ECONOMIC
ANALYSIS
OF
CATHODE
RAY
TUBE
MANAGEMENT,
FINAL
RULEMAKING
FINAL
REPORT
Prepared
for:

U.
S.
Environmental
Protection
Agency
Office
of
Solid
Waste
Prepared
by:

ICF
Consulting
March
19,
2004
March
19,
2004
Page
i
Table
of
Contents
1.0
Introduction
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1
2.0
Overview
of
the
Entities
Involved
in
Generating
and
Recycling
CRTs
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2
2.1
Original
Users
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3
2.2
Establishments
that
Reuse
Monitors
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4
2.3
Collectors
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4
2.4
Reclaimers
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6
2.5
Glass
Processors
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6
2.6
Transporters
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7
3.0
Methodology
and
Data
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7
3.1
Estimate
the
Number
of
Original
Users
Discarding
Computer
Monitors
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8
3.2
Estimate
the
Total
Number
of
Color
Computer
Monitors
Discarded
Annually
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8
3.2.1
Total
Number
of
Computers
in
All
Business
Establishments
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8
3.2.2
Discarded
Computer
Monitors
from
All
Original
Users
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9
3.2.3
Color
CRT
Monitors
Discarded
from
All
Original
Users
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9
3.3
Estimate
the
Number
of
Regulated
Original
Users
and
Collectors
and
the
Number
of
CRTs
They
Discard
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10
3.3.1
Computers
Discarded
per
Original
User
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11
3.3.2
Monitor
Weight
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11
3.3.3
Number
of
Original
Users
and
Collectors
that
are
Regulated
Generators
in
the
Subtitle
C
Baseline
Based
Only
on
the
Generation
of
CRTs
.
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12
3.3.4
Number
of
Original
Users
that
are
Regulated
Generators
in
the
Subtitle
C
Baseline
Due
to
a
Combination
of
CRTs
and
Non­
CRT
Hazardous
Waste
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13
3.3.5
Number
of
Original
Users
and
Collectors
that
are
Regulated
Generators
Under
the
Final
Rule
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16
3.4
Flow
of
CRTs
from
Generators
to
Disposal
Sites
Under
the
Subtitle
C
Baseline
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17
3.4.1
Disposal
Option
Assumptions
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21
3.5
Estimate
Administrative
Compliance
Costs
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24
3.5.1
Baseline
Unit
Costs
for
Original
Users
(
Generating
No
Non­
CRT
Hazardous
Waste)
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24
3.5.2
Baseline
Unit
Costs
for
Original
Users
Also
Generating
Non­
CRT
Hazardous
Waste
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24
3.5.3
Final
Rule
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24
3.6
Estimate
Disposal
Costs
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25
3.7
Estimate
Transportation
Costs
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27
Table
of
Contents
(
continued)

March
19,
2004
Page
ii
3.8
Estimate
Storage
Costs
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30
3.9
Estimate
Costs
for
Glass
Processors
and
Transporters
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30
3.9.1
Costs
to
Glass
Processors
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30
3.9.2
Costs
to
CRT
Glass
Transporters
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32
3.10
Estimate
the
Impact
of
Compliance
Costs
on
Affected
Entities
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32
3.11
Methodology
for
Subtitle
D
Management
Baseline
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33
3.12
Limitations
of
the
Methodology
and
Data
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36
3.12.1
Assumptions
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36
3.12.2
Limitations
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39
3.12.3
Other
Factors
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40
4.0
Cost
Results
and
Sensitivity
Analysis
for
Subtitle
C
Management
Baseline
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41
4.1
Costs
Under
the
Subtitle
C
Baseline
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42
4.2
Final
Rule
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42
4.2.1
Costs
Under
the
Final
Rule
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42
4.2.2
Incremental
Cost
Difference
Between
the
Subtitle
C
Baseline
and
the
Final
Rule
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43
4.2.3
Sensitivity
Analysis
for
the
Final
Rule
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44
4.2.4
Incremental
Cost
Difference
Between
the
Subtitle
C
Baseline
and
the
Final
Rule,
Including
Currently
Unregulated
Monitors
and
Televisions
.
.
.
.
.
.
48
5.0
Cost
Results
and
Sensitivity
Analysis
for
Subtitle
D
Management
Baseline
.
.
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.
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49
5.1
Costs
Under
the
Subtitle
D
Baseline
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49
5.2
Final
Rule
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50
5.2.1
Costs
Under
the
Final
Rule
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50
5.2.2
Incremental
Cost
Difference
Between
the
Subtitle
D
Baseline
and
the
Final
Rule
.
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50
5.2.3
Sensitivity
Analysis
for
the
Final
Rule
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51
5.2.4
Incremental
Cost
Difference
Between
the
Subtitle
D
Baseline
and
the
Final
Rule,
Including
Currently
Unregulated
Monitors
and
Televisions
.
.
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53
6.0
Economic
Impacts
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54
7.0
Qualitative
Environmental
Benefits
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57
8.0
Other
Administrative
Requirements
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59
8.1
Environmental
Justice
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59
8.2
Unfunded
Mandates
Reform
Act
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59
Table
of
Contents
(
continued)

March
19,
2004
Page
iii
8.3
Protection
of
Children
from
Environmental
Health
Risks
and
Safety
Risks
.
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60
8.4
Regulatory
Flexibility
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60
9.0
Discussion
of
Findings
and
Summary
.
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60
Appendix
A­
1:
Number
of
Establishments
by
Establishment
Employment
Size
Category
.
.
.
.
A­
1
Appendix
A­
2:
Number
of
Employees
by
Establishment
Employment
Size
Category
.
.
.
.
.
.
.
A­
5
Appendix
B:
Computer
Use
By
Employees
.
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B­
1
Appendix
C:
Crosswalk
of
SIC
and
NAICS
Codes
.
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C­
1
Appendix
D:
Computer
Use
Percentages
by
NAICS
Code
.
.
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.
D­
1
Appendix
E:
Disposal
Cost
Source
Details
.
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E­
1
Appendix
F:
Flow
of
CRTs
Under
Subtitle
C
(
Number)
.
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.
F­
1
Flow
of
CRTs
Under
Subtitle
C
(
Tons)
.
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.
F­
3
Flow
of
CRTs
Under
Subtitle
D
(
Number)
.
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.
.
F­
5
Flow
of
CRTs
Under
Subtitle
D
(
Tons)
.
.
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.
F­
7
Appendix
G:
Average
Shipment
Sizes
for
Each
Type
of
Establishment
Distributing
CRTs
to
Each
CRT
Management
Option
.
.
.
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.
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.
.
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.
.
.
.
G­
1
Number
of
Shipments
Each
Year
Under
Subtitle
C
.
.
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.
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.
.
.
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.
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.
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.
G­
3
Appendix
H:
Average
Annual
Sales
per
Establishment
by
3­
Digit
NAICS
Code
.
.
.
.
.
.
.
.
.
H­
1
Appendix
I:
Detailed
Sensitivity
Analysis
Results
on
All
Parameters
Tested
.
.
.
.
.
.
.
.
.
.
.
.
I­
1
Appendix
J:
Telephone
Contacts
.
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J­
1
Appendix
K:
Bibliography
.
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K­
1
March
19,
2004
Page
1
1.0
Introduction
Computers
and
televisions
are
in
almost
every
household
and
business
in
the
United
States.
Several
hundred
million
computers
and
televisions
are
in
use
and
many
more
millions
are
believed
to
be
in
storage.
Both
computer
monitors
and
televisions
typically
contain
a
cathode
ray
tube
(
CRT),
which
creates
the
images
seen
on
the
television
or
computer
monitor.
The
glass
in
CRTs
from
color
computer
monitors
and
color
televisions
can
contain
enough
lead
to
qualify
these
devices
as
hazardous
waste
(
D008,
characteristically
hazardous
for
lead)
when
they
are
discarded.
Under
current
Resource
Conservation
and
Recovery
Act
(
RCRA)
regulation,
postconsumer
CRTs
from
many
commercial
and
industrial
generators
are
hazardous
waste
whether
disposed,
or
sent
for
reclamation,
such
as
disassembly
and
glass
recycling
(
40
CFR
§
261.2(
C)(
3)).
CRTs
that
are
sent
for
refurbishment
or
reuse
are
not
considered
a
solid
waste
under
RCRA.

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

To
remedy
this
situation
the
Common
Sense
Initiative
(
CSI)
Council
tasked
the
Computers
and
Electronics
Sector
Subcommittee
with
recommending
regulations
that
encourage
environmentally
sound
recovery
of
CRTs
and
that
eliminate
unnecessary
regulatory
burden
for
recycling
post­
consumer
CRTs
back
into
new
CRT
glass.
In
June
1998,
the
CSI
Computers
and
Electronics
Sector
Subcommittee
recommended
changes
to
the
current
regulations
specifically
for
CRTs
that
encourage
recycling
CRT
glass
back
into
new
CRT
glass.
The
recommendations
included
extended
storage
limits,
no
manifesting,
reduced
recordkeeping
requirements,
and
no
biennial
reporting.
EPA's
final
regulation
builds
on
the
CSI
recommendation
by
further
streamlining
the
requirements
and
also
by
reducing
the
regulatory
requirements
for
CRTs
sent
to
lead
and
copper
smelters.
EPA
believes
that
the
additional
capacity
at
lead
and
copper
smelters
may
be
necessary
to
recycle
all
of
the
CRTs
generated
and,
therefore,
to
achieve
the
greatest
reduction
in
CRTs
requiring
disposal.
The
final
regulation
is
expected
to
encourage
glass­
to­
glass
and
other
types
of
recycling,
reduce
the
costs
on
the
regulated
community,
and
maintain
or
increase
the
degree
of
protection
provided
to
human
health
and
the
environment.
March
19,
2004
Page
2
The
purpose
of
this
analysis
is
to
analyze
the
costs
and
economic
impacts
of
EPA's
final
rule
related
to
encouraging
environmentally
sound
recycling
of
CRTs.
To
achieve
this
purpose
the
analysis
estimates
the
incremental
cost
of
the
final
rule
over
current
regulations
(
the
"
baseline").
The
analysis
uses
two
different
baselines:
one
that
models
full
compliance
with
RCRA
Subtitle
C
requirements
(
referred
to
as
the
Subtitle
C
management
baseline),
and
one
that
reflects
what
is
possibly
current
CRT
disposal
practice
(
referred
to
as
the
Subtitle
D
management
baseline).
The
remainder
of
this
report
is
organized
as
follows:
Section
2
provides
an
overview
of
the
types
of
entities
involved
in
generating
and
recycling
CRTs.
Section
3
describes
the
methodology
used
to
estimate
the
costs
of
the
final
rule
and
to
calculate
the
first
order
economic
impacts
associated
with
the
costs.
Sections
4
and
5
present,
respectively,
the
results
of
the
cost
analysis
for
each
of
the
two
baselines.
Section
6
presents
impact
analysis
results.
Section
7
discusses
environmental
benefits
associated
with
the
regulatory
change.
Other
administrative
requirements
are
addressed
in
Section
8.
Finally,
Section
9
concludes
with
a
summary
of
the
analytical
results.

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

The
seven
economic
based
entities
involved
in
generating
and
managing
CRTs
are:

C
original
users,

C
reusers,

C
collectors
(
including
exporters),

C
hazardous
waste
disposal
facilities,

C
reclaimers,

C
glass
processors,
and
C
CRT
glass
manufacturers.

Exhibit
2­
1
is
a
simplified
diagram
of
how
CRTs
flow
between
these
entities.
In
this
analysis,
original
users
are
businesses
that
first
use
monitors
and
televisions
for
their
intended
purpose.
They
may
be
regulated
generators
or
they
may
be
unregulated
under
RCRA,
as
discussed
in
Section
2.1.
Establishments
that
reuse
computers
are
similar
to
original
users,
but
are
typically
not
regulated
(
see
Section
2.2).
In
this
analysis,
collectors
are
intermediaries
that
accept
discarded
CRTs
from
original
users
or
reusers
prior
to
sending
the
CRTs
or
CRT
glass
to
other
entities.
Like
original
users,
collectors
may
be
regulated
generators
or
they
may
be
unregulated.
Collectors
are
described
in
more
detail
in
Section
2.3.
Reclaimers
considered
in
this
study
consist
of
secondary
lead
and
copper
smelters,
and
are
described
in
more
detail
in
Section
2.4.
Glass
processors
prepare
CRT
glass
for
introduction
into
a
CRT
glass
manufacturer's
glass
furnace,
and
are
the
subject
of
Section
2.5.
Hazardous
waste
facilities
and
CRT
glass
manufacturers
are
March
19,
2004
Page
3
included
in
Exhibit
2­
1
for
completeness
but,
because
these
types
of
entities
are
not
affected
by
the
final
rule,
they
are
not
discussed
further
in
this
overview.
Section
2.6
briefly
discusses
the
transporters
of
CRTs
that
move
CRTs
from
one
entity
to
the
next.

Exhibit
2­
1:
CRT
Life­
Cycle
Flow
Diagram
2.1
Original
Users
Original
users
are
establishments
that
first
use
and
discard
CRTs.
Original
users
include
entities
that
use
computers
and
televisions
in
the
normal
course
of
their
business
operations
and
that
periodically
discard
them.
For
example,
original
users
range
from
large
multinational
corporations
down
to
small
local
real
estate
offices.
Original
users
send
CRTs
for
reuse,
recycling,
reclamation,
disposal,
or
to
collectors.
As
considered
in
this
analysis,
original
users
do
not
include
entities
that
are
explicitly
excluded
from
hazardous
waste
requirements
(
e.
g.,
households).

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

Original
users
are
regulated
if
they
produce
hazardous
wastes
in
quantities
above
a
threshold
of
100
kilograms
(
kg)
per
month.
Original
users
that
produce
less
than
100
kg
per
month
of
hazardous
waste
are
conditionally
exempt
from
RCRA
requirements
and
are
not
1
The
number
of
CRT
monitors
is
based
on
an
assumed
monitor
life
of
3.5
years.
(
21
CRT
monitors
=
6
CRTs/
yr.
x
3.5
yrs)

March
19,
2004
Page
4
included
in
this
analysis
(
40
CFR
§
261.5).
Original
users
that
produce
between
100
and
1,000
kg
per
month
of
hazardous
waste
are
small
quantity
generators
(
SQGs)
and
must
comply
with
storage
limits,
manifesting,
recordkeeping,
and
safety
training
requirements
(
40
CFR
Part
262
generally).
Original
users
that
generate
more
than
1,000
kg
per
month
of
hazardous
waste
are
large
quantity
generators
(
LQGs)
and
must
comply
with
the
same
or
more
stringent
requirements
as
SQGs
and
must
also
comply
with
biennial
reporting
requirements.
Due
to
the
100
kg
per
month
threshold
(
equivalent
to
approximately
six
discarded
CRTs),
only
establishments
with
at
least
21
CRT
monitors
are
likely
to
qualify
as
regulated
generators
based
solely
on
their
generation
of
post­
consumer
CRTs.
1
However,
facilities
that
generate
hazardous
waste
other
than
CRTs
may
qualify
as
a
regulated
generator
with
less
than
100
kg
per
month
of
CRTs.
The
treatment
of
these
generators
in
this
analysis
is
discussed
in
Section
3.3.4.

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

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

2.3
Collectors
The
analysis
recognizes
a
category
of
entities
called
CRT
"
collectors,"
which
includes
intermediary
entities
that
collect
intact
televisions
or
computer
monitors,
and
then
send
the
CRTs
or
CRT
glass
for
reuse,
recycling,
reclamation,
or
disposal.
Because
collectors
often
make
a
decision
to
either
refurbish/
reuse
CRTs
or
to
dispose
of
them,
they
frequently
trigger
the
hazardous
waste
regulations,
becoming
potentially
regulated
generators
when
opting
to
send
CRTs
for
disposal,
reclamation,
or
recycling.
Like
original
users,
collectors
are
unregulated
if
they
send
CRTs
to
entities
(
e.
g.,
other
collectors)
that
might
refurbish/
reuse
them.

The
category
of
collectors
covers
a
wide
variety
of
entities.
For
example,
this
category
includes
establishments
that
primarily
refurbish
CRTs
for
reuse
and
also
establishments
that
primarily
dismantle
CRTs
for
recycling.
Collectors
that
primarily
refurbish
CRTs
for
reuse
tend
to
be
smaller
organizations,
including
non­
profit
entities.
Collectors
that
primarily
recycle
CRTs
2
Collectors
that
are
SQGs
are
assumed
to
not
crush
the
CRTs
because
the
large
capital
costs
of
the
crushing
equipment
and
the
relatively
low
volumes
of
CRTs
that
they
handle
does
not
make
crushing
economically
viable.
Collectors
that
are
LQGs
are
assumed
to
crush
the
CRTs
because
the
larger
volumes
of
CRTs
they
handle
combined
with
the
disposal
cost
savings
for
crushed
versus
whole
bare
CRTs
makes
the
purchase
and
operation
of
the
crushing
equipment
economically
feasible.

