considering
this
significant
avoided
cost,
the
proposed
rule
appears
to
impose
modest
costs
on
laundries
and
their
customers.
In
fact,
the
rule
represents
relief
from
a
costly
federal
regulatory
program.
This
relief
is
measured
by
the
cost
savings
shown
later
in
the
chapter
when
the
relatively
small
compliance
costs
are
compared
to
the
significant
savings.

3.2
Estimating
the
Universe
of
Solvent
Contaminated
Shop
Towels
3.2.1
All
Shop
Towel
Uses
As
with
our
assessment
of
disposables,
we
estimated
the
universe
of
reusable
towels
using
national
data
and
combined
this
with
usage
information
provided
by
individual
industries
and
from
site
visits.

Our
approach
for
estimating
annual
towel
usage
converted
data
on
the
amount
of
towels
that
are
washed
in
a
year
to
the
total
number
used.
EPA's
1994
survey
of
the
industrial
laundry
industry
study
reported
that
481
million
pounds
of
shop
towels
were
water
washed
in
1994.19
Many
sources
use
one
ounce
as
the
average
shop
towel
weight,
so
that
implies
about
7.7
billion
uses
in
1994.

The
estimate
used
in
this
analysis
includes
two
other
adjustments.
First,
approximately
1
percent
of
shop
towels
are
laundered
by
solvent
("
dry")
cleaners,
so
we
increased
the
total
use
estimate
20
EPA,
"
Technical
Development
Document
for
Proposed
Pretreatment
Standards
for
Existing
and
New
Sources
for
the
Industrial
Laundries
Point
Source
Category,"
1997.

21
US
Census,
Service
Annual
Survey
for
SIC
7218
at
www.
census.
gov/
svsd/
www/
sas.
html.

22
Op.
cit.,
note
16.

23
Op.
cit.,
note
2.

August
22,
2000
­
DRAFT
Page
3­
4
upwards
to
account
for
that
change.
20
Second,
we
escalated
the
1994
sales
figures
to
1997
(
the
base
year
for
the
facility
data
used
in
the
analysis)
based
on
the
growth
of
sales
in
the
industrial
laundry
sector
(
SIC
7218)
between
1994
and
1997.21
We
assumed
that
shop
towel
usage
grew
10
percent
over
this
period,
about
half
the
real
rate
of
growth
experienced
by
the
sector
as
a
whole.

Our
estimate
of
total
uses
of
reusable
towels
in
1997
was
8.55
billion.
Note
that
this
is
the
number
of
uses,
not
the
number
of
towels
in
use
because
towels
are
typically
used
and
laundered
an
average
of
10
to
15
times
during
their
usable
life.

3.2.2
Shop
Towels
Used
with
RCRA­
Regulated
Solvents
We
used
two
different
approaches
to
estimate
the
number
of
shop
towels
that
were
used
in
conjunction
with
RCRA­
regulated
solvents.
For
printers,
we
used
EPA's
Section
308
data
on
water­
washed
printer
towels
B
a
total
of
136
million
pounds
in
1994.22
Using
the
same
adjustment
factors
described
above
for
all
reusables,
we
computed
the
number
of
uses
in
1997
to
be
2.42
million
or
28
percent
of
all
uses
(
Exhibit
3­
1).

Some
shop
towels
are
used
with
RCRA­
regulated
solvents
outside
of
the
printing
industry.
To
compute
this
portion
of
the
universe,
we
identified
industries
that
were
likely
to
use
RCRA
solvents
and
cross­
referenced
that
list
with
the
information
on
shop
towel
customers
provided
in
the
UTSA
Customer
Profile
Analysis.
Kimberly­
Clark
research23
identified
five
non­
printing
industries
out
of
the
25
included
in
the
UTSA
customer
profile,
as
likely
to
use
RCRA
solvents
with
their
shop
towels:
Industrial
Machinery
and
Equipment
(
SIC
35),
Fabricated
Metal
Products
(
SIC
34),
Transportation
Equipment
(
SIC
37),
Chemical
and
Allied
Products
(
SIC
28),
and
Rubber
and
Miscellaneous
Plastics
Products
(
SIC
30).
Together
these
five
industries
accounted
for
just
under
20
percent
of
the
total
revenue
produced
from
laundering
shop
towels
in
1995.
We
assumed
that
this
revenue
share
provided
a
reasonable
proxy
for
the
share
of
towels
used
in
these
industries.
Kimberly­
Clark
then
estimated
that
22
percent
of
shop
towel
uses
in
these
industries
involved
solvents.

We
computed
non­
printer
total
towel
usage
with
solvents
at
370
million
annually
as
shown
in
Exhibit
3­
1.
Adding
this
to
the
2.42
billion
uses
in
the
printing
industry
yields
a
total
annual
estimate
of
2.79
billion
shop
towel
uses
with
solvents.
This
is
substantially
greater
than
the
166
million
disposable
wipes
and
rags
used
with
hazardous
solvents
as
estimated
in
Chapter
2.
The
August
22,
2000
­
DRAFT
Page
3­
5
prevalence
of
solvent
use
with
reusables
is
consistent
with
anecdotal
evidence
obtained
by
EPA
in
its
site
visits
and
meetings
with
various
stakeholders.

Exhibit
3­
1
Summary
of
Shop
Towel
Usage
Annual
Uses
Total
Annual
Uses
(
1997)
8.55
billion
Printer
Towels
(
assume
all
used
with
solvents)

Non­
printers
Towels
sold
to
solvent­
using
industries:
1.68
billion
Of
which,
22%
are
used
with
solvents
Total
Annual
Uses
with
Solvents
2.42
billion
0.37
billion
2.79
billion
Additional
data
on
characteristics
of
reusables
towels
are
provided
below:


Average
weight
per
shop
towel:
1
ounce

Solvent
to
towel
weight
ratio:
1:
1

Typical
weight
of
55
gallon
drum
filled
with
used
towels:
160
pounds

Wet
towels
per
55
gallon
drum:
1,280

Wet
towels
per
15
gallon
drum:
349
3.3
Characterizing
the
Generator
Universe
As
described
in
Section
2.3
we
were
unable
to
calculate
directly
the
number
or
regulatory
status
of
generators
of
solvent
contaminated
wipers.
Instead,
we
relied
on
indirect
analysis
using
data
compiled
from
the
generator
industries
and
from
EPA
databases.

3.3.1
Facilities
Using
Reusables
With
Solvents
24
Op.
cit.,
note
3.

25
Op.
cit.,
note
4.

August
22,
2000
­
DRAFT
Page
3­
6
The
approach
for
characterizing
the
generator
universe
parallels
that
described
in
Chapter
2
for
disposable
wipers.
EPA
combined
facility
data
from
site
visits
and
meetings
with
stakeholders
with
information
from
the
Office
of
Enforcement
and
from
RCRIS.
24
Northbridge
integrated
EPA's
analysis
into
the
data
already
compiled
on
reusables
to
develop
the
information
summarized
below.
25
Based
on
the
industries
where
industrial
wipers
are
used,
EPA
used
Census
data
to
estimate
the
number
of
facilities
in
each
industry
group
(
by
SIC
code).
Within
each
group,
the
number
of
LQGs
was
derived
from
the
1995
Biennial
Reporting
System.
The
remaining
establishments
were
apportioned
between
SQG
and
CESQG
status
based
on
employment:
those
with
fewer
than
20
employees
were
assumed
to
be
CESQGs
and
the
remainder
were
SQGs.

EPA
then
characterized
the
prevalence
of
disposables
and
reusables
by
industry
group.
From
these
assessments
we
were
able
to
calculate
the
number
of
facilities
by
industry
group
and
in
total
that
use
reusables
in
conjunction
with
solvents.
Exhibit
3­
2
shows
that
188,421
facilities
are
assumed
to
use
these
solvents
with
reusable
towels.
Only
4,384
or
2.3
percent
of
these
generators
are
LQGs,
59,305
(
31.5
percent)
are
SQGs,
and
the
remaining
124,732
are
assumed
to
be
CESQGs.
Therefore,
this
proposed
rule
will
have
no
impact
on
about
two­
thirds
of
the
facilities
where
reusables
are
used
in
conjunction
with
solvents.
Printers
account
for
59
percent
of
all
generator
facilities
and
87
percent
of
towel
uses
with
solvents.

3.2.2
Usage
per
Facility
Information
from
the
site
visits
and
from
EPA's
meetings
with
stakeholders
enabled
us
to
estimate
typical
usage
patterns
among
printers
and
non­
printers.
Actual
usage
varies
widely,
of
course,
but
the
typical
values
(
shown
in
the
last
row
of
Exhibit
3­
2)
appeared
to
be
consistent
with
several
of
our
information
sources.

The
facility
counts
and
typical
usage
levels
were
multiplied
together
to
compute
the
total
number
of
solvent
contaminated
towels
used
by
LQGs,
SQGs,
and
CESQGs.
As
shown
in
Exhibit
3­
2,
just
over
half
of
these
towels
are
generated
by
SQGs,
with
CESQGs
accounting
for
41
percent
of
generation
and
LQGs
just
over
8
percent.
Therefore,
the
34
percent
of
facilities
affected
by
the
proposal
are
responsible
for
59
percent
of
the
solvent
contaminated
shop
towels
generated.

Unlike
the
analysis
of
disposables,
storage
time
was
not
an
issue
for
these
facilities
since
collection
of
soiled
towels
for
laundering
is
assumed
to
be
much
more
frequent
than
the
90­
or
180­
day
accumulation
limits
for
RCRA­
regulated
generators.
August
22,
2000
­
DRAFT
Page
3­
7
Exhibit
3­
2
Reusable
Towel
Generation
and
Regulated
Facility
Assumptions
LQGs
SQGs
CESQGs
Totals
Generators
of
Solvent
Contaminated
Towels
(%
of
Total)
4,384
(
2.3%)
59,305
(
31.5%)
124,732
(
66.2%)
188,421
(
100%)

Solvent
Contaminated
Towels
Generated
Annually
(%
of
Total)
234
million
(
8.4%)
1,418
million
(
50.9%)
1,136
million
(
40.7%)
2,788
million
(
100%)