3
Bare
CRTs
are
televisions
or
monitors
that
have
had
the
casing,
electronics,
and
electron
gun
removed
from
them,
leaving
only
the
panel
and
funnel
glass
that
are
still
fused
together.

March
19,
2004
Page
5
are
typically
small
to
medium
for
profit
businesses.
Although
there
are
some
large
businesses
that
have
extensive
CRT
and
electronics
recycling
operations
(
e.
g.,
Hewlett
Packard).
Since
not
all
CRTs
can
be
refurbished
for
reuse,
the
collectors
that
refurbish
CRTs
typically
send
unusable
CRTs
to
collectors
that
primarily
recycle
CRTs.
Some
collectors
that
primarily
recycle
CRTs
break
and
grind
the
CRTs
to
separate
out
the
metal
from
the
glass.
Separating
the
metal
from
the
glass
also
reduces
the
CRT
management
costs
of
the
glass
if
it
is
sent
to
glass
processors.
The
grinding
process
increases
the
density
of
the
CRTs,
thus
reducing
shipping
costs,
and
also
results
in
a
better
price
from
the
glass
processor.
The
collector
category
also
includes
brokers
that
arrange
for
large
quantities
of
electronic
equipment,
including
CRTs,
to
be
sent
to
electronics
recycling
facilities
or
for
export.
This
analysis
assumes
that
collectors
that
are
SQGs
discard
bare
CRTs
and
collectors
that
are
LQGs
discard
broken
or
crushed
CRT
glass.
2
Collectors
are
assumed
not
to
generate
hazardous
waste
other
than
CRTs.

Current
RCRA
Regulatory
Requirements
Under
current
EPA
policy,
CRTs
that
are
discarded
are
assumed
to
be
products
and
not
wastes
if
there
is
the
possibility
that
the
CRTs
will
be
refurbished
or
reused.
Therefore,
under
current
requirements,
collectors
that
discard
intact
CRTs
are
only
regulated
generators
if
they
send
the
CRTs
for
intended
disposal
(
e.
g.,
a
landfill),
to
a
lead
or
copper
smelter,
or
to
a
glass
processor
that
does
not
refurbish
any
of
the
CRTs
it
receives.
Collectors
that
discard
bare
CRTs
or
broken
CRT
glass
are
regulated
generators
regardless
of
where
they
are
sent
because
it
is
assumed
they
cannot
be
reused
at
this
point.
3
Collectors
are
regulated
if
they
produce
hazardous
wastes
in
quantities
above
a
threshold
of
100
kilograms
(
kg)
per
month.
Collectors
that
produce
less
than
100
kg
per
month
of
hazardous
waste
are
conditionally
exempt
from
RCRA
requirements
and
are
not
included
in
this
analysis
(
40
CFR
§
261.5).
Collectors
that
produce
between
100
and
1,000
kg
per
month
of
hazardous
waste
are
small
quantity
generators
(
SQGs)
and
must
comply
with
storage
limits,
manifesting,
recordkeeping,
and
safety
training
requirements
(
40
CFR
Part
262
generally).
Collectors
that
generate
more
than
1,000
kg
per
month
of
hazardous
waste
are
large
quantity
generators
(
LQGs)
and
must
comply
with
the
same
or
more
stringent
requirements
as
SQGs
and
must
also
comply
with
biennial
reporting
requirements.

Final
Rule
Under
the
final
rule,
bare
intact
CRTs
that
are
sent
to
lead
or
copper
smelters
and
glass
processors
(
see
Sections
2.4
and
2.5)
are
unconditionally
excluded
from
the
definition
of
solid
4
Cutter
Information
Corp.'
s,
Product
Stewardship
Advisor,
"
The
Long­
Term
Future
of
CRT
Glass
Recycling:
How
NEC
Is
Planning
Ahead."
Volume
I,
No.
6,
November
1997.

March
19,
2004
Page
6
waste.
Used
intact
CRTs
exported
for
reuse
or
recycling
are
conditionally
excluded
when
the
exporters
notify
EPA
of
their
intent
to
export.
Used
broken
CRTs
are
conditionally
excluded
when
stored
in
containers
or
buildings.
Therefore,
the
collectors
that
send
CRTs
to
these
disposal
options
are
no
longer
considered
generators
of
CRTs.
Collectors
that
send
their
CRTs
for
disposal
continue
to
be
generators
under
the
final
rule.

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

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

Final
Rule
Reclaimers
include
entities
that
use
CRT
glass
as
a
substitute
for
raw
materials.
Under
the
final
rule
only
lead
and
copper
smelters
are
recognized
as
reclaimers.
Other
types
of
reclaimers
that
are
not
recognized
under
the
final
rule
include
establishments
that
turn
the
CRT
glass
into
a
usable
product,
such
as
glass
construction
blocks.
Another
example
is
a
reclaimer
that
has
a
value
added
process
that
turns
the
CRT
glass
into
a
marketable
product
called
LeadX,
which
can
be
used
as
a
sand­
blasting
abrasive
suitable
for
the
abatement
of
leaded
paint.
4
The
final
rule
only
changes
the
RCRA
regulatory
requirements
for
lead
and
copper
smelters,
but
not
for
other
types
of
reclaimers.

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

Final
Rule
Glass
processors
disassemble
the
televisions
and
computer
monitors,
intentionally
break
the
CRT
glass
and
prepare
the
CRT
glass,
by
cleaning
and
sorting
it,
for
shipment
to
CRT
glass
5
Pre­
consumer
CRTs
are
not
addressed
in
this
analysis.

March
19,
2004
Page
7
manufacturers.
Glass
processors
receive
discarded
post­
consumer
televisions
and
computer
monitors
from
both
original
users
and
collectors,
and
off­
specification
pre­
consumer
CRTs
from
manufacturers
of
televisions
and
computer
monitors.
5
Although
a
subset
of
collectors
perform
some
of
the
same
processing
steps
as
glass
processors,
the
primary
difference
between
glass
processors
and
collectors
is
that
glass
processors
prepare
the
glass
for
input
directly
into
a
CRT
glass
manufacturers
furnace,
while
CRT
glass
from
collectors
requires
further
processing
before
it
can
be
sent
to
a
CRT
glass
manufacturer.

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

Final
Rule
Under
the
final
rule,
any
non­
hazardous
material
carrier
may
transport
whole
televisions
and
computer
monitors
between
original
users
and
collectors
and
between
generators
and
glass
processors
without
being
certified
hazardous
waste
handlers.
Under
the
final
rule,
any
nonhazardous
material
carrier
may
transport
intact
or
broken
CRTs
between
generators
and
reclaimers
and
between
glass
processors
and
reclaimers.

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

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

These
steps,
along
with
the
applicable
data
and
assumptions
used,
are
described
below
in
Sections
3.1
through
3.10.
Section
3.11
describes
the
methodology,
data,
and
assumptions
used
6
U.
S.
Bureau
of
the
Census,
"
County
Business
Patterns:
2001."

March
19,
2004
Page
8
to
analyze
the
Subtitle
D
management
baseline
where
a
large
percentage
of
CRTs
are
disposed
in
Subtitle
D
landfills
without
treatment.
This
baseline
may
more
closely
represent
current
CRT
disposal
practices.
Section
3.12
identifies
key
assumptions
and
limitations
of
the
methodology
and
data.
It
is
worth
noting
at
this
time
that
the
CRTs
from
televisions
are
addressed
only
in
a
sensitivity
analysis
presented
in
Section
4.2.4.
For
reasons
discussed
in
Section
3.12,
this
is
not
believed
to
have
a
significant
bearing
on
the
results.

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

3.1
Estimate
the
Number
of
Original
Users
Discarding
Computer
Monitors
Computers
are
used
in
all
industries;
it
is
rare
to
find
a
business
establishment
without
at
least
one
computer.
However,
businesses
utilize
computers
at
different
rates.
For
example,
financial
institutions
are
far
more
likely
to
have
high
ratios
of
computers
per
employee
than
are
farms.
Given
that
computers
are
used,
and
therefore
discarded,
by
virtually
all
establishments,
the
total
number
of
establishments
in
three­
digit
NAICS
codes
provides
an
estimate
of
the
number
of
business
original
users
discarding
computer
monitors.
These
data
are
currently
available
for
2001
from
the
U.
S.
Bureau
of
the
Census.
The
total
number
of
establishments
in
all
NAICS
codes
in
2001
is
6,998,939.
In
addition
to
obtaining
the
total
number
of
establishments
in
each
three­
digit
NAICS
code,
the
distribution
of
establishments
by
size
and
the
number
of
employees
in
each
size
category,
as
measured
by
the
number
of
employees
per
establishment,
was
obtained
for
use
in
subsequent
steps
in
the
modeling
process.
Appendix
A
contains
tables
of
the
number
of
establishments
and
the
number
of
employees
for
all
three­
digit
NAICS
codes.

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

3.2.1
Total
Number
of
Computers
in
All
Business
Establishments
To
determine
the
total
number
of
computers
in
use
by
all
original
users,
an
estimate
of
the
ratio
of
computers
per
employee
is
developed
for
each
three­
digit
NAICS
code
based
on
two
sets
of
U.
S.
Bureau
of
the
Census
data.
The
first
data
set,
current
as
of
September
2001,
contains
the
number
of
employees
using
a
computer
and
the
total
number
of
employees
in
approximately
250
different
SIC
codes.
Using
this
information,
the
analysis
calculated
the
percent
of
employees
using
computers
in
each
of
the
SIC
codes.
The
second
data
set,
current
as
of
2001,
contains
the
number
of
establishments
and
employees
in
various
size
categories
by
NAICS
code.
6
A
crosswalk
between
the
NAICS
codes
and
the
SIC
codes
was
created,
so
that
the
average
percent
of
7
Matthews,
Scott
H.,
McMichael,
Francis
Co.,
Hendrickson,
Chris
T.,
Hart,
Deanna,
J.,
Disposition
and
End­
of­
Life
Options
for
Personal
Computers,
Carnegie
Mellon
University:
Green
Design
Initiative
Technical
Report
#
97­
10,
July
7,
1997.

8
National
Safety
Council,
Electronic
Product
Recovery
and
Recycling
Baseline
Report,
Recycling
of
Selected
Electronic
Products
in
the
United
States.
May
1999.
page
29.

9
Monochrome
computer
monitors
are
assumed
not
to
contain
enough
lead
to
qualify
them
as
hazardous
waste
when
discarded
and
thus
are
excluded
from
the
analysis.
Source:
Overview
of
Cathode
Ray
Tube
Recycling,
February
27,
1997,
page
8.
The
original
source
in
the
referenced
report
is
a
letter
from
Robert
Dodds,
Sony,
to
Nancy
Helm,
EPA
Region
X,
dated
July
8,
1996.

March
19,
2004
Page
9
employees
using
computers
could
be
developed
for
each
NAICS
code.
To
determine
the
percentages,
the
analysis
averaged
the
percentages
of
employees
using
computers
for
all
SIC
codes
that
corresponded
to
each
NAICS
code.
The
percentage
was
then
multiplied
by
the
total
number
of
employees
in
each
NAICS
code
to
obtain
the
number
of
computers
in
each
NAICS
code.
The
total
number
of
computers
in
all
business
establishments
is
the
sum
of
the
computers
used
in
each
NAICS
code.
The
model
estimates
there
are
62,829,000
computers
used
by
all
original
users.
Appendix
B
lists
the
ratios
of
computers
per
employee
for
each
NAICS
code.
Appendix
C
presents
the
crosswalk
between
the
SIC
and
NAICS
codes.
Appendix
D
presents
the
ratios
of
computers
per
employee
estimated
for
each
NAICS
code.

3.2.2
Discarded
Computer
Monitors
from
All
Original
Users
To
determine
the
total
number
of
computers
discarded
by
all
original
users,
the
estimated
number
of
computers
in
use
by
all
original
users
is
divided
by
an
estimate
of
the
average
computer
monitor
life.
The
analysis
assumes
that
computer
monitors
last
an
average
of
3.5
years
in
businesses.
A
literature
search
yielded
a
wide
range
of
estimates
for
monitor
lifetimes.
For
example,
a
1997
study
by
Carnegie
Mellon
suggested
lifetimes
of
four
to
five
years,
7
while
a
1999
report
by
the
National
Safety
Council
estimates
that
monitor
lifetimes
would
be
2.8
years
in
the
year
2000.8
The
model
results
are
sensitive
to
monitor
lifetime.
The
estimated
total
number
of
computers
discarded
per
year
by
all
original
users
is
17,951,000.
This
value
includes
monitors
that
are
sent
by
original
users
to
organizations
that
will
reuse
the
monitors
and
it
includes
laptop
computers
and
non­
CRT
monitors.

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

3.2.3
Color
CRT
Monitors
Discarded
from
All
Original
Users
To
determine
the
total
number
of
color
CRT
monitors
discarded,
the
model
subtracts
out
flat
panel
monitors
and
laptop
computers,
which
do
not
use
CRTs,
and
monochrome
monitors,
which
do
not
use
glass
with
high
lead
concentrations,
from
the
total
number
of
computers
discarded.
9
After
these
subtractions,
described
below,
the
resulting
number
of
color
monitors
discarded
per
year
by
all
original
users
is
estimated
at
12,534,000.
10
U.
S.
Bureau
of
the
Census,
Current
Industrial
Reports.
"
MA334R­
Computer
and
Office
and
Accounting
Machines."
www.
census.
gov/
cir/
www/
334/
ma334r.
html,
Accessed
August
2003.

11
Estimates
on
the
percent
of
CRT
monitors
sold
in
2002
of
all
monitors
range
from
60
percent
to
78
percent,
with
an
average
of
69
percent.
The
sources
of
these
estimates
are
the
articles
by
Gillian
Law,
Linda
Rosencrance,
and
Tom
Spring.

12
U.
S.
Bureau
of
the
Census,
"
Computer
Use
in
the
United
States:
October
1993."
www.
census.
gov/
population/
socdemo/
computer/
compwork.
txt.

March
19,
2004
Page
10
Percent
of
Discarded
Computers
that
are
Laptops.
The
model
assumes
that
25
percent
of
all
discarded
computers
are
laptops.
Laptops
have
become
an
important
segment
of
the
computer
market
over
the
last
five
to
eight
years.
Computer
sales
estimates
for
2000
indicate
that
25
percent
of
computer
sales
are
laptops.
10
The
model
results
are
somewhat
sensitive
to
the
percent
of
laptops
discarded.

Percent
of
Discarded
Monitors
that
are
Flat
Panel
Monitors.
The
model
assumes
that
five
percent
of
all
discarded
monitors
are
flat
panel
monitors.
During
the
last
few
years
flat
panel
monitors
have
become
an
increasing
segment
of
the
computer
monitor
market.
Sales
of
flat
panel
monitors
in
2002
are
estimated
to
be
approximately
30
percent
of
computer
monitor
sales.
11
Data
for
the
percent
of
flat
panel
monitors
sold
of
all
monitors
for
2000
and
2001
were
unavailable.
Flat
panel
monitors
started
to
become
widely
available
in
1999,
however,
their
initial
high
cost
slowed
their
market
penetration.
The
model
results
are
slightly
sensitive
to
the
percent
of
the
flat
panel
monitors
discarded.

Percent
of
Discarded
Monitors
that
are
Color.
The
Census
survey
from
1993
reported
that
61
percent
of
households
with
computers
have
color
monitors.
12
This
analysis
considers
that
figure
to
be
a
lower­
bound
estimate
for
businesses,
based
on
the
assumption
that
businesses
are
more
likely
to
have
color
monitors
than
households.
Since
color
monitors
have
become
much
more
common
over
the
last
ten
years,
the
model
uses
an
estimate
of
98
percent
for
the
percent
of
color
monitors
discarded
from
businesses.
The
model
results
are
not
sensitive
to
the
percent
of
color
monitors
assumed
as
a
percentage
of
all
monitors
discarded.

3.3
Estimate
the
Number
of
Regulated
Original
Users
and
Collectors
and
the
Number
of
CRTs
They
Discard
The
next
step
in
the
methodology
is
to
determine
the
number
of
original
users
and
collectors
that
are
subject
to
RCRA
requirements
for
generators
and
that
would
be
affected
by
the
final
rule.
This
section
also
estimates
the
number
of
CRTs
that
are
discarded
by
original
users
and
collectors.
To
complete
these
calculations,
the
number
of
computers
discarded
per
establishment
and
an
estimate
of
monitor
weight
is
required.
The
report
then
explains
the
methodologies
used
to
estimate
the
number
of
establishments
for
three
types
of
entities:
original
users
that
are
currently
generators
solely
due
to
CRTs;
original
users
that
are
generators
due
to
a
combination
of
CRTs
and
non­
CRT
hazardous
waste;
and
collectors
that
are
currently
generators.
13
The
table
below
presents
the
number
and
percent
of
monitors
sold
in
2000
and
2001
by
size
of
monitor.
The
source
of
the
sales
data
is
the
Electronic
Industries
Alliance
report,
Spring
2001.
The
15­
inch
monitor
weight
was
obtained
from
the
user
manuals
for
a
Sony
Trinitron
Color
Computer
Display
(
manufactured
in
1998),
and
for
an
Apple
Multiple
Scan
15
Display
(
manufactured
in
1994).
The
17­
inch
monitor
weight
was
obtained
from
the
user
manuals
for
a
Sony
Trinitron
Color
Computer
Display
(
manufactured
in
1998)
and
a
Samsung
monitor.
The
14­,
19­,
and
21­
inch
monitor
weights
are
based
on
Samsung
monitor
weights
obtained
from
user
manuals.
(
continued...)