Weekly
Generation
per
Facility
Printers
Non­
Printers
3,000
750
750
100
260
34
3.3
Overview
of
Proposed
Rule
EPA's
proposal
would
amend
the
hazardous
waste
management
regulations
under
RCRA
and
formally
codify
a
conditional
exemption
from
the
definition
of
hazardous
waste
for
certain
shop
towels.
The
exemption
would
be
granted
if
(
1)
generators
accumulate,
store,
and
transport
solvent
contaminated
shop
towels
in
covered
containers
and
(
2)
generators
ensure
that
no
liquids
drip
from
the
towels
when
they
are
hand­
wrung
and
that
any
released
solvent
is
contained.
Wipers
sent
offsite
must
be
labeled
"
Solvent
Contaminated
Wipers"
and
must
be
packaged
either
in
containers
that
comply
with
existing
DOT
requirements
(
49
CFR
171­
180)
or
that
will
contain
the
solvents.
Wipers
that
meet
these
requirements
may
be
sent
to
an
industrial
laundry
that
does
not
have
a
RCRA
Subtitle
C
permit.

Recipients
of
these
towels
must
store
the
wipers
in
a
closed
container
until
they
are
washed.
If
any
liquid
solvent
arrives
with
the
towels,
the
laundry
must
return
the
shipment
to
the
generator
or
recover
and
properly
manage
the
liquid
solvent.

If
towels
are
"
dry,"
(
i.
e.,
contain
less
than
five
grams
of
solvent),
generators
do
not
have
to
comply
with
the
transportation
and
storage
conditions.
Towels
may
be
dry
because
of
low
solvent
use
or
because
solvents
have
been
extracted
from
the
towel
by
wringing
or
a
centrifuge.

3.4
Unit
Costs
for
Generators
August
22,
2000
­
DRAFT
Page
3­
8
As
with
disposables,
the
conditions
for
obtaining
the
exemption
may
impose
costs
on
generators
and,
potentially,
industrial
laundries.
The
components
of
the
proposed
rule
have
somewhat
different
implications
for
shop
towels
because
of
differences
in
the
current
practices
between
generators
of
reusables
and
disposables.
The
requirement
to
remove
excess
liquid
from
used
towels
is
already
a
prerequisite
for
the
exemption
granted
to
generators
of
reusable
shop
towels
in
the
vast
majority
of
states;
it
is
also
a
condition
of
doing
business
with
most
industrial
laundries.
The
condition
therefore
represents
no
incremental
cost
for
generators
or
laundries.
The
requirement
for
covered
containers,
however,
would
affect
a
large
portion
of
generators
and
laundries.
The
incremental
costs
associated
with
acquiring
these
containers
are
analyzed
below.
Generators
would
also
be
required
to
label
containers
containing
reusable
shop
towels
and
this
requirement
would
impose
incremental
costs
as
well.

3.4.1
No
Liquid
Drips
from
the
Wipers
To
qualify
for
the
exemption
under
the
proposed
rule,
generators
are
required
to
ensure
that
no
liquid
solvent
drips
from
the
towels
when
hand
wrung.
Most
of
the
46
states
with
exemptions
in
place
already
include
this
condition
as
part
of
an
existing
regulatory
exemption.
Therefore
the
practices
employed
to
wring
or
otherwise
remove
free
liquids
should
be
part
of
the
current
operating
practices
at
generator
facilities.
It
would
be
inappropriate
for
us
to
attribute
to
the
proposal
any
additional
costs
for
wringing
or
managing
the
removed
solvents,
since
these
costs
are
already
being
incurred.

If
industrial
laundries
receive
containers
with
liquids,
they
are
required
to
return
the
shipment
to
the
generator
or
manage
the
liquids
appropriately
themselves.
In
either
case,
the
cost
of
this
condition
would
ultimately
be
borne
by
the
generators.
Since
laundries
currently
impose
a
no
free
liquids
standard,
however,
we
do
not
expect
significant
new
costs
as
a
result
of
this
condition.
If,
in
fact,
generators
elect
to
send
dripping
towels
to
laundries,
the
laundries
would
either
charge
the
generator
for
solvent
management
or
discontinue
handling
the
towels.
Neither
of
these
outcomes
should
be
attributed
to
the
proposed
rule.

3.4.2
Covered
Containers
Covered
containers
(
i.
e.,
drums)
are
used
by
some
generators
and
industrial
laundries
for
handling
heavily
soiled
shop
towels.
However,
this
practice
is
not
common
for
most
generators
or
laundries,
based
on
information
EPA
collected
during
site
visits.
To
comply
with
this
condition,
we
assumed
that
generators
would
use
drums
to
store
and
ship
solvent
contaminated
reusable
shop
towels
and
that
this
would
impose
an
incremental
cost
for
the
purchase
of
containers
and
their
replacement
over
time.
It
is
possible
that
less
expensive
options
may
exist,
such
as
use
of
wheeled
carts
or
other
containers,
but
for
simplicity
we
focused
on
the
use
of
drums
for
those
who
do
not
currently
use
them.
26
Op.
cit.,
note
9.

27
A
drum
handler
and
plastic
drum
adaptor
was
$
646
on
handlingnet.
com,
August
14,
2000;
assuming
7­
year
life
and
10
percent
discount
rate
the
annualized
cost
is
$
133.

Page
3­
9
August
22,
2000
­
DRAFT
We
obtained
pricing
information
for
various
sizes
and
types
of
drums
that
would
meet
the
requirement
and
computed
average
prices
for
55
gallon
drums
(
assumed
to
be
used
by
LQGs)
and
15
gallon
drums
(
for
SQGs).
The
number
of
drums
required
is
keyed
to
our
assumptions
about
average
usage
described
earlier
in
Section
3.2;
these
assumptions
are
spelled
out
in
the
Appendix.
Assuming
a
three­
year
life
for
the
inventory
of
drums
required,
the
annualized
cost
per
generator
ranges
from
$
18.52
for
a
SQG
non­
printer
to
$
98.23
for
a
LQG
printer.
The
derivation
of
the
costs
is
described
in
additional
detail
in
the
Appendix.

In
addition
to
the
container
requirement,
the
proposal
includes
a
requirement
that
generators
label
containers
with
a
label
containing
specific
language
designating
the
towels
as
"
Solvent
Contaminated
Wipers."
The
cost
would
be
approximately
$
0.33
per
label.
26
We
should
note
that
we
have
not
included
in
these
costs
any
modifications
to
facilities
or
equipment
required
to
store
and
handle
the
drums.
For
example,
some
industrial
laundries
may
require
equipment
to
unload
and
rotate
drums
which
is
not
already
in
place.
Those
with
existing
hoist
and
conveyor
systems
for
handling
bags
could
purchase
inexpensive
slings
or
other
equipment
to
handle
drums.
A
more
elaborate
option
would
be
a
mechanical
drum
handler
and
rotator
that
attaches
to
a
forklift.
The
annualized
cost
of
this
attachment
is
about
$
133.27
Even
if
we
assumed
that
half
of
the
laundries
handling
printer
towels
purchased
this
equipment,
the
annual
cost
would
be
less
than
$
32,000
nationally.
This
is
not
included
in
the
cost
estimates
presented
below.

3.5
Results
3.5.1
Current
Practices
Baseline
First,
we
present
the
incremental
costs
relative
to
current
practices.
In
other
words,
these
costs
are
measured
incrementally
to
the
state­
granted
exemptions
from
Subtitle
C
compliance
for
solvent
contaminated
shop
towels.

3.5.1.1
Costs
Per
Generator
The
per­
facility
costs
of
complying
with
the
conditional
exemption
are
summarized
in
Exhibit
3­
3.
Note
that
in
some
cases
the
costs
are
not
applicable
to
all
generators.
For
example,
generators
who
already
use
drums
to
store
and
transport
reusable
shop
towels
will
not
incur
any
additional
cost
to
comply
with
the
closed
container
condition.
The
compliance
costs
are
quite
low:
the
Page
3­
10
August
22,
2000
­
DRAFT
maximum
estimated
cost
is
less
than
$
100
per
LQG
and
less
than
$
40
per
SQG
per
year.
For
generators
that
already
use
drums,
the
incremental
cost
would
be
insignificant.

As
we
have
developed
and
presented
the
costs,
we
have
assumed
that
the
cost
of
the
drums
and
labels
would
be
borne
by
the
generator.
Depending
on
competitive
conditions,
it
is
possible
that
a
laundry
might
offer
to
absorb
some
of
the
cost
of
the
drums
used
to
service
its
customers.
In
this
case,
the
cost
per
laundry
could
be
higher
than
the
cost
per
generator
shown
here
(
however,
total
costs
would
be
the
same).

Exhibit
3­
3
Annual
Costs
per
Generator
Facility
Regulatory
Element
LQGs
SQGs
No
Dripping
Liquids
$
0
$
0
Closed
Containers
Drums*
Labels
$
32.78
­
$
98.34
$
0.82
$
18.52
­
$
37.04
$
1.39
*
Range
captures
printers
(
high
end)
and
non­
printers
(
low
end)

3.5.1.2
Total
Costs
The
total
annual
costs
associated
with
the
proposed
exemption
for
reusable
shop
towels
is
$
2.33
million
as
shown
in
Exhibit
3­
4.
All
of
the
cost
results
from
the
use
of
covered
containers
and
labels.
As
noted
earlier,
some
laundries
might
also
purchase
equipment
to
handle
drums
at
their
facilities,
but
the
aggregate
cost
would
add
less
than
2
percent
to
the
total
shown
in
Exhibit
3­
4.

As
in
the
disposables'
analysis,
we
computed
the
incremental
cost
per
shop
towel
(
Exhibit
3­
4).
The
regulatory
costs
on
shop
towels
alone
would
have
little
effect
on
generators'
choice
of
industrial
wipers.
Using
a
low­
end
price
of
12
¢
per
shop
towel
use,
the
highest
impact
per
towel
(
0.15
¢
per
SQG
towel)
represents
only
a
1.3
percent
increase
in
overall
shop
towel
cost.
Page
3­
11
August
22,
2000
­
DRAFT
Exhibit
3­
4
Proposal
Annual
Costs
and
Costs
per
Shop
Towel
Use
­
Current
Practices
Baseline
Large
Quantity
Generators
$
165,000
$
0.0007
Small
Quantity
Generators
$
2,166,000
$
0.0015
Total
$
2,331,000
$
0.0014
3.5.2
Federal
Program
Baseline
As
noted
earlier
in
the
chapter,
the
proposal
represents
significant
relief
from
federal
Subtitle
C
standards
for
industrial
laundries
and
their
customers.
Based
on
our
calculations,
firms
that
generate
and
launder
solvent
contaminated
shop
towels
would
have
to
spend
(
conservatively)
between
$
16.1
million
and
$
45.5
million
annually
to
comply
with
federal
permitting
and
treatment
requirements.
If
the
federal
standards
governed
current
operations
at
these
laundries,
the
proposed
rule
would
impose
no
new
incremental
costs,
except
for
labeling
which
costs
less
than
$
100,000
per
year.