March
19,
2004
Page
11
3.3.1
Computers
Discarded
per
Original
User
To
estimate
the
average
number
of
computers
discarded
annually
per
original
user
in
each
of
the
three­
digit
NAICS
codes,
the
analysis
uses
the
average
number
of
employees
per
establishment
in
each
size
category,
multiplies
this
estimate
by
the
number
of
computers
per
employee
(
as
discussed
in
Section
3.2.1),
and
then
adjusts
for
the
number
of
color
computer
monitors
discarded.
Exhibit
3­
1
contains
the
summary
statistics
generated
by
this
analysis
for
the
number
of
color
CRTs
discarded
per
original
user
for
all
two­
digit
SIC
codes.

Exhibit
3­
1:
Number
of
Color
CRTs
Discarded
per
Original
User
for
All
Three­
Digit
NAICS
Codes
Statistic
Number
of
Color
CRTs
Discarded
by
Establishment
Size
As
Determined
by
the
Number
of
Employeesa
20­
49
50­
99
100­
249
250­
499
500­
999
1,000­
1,499
1,500­
2,499
2,500­
4,999
>
5,000
Minimum
1
3
6
13
28
64
102
192
511
25th
Percentile
2
5
12
27
56
104
164
329
955
Median
3
7
16
36
72
132
209
400
1,175
Average
3
7
16
36
75
136
217
414
1,178
75th
Percentile
4
9
19
43
91
161
259
487
1,429
Maximum
6
13
29
64
135
227
364
682
1,820
a
Establishments
with
less
than
20
employees
are
not
expected
to
trigger
the
SQG
threshold.

The
Census
reports
the
number
of
establishments
and
he
number
of
employees
by
threedigit
NAICS
code
for
twelve
size
ranges
of
employees
(
1­
4,
5­
9,
10­
19,
20­
49,
50­
99,
100­
249,
250
to
499;
500
to
999;
1,000
to
1,499;
1,500
to
2,499;
2,500
to
4,999;
and
5,000
or
more
employees).
The
number
of
employees
is
divided
by
the
number
of
establishments
for
each
size
category
to
estimate
the
average
number
of
employees
in
each
establishment
within
each
defined
size
range.

3.3.2
Monitor
Weight
Throughout
the
analysis,
the
model
assumes
an
average
monitor
weight
of
40.6
pounds,
based
on
the
percentage
and
weight
of
each
size
of
monitor
sold
3.5
years
prior
to
the
modeled
year
which
is
2004.13
The
analysis
uses
a
weighted
average
of
the
monitors
sold
in
2000
and
2001
13
(...
continued)

Monitor
Size
(
inches)
Monitor
Weight
(
lbs)
2000
2001
Number
Sold
Percent
Sold
Number
Sold
Percent
Sold
<
=
14
23.2
500
1%
400
1%
15
30.9
20,000
38%
23,700
37%
17
42.0
25,000
48%
31,100
48%
19
­
21
63.3
6,500
13%
9,400
14%
Totals
52,000
100%
64,600
100%

14
This
calculation
assumes
that,
in
any
one
month,
an
establishment
will
be
subject
to
RCRA
regulation
if
it
discards
six
or
more
color
monitors
(
6
monitors
*
18
kg/
monitor
=
108
kg;
100
kg
per
month
is
the
threshold
for
SQGs).
Assuming
least­
cost
behavior,
the
largest
number
of
color
monitors
an
establishment
could
discard
annually
and
just
trigger
the
RCRA
requirements
for
SQGs
is
[(
11
months
*
(
6­
1
CRTs))
+
(
1
month
*
6
CRTs)
=]
61
CRTs
per
year.
Given
the
assumed
monitor
lifetime
(
3.5
years,
SQGs
must
possess
a
minimum
of
61
x
3.5,
or
214
operating
color
monitors.
The
numbers
for
LQGs
are
calculated
using
the
same
method,
with
the
threshold
for
discard
starting
at
55
color
monitors
per
month,
or
649
in
a
year,
for
a
total
number
of
computers
of
2,272
in
each
LQG
establishment.

March
19,
2004
Page
12
to
determine
the
average
weight
of
monitors
discarded
in
the
model
year.
In
the
future,
the
average
monitor
weight
is
expected
to
slightly
increase
with
the
use
of
larger
screens,
which
tends
to
push
more
original
users
into
the
regulated
universe.

3.3.3
Number
of
Original
Users
and
Collectors
that
are
Regulated
Generators
in
the
Subtitle
C
Baseline
Based
Only
on
the
Generation
of
CRTs
Original
Users
To
estimate
the
number
of
original
users
that
are
regulated
solely
due
to
their
generation
of
CRTs,
assumptions
must
be
made
regarding
the
behavior
that
establishments
will
exhibit
in
discarding
computer
monitors.
The
analysis
assumes
that
businesses
will
exhibit
least
cost
behavior
to
the
extent
possible
by
discarding
monitors
each
month
just
below
the
100
kilogram
per
month
limit
for
SQGs.
An
original
user
becomes
an
SQG
if
in
any
one
month
it
exceeds
the
100
kilogram
per
month
threshold.

Based
on
the
current
SQG
threshold
(
100
kg/
month)
and
LQG
threshold
(
1,000
kg/
month)
under
the
Subtitle
C
baseline,
and
the
assumptions
made
regarding
monitor
lifetime
and
weight,
and
the
assumed
least
cost
behavior,
original
users
who
discard
61
to
648
monitors
annually
are
SQGs
and
those
who
discard
649
or
more
monitors
annually
are
LQGs.
14
Based
on
the
assumed
monitor
lifetime
of
3.5
years,
the
smallest
SQG
possesses
214
operating
color
computer
monitors
and
the
smallest
LQG
possesses
2,272
operating
color
computer
monitors.
Under
these
assumptions
and
the
estimated
number
of
computers
discarded
per
establishment,
there
are
an
estimated
17,281
potential
SQGs
and
438
potential
LQGs
in
the
Subtitle
C
baseline
due
solely
to
the
generation
of
CRTs.
These
entities
discard
an
estimated
total
of
3,064,000
CRTs
per
year.
Some
of
these
potential
SQGs
and
LQGs
only
send
CRTs
to
collectors,
for
reuse,
or
to
glass
processors
who
refurbish
and
resell
some
of
the
monitors
they
receive.
Thus
15
The
database
is
the
International
Association
of
Electronics
Recyclers
(
IAER)
industry
directory
that
is
located
on
IAER's
web
site,
www.
iaer.
org.

16
The
ratio
of
all
hazardous
waste
generators
to
all
establishments
was
calculated
from
data
obtained
from
the
biennial
reporting
system
database
(
number
of
LQGs)
and
the
Resource
Conservation
and
Recovery
Information
System
(
RCRIS)
database
(
number
of
SQGs
in
each
SIC
code)
and
1995
U.
S.
(
continued...)

March
19,
2004
Page
13
not
all
of
the
potential
SQGs
and
LQGs
are
actually
regulated
generators.
The
analysis
estimates
that
there
are
2,938
actual
SQGs
and
74
actual
LQGs.
The
analysis
models
the
flow
of
all
of
the
CRTs
generated
by
all
the
potential
original
user
generators,
because
although
the
establishments
generating
these
CRTs
are
not
regulated,
the
CRTs
themselves
may
still
become
subject
to
regulation
with
subsequent
handlers.

Collectors
To
estimate
the
number
of
collectors
the
analysis
started
with
a
database
of
establishments
involved
in
the
electronics
recycling
industry.
15
By
comparing
this
database
with
the
names
of
electronics
recyclers
mentioned
in
the
literature
review,
a
rough
estimate
of
the
number
of
collectors
was
obtained.
The
analysis
estimates
there
are
100
potential
SQGs
and
500
potential
LQGs
that
are
collectors.
Collectors
are
assumed
to
only
be
hazardous
waste
generators
due
to
their
discarding
of
CRTs.
The
600
potentially
regulated
collectors
are
estimated
to
process
approximately
2.44
million
CRTs
per
year.
Some
of
these
potential
collectors
only
send
CRTs
for
reuse
or
for
export,
neither
of
which
are
regulated
activities
if
the
CRTs
have
the
possibility
of
being
reused.
Thus,
the
collectors
who
send
CRTs
for
reuse
or
export
are
not
considered
regulated
generators
in
this
analysis.
The
analysis
assumes
that
there
are
50
SQGs
and
250
LQGs.

3.3.4
Number
of
Original
Users
that
are
Regulated
Generators
in
the
Subtitle
C
Baseline
Due
to
a
Combination
of
CRTs
and
Non­
CRT
Hazardous
Waste
The
number
of
generators
due
in
part
to
non­
CRT
hazardous
waste
is
estimated
from
the
number
of
original
users
discarding
between
30
and
60
CRTs
per
year
and
the
total
number
of
SQGs
and
LQGs
in
each
three­
digit
NAICS
code.
The
lower
bound
of
30
CRTs
discarded
per
year
is
based
on
the
assumption
that
generators
discarding
fewer
than
30
CRTs
per
year
do
not
send
their
CRTs
to
glass­
to­
glass
processors
due
to
the
high
transportation
costs
and
low
volume
of
CRTs
discarded.
The
upper
bound
of
60
CRTs
discarded
per
year
is
used
because
original
users
generating
61
or
more
CRTs
per
year
are
captured
as
SQGs
or
LQGs
in
the
analysis
above.

The
total
number
of
all
original
users
discarding
between
30
and
60
CRTs
per
year
in
each
three­
digit
NAICS
code
is
estimated
using
the
same
methodology
as
described
in
Sections
3.3.1
to
3.3.3.
The
total
number
of
original
users
generating
between
30
and
60
CRTs
per
year
is
estimated
at
23,194.
To
estimate
the
number
of
hazardous
waste
generators
in
each
three­
digit
NAICS
code
from
the
number
of
all
establishments
discarding
30
to
60
CRTs
per
year,
the
ratio
of
all
hazardous
waste
generators
to
all
establishments
in
each
three­
digit
NAICS
code
is
multiplied
by
the
total
number
of
establishments
discarding
between
30
and
60
CRTs
per
year.
16
16
(...
continued)
Census
data.

March
19,
2004
Page
14
To
account
for
the
fact
that
SQGs
and
LQGs
are
more
likely
to
be
larger
organizations,
the
ratio
for
SQGs
is
multiplied
by
a
factor
of
1.25
and
the
ratio
for
LQGs
is
multiplied
by
a
factor
of
1.75.
Under
these
assumptions
there
are
2,754
potential
SQGs
and
831
potential
LQGs
because
they
generate
a
combination
of
CRTs
and
non­
CRT
hazardous
waste.
These
generators
discard
an
estimated
total
of
148,000
CRTs
per
year.
Some
of
these
potential
SQGs
and
LQGs
only
send
CRTs
to
collectors,
so
not
all
of
the
potential
SQGs
and
LQGs
are
actually
regulated
generators.
The
analysis
estimates
that
there
are
689
actual
SQGs
and
208
actual
LQGs.
The
total
number
of
original
user
generators
under
the
baseline
is
estimated
at
3,627
SQGs
and
282
LQGs.

A
list
of
the
number
of
SQG
and
LQG
original
users
by
three­
digit
NAICS
code
under
the
Subtitle
C
baseline
and
the
final
rule
is
shown
in
Exhibit
3­
2.
Under
the
baseline
there
are
generators
in
76
different
three­
digit
NAICS
codes.

Exhibit
3­
2:
Original
User
Generators
Under
the
Baseline
by
3­
digit
NAICS
Code
Industry
NAICS
Code
Potential
SQG
Establishments
Potential
LQG
Establishments
Due
to
CRTs
Only
Due
to
Other
Haz.
Waste
Total
Due
to
CRTs
Only
Due
to
Other
Haz.
Waste
Total
FORESTRY,
FISHING,
AND
HUNTING
Forestry
and
Logging
113
0
0
0
0
0
0
Fishing,
hunting,
and
trapping
114
0
0
0
0
0
0
Agriculture
and
forestry
support
activities
115
1
0
1
0
0
0
MINING
Oil
and
gas
extraction
211
12
12
24
0
9
9
Mining
(
except
oil
and
gas)
212
7
2
9
0
1
1
Mining
support
activities
213
18
1
19
1
0
1
UTILITIES
Utilities
221
191
67
258
1
47
48
CONSTRUCTION
Construction
of
Buildings
233
124
1
125
0
0
0
Heavy
construction
234
128
10
138
3
3
6
Special
trade
contractors
235
66
0
66
0
0
0
MANUFACTURING
Food
manufacturing
311
183
25
208
2
7
9
Beverage
and
tobacco
product
manufacturing
312
13
18
31
0
4
4
Textile
mills
313
18
21
39
0
4
4
Textile
product
mills
314
8
8
16
0
1
1
Apparel
manufacturing
315
12
1
13
0
0
0
Leather
and
allied
product
manufacturing
316
4
24
28
0
8
8
Wood
product
manufacturing
321
11
6
17
0
2
2
Paper
manufacturing
322
159
86
245
0
26
26
Printing
and
related
support
activities
323
126
29
155
0
6
6
Petroleum
and
coal
products
manufacturing
324
45
16
61
0
9
9
Chemical
manufacturing
325
251
124
375
7
93
100
Plastics
and
rubber
products
manufacturing
326
54
255
309
0
35
35
Exhibit
3­
2:
Original
User
Generators
Under
the
Baseline
by
3­
digit
NAICS
Code
(
continued)

Industry
NAICS
Code
Potential
SQG
Establishments
Potential
LQG
Establishments
Due
to
CRTs
Only
Due
to
Other
Haz.
Waste
Total
Due
to
CRTs
Only
Due
to
Other
Haz.
Waste
Total
March
19,
2004
Page
15
Nonmetallic
mineral
product
manufacturing
327
24
5
29
0
1
1
Primary
metal
manufacturing
331
187
201
388
4
112
116
Fabricated
metal
product
manufacturing
332
232
96
328
0
39
39
Machinery
manufacturing
333
371
117
488
2
28
30
Computer
and
electronic
product
manufacturing
334
587
161
748
22
44
66
Electrical
equipment,
appliance,
and
component
manufacturing
335
225
269
494
0
87
87
Transportation
equipment
manufacturing
336
573
200
773
40
96
136
Furniture
and
related
product
manufacturing
337
36
75
111
1
31
32
Miscellaneous
manufacturing
339
171
33
204
0
10
10
WHOLESALE
Wholesale
trade,
durable
goods
421
278
8
286
1
1
2
Wholesale
trade,
nondurable
goods
422
302
9
311
5
5
10
RETAIL
TRADE
Motor
vehicle
and
parts
dealers
441
19
11
30
0
0
0
Furniture
and
home
furnishing
stores
442
0
1
1
0
0
0
Electronics
and
appliance
stores
443
9
1
10
0
0
0
Building
material
and
garden
equipment
and
support
dealers
444
6
4
10
0
1
1
Food
and
beverage
stores
445
0
0
0
0
0
0
Health
and
personal
care
stores
446
6
1
7
0
0
0
Gasoline
stations
447
0
0
0
0
0
0
Clothing
and
clothing
accessories
stores
448
76
0
76
0
0
0
Sporting
goods,
hobby,
book,
and
music
stores
451
5
0
5
0
0
0
General
merchandise
stores
452
13
32
45
0
1
1
Miscellaneous
store
retailers
453
2
0
2
0
0
0
Nonstore
retailers
454
123
3
126
0
1
1
TRANSPORTATION
Air
transportation
481
147
12
159
23
4
27
Water
transportation
483
20
0
20
0
0
0
Truck
transportation
484
50
3
53
4
1
5
Transit
and
ground
passenger
transportation
485
9
1
10
0
0
0
Scenic
and
sightseeing
transportation
487
0
0
0
0
0
0
Transportation
support
activities
488
62
15
77
2
3
5
Couriers
and
messengers
492
61
11
72
27
3
30
Warehousing
and
storage
493
6
16
22
0
3
3
INFORMATION
Publishing
industries
511
320
57
377
4
11
15
Motion
picture
and
sound
recording
industries
512
34
9
43
0
1
1
Broadcasting
and
telecommunications
513
513
4
517
1
6
7
Information
and
data
processing
services
514
159
20
179
2
6
8
FINANCE
AND
INSURANCE
Monetary
authorities
­
central
bank
521
14
3
17
0
0
0
Credit
intermediation
and
related
activities
522
577
2
579
0
0
0
Security,
commodity
contracts
and
like
activity
523
344
0
344
25
0
25
Exhibit
3­
2:
Original
User
Generators
Under
the
Baseline
by
3­
digit
NAICS
Code
(
continued)