The
net
impact
of
the
proposed
rule,
therefore,
is
to
produce
compliance
cost
savings
of
between
$
16.1
million
and
$
45.5
million
for
industrial
laundries
and
their
customers
relative
to
the
federal
program
baseline.
Page
4­
1
August
22,
2000
­
DRAFT
4.
Summary
of
Costs
and
Savings
The
proposed
rule
will
impose
modest
compliance
costs
on
generators
of
disposable
and
reusable
industrial
wipers
used
with
solvents.
These
incremental
costs
result
from
compliance
activity
required
to
meet
the
conditions
for
the
proposed
exemption
from
hazardous
waste
management.
Where
these
conditions
are
already
met
in
the
course
of
current
practices,
we
did
not
compute
any
incremental
cost.

Generators
of
disposable
wipes
and
rags
will
also
experience
significant
savings,
primarily
as
the
result
of
lower
waste
management
costs
for
disposables
contaminated
with
hazardous
waste
solvents.
As
shown
in
Exhibit
2­
2,
these
savings
far
outweigh
the
incremental
costs.

Facilities
that
use
and
manage
reusable
shop
towels
contaminated
with
hazardous
waste
already
have
an
exemption
from
hazardous
waste
management
requirements
in
46
states,
so
they
already
benefit
from
the
savings
that
this
proposal
would
confer
on
generators
of
disposables.
Using
the
current
practices
baseline,
therefore,
the
proposal
imposes
incremental
national
costs
of
just
over
$
2.3
million
(
Exhibit
3­
4).

From
the
perspective
of
the
current
federal
requirements,
the
proposal
offers
generators
and
laundries
regulatory
relief
in
the
form
of
an
exemption
from
RCRA
Subtitle
C
management
standards
for
towels
and
solvents.
The
savings
associated
with
this
relief
are
estimated
conservatively
at
between
$
16.1
million
and
$
45.5
million
(
Section
3.5.2).

4.1
Combined
Cost
and
Savings
Estimates
The
proposal
would
result
in
annual
cost
savings
of
between
$
8.8
million
and
$
61
million;
the
combined
impacts
for
disposables
and
reusables
are
shown
in
Exhibit
4­
1.

Exhibit
4­
1
Annual
Costs
and
(
Savings)
from
the
Proposal
Current
Practices
Baseline
Federal
Program
Baseline
Disposables
($
11.1
­
$
15.6
million)
($
11.1
­
$
15.6
million)

Reusables
$
2.3
million
($
16.1
­
$
45.5
million)

Net
(
Savings)
($
8.8
­
$
13.3
million)
($
27.2
­
$
61.1
million)
28
"
Revised
Small
Business
Estimates
for
Reusables,"
memorandum
from
Kevin
Dietly
and
Brad
Strowger
(
Northbridge)
to
Mary
Wolfe
(
SAIC)
and
Jim
O'Leary
(
EPA),
April
20,
2000.
No
screening
analysis
was
conducted
for
disposables
since
all
facilities
will
experience
either
no
costs
or
savings.

Page
4­
2
August
22,
2000
­
DRAFT
4.2
Discussion
of
Economic
and
Small
Business
Impacts
The
principal
effect
of
the
proposal
is
to
provide
regulatory
relief
to
some
facilities
that
generate
and
manage
industrial
wipers
that
are
regulated
as
hazardous
waste
under
federal
RCRA
regulations.
Despite
the
de­
regulatory
thrust
of
the
proposal,
there
is
still
concern
that
the
proposal
might
impose
burdensome
costs
on
individual
facilities
or
disproportionate
costs
on
small
businesses.
Our
research
indicates
that

The
proposal
is
not
a
major
rule

Individual
generators
face
a
maximum
annualized
compliance
cost
of
less
than
$
100

Many
generators
save
money
as
a
result
of
the
proposal

Those
facilities
that
do
incur
modest
costs
are
actually
being
relieved
of
a
serious
liability
as
a
result
of
becoming
exempt
from
regulation
under
RCRA
Subtitle
C
We
have
also
identified
a
number
of
ways
in
which
generators
could
increase
savings
(
reduce
costs).

The
proposal
may
create
an
economic
incentive
for
generators
to
use
disposable
wipers
instead
of
reusable
towels
with
hazardous
solvents.
Since
reusables
account
for
over
90
percent
of
all
wiper
use
with
solvents,
there
is
a
large
potential
market
for
the
disposables.
However,
cost
of
disposal
is
only
one
consideration
in
the
selection
of
an
industrial
wiper.
The
wiper's
performance
characteristics
are
far
more
important
in
determining
which
product
is
used
and,
since
the
proposal
does
not
affect
those
characteristics,
we
expect
any
shift
in
use
patterns
to
be
limited.