Industry
NAICS
Code
Potential
SQG
Establishments
Potential
LQG
Establishments
Due
to
CRTs
Only
Due
to
Other
Haz.
Waste
Total
Due
to
CRTs
Only
Due
to
Other
Haz.
Waste
Total
March
19,
2004
Page
16
Insurance
carriers
and
related
activities
524
590
0
590
51
0
51
Funds,
trusts,
and
other
financial
vehicles
(
part)
525
11
0
11
0
0
0
REAL
ESTATE
AND
RENTAL
AND
LEASING
Real
estate
531
85
1
86
0
0
0
Rental
and
leasing
services
532
65
7
72
0
0
0
Lessors
of
other
nonfinancial
intangible
asset
533
14
0
14
0
0
0
PROFESSIONAL,
SCIENTIFIC,
AND
TECHNICAL
SERVICES
Professional,
scientific
and
technical
services
541
938
4
942
22
1
23
MANAGEMENT
OF
COMPANIES
AND
ENTERPRISES
Management
of
companies
and
enterprises
551
2,342
0
2,342
75
0
75
ADMINISTRATIVE
AND
SUPPORT
AND
WASTE
MANAGEMENT
AND
REMEDIATION
SERVICES
Administrative
and
support
services
561
1,938
23
1,961
0
4
4
Waste
management
and
remediation
services
562
20
11
31
0
6
6
EDUCATIONAL
SERVICES
Educational
services
611
684
40
724
35
4
39
HEALTH
CARE
AND
SOCIAL
ASSISTANCE
Ambulatory
health
care
services
621
426
5
431
3
1
4
Hospitals
622
2,721
567
3,288
71
64
135
Nursing
and
residential
care
facilities
623
18
3
21
0
0
0
Social
assistance
624
24
0
24
0
0
0
ARTS,
ENTERTAINMENT,
AND
RECREATION
Performing
arts,
spectator
sports
and
related
industries
711
68
4
72
0
1
1
Museums,
historical
sites
and
like
institutions
712
19
2
21
0
0
0
Amusement,
gambling
and
recreation
industries
713
90
0
90
0
0
0
ACCOMMODATION
AND
FOOD
SERVICES
Accommodation
721
0
0
0
0
0
0
Food
services
and
drinking
places
722
89
0
89
0
0
0
OTHER
SERVICES
Repair
and
maintenance
811
30
0
30
0
0
0
Personal
and
laundry
services
812
4
1
5
0
0
0
Religious,
grant
making,
civic,
prof
and
like
organizations
813
113
0
113
4
0
4
Total
Original
Users
Under
the
Baseline
17,281
2,754
20,035
438
831
1,269
Total
Number
of
Actual
Original
User
Generators
Under
the
Baseline
2,938
689
3,627
74
208
282
Total
Number
of
Actual
Original
User
Generators
Under
the
Final
Rule
401
SQGs
2,592
Not
Regulated
26
LQGs
65
Not
Regulated
3.3.5
Number
of
Original
Users
and
Collectors
that
are
Regulated
Generators
Under
the
Final
Rule
Under
the
final
rule,
the
generators
under
the
baseline
that
send
their
monitors
to
glass
processors
or
reclaimers
are
no
longer
regulated
as
generators
of
hazardous
waste.
However,
the
March
19,
2004
Page
17
baseline
generators,
whether
original
users
or
collectors,
that
continue
to
send
monitors
for
hazardous
waste
disposal
will
be
subject
to
full
RCRA
Subtitle
C
regulation
and
will
qualify
as
SQGs
or
LQGs
at
the
RCRA
thresholds
of
100
and
1,000
kilograms
of
CRTs
generated
per
month,
respectively.

The
analysis
assumes
that
two
percent
of
original
users
(
both
SQGs
and
LQGs)
will
send
their
monitors
for
disposal
under
the
final
rule.
This
assumption
is
based
on
the
high
costs
associated
with
disposal
of
intact
CRTs
and
anecdotal
evidence
regarding
the
current
disposal
practices.
For
original
users
under
this
assumption,
there
are
401
SQGs,
26
LQGs,
and
3,482
former
generators
under
the
final
rule.
For
collectors,
the
analysis
assumes
that
two
percent
of
collectors
will
continue
to
send
at
least
one
shipment
per
year
for
disposal.
Thus
the
analysis
estimates
there
are
two
SQG
collectors,
ten
LQG
collectors,
and
288
former
generators
that
are
collectors
under
the
final
rule.

3.4
Flow
of
CRTs
from
Generators
to
Disposal
Sites
Under
the
Subtitle
C
Baseline
The
analysis
considers
the
flow
of
CRTs
from
original
users,
through
collectors,
reusers,
and
glass
processors,
and
on
to
treatment
and
disposal
destinations.
Exhibit
3­
3
presents
a
simplified
diagram
of
this
flow
under
the
Subtitle
C
baseline,
which
shows
how
CRTs
flow
from
original
users
to
the
final
CRT
management
options.
The
exhibit
shows
that
the
CRT
management
options
for
original
users
include
collectors,
establishments
that
reuse
CRTs,
hazardous
waste
treatment
and
disposal
facilities,
reclaimers,
and
glass
processors.
The
CRT
management
options
for
collectors
include
establishments
that
reuse
CRTs,
hazardous
waste
treatment
and
disposal
facilities,
reclaimers,
and
glass
processors.
The
CRT
management
options
for
glass
processors
include
reclaimers
and
CRT
glass
manufacturers.
The
actual
flows
modeled
for
this
baseline
are
presented
in
Exhibit
3­
4.

Exhibit
3­
3:
CRT
Life­
Cycle
Flow
Diagram
17
National
Safety
Council,
Electronic
Product
Recovery
and
Recycling
Baseline
Report,
Recycling
of
Selected
Electronic
Products
in
the
United
States.
May
1999.

March
19,
2004
Page
18
The
analysis
recognizes
that
the
final
rule
will
provide
incentives
for
behavioral
changes
and
will
result
in
altered
flows.
Exhibit
3­
5
shows
the
flows
assumed
to
occur
under
the
final
rule.
It
reflects
all
CRTs
that
are
regulated
in
the
baseline,
even
though
many
of
them
will
be
unregulated
post­
rule.
These
two
exhibits
show
the
estimated
percentages
for
the
flow
of
CRTs
from
each
type
of
entity
to
each
of
the
various
CRT
management
options,
and
the
total
tons
of
CRTs
sent
from
each
type
of
entity.
Thus,
the
total
tons
of
CRTs
generated
multiplied
by
each
percentage
yields
the
tons
of
CRTs
sent
from
each
type
of
generator
to
each
CRT
management
option.
These
two
exhibits
also
show,
for
reference
purposes,
representative
disposal
costs
for
each
CRT
management
option
to
provide
an
indication
of
the
comparative
economic
advantage
of
sending
CRTs
to
each
CRT
management
option.

Collectors
and
glass
processors
are
only
intermediaries
in
the
flow
of
CRTs
towards
their
ultimate
disposal
endpoint.
Thus
all
of
the
CRTs
that
collectors
and
glass
processors
receive
are
expected
to
be
sent
to
other
entities.
Although
reuse
is
not
the
ultimate
disposal
endpoint
for
CRTs,
within
the
one
year
time
frame
of
this
analysis,
CRTs
that
are
sent
for
reuse
are
not
expected
to
be
discarded
again,
since
the
expected
lifetime
of
a
reused
CRT
is
two
to
four
years.
17
Under
the
final
rule,
3,959
additional
tons
of
CRTs
are
sent
to
glass
processors
relative
to
the
Subtitle
C
baseline.
These
CRTs
are
re­
directed
primarily
from
hazardous
waste
facilities
(
decrease
of
2,859
tons)
and
from
export
(
decrease
of
5,579
tons)
under
the
baseline.
The
2,859
tons
of
CRTs
diverted
from
landfills
translates
to
a
volume
of
423,000
cubic
feet.
The
tons
of
CRTs
recycled
under
the
final
rule
increases
by
6,176
tons
over
the
baseline.

Under
the
Subtitle
C
baseline,
generators
will
send
the
minimum
number
of
shipments
to
stay
in
compliance
with
hazardous
waste
accumulation
limits.
For
small
quantity
generators,
the
storage
limit
is
180
days;
these
establishments
will
make
two
shipments
per
year.
Large
quantity
generators
have
a
storage
limit
of
90
days;
they
will
make
four
shipments
per
year.
Collectors
are
assumed
to
handle
relatively
larger
volumes
of
CRTs
and
thus
are
assumed
to
ship
CRTs
when
they
have
full
loads
or
at
least
four
times
per
year
for
LQGs
and
two
times
a
year
for
SQGs.
On
average,
collectors
ship
CRTs
two
and
four
times
per
year,
respectively
for
SQGs
and
LQGs.
Glass
processors
are
also
assumed
to
handle
relatively
larger
volumes
of
CRTs
and
thus
are
assumed
to
ship
CRTs
when
they
have
full
loads
or
at
least
four
times
per
year.
On
average
glass
processors
ship
CRT
funnel
and
panel
glass
93
and
128
times
per
year
under
the
baseline
and
the
final
rule,
respectively.
Under
the
final
rule,
each
former
generator
is
assumed
to
send
discarded
CRTs
off­
site
once
a
year
or
more
frequently
if
the
volume
of
CRTs
warrants
increased
shipment
frequency.
March
19,
2004
Page
19
Exhibit
3­
4:
Assumed
Distribution
of
Discarded
Monitors
and
CRT
Glass
Under
the
Subtitle
C
Management
Baseline
Entity
Distributing
CRTs
Reuse
Export
Intermediate
Processors
Disposal
Options
Total
Percent
Total
Tons
Disposed
Collector
Glass
Processor
Hazardous
Waste
Facility
Reclaimer
CRT
Glass
Manufacturer
Disposal
Cost*
$
0/
ton
(
I)
$
108/
ton
(
I)
$
274/
ton
(
I)
$
344/
ton
(
I)

$
0/
ton
(
C)
$
1,548/
ton
(
I)

$
165/
ton
(
C)
$
211/
ton
(
I)

$
153/
ton
(
C)
­
$
181/
ton
(
C)

Original
User
SQGs
and
LQGs
Due
to
CRTs
Only
2%
(
I)
0%
76%
(
I)
5%
(
I)
2%
(
I)
15%
(
I)
NA
100%
62,203
Due
to
CRTs
and
Non­
CRT
Hazardous
Waste
0%
(
I)
0%
75%
(
I)
0%
25%
(
I)
0%
NA
100%
3,006
Collectors
SQGs
20%
(
I)
30%
(
I)
NA
25%
(
B)
2%
(
B)
23%
(
B)
NA
100%
3,302
LQGs
20%
(
I)
30%
(
I)
NA
30%
(
C)
10%
(
C)
10%
(
C)
NA
100%
36,321
Glass
Processors
0%
0%
NA
NA
0%
2%
(
C)
98%
(
C)
100%
10,658
Total
Tons
11,150
14,859
49,529
10,658
4,769
12,837
10,444
*
Disposal
costs
shown
are
representative
simplifications
of
the
actual
costs
used
in
the
analysis.
See
Exhibit
3­
8
for
further
details.

(
I)
=
Intact
whole
monitors.

(
B)
=
Bare
CRTs
without
the
casing.

(
C)
=
Crushed
CRT
glass.

NA
=
Not
Applicable.
March
19,
2004
Page
20
Exhibit
3­
5:
Assumed
Distribution
of
Discarded
Monitors
Under
the
Final
Rule
Entity
Distributing
CRTs
Reuse
Export
Intermediate
Processors
Disposal
Options
Total
Percent
Total
Tons
Disposed
Collector
Glass
Processor
Hazardous
Waste
Facility
Reclaimer
CRT
Glass
Manufacturer
Disposal
Cost*
$
0/
ton
(
I)
$
108/
ton
(
I)
$
274/
ton
(
I)
$
344/
ton
(
I)

$
0/
ton
(
C)
$
1,548/
ton
(
I)

$
165/
ton
(
C)
$
211/
ton
(
I)

$
153/
ton
(
C)
­
$
181/
ton
(
C)

Original
Users
SQGs
and
LQGs
NA
NA
NA
NA
100%
(
I)
NA
NA
100%
1,312
Former
SQGs
and
LQGs
2%
(
I)
0%
78%
(
I)
5%
(
I)
NA
15%
(
I)
NA
100%
63,898
Collectors
Regulated
Post­
Rule
SQGs
NA
NA
NA
NA
100%
(
B)
NA
NA
100%
50
LQGs
NA
NA
NA
NA
100%
(
C)
NA
NA
100%
548
Unregulated
Post­
Rule
Former
SQGs
20%
(
I)
30%
(
I)
NA
25%
(
B)
NA
25%
(
B)
NA
100%
3,256
Former
LQGs
20%
(
I)
18%
(
I)
NA
45%
(
C)
NA
17%
(
C)
NA
100%
33,669
Glass
Processors
0%
0%
NA
NA
0%
2%
(
C)
98%
(
C)
100%
14,616
Total
Tons
11,047
9,280
49,840
14,616
1,910
15,054
14,324
*
Disposal
costs
shown
are
representative
simplifications
of
the
actual
costs
used
in
the
analysis.
See
Exhibit
3­
8
for
further
details.

(
I)
=
Intact
whole
monitors.

(
B)
=
Bare
CRTs
without
the
casing.

(
C)
=
Crushed
CRT
glass.

NA
=
Not
Applicable.
18
National
Safety
Council,
Electronic
Product
Recovery
and
Recycling
Baseline
Report,
Recycling
of
Selected
Electronic
Products
in
the
United
States.
May
1999.

March
19,
2004
Page
21
3.4.1
Disposal
Option
Assumptions
The
following
assumptions
are
used
to
develop
the
estimates
of
the
volume
of
discarded
monitors
being
sent
to
each
of
the
disposal
alternatives
(
collectors,
reuse,
hazardous
waste
facilities,
reclaimers,
and
glass
processors):

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

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

C
Businesses
donating
computers
are
concerned
about
proprietary
information
that
may
be
left
on
hard
drives.
This
concern
reduces
the
number
of
computers
that
businesses
donate.

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

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

Collectors.
Under
the
baseline,
the
analysis
assumes
that
76
percent
of
CRTs
from
original
users
are
sent
to
collectors.
CRTs
going
to
collectors
are
consolidated,
reused
when
possible,
demanufactured
and
recycled,
or
refurbished.
Although
collectors
are
not
the
least
expensive
disposal
option
they
become
an
economically
attractive
alternative
when
administrative
and
transportation
costs
are
considered.
Thus,
most
discarded
CRTs
are
assumed
to
be
sent
to
collectors.
There
are
two
factors
that
reduce
the
costs
of
sending
CRTs
to
collectors.
First,
collectors
are
typically
located
near
businesses,
and
thus
the
transportation
costs
are
comparatively
low.
Second,
CRTs
sent
to
collectors
are
considered
a
product
and
not
a
waste
and
thus
do
not
fall
under
RCRA
control.
19
Envirosafe
Services
of
Ohio
reported
receiving
no
CRTs
in
2000
and
approximately
20
to
30
tons
in
1999.
Clean
Harbours
in
Massachusetts
reported
that
they
do
receive
CRTs,
however,
all
of
the
CRTs
they
receive
are
processed
in
Clean
Harbours
Bristol
Connecticut
recycling
facility
and
none
are
disposed.

March
19,
2004
Page
22
The
collectors
typically
will
consolidate
the
CRTs
from
various
establishments
and
send
them
to
reclaimers
or
glass
processors.
The
collectors
demanufacture
the
monitors
and
recycle
the
components
that
have
value.
The
analysis
assumes
that
LQG
collectors
have
high
enough
volumes
of
CRTs
to
warrant
purchasing
glass
crushing
equipment.
Thus
all
shipments
of
CRTs
from
LQGs
to
glass
processors,
hazardous
waste
facilities,
and
reclaimers
are
assumed
to
be
crushed
CRT
glass,
which
has
economic
benefit.
The
baseline
assumes
that
30
percent
of
the
CRTs
the
LQG
collectors
receive
are
crushed
and
sent
to
glass
processors,
10
percent
are
crushed
and
sent
to
reclaimers,
and
10
percent
are
crushed
and
sent
to
hazardous
waste
facilities.
Crushing
the
CRTs
significantly
reduces
the
disposal
costs
charged
by
glass
processors,
reclaimers,
and
hazardous
waste
facilities.
More
CRTs
are
assumed
to
be
sent
to
glass
processors
because
the
low
disposal
cost
for
crushed
glass
at
glass
processors
often
outweighs
the
higher
transportation
costs
due
to
longer
distances.
As
mentioned
above,
20
percent
of
the
regulated
CRTs
that
collectors
receive
are
refurbished
and
sold
for
reuse.
Thirty
percent
of
the
CRTs
received
by
collectors
are
assumed
to
be
exported
for
reuse
or
recycling.
Since
SQG
collectors
do
not
crush
the
CRT
glass
they
are
assumed
to
send
more
CRTs
to
reclaimers
than
to
hazardous
waste
facilities,
because
of
the
lower
tipping
fees
at
reclaimers.
Under
the
final
rule
the
analysis
assumes
that
more
crushed
CRTs
are
sent
to
glass
processors
because
of
the
low
tipping
fees
and
absence
of
administrative
costs.
Similarly,
more
crushed
CRTs
are
assumed
to
be
sent
to
reclaimers
and
less
are
sent
to
hazardous
waste
facilities
because
of
the
administrative
burden
on
CRTs
sent
to
hazardous
waste
facilities.

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

Hazardous
Waste
Facilities.
The
analysis
assumes
that
original
users,
who
are
generators
due
to
CRTs
only,
will
send
two
percent
of
discarded
CRTs
to
hazardous
waste
facilities
in
the
Subtitle
C
baseline,
and
that
this
percentage
remains
at
two
percent
under
the
final
rule.
Several
contacts
at
one
of
the
largest
Subtitle
C
facilities
in
the
United
States,
Chemical
Waste
Management,
reported
receiving
no
CRTs
during
1998.
Contacts
at
other
commercial
hazardous
waste
disposal
facilities
also
report
receiving
few
CRTs
for
disposal
over
the
last
couple
of
years.
19
However,
a
Tufts
University
study
reports
that
14
percent
of
CRTs
are
sent
to
landfills
or
municipal
waste
combustors.
The
Tufts
data
are
believed
to
include
monitors
from
households.
Households
are
more
likely
to
send
their
CRTs
to
landfills
than
are
RCRA
regulated
establishments
because
households
incur
no
direct
costs
to
send
monitors
to
Subtitle
D
landfills,
but
it
is
expensive
for
regulated
generators
to
send
monitors
for
treatment
and
disposal
in
Subtitle
C
or
D
landfills.
Sending
intact
CRTs
to
a
hazardous
waste
facility
is
more
expensive
than
sending
the
CRTs
to
lead
or
copper
smelters
or
glass
processors.
Therefore,
most
CRTs
ending
up
at
20
Doe
Run
indicated
that
they
accept
whole
monitors.
The
article
by
Aanstoos,
T.,
Mizuki,
C.,
Nichols,
S.,
and
Pitts,
G.
CRT
Disposition:
An
Assessment
of
Limitations
and
Opportunities
in
Reuses,
Refurbishment,
and
Recycling
in
the
U.
S.
(
page
75)
states
that
lead
smelters
accept
whole
monitors.

21
Conversation
with
Greg
Vorhees
of
Envirocycle,
April
25,
2001.

22
Sony
Trinitron
Color
Computer
Display
(
manufactured
in
1998)
owners
manual.

23
Based
on
a
conversation
with
Chris
Beyus
of
Clean
Harbor.

March
19,
2004
Page
23
hazardous
waste
facilities
are
probably
originating
in
areas
of
the
country
without
nearby
lead
or
copper
smelters,
glass
processors,
or
collectors.

Reclaimers.
The
analysis
assumes
that
under
the
Subtitle
C
baseline,
15
percent
of
CRTs
from
original
users
are
sent
directly
to
reclaimers
and
that
this
percentage
remains
constant
under
the
final
rule.
Lead
and
copper
smelters
receive
monitors
from
original
users,
collectors,
and
glass
processors.
Most
reclaimed
CRTs
are
sent
to
lead
smelters;
however,
copper
smelters
also
accept
CRT
glass.
The
glass
is
used
as
a
fluxing
agent
in
the
smelting
furnaces.
Two
references
indicated
that
lead
smelters
take
whole
monitors,
crush
them,
and
then
add
the
crushed
monitor
to
the
smelting
furnace.
20
However,
Noranda
indicated
that
the
monitor's
plastic
casing
tends
to
foul
their
sulfuric
acid
plant,
so
they
only
accept
the
glass.
Copper
smelters
put
crushed
or
whole
monitors
into
the
smelting
furnace
to
recover
the
copper
from
the
electronics
and
use
the
glass
as
a
fluxing
agent.
Glass
processors
send
approximately
two
percent
of
the
glass
they
receive
to
reclaimers.
21
This
CRT
glass
is
in
the
form
of
fines
that
cannot
be
sent
to
CRT
glass
manufacturers.

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

Monitor
Shipping
Size.
A
typical
15
inch
monitor
has
a
volume
of
1.5
cubic
feet.
22
Based
on
the
assumption
that
discarded
CRT
monitors
will
be
shipped
carefully
to
avoid
breakage
of
the
CRT
glass,
the
model
includes
the
assumption
that
the
monitors
will,
on
average,
occupy
3.0
cubic
feet
during
shipment.
23
This
includes
approximately
0.3
cubic
feet
per
monitor
for
the
actual
packing
material,
such
as
a
pallet
or
box.
Whole
monitors
or
whole
CRTs
are
placed
on
a
pallet
and
wrapped
in
plastic,
or
are
placed
in
one
cubic
yard
boxes
(
Gaylord
containers)
to
minimize
breakage
and
to
contain
any
broken
glass
during
transport.

Truck
Capacity.
The
maximum
number
of
monitors
that
can
be
shipped
in
a
truck
by
volume
and
weight
is
calculated
to
determine
if
the
largest
individual
shipment
from
a
generator
or
handler
could
be
sent
in
one
truck
or
would
require
two
trucks.
A
truck
volume
of
4,280
cubic
feet
represents
the
volume
of
a
semi­
trailer
measuring
9.5
by
53
by
8.5
feet,
which
is
the
largest
standard
for
trailers.
A
truck
of
this
size
carries
up
to
1,426
monitors
(
based
on
the
assumption
that
the
shipping
size
of
a
monitor
is
3.0
cubic
March
19,
2004
Page
24
feet).
The
maximum
payload
for
standard
trucks
is
about
22
tons,
which
is
equivalent
to
1,083
monitors
weighing
40.6
pounds
each.
Thus
the
truck
weight
limit
is
the
limiting
factor.
The
maximum
number
of
CRTs
that
the
largest
establishments
are
estimated
to
generate
in
one
year
is
1,820
(
see
Exhibit
3­
1).
Thus
under
the
final
rule,
where
generators
can
accumulate
CRTs
up
to
one
year,
shipments
from
the
largest
generators
would
require
two
truckloads
per
year.
Under
the
baseline
it
is
assumed
that
all
SQGs
ship
twice
a
year
and
that
all
LQGs
ship
four
times
per
year.
Under
the
final
rule,
for
the
generators
that
now
send
CRTs
to
glass
processors
or
reclaimers
and
are
thus
eligible
for
regulatory
relief,
the
model
assumes
that
all
former
SQGs
and
former
LQGs
make
the
number
of
shipments
per
year
that
minimizes
the
total
of
their
administrative,
storage,
and
transportation
costs.
The
analysis
estimates
that
under
the
final
rule
former
SQGS
make
one
shipments
and
former
LQGs
make
one
shipment
per
year.

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

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

The
analysis
models
the
current
management
of
discarded
CRTs
assuming
100
percent
compliance
with
RCRA
Subtitle
C
requirements
under
the
Subtitle
C
baseline.
Administrative
activities
required
under
Subtitle
C
and
the
associated
unit
costs
are
summarized
in
Exhibit
3­
6.

3.5.2
Baseline
Unit
Costs
for
Original
Users
Also
Generating
Non­
CRT
Hazardous
Waste
The
analysis
models
the
current
management
of
discarded
CRTs
assuming
100
percent
compliance
with
RCRA
Subtitle
C
requirements
under
the
Subtitle
C
baseline.
However,
most
of
the
administrative
costs
(
all
but
manifests
for
shipments
of
CRTs
to
smelters
and
glass
processors
that
do
not
refurbish
CRTs)
are
assumed
to
be
due
to
non­
CRT
hazardous
waste
and
thus
are
not
included
in
the
analysis.
The
manifest
costs
that
are
assumed
to
be
due
to
CRTs
are
only
for
shipments
to
smelters
and
glass
processors
that
do
not
refurbish
CRTs
and
have
the
same
cost
as
contained
in
Exhibit
3­
6.

3.5.3
Final
Rule
The
full
Subtitle
C
administrative
requirements
are
eliminated
under
the
final
rule
for
entities
shipping
CRTs
to
collectors,
glass
processors,
and
lead
and
copper
smelters.
The
activities
required
for
these
entities
are
only
packaging
and
labeling
requirements
for
CRTs
that
are
broken.
Generators
sending
CRT
waste
for
disposal
are
still
subject
to
full
RCRA
requirements.
March
19,
2004
Page
25
Exhibit
3­
6:
Generator
Administrative
Requirements
and
Unit
Costs
Under
the
Subtitle
C
Baseline
Required
Activity
Unit
Costs
SQG
LQG
One­
Time
Costs*
Notification
of
Hazardous
Waste
Activity
$
231
$
231
Rule
Familiarization
$
93
$
93
Emergency
Planning
$
563
$
831
Total
One­
Time
Costs
per
Facility
$
887
$
1,155
Annual
Costs
Annual
Review
of
Regulations
$
63
$
63
Recordkeeping
$
50
$
50
Personnel
Safety
Training
(
annualized
cost)
$
384
$
486
Manifest
Training
$
37
$
181
Biennial
Reporting
(
annualized
cost)
$
0
$
205
Total
Annual
Costs
per
Facility
$
567
$
985
Variable
Costs**
Manifest
and
Land
Disposal
Restriction
Notification
(
per
shipment)
$
45
$
56
Exception
Reporting
(
per
report)***
$
46
$
102
Storage
Costs
(
per
square
foot
of
storage
area)
$
8
$
8
*
Each
year
one
percent
of
the
generators
are
assumed
to
be
new
facilities
and
thus
they
incur
additional
costs
as
startup
facilities.
The
entry
rate
is
used
to
determine
the
number
of
establishments
expected
to
incur
initial
costs
in
any
year
(
one
percent
of
the
generator
universe).
**
Variable
costs
depend
on
the
number
of
shipments
made
by
a
generator.
The
number
of
shipments
per
year
is
calculated
and
used
to
estimate
the
administrative
costs.
***
The
analysis
uses
an
estimate
of
one
half
of
one
percent
of
manifests
require
an
exception
report.
Sources
of
Cost
Data:
Supporting
Statement
for
EPA
ICR
#
261
"
Reporting
and
Recordkeeping
Requirements
for
Generators
of
Mercury­
Containing
Lamps"
June
29,
1994;
Supporting
Statement
for
ICR
#
801
"
Requirements
for
Generators,
Transporters,
&
Waste
Management
Facilities
Under
the
RCRA
Hazardous
Waste
Manifest
System."
2/
13/
97;
Technical
Background
Document,
Economic
Impact
Analysis
for
the
Proposes
Rule
for
the
Management
of
Spent
Mercury­
Containing
Lamps.
1994;
and
Supporting
Statement
for
EPA
ICR
#
0976,
Amendment
to
OMB
ICR
#
2050­
0024
"
Analysis
of
Costs
Under
Draft
Modifications
to
The
Manifest
System,
Final
Report,"
August
1,
1997.

Administrative
activities
required
under
the
final
rule
and
the
associated
unit
costs
are
summarized
in
Exhibit
3­
7.

3.6
Estimate
Disposal
Costs
The
CRT
management
options
currently
being
used
by
CRT
generators
include
giving
CRTs
to
establishments
that
will
reuse
them,
and
sending
CRTs
to
collectors,
glass
processors,
smelters,
or
treatment
and
disposal
facilities
that
dispose
of
the
treated
CRTs
in
Subtitle
C
or
D
landfills.
The
per
ton
cost
for
each
disposal
option
is
based
on
a
literature
search
and
on
contacts
at
representative
facilities.
The
disposal
costs
obtained
for
each
disposal
option
varied
considerably.
The
maximum
cost
typically
is
two
to
four
times
the
minimum
cost
obtained
for
each
disposal
option.
For
each
disposal
option
the
average
of
the
costs
obtained
is
used
in
the
analysis.
Exhibit
3­
8
summarizes
the
cost
per
ton
for
each
disposal
option.
March
19,
2004
Page
26
Exhibit
3­
7:
Generator
Administrative
Requirements
and
Unit
Costs
Under
the
Final
Rule
Required
Activity
Unit
Costs
SQG
LQG
Exporters
One­
Time
Costs*
Rule
Familiarization
Notification
of
Intent
to
Export
for
Reuse
$
93
NA
$
93
NA
NA***
$
50
Total
One­
Time
Costs
per
Facility
$
93
$
93
NA
Annual
Costs
Recordkeeping
(
exporters
only)
Notification
of
Intent
to
Export
for
Recycling
$
0
$
0
$
49
$
201
Total
Annual
Costs
per
Facility
$
0
$
0
$
250
Variable
Costs**
Labeling
and
Packaging
Requirements
for
Shipments
of
Broken
CRTs
$
19
$
19
NA***
Storage
Costs
(
per
square
foot
of
storage
area)
$
8
$
8
NA***
*
Each
year
one
percent
of
the
generators
are
assumed
to
be
new
facilities
and
thus
they
incur
additional
costs
as
startup
facilities.
The
entry
rate
is
used
to
determine
the
number
of
establishments
expected
to
incur
initial
costs
in
any
year
(
one
percent
of
the
generator
universe).
**
Variable
costs
depend
on
the
number
of
shipments
made
by
a
generator.
The
number
of
shipments
per
year
is
calculated
and
used
to
estimate
the
administrative
costs.
***
Costs
captured
under
SQG
and
LQG
categories.
Sources
of
Cost
Data:
Supporting
Statement
for
EPA
ICR
#
261
"
Reporting
and
Recordkeeping
Requirements
for
Generators
of
Mercury­
Containing
Lamps"
June
29,
1994;
Supporting
Statement
for
ICR
#
801
"
Requirements
for
Generators,
Transporters,
&
Waste
Management
Facilities
Under
the
RCRA
Hazardous
Waste
Manifest
System."
2/
13/
97;
Technical
Background
Document,
Economic
Impact
Analysis
for
the
Proposes
Rule
for
the
Management
of
Spent
Mercury­
Containing
Lamps.
1994;
and
Supporting
Statement
for
EPA
ICR
#
0976,
Amendment
to
OMB
ICR
#
2050­
0024
"
Analysis
of
Costs
Under
Draft
Modifications
to
The
Manifest
System,
Final
Report,"
August
1,
1997.
Supporting
Statement
for
EPA
Information
Collection
Request
Number[]
"
Reporting
and
Recordkeeping
Requirements
for
the
Proposed
Rule
on
Cathode
Ray
Tube
(
CRT)
Glass
Reuse."
Working
Draft,
October
9,
1998.
March
19,
2004
Page
27
Exhibit
3­
8:
CRT
Disposal
Costs
(
per
ton)

Disposal
Option
Cost
(
Price
Paid)
per
Ton
Collectors
$
274
Export
$
108
Reuse
$
0
Treatment
and
Subtitle
C
or
D
Landfill
Disposal
Whole
CRTs
$
1,548
Crushed
CRTs
$
165
Reclaimer
Whole
CRTs
$
300
Whole
bare
CRTs
$
211
Crushed
CRTs
$
153
Glass
Processor
Broken
CRTs
with
no
metal
$
0
Broken
CRTs
with
metal
$
103
Whole
bare
CRTs
$
198
Broken
mixed
color
and
monochrome
CRTs
$
335
Whole
CRTs
$
344
CRT
Glass
Manufacturer
($
181)
Details
of
the
disposal
costs
by
source
are
presented
in
Appendix
E.

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

C
the
collectors
get
the
highest
benefit
from
returning
the
CRTs
to
the
market
place
as
quickly
as
possible,
and
thus
are
less
likely
to
wait
until
they
have
a
full
truckload.

C
the
shipping
distances
for
reuse
are
likely
to
be
relatively
short,
because
most
CRTs
are
reused
locally,
thus
the
expense
of
sending
partial
loads
is
roughly
equivalent
to
sending
full
shipments.