Turning
to
small
business
concerns,
we
recognize
that
a
large
fraction
of
the
reusables
generators
are
small
businesses.
A
screening
analysis
suggested
that
over
94
percent
of
the
188,421
generators
are
small
businesses.
28
Yet,
with
annual
compliance
costs
for
most
of
those
facilities
of
less
than
$
40,
it
was
not
necessary
to
conduct
any
further
analysis
of
adverse
impacts
on
these
small
businesses.
29
"
Pricing
for
Waste
Management
Types
by
Year,"
compiled
by
DPRA
for
SAIC,
May
1995.

August
22,
2000
­
DRAFT
Appendix
Page
A­
1
Appendix:
Cost
Background
Document
This
document
supplements
the
unit
cost
information
provided
in
the
full
report.
The
categories
of
costs
and
savings
are
presented
in
the
order
they
are
discussed
in
the
report.
In
some
cases
the
information
applies
to
both
the
disposables
and
reusables
analysis
and
in
others
it
may
apply
to
only
one
of
them.

A.
1
No
Liquids
Drip
from
Wipers
When
Wrung
Compliance
costs
associated
with
this
requirement,
assuming
hand
wringing
of
the
towels,
rags,
and
wipes,
are
limited
to
management
of
solvents
extracted
from
disposable
wipes
and
rags.
The
cost
of
hand
wringing
to
extract
free
liquids
was
assumed
to
be
negligible.
The
solvents
removed
from
disposables
would
be
sent
to
a
fuel
blender.
The
cost
of
managing
liquid
wastes
at
these
facilities
is
relatively
low,
averaging
$
0.11
per
pound.
29
The
cost
translates
into
an
incremental
cost
of
about
$
1.10
for
the
solvent
extracted
(
by
hand)
from
one
drum
of
contaminated
wipes
and
rags.
Other
options
such
as
solvent
tolling
or
reuse
contracts
would
be
a
less
expensive
alternative
which
we
did
not
factor
into
our
analysis.

A.
2
Covered
Containers
LQGs
and
SQGs
generating
disposable
wipes
and
rags
contaminated
with
solvents
are
already
required
to
store
the
wipers
in
closed
containers.
The
proposal
would
not
impose
any
incremental
costs
on
these
generators.

The
situation
for
shop
towel
users
is
different,
however.
The
first
step
in
analyzing
the
costs
of
this
requirement
was
to
identify
how
many
generators
currently
use
drums
versus
cloth
bags
for
storage
and
transportation.
Based
on
site
visits
and
anecdotal
information,
we
assumed
that
90
percent
of
generators
have
towels
picked
up
in
cloth
bags
with
the
remaining
10
percent
using
drums.

Given
typical
usage
estimates
for
LQG
and
SQG
printers
and
non­
printers,
we
determined
the
size
and
number
of
containers
that
would
be
required
as
shown
in
Exhibit
A.
The
smaller
drum
size
for
SQGs
provides
a
lighter,
more
manageable
container.
The
next
step
was
to
obtain
cost
data
for
drums
which
we
collected
from
several
firms
and
then
averaged.
The
drums
are
new,
open
head
plastic
drums
with
a
locking
lid.
We
assumed
that
the
drums
would
be
ordered
in
bulk,
probably
by
a
laundry
for
its
customers.
The
drums
were
assumed
to
last
for
three
years.
Since
the
drums
would
be
used
both
for
storage
and
transportation,
we
assumed
that
the
total
inventory
30
Lab
Safety
Supply,
August
1998.

August
22,
2000
­
DRAFT
Appendix
Page
A­
2
of
drums
would
need
to
be
double
the
number
required
to
be
shipped
each
week.
For
example,
a
LQG
printer
would
need
six
55
gallon
drums
B
three
for
storing
towels
and
three
for
shipment
to
the
laundry;
a
SQG
non­
printer
would
need
two
15
gallon
drums.
Finally,
we
annualized
the
cost
of
the
drums
over
the
expected
three­
year
life
using
a
10
percent
discount
rate.
The
annualized
cost
per
drum
is
$
16.39
for
55­
gallon
drums
and
$
9.26
for
15­
gallon
drums.

Exhibit
A
Container
Costs
LQGs
SQGs
Drum
size
55
gallon
15
gallon
Drums
required
Printers
Non­
printers
62
62
Average
cost
per
drum
$
44.82
$
25.34
Annualized
cost
per
drum
$
16.39
$
9.26
A.
3
Labeling
For
disposables,
where
generators
are
already
using
closed
containers,
the
proposal
would
require
the
application
of
pre­
printed
labels
designating
the
wipes
and
rags
as
exempt
from
hazardous
waste
requirements.
We
estimated
the
cost
for
a
6"
x
6"
pre­
printed,
vinyl
adhesive
label
at
$
0.33
each.
30
The
same
label
cost
was
used
for
drums
purchased
to
store
and
transport
shop
towels.
Because
the
drums
are
reused,
however,
we
assumed
that
the
labels
would
last
for
one
year
before
needing
to
be
replaced.

A.
4
Manifesting
LQGs
and
SQGs
have
three
general
requirements
related
to
manifesting
hazardous
waste
shipments:
manifests,
exception
reports,
and
special
requirements
for
exporters.
For
the
purposes
31
Manifest
data
and
information
taken
from
"
Supporting
Statement
for
Information
Collection
Request
Number
801,
`
Requirements
for
Generators,
Transporters,
and
Waste
Management
Facilities
Under
the
RCRA
Hazardous
Waste
Management
System,'"
pp.
7,
21,
and
24,
July
31,
1996.

August
22,
2000
­
DRAFT
Appendix
Page
A­
3
of
this
analysis,
we
focused
on
the
manifests
because
the
other
reports
are
required
for
only
a
small
fraction
of
all
generators.
The
tasks
associated
with
the
manifest
are:


Manifest
completion
(
read
applicable
regulations,
complete
manifest
with
the
specified
data
items)


Manifest
transmittal
and
recordkeeping
(
read
applicable
regulations,
provide
copies
of
the
manifest
to
the
transporter
and
keep
copies)

The
costs
are
shown
in
Exhibit
B.
31
These
costs
were
used
to
compute
savings
for
generators
of
disposable
wipes
and
rags
who
would
no
longer
be
required
to
manifest
shipments
of
solvent
contaminated
wipers.
Because
generators
of
shop
towels
are
already
exempt
from
this
requirement
in
the
vast
majority
of
states,
we
did
not
compute
any
savings
for
them.

Exhibit
B
Manifest
Costs
Manifest
Procedure
Total
Cost
per
Shipment
Complete
the
manifest
­
SQG
$
16.22
Complete
the
manifest
­
LQG
$
16.93
A.
5
Waste
Management
Costs
All
of
the
costs
discussed
in
this
section
apply
to
the
analysis
of
disposable
wipes
and
rags.
Savings
on
the
management
of
these
wipers,
now
handled
as
hazardous
waste,
constitute
the
most
significant
economic
impact
of
the
proposal.
The
first
area
we
review
relates
to
baseline
costs
of
hazardous
waste
management
and
the
change
in
those
costs
if
the
material
collected
is
no
longer
deemed
to
be
hazardous
waste.
The
second
part
of
the
discussion
summarizes
alternative
disposal
costs
using
municipal
facilities.
August
22,
2000
­
DRAFT
Appendix
Page
A­
4
A.
5.1
Pickup,
Transportation
and
Disposal
Services
Northbridge
surveyed
seven
New
England
waste
disposal
companies
to
obtain
typical
costs
for
pickup,
transportation
and
disposal
of
solvent
contaminated
wipes
and
rags.
The
companies
included
Clean
Harbors,
Environmental
Waste
Technology,
Inc.,
ENPRO
Services,
Inc.,
and
Advanced
Environmental
Technical
Services.
We
did
not
receive
responses
from
the
remaining
firms
or
received
responses
that
were
unusable.

Our
survey
described
two
scenarios
for
which
we
asked
the
companies
to
provide
cost
estimates.
The
scenarios
were
as
follows:


The
cost
to
pick
up,
transport,
and
dispose
of
a
55
gallon
container
full
of
solvent
contaminated
rags
and
wipes
at
a
Subtitle
C­
permitted
incinerator
or
fuel
blender.


The
cost
to
pick
up,
transport,
and
dispose
of
a
55
gallon
container
full
of
solvent
contaminated
wipes
and
rags
exempt
from
hazardous
waste
regulations;
these
could
be
disposed
of
at
a
non­
Subtitle
C
facility,
but
not
in
a
municipal
facility.

The
first
scenario
represents
the
current
situation
and
therefore
is
the
"
baseline
cost"
from
which
we
derived
cost
savings.
The
second
scenario
represents
the
proposed
exemption.
The
results
from
the
survey
are
summarized
in
Exhibit
C.
The
savings
from
the
exemption
average
$
227
per
55­
gallon
container.

Exhibit
C
Survey
Data
on
Pickup,
Transportation,
and
Disposal
Costs
Scenario
Cost
Company
Average
(
A)
(
B)
(
C)
(
D)

Baseline
Pickup
$
25
$
100
$
150
$
150
$
106
Transportation/
Disposal
$
195
$
440
$
275
$
280
$
298
Total
$
220
$
540
$
425
$
430
$
404
Exempt
from
Subtitle
C
Pickup
$
25
$
100
$
62
Transportation/
Disposal
$
79
$
150
$
115
Total
$
104
$
250
NA
NA
$
177
32
Letter
from
Mary
McCarty
to
Jim
O'Leary,
EPA,
February
1998.

August
22,
2000
­
DRAFT
Appendix
Page
A­
5
We
also
tested
several
assumptions
made
in
the
analysis.
For
example,
we
confirmed
that
a
55
gallon
container
was
a
typical
storage
and
transport
container
for
these
wastes
from
print
shops
and
automotive
repair
stations.
We
also
confirmed
the
net
weight
of
wastes
typically
contained
in
these
drums.