C
collectors
who
primarily
refurbish
CRTs
for
reuse
tend
to
be
smaller
and
handle
smaller
volumes
and
thus
may
take
a
long
time
to
generate
a
full
truckload
of
CRTs
for
reuse.
March
19,
2004
Page
28
Exhibit
3­
9
provides
a
summary
of
the
two
factors
(
i.
e.,
hazardous
or
non­
hazardous
transport
and
partial
or
full
truckload)
that
drive
the
transportation
costs
for
each
of
the
disposal
options.
The
analysis
assumes
that
shipments
of
less
than
one
truckload
are
consolidated
by
the
shipping
company
prior
to
trucking
the
waste
CRTs
to
a
disposal
facility,
and
that
consolidated
rates
are
passed
on
to
generators.
The
analysis
assumes
consolidated
shipments
because
of
the
low
volumes
of
waste
(
0.2
to
14
tons
for
original
users
and
11
to
21
tons
for
collectors
under
the
baseline)
and
because
generators
are
clustered
around
urban
and
suburban
areas.
As
discussed
in
Section
3.4,
regulated
generators
are
found
in
76
different
three­
digit
NAICS
codes.
For
any
individual
generator
the
assumption
made
in
this
analysis
will
not
be
accurate.
However,
in
the
aggregate
the
assumptions
used
in
the
analysis
reasonably
estimate
the
actual
transportation
costs
incurred.

Exhibit
3­
9:
Transportation
Cost
Driver
Assumptions
CRT
Management
Options
Collectors
Reuse
Treatment
&
Disposal
Reclaimer
Glass
Processor
CRT
Glass
Manufacturer
Baseline
Original
Users
NH
­
LTT
NH
­
LTT
H
­
LTT
H
­
LTT
NH
­
LTT
NA
Collectors
NA
NH
­
LTT
H
­
TL
H
­
TL
H
­
TL
NA
Glass
Processors
NA
NA
NA
H
­
TL
NA
H
­
TL
Final
Rule
Original
Users
NH
­
LTT
NH
­
LTT
H
­
LTT
NH
­
LTT
NH
­
LTT
NA
Collectors
NA
NH
­
LTT
H
­
TL
NH
­
TL
NH
­
TL
NA
Glass
Processors
NA
NA
NA
NH
­
TL
NA
NH
­
TL
NH
=
Non­
hazardous
transport.
H
=
Hazardous
material
transport.
LTT
=
Less
than
truck
load
shipments.
TL
=
Full
truck
load
shipments.
NA
=
Not
applicable.

The
transportation
costs
for
less
than
truck
load
shipments
consist
of
two
parts,
a
fixed
fee
and
a
variable
fee
based
on
tons
shipped
and
miles
driven.
The
variable
portion
of
the
per
shipment
transportation
cost
is
based
on
an
average
shipment
size
and
the
assumed
miles
that
the
CRTs
are
shipped
to
each
disposal
option.
For
SQGs
the
average
shipment
size
is
calculated
by
dividing
the
total
tons
of
CRTs
shipped
by
the
total
number
of
shipments.
The
total
number
of
shipments
is
calculated
by
assuming
that
each
SQG
ships
twice
a
year
and
multiplying
by
the
number
of
SQGs.
The
same
methodology
is
used
for
calculating
the
average
shipment
size
for
LQGs,
except
LQGs
ship
CRTs
four
times
per
year.
Under
the
final
rule,
unregulated
establishments
are
assumed
to
ship
CRTs
once
per
year,
unless
they
generate
enough
CRTs
to
need
two
shipments.
Only
formerly
regulated
collectors
generate
enough
CRTs
to
need
two
shipments
per
year.
Glass
processors
are
estimated
to
make
32
shipments
of
funnel
glass
under
the
baseline
and
44
shipments
under
the
final
rule.
The
glass
processor
shipments
only
include
24
The
cost
to
transport
CRTs
for
generators
due
to
non­
CRT
waste
is
estimated
to
be
less
than
$
20
per
shipment.
This
estimate
is
based
on
the
per
ton­
mile
rate
of
$
0.16,
250
miles
to
a
treatment
and
disposal
facility,
and
0.5
tons
of
CRTs
per
shipment.
The
actual
tons
shipped
by
these
generators
is
typically
less
than
0.5
tons.
There
are
approximately
1,000
establishments
in
this
category.
Thus
the
total
shipping
cost
is
approximately
$
20,000,
or
less
than
one
tenth
of
one
percent
of
the
savings
under
the
final
rule.

March
19,
2004
Page
29
shipments
of
funnel
glass,
because
panel
glass
does
not
contain
enough
lead
to
render
it
hazardous
waste
when
discarded.
The
transportation
costs
for
full
truck
load
shipments
consists
of
a
variable
fee
based
on
the
miles
the
load
must
be
shipped.
Appendix
G
contains
the
average
shipment
sizes
for
each
type
of
entity
distributing
CRTs
to
each
of
the
management
options.
Exhibit
3­
10
presents
the
cost
functions
for
hazardous
waste
and
non­
hazardous
materials
for
both
less
than
truckload
and
full
truck
loads.
These
cost
functions
include
the
pre­
shipment
handling
and
administrative
costs
associated
with
each
shipment.
Exhibit
3­
11
presents
the
estimated
or
assumed
mileage
between
each
type
of
establishment
distributing
CRTs
and
the
CRT
management
options.

Exhibit
3­
10:
Transportation
Cost
Functions
<
50
miles
50
to
400
miles
Hazardous
Non­
Hazardous
Hazardous
Non­
Hazardous
Full
Truck
Loads
NA
$
3.41/
mile
$
2.98/
mile
$
2.25/
mile
Less
Than
Truck
Load
NA
$
108
+
$
0.18/
ton­
mile
$
162
+
$
0.16/
ton­
mile
$
108
+
$
0.12/
ton­
mile
Source:
ICF
Memorandum
to
Allen
Maples,
EPA,
August
31,
1998.
NA
=
Not
applicable.

Exhibit
3­
11:
Transportation
Distances
for
Each
CRT
Management
Option
(
Miles)

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

The
transportation
costs
to
collectors
and
disposal
facilities
for
generators
due
to
non­
CRT
hazardous
waste
are
zero
because
the
CRTs
are
assumed
to
be
shipped
with
the
generator's
other
hazardous
waste.
The
actual
cost
is
greater
than
zero
but
is
not
significant
to
the
analysis.
24
25
Conversation
with
Hagerstown
Transload
Services
on
February
9,
1999.

26
Conversation
with
American
Moving
and
Storage
on
February
9,
1999.

27
The
storage
cost
of
eight
dollars
per
square
foot
is
an
assumed
average
cost
based
on
the
information
from
the
two
storage
companies
contacted,
Hagerstown
Transload
Services
and
American
Moving
and
Storage.

28
ICF
Incorporated,
Economic
Impact
Analysis
for
the
Military
Munitions
Final
Rule,
June
1996.

March
19,
2004
Page
30
3.8
Estimate
Storage
Costs
Storage
costs
may
increase
for
former
generators
under
the
final
rule
because
the
frequency
of
shipments
decreases
relative
to
shipments
by
generators.
This
section
contains
the
storage
costs
applicable
to
generators
and
former
generators.

Storage
costs
depend
on
several
assumptions
about
the
type
of
storage
facility
that
is
used
by
the
generator.
Some
generators
may
use
offsite
commercial
warehouse
space
which
generally
cost
three
to
four
dollars
per
square
foot
for
an
annual
rental,
plus
handling
fees
for
each
shipment
in
or
out
of
the
warehouse.
25
Other
generators
may
store
materials
in
self
storage
facilities
that
generally
cost
$
12
to
$
15
per
square
foot
per
year.
26
Finally
other
generators
may
have
on
site
storage
that
they
use.
The
on
site
storage
cost
can
be
considered
to
be
zero
if
space
is
available
and
the
building
space
is
considered
a
sunk
cost.
However,
for
some
generators
there
will
be
an
opportunity
cost
of
storing
the
CRTs.
In
this
case
the
storage
cost
is
the
cost
of
the
lease
or
rent
per
square
foot.
The
analysis
assumes
an
average
cost
of
eight
dollars
per
square
foot
per
year
for
storage.
27
The
model
assumes
that
each
CRT
will
occupy
three
cubic
feet
and
that
the
CRTs
will
be
stacked
up
to
eight
feet
high.
Exhibit
3­
12
summarizes
the
number
of
CRTs
stored
and
the
annual
storage
costs
for
each
type
of
generator.

3.9
Estimate
Costs
for
Glass
Processors
and
Transporters
3.9.1
Costs
to
Glass
Processors
Only
a
small
number
of
dedicated
processors
exists
at
present.
The
analysis
estimates
there
are
five
glass
processors.
The
glass
reclamation
process
is
exempt
from
RCRA
Subtitle
C
regulation
(
40
CFR
261.6(
c)(
1)).
However,
under
the
baseline
the
storage
of
CRTs
prior
to
reclamation
requires
a
RCRA
Part
B
Permit.
The
estimated
cost
for
obtaining
a
storage
permit
is
$
13,300.28
If
a
glass
processor
refurbishes
some
of
the
CRTs,
then
any
CRTs
sent
to
the
glass
processor
that
possibly
will
be
refurbished
are
not
a
solid
waste.
Exhibit
3­
13
shows
the
glass
processor
activities
required
under
the
baseline
and
final
rule
and
the
associated
unit
costs.
March
19,
2004
Page
31
Exhibit
3­
12:
Storage
Costs
for
Monitors
Number
of
CRTs
Stored
Storage
Area
Required
(
ft2)
Cost
per
Square
Foot
Annual
Storage
Cost
Generators
Due
to
CRTs
Alone
Baseline
SQG
72
27
$
8.45
$
227
LQG
333
125
$
8.45
$
1,055
Final
Rule
SQG
72
27
$
8.45
$
227
LQG
333
125
$
8.45
$
1,055
Former
SQG
144
54
$
8.45
$
455
Former
LQG
666
250
$
8.45
$
2,111
Generators
Due
to
CRTs
and
Non­
CRT
Hazardous
Waste
Baseline
SQG
21
8
$
8.45
$
67
LQG
10
4
$
8.45
$
32
Final
Rule
SQG
21
8
$
8.45
$
67
LQG
10
4
$
8.45
$
32
Former
SQG
42
16
$
8.45
$
132
Former
LQG
40
15
$
8.45
$
127
NA
=
Not
Applicable
March
19,
2004
Page
32
Exhibit
3­
13:
Glass
Processor
Compliance
Requirements
and
Unit
Costs
Required
Activity
Unit
Costs
Baseline
Final
Rule
Initial
Fixed
Costs
Notification
of
Hazardous
Waste
Activity
$
230
$
230
Rule
Familiarization
$
93
$
93
Emergency
Planning
$
832
$
832
Environmental
Justice
Requirements
$
0
$
0
Total
Initial
Fixed
Costs
per
Facility
$
1,155
$
1,155
Annual
Costs
Annual
Review
of
Regulations
$
63
$
63
Recordkeeping
$
50
$
50
Personnel
Safety
Training
(
annualized
cost)
$
486
$
486
Manifest
Training
$
181
$
181
Biennial
Reporting
$
205
$
205
Total
Annual
Costs
per
Facility
$
985
$
985
Variable
Costs
Manifest
and
Land
Disposal
Restriction
Notification
(
per
shipment)
$
56
$
0
Recordkeeping
of
Incoming
Shipments
(
per
shipment)
$
0
$
0
Recordkeeping
of
Outbound
Shipments
(
per
shipment)
$
0
$
0
Source
of
Cost
Data:
Supporting
Statement
for
EPA
Information
Collection
Request
Number
[
]
"
Reporting
and
Recordkeeping
Requirements
for
the
Proposed
Rule
on
Cathode
Ray
Tube
(
CRT)
Glass
Reuse,"
October
1998;
and
Supporting
Statement
for
EPA
ICR
#
261
"
Reporting
and
Recordkeeping
Requirements
for
Generators
of
Mercury­
Containing
Lamps"
June
29,
1994.

3.9.2
Costs
to
CRT
Glass
Transporters
Current
CRT
transporters
are
assumed
to
transport
other
hazardous
wastes
and
other
nonhazardous
materials
and,
consequently,
do
not
incur
savings
under
the
final
rule.
To
the
extent
that
new
transporters
enter
the
CRT
market
that
do
not
transport
other
hazardous
wastes,
these
new
transporters
will
incur
minor
compliance
costs
attributable
to
reviewing
regulations.
The
analysis
does
not
attempt
to
quantify
the
costs
associated
with
new
transporters
shipping
CRTs
due
to
the
uncertainty
in
the
number
of
new
transporters
likely
to
enter
this
market
and
the
estimated
small
impact
on
the
overall
analytical
results.

3.10
Estimate
the
Impact
of
Compliance
Costs
on
Affected
Entities
The
analysis
estimates
first­
order
economic
impacts
of
incremental
costs
by
calculating
the
cost­
to­
sales
ratio
for
each
type
of
original
user
in
each
three­
digit
NAICS
code.
Census
data
for
the
year
2001
served
as
the
source
of
average
sales
data
for
establishments
in
each
three­
digit
NAICS
code.
(
Appendix
H
presents
the
average
sales
per
establishment
for
all
NAICS
codes
used
in
the
calculations
for
this
report.)
Incremental
compliance
costs
or
cost
savings
for
representative
establishments
are
developed
by
adding
the
costs
as
described
previously.
For
purposes
of
this
analysis,
economic
impacts
are
considered
significant
if
costs
exceed
three
percent
of
sales.
March
19,
2004
Page
33
The
impacts
analysis
is
likely
to
overstate
economic
impacts
(
whether
costs
or
savings)
because
the
sales
data
used
in
the
analysis
represent
average
values
for
each
NAICS
code
as
a
whole,
whereas
the
estimated
compliance
costs
arise
only
for
the
entities
that
are
large
enough
to
be
considered
an
SQG
or
LQG
in
the
baseline.
Such
entities
are
likely
to
have
an
average
sales
value
higher
than
the
average
for
the
industry
as
a
whole.

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

The
Subtitle
D
management
baseline
assumes
that
20
percent
of
facilities
are
managing
their
CRTs
as
Subtitle
C
waste
and
80
percent
of
facilities
are
managing
their
CRTs
as
Subtitle
D
waste.
The
20
percent
of
facilities
that
are
managing
their
CRTs
under
Subtitle
C
incur
all
of
the
administrative,
disposal,
transportation,
and
storage
costs
as
discussed
in
Sections
3.5
through
3.8.
Under
these
assumptions
in
the
baseline,
there
are
297
SQGs,
23
LQGs,
and
3,589
establishments
sending
CRTs
to
Subtitle
D
landfills
without
treatment.
The
final
rule
is
assumed
to
induce
some
establishments
sending
CRTs
to
Subtitle
D
landfills
to
send
their
CRTs
to
glass
processors
or
reclaimers.
Thus
under
the
final
rule,
there
are
80
SQGs,
5
LQGs,
173
former
SQGs,
4
former
LQGs,
and
3,589
establishments
sending
CRTs
to
Subtitle
D
landfills.
Exhibit
3­
14
contains
the
flow
assumptions
for
CRTs
under
the
Subtitle
D
management
baseline.
Exhibit
3­
15
contains
the
flow
assumption
for
CRTs
under
the
final
rule.

The
cost
for
managing
CRTs
under
the
Subtitle
D
baseline
are
assumed
to
include
only
disposal
costs
of
$
42
per
ton.
Thus,
facilities
managing
CRTs
under
the
Subtitle
D
baseline
have
no
administrative
costs,
no
storage
costs,
and
no
transportation
costs.
There
are
no
administrative
costs
because
these
facilities
will
not
prepare
manifests,
review
regulations
on
an
annual
basis,
or
conduct
any
of
the
other
activities
required
under
Subtitle
C
management.
The
storage
costs
are
assumed
to
be
zero
because
facilities
will
not
store
the
CRTs,
but
will
place
them
with
their
other
trash
as
soon
as
they
discard
the
CRTs.
The
transportation
costs
are
approximately
zero
because
facilities
will
place
the
CRTs
in
with
their
other
trash
and
not
ship
the
CRTs
separately.
An
incremental
transportation
cost
could
be
attributed
to
the
CRTs
based
on
the
weight
of
the
CRTs
and
the
hauling
charges
companies
pay
for
their
trash;
however,
the
analysis
assumes
that
any
incremental
transportation
cost
is
immaterial
to
the
results.
March
19,
2004
Page
34
Exhibit
3­
14:
Assumed
Distribution
of
Discarded
Monitors
and
CRT
Glass
Under
the
Subtitle
D
Management
Baseline
Entity
Distributing
CRTs
Reuse
Export
Intermediate
Processors
Disposal
Options
Total
Percent
Total
Tons
Disposed
Collector
Glass
Processor
Municipal
Solid
Waste
Landfill
Hazardous
Waste
Facility
Reclaimer
CRT
Glass
Manufacturer
Disposal
Cost
$
0/
ton
(
I)
$
108/
ton
(
I)
$
274/
ton
(
I)
$
344/
ton
(
I)

$
0/
ton
(
C)
$
42/
ton
$
1,548/
ton
(
I)

$
165/
ton
(
C)
$
211/
ton
(
I)

$
153/
ton
(
C)
­
$
181/
ton
(
C)

Original
User
SQGs
and
LQGs*

Due
to
CRTs
Only
2%
(
I)
0%
6%
(
I)
5%
(
I)
80%
(
I)
2%
(
I)
5%
(
I)
NA
100%
62,203
Due
to
CRTs
and
Non­
CRT
Hazardous
Waste
0%
(
I)
0%
10%
(
I)
0%
80%
(
I)
10%
(
I)
0%
NA
100%
3,006
Collectors
SQGs
20%
(
I)
20%
(
I)
NA
5%
(
I)
50%
(
B)
0%
(
B)
5%
(
B)
NA
100%
323
LQGs
20%
(
I)
20%
(
I)
NA
10%
(
C)
43%
(
B)
2%
(
C)
5%
(
C)
NA
100%
3,445
Glass
Processors
0%
0%
NA
NA
0%
0%
2%
(
C)
98%
(
C)
100%
2,098
Total
Tons
2,051
807
4,033
2,089
53,925
1,589
3,273
2,056
*
Disposal
costs
shown
are
representative
simplifications
of
the
actual
costs
used
in
the
analysis.
See
Exhibit
3­
8
for
further
details.