A.
5.2
Municipal
Disposal
Options
The
proposal
permits
facilities
with
access
to
municipal
waste
combustors
to
use
those
facilities
to
dispose
of
waste
qualifying
for
the
exemption.
Since
the
materials
could
presumably
be
transported
with
other
solid
wastes
from
the
facility,
no
additional
transportation
cost
was
assumed.
We
did
measure
the
costs
of
disposal
in
these
facilities,
based
on
a
national
average
of
tipping
fees
published
in
Solid
Waste
Digest
in
October
1997.
The
average
municipal
waste
combustor
cost
was
$
54
per
ton
($
5.36
per
drum),
representing
a
savings
of
nearly
$
400
per
drum
compared
to
the
baseline.
If
municipal
landfills
could
be
used,
the
savings
would
be
even
greater
as
the
average
landfill
cost
was
estimated
at
$
33
per
ton
($
3.28
per
drum).

A.
5.3
Centrifuging
Costs
Centrifuging
was
evaluated
as
a
way
to
make
disposables
"
dry"
and
thereby
allow
them
to
be
disposed
in
municipal
landfills.
Centrifuging
is
assumed
to
be
performed
in
a
mobile
unit
which
provides
the
service,
but
leaves
the
solvent
and
wipers
for
the
generator
to
manage.
EPA
obtained
data
from
a
firm
providing
this
service
and
found
that
the
price
charged
varied
with
the
volume
of
wipers
handled.
32
We
used
our
assumed
wiper
generation
rate
for
SQGs
and
LQGs
to
see
where
in
the
cost
range
our
"
model"
facilities
would
fall.
The
SQGs
are
assumed
to
use
about
7,400
wipes
and
rags
with
solvents
each
year.
If
the
wipes
and
rags
were
centrifuged
prior
to
shipment
offsite
(
i.
e.,
every
180
days),
the
cost
would
be
$
0.04
per
wiper
or
$
296
per
year
plus
solvent
management
(
about
$
15
per
year).
LQGs,
assumed
to
use
almost
30,000
wipes
and
rags
per
year,
would
pay
a
slightly
lower
price
of
about
$
0.03
per
wiper
and
would
use
the
service
every
90
days.
The
annual
cost
for
LQGs
would
be
$
888
for
centrifuging
plus
about
$
60
for
solvent
management.

Solvents
removed
from
the
wipers
would
be
sent
to
a
fuel
blender.
The
cost
of
managing
liquid
wastes
at
these
facilities
is
relatively
low,
averaging
$
0.11
per
pound
as
described
in
A.
1
or
about
$
8
for
the
solvent
extracted
from
one
drum
of
contaminated
wipers.
33
Information
is
from
the
following
except
where
otherwise
noted:
"
Supporting
Statement
for
EPA
Information
Collection
Request
Number
0820.07:
`
Hazardous
Waste
Generator
Standards,'"
pp.
5,
8,
64,
69,
and
74,
November
19,
1997.

August
22,
2000
­
DRAFT
Appendix
Page
A­
6
A.
6
Administrative
Costs
for
SQGs:
Recordkeeping,
Waste
Analysis,
Contingency
Plan33
As
part
of
the
analysis
of
disposable
wipes
and
rags,
we
assumed
that
the
conditional
exemption
might
permit
a
small
fraction
of
SQGs
to
qualify
as
conditionally
exempt
SQGs
because
they
would
no
longer
count
disposable
wipes
and
rags
toward
their
hazardous
waste
generation
totals.
In
this
instance,
the
facilities
would
save
administrative
costs
associated
with
SQG
status.

SQGs
are
required
to
conduct
waste
analysis,
document
these
analyses,
and
keep
records
of
any
test
results,
waste
analysis,
or
other
determination
for
at
least
three
years.
SQGs
are
also
required
to
formulate
and
maintain
contingency
plans.
The
ICR
did
not
identify
costs
specific
to
SQGs,
but
we
used
the
contingency
plan
costs
described
for
LQGs
and
assumed
that
they
provide
a
reasonable
estimate.
The
costs
associated
with
these
activities
are
shown
in
the
following
exhibit.

The
total
cost
for
these
administrative
elements
is
$
6,957.79
per
generator
per
year.
Costs
to
implement
emergency
procedures
and
to
respond
to
spills
and
incidents
were
not
included
for
this
analysis,
because
these
incidents
occur
only
rarely.
August
22,
2000
­
DRAFT
Appendix
Page
A­
7
Exhibit
D
Small
Quantity
Generator
Administrative
Costs
Recordkeeping
Procedure
Annual
Cost
per
Generator
Store,
file
and
maintain
records
of
any
test
results,
waste
analysis,
or
other
determinations.
$
4.80
Waste
Analysis
Procedure
Gather
information
(
initially
and
annually
thereafter)
Document
information
(
initially
and
annually
thereafter)
Maintain
documentation
at
the
facility
Total
waste
analysis
$
6,395.23
50.20
10.04
$
6,455.47
Contingency
Procedure
Collect
data
required
in
a
contingency
plan
Document
whether
authorities
decline
arrangement
Write
contingency
plan
Maintain
contingency
plan
Submit
contingency
plan
to
relevant
emergency
centers
Amend
contingency
plan
when
appropriate
Total
contingency
$
73.09
2.51
338.15
2.51
8.07
73.19
$
497.52
Total
Administrative
Costs
$
6,957.79