(
I)
=
Intact
whole
monitors.

(
B)
=
Bare
CRTs
without
the
casing.

(
C)
=
Crushed
CRT
glass.

NA
=
Not
Applicable.
March
19,
2004
Page
35
Exhibit
3­
15:
Assumed
Distribution
of
Discarded
Monitors
Under
the
Final
Rule
and
the
Subtitle
D
Baseline
Entity
Distributing
CRTs
Reuse
Export
Intermediate
Processors
Disposal
Options
Total
Percent
Total
Tons
Disposed
Collector
Glass
Processor
Municipal
Solid
Waste
Landfill
Hazardous
Waste
Facility
Reclaimer
CRT
Glass
Manufacturer
Disposal
Cost*
$
0/
ton
(
I)
$
108/
ton
(
I)
$
274/
ton
(
I)
$
344/
ton
(
I)

$
0/
ton
(
C)
$
42/
ton
$
1,548/
ton
(
I)

$
165/
ton
(
C)
$
211/
ton
(
I)

$
153/
ton
(
C)
­
$
181/
ton
(
C)

Original
Users
SQGs
and
LQGs
NA
NA
NA
NA
NA
100%
(
I)
NA
NA
100%
1,312
Former
SQGs
and
LQGs
2%
(
I)
0%
10%
(
I)
6%
(
I)
NA
NA
7%
(
I)
NA
100%
63,898
Out
of
Compliance
SQGs
and
LQGs
NA
NA
NA
NA
75%
(
I)
NA
NA
NA
Collectors
Regulated
Post­
Rule
SQGs
20%
(
I)
30%
(
I)
NA
10%
(
B)
40%
(
B)
2%
(
B)
13%
(
B)
NA
100%
10
LQGs
20%
(
I)
18%
(
I)
NA
15%
(
C)
40%
(
B)
2%
(
C)
8%
(
C)
NA
100%
105
Unregulated
Post­
Rule
Former
SQGs
20%
(
I)
15%
(
I)
NA
10%
(
B)
40%
(
B)
NA
15%
(
B)
NA
100%
470
Former
LQGs
20%
(
I)
15%
(
I)
NA
15%
(
C)
40%
(
B)
NA
10%
(
C)
NA
100%
5,166
Glass
Processors
0%
0%
NA
NA
0%
0%
2%
(
C)
98%
(
C)
100%
2,859
Total
Tons
2,556
958
6,390
2,859
50,479
1,314
4,928
2,802
*
Disposal
costs
shown
are
representative
simplifications
of
the
actual
costs
used
in
the
analysis.
See
Exhibit
3­
8
for
further
details.

(
I)
=
Intact
whole
monitors.

(
B)
=
Bare
CRTs
without
the
casing.

(
C)
=
Crushed
CRT
glass.

NA
=
Not
Applicable.
29
One
of
the
most
likely
industries
to
discard
a
significant
quantity
of
televisions
is
the
hotel
industry,
which
is
exempt
from
the
RCRA
hazardous
waste
requirements
(
40
CFR
§
261.4(
b)(
1)).

March
19,
2004
Page
36
3.12
Limitations
of
the
Methodology
and
Data
The
accuracy
of
the
analysis
depends
on
a
wide
variety
of
data
and
assumptions.
The
following
is
a
list
of
assumptions,
limitations,
and
other
factors
affecting
the
accuracy
of
the
analysis.
Some
assumptions
tend
to
increase
or
decrease
the
savings
of
the
alternatives,
as
noted
in
the
discussion
of
the
individual
assumptions.
Except
where
noted,
assumptions
are
best
estimates
and
are
not
believed
to
introduce
systematic
bias
into
the
results.

3.12.1
Assumptions
Life
Cycle
Flow
of
CRTs
C
The
assumed
percentages
of
CRTs
sent
from
generators
to
Subtitle
C
or
D
landfills,
smelters,
glass
processors,
collectors,
and
for
reuse
or
export.
Information
on
the
flow
of
CRTs
is
mostly
anecdotal.
See
Exhibits
3­
4,
3­
5,
3­
14,
and
3­
15
for
the
percentages
used
in
the
analysis.
In
developing
the
flow
percentages,
the
analysis
takes
into
consideration
the
stigma
of
hazardous
waste.

C
The
assumed
percentage
of
generators
that
are
no
longer
regulated
under
the
final
rule.
Under
the
final
rule
98
percent
of
baseline
generators
are
assumed
to
no
longer
be
regulated.

C
The
number
of
CRTs
from
televisions
discarded
by
businesses
is
insignificant
compared
to
the
number
of
CRTs
from
monitors.
Available
data
on
television
use
in
businesses
are
not
adequate
to
incorporate
into
the
analysis.
The
number
of
televisions
used
in
businesses
is
believed
to
be
relatively
insignificant
compared
with
the
number
of
computer
monitors.
29
Eliminating
televisions
from
the
analysis
is
not
believed
to
significantly
affect
the
analysis,
although
this
assumption
could
change
if
business
use
of
televisions
increases
(
e.
g.,
due
to
increases
in
televideo
conferencing).
This
assumption
may
result
in
the
reported
savings
of
the
final
rule
being
understated
because
the
total
number
of
CRTs
generated
is
underestimated.

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

C
One
half
of
all
exports
of
CRTs
are
of
intact
CRTs
for
refurbishment
and
reuse
and
one
half
of
all
exports
of
CRTs
are
of
intact
CRTs
sent
for
recycling.

Monitor
Characteristics
C
The
lifetime
of
a
computer
monitor
in
businesses
is
assumed
to
be
3.5
years.

C
The
estimated
percentage
of
color
monitors
in
use
in
businesses
3.5
years
prior
to
the
modeled
year
is
98
percent.
March
19,
2004
Page
37
C
The
assumed
percentage
of
flat
panels
discarded
in
2004
is
five
percent
of
all
monitors
discarded.

C
The
assumed
percentage
of
laptop
computers
in
use
3.5
years
prior
to
the
modeled
year
is
25
percent.

C
The
estimated
average
weight
of
computer
monitors
being
discarded
in
the
modeled
year
is
40.6
pounds.

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

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

C
The
distances
to
each
of
the
CRT
management
options.
See
Exhibit
3­
11
for
the
transportation
distances
used
in
the
analysis.

Generators
C
The
assumed
distribution
of
SQGs
across
all
three­
digit
NAICS
codes.
Existing
databases
do
not
track
the
NAICS
codes
of
all
SQG
generators.
The
analysis
assumes
that
the
distribution
of
SQGs
across
NAICS
codes
is
the
same
as
it
is
for
SQGs
that
are
reported
in
the
Resource
Conservation
and
Recovery
Information
System
(
RCRIS)
database.

C
The
assumed
distribution
of
SQGs
and
LQGs
across
establishment
size
ranges
within
a
three­
digit
NAICS
code.
The
analysis
assumes
that
SQGs
are
1.25
times
and
LQGs
are
1.75
times
more
likely
to
have
more
employees
than
non­
generator
establishments.
This
is
based
on
the
presumption
that
larger
facilities
with
more
employees
are
more
likely
to
meet
the
thresholds
for
establishments
becoming
SQGs
or
LQGs.
March
19,
2004
Page
38
C
The
assumed
cost
savings
for
generators
that
are
generators
due
solely
to
the
disposal
of
CRTs.
The
analysis
assumes
that
establishments
qualifying
as
generators
solely
due
to
CRTs
do
not
generate
any
other
hazardous
waste
and
thus
can
achieve
the
maximum
savings
possible
under
the
final
rule.
This
assumption
results
in
the
reported
savings
of
the
final
rule
being
overstated
because
the
total
number
of
these
generators
is
likely
to
be
overestimated.

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

C
The
analysis
includes
all
establishments
in
a
NAICS
code
size
category
if
the
number
of
CRTs
discarded
using
the
average
number
of
employees
is
over
the
SQG
or
LQG
threshold.
For
the
smallest
size
category
within
a
NAICS
code
that
meets
the
threshold
to
be
an
SQG
or
LQG,
this
assumption
may
overestimate
the
number
of
establishments
that
are
SQGs
or
LQGs.

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

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

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

C
The
number
of
CRTs
that
glass
processors
send
for
reuse
is
insignificant
compared
to
the
number
of
CRTs
that
are
processed
for
new
CRT
glass.
This
assumption
results
in
the
reported
savings
of
the
final
rule
being
understated
because
potential
savings
are
not
captured.

C
Seventeen
percent
of
collectors
are
assumed
to
be
SQGs.
Collectors
who
are
SQGs
are
assumed
to
be
primarily
refurbishers
who
are
able
to
resell
most
CRTs
with
only
small
volumes
that
they
discard.
Collectors
who
are
LQGs
are
assumed
to
be
primarily
recyclers
who
need
to
recycle
large
volumes
of
CRTs
to
make
their
business
profitable.

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

C
The
analysis
models
the
flow
of
all
CRTs
discarded
by
original
users
in
amounts
exceeding
the
threshold
for
conditionally
exempt
small
quantity
generators
(
more
than
100
kg
per
month),
even
though
many
of
these
original
users
are
not
regulated
(
because
they
send
their
CRTs
to
collectors,
for
reuse,
or
to
glass
processors
that
March
19,
2004
Page
39
refurbish
CRTs),
and
do
not
accrue
incremental
costs.
The
flow
of
CRTs
from
these
entities
is
modeled
in
order
to
calculate
incremental
costs
on
other
regulated
entities
(
e.
g.,
collectors).

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

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

Storage
C
The
analysis
assumes
a
single
storage
cost
rate
($
8.45/
ft2)
for
all
facilities,
regardless
of
potentially
available
storage
alternatives.

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

3.12.2
Limitations
C
State
and
local
governments
and
their
discarded
CRTs
are
not
included
in
the
model.
This
assumption
results
in
the
reported
savings
of
the
final
rule
being
understated
because
the
total
number
of
generators
is
underestimated.

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

C
The
impacts
analysis
is
likely
to
overstate
economic
impacts
(
whether
costs
or
savings)
because
the
sales
data
used
in
the
analysis
represent
average
values
for
each
SIC
code
as
a
whole,
whereas
the
estimated
compliance
costs
arise
only
for
the
entities
that
are
large
enough
to
be
considered
an
SQG
or
LQG
in
the
baseline.
Such
entities
are
likely
to
have
an
average
sales
value
higher
than
the
average
for
the
industry
as
a
whole.
30
Monchamp,
A.,
Evans,
H.,
Nardone,
J.,
Wood,
S.,
Proch,
E.,
and
Wagner,
T.,
Cathode
Ray
Tube
Manufacturing
and
Recycling:
Analysis
of
Industry
Survey.
Electronics
Industries
Alliance,
May
2001.

31
The
Microelectronics
and
Computer
Technology
Corporation
(
MCC),
page
231.

March
19,
2004
Page
40
3.12.3
Other
Factors
C
Consistent
with
least­
cost
behavior,
the
analysis
reflects
generators
of
non­
CRT
hazardous
wastes
only
to
the
extent
that
these
entities
generate
30
or
more
CRTs
per
year.
Generators
discarding
less
than
30
CRTs
per
year
are
assumed
in
the
baseline
to
consolidate
their
CRTs
shipments
with
shipments
of
other
hazardous
waste;
in
this
case,
the
transportation
cost
for
shipping
the
CRTs
is
only
an
incremental
cost
(
i.
e.,
relative
to
the
cost
of
shipping
the
other
hazardous
wastes).
The
incremental
cost
for
shipping
less
than
30
CRTs
is
less
than
$
18
per
shipment.
Under
the
two
regulatory
alternatives,
if
these
generators
were
to
ship
CRTs
to
glass
processors
or
reclaimers,
they
would
be
assumed
to
ship
the
CRTs
on
a
separate
truck,
thereby
incurring
a
significant
increase
in
transportation
costs
of
more
than
$
100
per
shipment.
Given
the
increase
in
transportation
cost
and
the
low
volume
of
CRTs
(
i.
e.,
less
than
30),
the
least
cost
behavior
for
these
hazardous
waste
generators
is
to
continue
consolidating
CRTs
with
other
hazardous
waste
shipments.
The
model
does
not
include
such
generators
whose
behavior
will
not
be
affected
by
the
alternatives.
The
sensitivity
analysis
in
Sections
4.2.4
and
5.2.4
includes
the
CRTs
from
these
entities
as
well
as
from
CESQGs.

C
The
amount
of
CRT
glass
that
CRT
glass
manufacturers
can
recycle
is
a
potentially
limiting
factor
in
the
amount
of
CRTs
that
can
be
economically
recycled.
A
recent
study
estimates
that
CRT
glass
manufacturers
could
use
125,100
tons
of
postconsumer
cullet
using
the
current
sorting
technology.
30
If
better
sorting
technology
is
developed,
then
the
amount
the
CRT
glass
manufacturers
could
use
will
increase
to
at
least
161,600
tons
per
year.
The
model
estimates
that
12.5
million
color
CRT
monitors
enter
the
waste
stream
each
year
from
all
businesses
(
regulated
and
unregulated).
At
an
average
weight
of
40.6
pounds
per
CRT,
the
total
weight
of
color
CRT
monitors
entering
the
waste
stream
is
254,000
tons.
The
CRT
glass
constitutes
approximately
60
percent
of
the
CRT
weight;
so
the
total
amount
of
CRT
glass
entering
the
waste
stream
per
year
from
businesses
is
approximately
153,000
tons.
31
Thus,
all
post
consumer
CRT
glass
that
is
estimated
to
be
generated
by
all
businesses,
not
just
those
entities
considered
in
this
analysis,
could
theoretically
be
used
by
CRT
glass
manufacturers.
The
amount
of
CRT
glass
currently
entering
the
waste
stream
from
regulated
establishments
is
estimated
at
65,000
tons.
Therefore,
it
does
not
appear
that
the
amount
of
glass
that
CRT
glass
manufacturers
can
accept
should
be
a
limiting
factor
in
CRT
glass­
to­
glass
recycling.

C
The
production
capacity
of
glass
processors
is
a
potentially
limiting
factor
in
the
amount
of
discarded
CRTs
that
can
be
recycled
each
year,
and
thus
is
a
limiting
factor
for
the
success
of
the
final
rule.
Currently
there
are
only
a
few
glass
processors.
The
largest
processor
is
Envirocycle,
with
an
estimated
production
capacity
of
45,000
tons
32
ICF
communication
with
Greg
Voorhees
of
Envirocycle,
2001.

33
ICF
communication
with
Greg
Voorhees
of
Envirocycle,
1996
and
2001,
and
Envirocycle
web
page.

March
19,
2004
Page
41
of
CRTs
per
year.
32
However,
the
estimated
total
amount
of
CRTs
generated
by
regulated
generators
is
65,000
tons
per
year.
Envirocycle
obtains
about
10,000
tons
of
CRTs
from
computer
monitor
and
television
manufacturers.
33
Thus,
Envirocycle
does
not
have
enough
capacity
to
process
all
CRTs
generated
by
regulated
entities.
The
capacity
of
the
second
glass
processor
is
unknown,
but
is
assumed
to
be
significantly
less
than
Envirocycle's
capacity.
Therefore,
the
production
capacity
of
glass
processors
is
an
active
constraint
on
the
number
of
regulated
CRTs
that
could
be
recycled
into
new
CRT
glass
each
year.

C
The
inclusion
of
smelters
as
an
excluded
CRT
management
option
mitigates
the
need
for
glass
processors
and
CRT
glass
manufacturers
to
have
sufficient
capacity
to
be
able
to
accept
all
CRTs
from
regulated
generators.
Analysis
of
the
amount
of
silica
in
slag
from
operating
lead
and
copper
smelters
in
the
U.
S.
and
in
CRT
glass
results
in
an
estimate
that
lead
and
copper
smelters
could
use
about
2.2
million
metric
tons
of
CRT
glass
as
fluxing
agent.
This
is
the
theoretical
maximum
capacity
for
smelters
to
use
CRT
glass
as
a
fluxing
agent.
Assuming
that
smelters
could
only
use
one
third
of
the
possible
2.2
million
metric
tons
of
silica
from
CRT
glass,
yields
a
total
of
733,000
metric
tons
of
CRT
glass
that
could
be
used
by
smelters.
Thus
given
a
total
of
65,000
tons
of
CRT
glass
from
regulated
generators
and
approximately
153,000
tons
of
CRT
glass
from
all
businesses,
the
combined
capacity
of
CRT
glass
manufactures
and
smelters
is
adequate
to
handle
all
CRTs
generated
from
all
businesses.
This
analysis
shows
the
importance
of
including
smelters
as
an
excluded
CRT
management
option.

C
The
real­
world
conditions
that
are
approximated
in
the
analysis
are
likely
to
change
significantly
over
the
next
several
years.
For
example,
the
number
of
flat
panel
monitors
and
laptops
used
in
businesses
and
the
monitor
lifetime
are
expected
to
increase
over
time,
which
would
decrease
the
savings
under
the
final
rule.

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

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

4.1
Costs
Under
the
Subtitle
C
Baseline
The
total
applicable
cost
of
compliance
in
the
Subtitle
C
baseline
is
calculated
for
several
groups
of
affected
entities.
As
shown
in
Exhibit
4­
1,
the
analysis
categorizes
affected
entities
March
19,
2004
Page
42
based
on
whether
they
are
original
users
or
collectors,
the
amount
of
waste
they
generate
(
SQGs
or
LQGs),
and,
for
original
users,
whether
they
are
regulated
solely
because
of
CRT
generation
or
because
of
a
combination
of
CRT
and
non­
CRT
hazardous
waste
generation.
Collectors
are
all
assumed
to
be
regulated
solely
because
of
CRT
generation.
Compliance
costs
also
are
calculated
for
glass
processors.
Exhibit
4­
1
presents
the
cost
per
establishment
for
administrative,
storage,
transportation,
and
disposal
costs,
and
for
the
total
cost
of
compliance
under
the
baseline.
Administrative
costs
are
assumed
to
be
the
same
for
all
generators
in
each
size
category
(
small
or
large).
The
other
costs
vary
across
the
categories
(
based
on
RCRA
requirements
for
different
types
of
generators,
on
the
average
number
of
CRTs
discarded,
and
on
the
disposal
method
used
by
that
generator).
So
Exhibit
4­
1
presents
the
average
cost
for
each
group
of
generators.

Exhibit
4­
1:
Subtitle
C
Baseline
Compliance
Costs
Average
Costs
per
Generator
Number
of
Regulated
Generators
Average
Costs
per
Potentially
Regulated
Generator
Number
of
Potentially
Regulated
Generators
Total
Cost
Admin.
Storage
Transp.
Disposal
Transp.
Disposal
Original
Users
(
Generating
No
Non­
CRT
Hazardous
Waste)

SQG
$
634
$
227
$
273
$
878
2,933
$
273
$
878
14,343
$
22,422,000
LQG
$
1,227
$
1,055
$
805
$
8,147
74
$
805
$
8,147
364
$
4,090,000
Subtotal
$
26,512,000
Original
Users
Also
Generating
Non­
CRT
Hazardous
Waste
SQG
$
91
$
67
$
257
$
502
689
$
257
$
502
2,065
$
2,199,000
LQG
$
224
$
32
$
503
$
480
208
$
503
$
480
623
$
870,000
Subtotal
$
3,069,000
Collectors
SQG
$
639
$
0
$
842
$
4,865
50
$
842
$
4,865
50
$
603,000
LQG
$
1,278
$
0
$
1,967
$
5,736
250
$
1,967
$
5,736
250
$
4,171,000
Subtotal
$
4,774,000
Glass
Processors
$
2,875
$
0
$
9,477
$(
122,647)
5
N/
A
N/
A
N/
A
$
(
551,000)

Total
Baseline
Compliance
Costs
$
33,804,000
Note:
Total
cost
numbers
rounded
to
nearest
thousand.
Costs
may
not
add
due
to
rounding.

4.2
Final
Rule
4.2.1
Costs
Under
the
Final
Rule
The
total
applicable
cost
of
compliance
under
the
final
rule
is
calculated
for
all
of
the
generators
described
in
Section
4.1,
and
for
all
of
the
entities
that
were
formerly
generators
but
that
no
longer
are
required
to
comply
with
the
hazardous
waste
regulations.
These
are
called
"
former
generators."
Exhibit
4­
2
presents
the
cost
per
establishment
for
administrative,
storage,
transportation,
and
disposal
costs,
and
for
the
total
cost
of
compliance
under
the
final
rule.
Administrative
costs
are
assumed
to
be
the
same
for
all
generators
in
each
size
category
(
small
or
large).
The
other
costs
vary
across
the
categories
(
based
on
RCRA
requirements
for
different
March
19,
2004
Page
43
types
of
generators,
on
the
average
number
of
CRTs
discarded,
and
on
the
CRT
management
method
used
by
that
generator).
So
Exhibit
4­
2
presents
the
average
cost
for
each
group
of
generators.

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

Former
SQG
$
94
$
455
$
138
$
804
2,592
$
138
$
804
14,343
$
17,362,000
Former
LQG
$
94
$
2,111
$
488
$
7,458
65
$
480
$
7,458
364
$
3,549,000
Subtotal
$
20,911,000
Original
Users
Also
Generating
Non­
CRT
Hazardous
Waste
Former
SQG
$
93
$
132
$
118
$
234
634
$
118
$
234
2,065
$
1,091,000
Former
LQG
$
93
$
127
$
118
$
224
191
$
118
$
224
623
$
320,000
Subtotal
$
1,411,000
Collectors
Former
SQG
$
284
$
0
$
1,223
$
4,913
48
$
1,223
$
4,913
50
$
615,000
Former
LQG
$
471
$
0
$
2,722
$
4,736
240
$
2,722
$
4,736
250
$
3,767,000
Subtotal
$
4,382,000
Total
Cost
to
Regulated
Generators
$
2,010,000
Total
Compliance
Costs
under
the
Final
Rule
$
28,714,000
Note:
Total
cost
numbers
rounded
to
nearest
thousand.
Costs
may
not
add
due
to
rounding.

The
average
transportation
and
disposal
cost
for
SQGs
and
LQGs
changes
between
the
baseline
and
the
final
rule
because,
in
the
baseline,
five
CRT
management
options
(
collector,
reuse,
processor,
smelter,
and
hazardous
waste
landfill)
are
available
while
the
final
rule
has
only
one
disposal
option
(
hazardous
waste
landfill)
for
regulated
generators
and
four
CRT
management
options
are
available
(
collector,
reuse,
processor,
and
smelter)
for
"
former"
generators.
The
reason
for
the
changes
in
average
collector
costs
is
similar.
Under
the
baseline,
five
CRT
management
options
are
available
(
reuse,
processor,
smelter,
hazardous
waste
landfill,
and
export).
Under
the
final
rule,
the
same
five
CRT
management
options
are
averaged
for
regulated
collectors,
while
"
former"
collectors
have
only
four
CRT
management
options
(
reuse,
processor,
smelter,
and
export).

4.2.2
Incremental
Cost
Difference
Between
the
Subtitle
C
Baseline
and
the
Final
Rule
The
final
rule
generates
a
net
savings
relative
to
the
baseline,
due
primarily
to
reduced
administrative
requirements
and
savings
from
reduced
transportation
and
disposal
costs.
Savings
from
the
final
rule
accrue
to
former
generators
that
would
no
longer
be
regulated.
The
range
of
34
The
lower
bound
assumes
a
six
year
monitor
life
and
an
average
monitor
weight
of
30
pounds.

35
The
upper
bound
assumes
a
two
year
monitor
life
and
an
average
monitor
weight
of
45
pounds.

36
The
best
estimate
assumes
a
3.5
year
monitor
life
and
an
average
monitor
weight
of
40.6
pounds.

March
19,
2004
Page
44
potential
savings
under
the
final
rule
is
estimated
to
be
from
$
2,553,00034
to
$
10,335,000,35
with
a
best
estimate
of
$
5,090,000.36
Exhibit
4­
3
summarizes
the
costs
under
the
baseline
and
the
final
rule
by
cost
category.

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

Administrative
$
2,430,000
$
711,000
$
1,719,000
Disposal
$
23,261,000
$
21,781,000
$
1,480,000
Transportation
$
7,315,000
$
4,706,000
$
2,609,000
Storage
$
799,000
$
1,517,000
$
(
718,000)

Total
$
33,805,000
$
28,715,000
$
5,090,000
Note:
Cost
numbers
rounded
to
nearest
thousand.
Costs
may
not
add
due
to
rounding.

4.2.3
Sensitivity
Analysis
for
the
Final
Rule
Individual
sensitivity
and
bounding
analysis
is
conducted
on
the
difference
between
the
Subtitle
C
baseline
and
the
final
rule
for
the
following
three
parameters:
monitor
weight,
monitor
lifetime,
and
storage
costs.
Appendix
G
lists
the
parameters
to
which
the
analysis
results
are
relatively
insensitive.
The
individual
sensitivity
analysis
is
conducted
by
changing
one
parameter
at
a
time
while
holding
all
other
parameters
at
their
best
estimate
value.
Exhibit
4­
4
contains
the
upper
and
lower
bounds
and
the
best
estimate
values
for
the
three
parameters
as
well
as
the
percent
change
of
the
lower
and
upper
bounds
from
the
best
estimate.
The
upper
and
lower
bounds
were
selected
because
they
represent
probable
limits
on
the
selected
parameters.

Exhibit
4­
4:
Parameter
Values
for
Individual
Sensitivity
Analysis
Lower
Bound
%
Change
from
Best
Estimate
Best
Estimate
Upper
Bound
%
Change
from
Best
Estimate
Monitor
Weight
35
lbs.
­
14
%
40.6
lbs.
45
lbs.
11
%

Monitor
Life
2
years
­
43
%
3.5
years
6
years
71
%

Storage
Cost
$
0
­
100
%
$
8.45
$
15
78
%
March
19,
2004
Page
45
$
2,000,000
$
3,000,000
$
4,000,000
$
5,000,000
$
6,000,000
$
7,000,000
$
8,000,000
$
9,000,000
$
10,000,000
­
150%
­
100%
­
50%
0%
50%
100%

Percent
Change
from
Best
Estimate
Total
Cost
Difference
($)

Monitor
Weight
Monitor
Life
Storage
Cost
Exhibit
4­
5
contains
the
model
results
for
each
individual
change.
Exhibit
4­
6
plots
the
data
in
Exhibit
4­
5
from
the
individual
sensitivity
analysis
for
the
three
parameters.
The
graph
illustrates
that
the
analysis
is
most
sensitive
to
the
monitor
weight
and
monitor
lifetime.
The
graph
also
indicates
that
the
model
results
are
not
linearly
related
with
respect
to
monitor
weight
and
monitor
life,
since
the
lines
for
these
parameters
are
not
straight.
To
determine
a
potential
maximum
upper
bound
on
the
savings,
a
combined
sensitivity
analysis
is
conducted
using
a
monitor
weight
of
45
pounds,
a
monitor
lifetime
of
two
years,
and
storage
cost
of
zero
dollars
per
square
foot.
The
savings
under
the
combined
sensitivity
analysis
is
$
11,879,000.

Exhibit
4­
5:
Individual
Sensitivity
Analysis
Results
Lower
Bound
Best
Estimate
Upper
Bound
Monitor
Weight
$
4,298,000
$
5,090,000
$
6,260,000
Monitor
Life
$
9,417,000
$
5,090,000
$
3,321,000
Storage
Cost
$
5,808,000
$
5,090,000
$
4,534,000
Numbers
rounded
to
nearest
thousand.

Exhibit
4­
6:
Plot
of
Individual
Sensitivity
Analysis
Results
for
the
Final
Rule
Note:
Lines
with
relatively
steeper
slopes
indicate
greater
sensitivity
of
the
results
to
changes
(
or
uncertainty)
in
the
given
parameters.
March
19,
2004
Page
46
Sensitivity
analysis
is
also
conducted
for
disposal
costs
above
and
below
the
best
estimate
values.
By
changing
the
cost
for
disposal
at
a
hazardous
waste
landfill
to
$
800
and
$
1700
per
ton
for
whole
CRTs
(
from
a
best
estimate
of
$
1,548),
and
to
$
50
and
$
250
per
ton
for
crushed
CRTs
(
from
a
best
estimate
of
$
165),
the
savings
ranged
from
$
4,298,000
to
$
5,349,000.
By
changing
the
cost
for
disposal
at
a
reclaimer
to
$
150
and
$
500
per
ton
for
whole
CRTs
(
from
a
best
estimate
of
$
300),
to
$
100
and
$
300
per
ton
for
bare
CRTs
(
from
a
best
estimate
of
$
211),
and
to
$
75
and
$
250
per
ton
for
crushed
CRTs
(
from
a
best
estimate
of
$
153),
the
savings
ranged
from
$
5,253,000
to
$
4,820,000.
By
changing
the
cost
for
disposal
to
a
collector
to
$
100
and
$
350
per
ton
(
from
a
best
estimate
of
$
274),
the
savings
ranged
from
$
5,114,000
to
$
5,036,000.
The
sensitivity
analysis
on
disposal
costs
shows
that
the
model
is
moderately
sensitive
to
hazardous
waste
disposal
costs
and
only
slightly
sensitive
to
the
reclaimer
and
collector
disposal
costs.

Finally,
sensitivity
analysis
was
conducted
on
the
assumption
regarding
the
number
of
CRTs
that
an
establishment
would
discard
before
becoming
an
SQG
or
LQG.
Based
on
the
estimated
average
weight
of
40.6
pounds
(
18.4
kg)
per
CRT
discarded
in
2004,
an
establishment
would
need
to
discard
six
color
CRT
monitors
in
one
month
to
qualify
as
an
SQG
and
55
color
CRT
monitors
in
one
month
to
qualify
as
an
LQG.
The
analysis
assumes
that
the
threshold
to
become
an
SQG
is
defined
by
an
establishment
that
discards
five
monitors
per
month
for
eleven
months
and
six
monitors
in
the
twelfth
month,
or
61
color
CRT
monitors
in
one
year.
These
values,
six
and
61,
bound
the
possible
thresholds
for
the
number
of
monitors
an
establishment
would
discard
to
become
an
SQG.
Businesses
typically
have
a
mixture
of
monitor
types,
including
CRTs,
flat
panel
monitors,
and
laptops.
Thus
the
average
business
discarding
six
color
CRT
monitors
would
actually
discard
approximately
nine
monitors
[
9
=
6
CRTs/((
1­
25%
laptops)*(
1­
5%
flat
panel))].
The
sensitivity
analysis
was
conducted
by
varying
between
6
and
61
the
number
of
CRTs
an
entity
discards
to
become
an
SQG.
Exhibit
4­
7
presents
the
results
of
this
sensitivity
analysis
graphically
and
shows
that
the
results
are
sensitive
to
this
parameter
for
values
between
six
and
about
25
and
that
the
results
are
relatively
insensitive
for
values
between
25
and
61.
Exhibit
4­
8
presents
a
table
of
selected
results
from
this
sensitivity
analysis.
As
might
be
expected,
as
the
value
of
this
parameter
is
decreased
the
number
of
regulated
establishments
increases
along
with
the
number
of
regulated
CRTs
generated.
For
example,
at
a
parameter
value
of
six,
there
would
be
approximately
54,000
regulated
generators,
who
would
generate
seven
million
CRTs.
As
with
the
results
presented
in
Section
4.2.2,
the
savings
shown
in
Exhibits
4­
7
and
4­
8
are
dominated
by
the
savings
attributable
to
administrative
and
transportation
activities.
March
19,
2004
Page
47
$
0
$
10
$
20
$
30
$
40
$
50
$
60
$
70
6
10
14
18
22
26
30
3
4
38
42
46
50
54
58
Number
of
CRTs
Discarded
Savings
(
millions)
Exhibit
4­
7:
Sensitivity
Results
on
the
Number
of
CRTs
Generated
to
Become
an
SQG
Exhibit
4­
8:
Selected
Sensitivity
Results
on
the
Number
of
CRTs
Generated
to
Become
an
SQG
Number
of
CRTs
Discarded
to
be
an
SQG
Incremental
Savings
6
$
64,301,000
7
$
57,813,000
8
$
50,356,000
9
$
42,714,000
10
$
39,556,000
15
$
24,321,000
20
$
14,412,000
25
$
10,319,000
30
$
8,127,000
40
$
6,648,000
50
$
5,931,000
60
$
5,230,000
61
$
5,090,000
37
The
number
of
televisions
disposed
of
is
based
on
the
assumption
that
there
are
100
million
households
each
with
two
televisions
and
that
the
TVs
are
discarded
after
ten
years.
The
20
million
TVs
discarded
is
also
consistent
with
the
number
of
televisions
sold
in
1991,
which
was
19.5
million.
The
number
of
computer
monitor
CRTs
disposed
of
is
based
on
data
from
the
US
Census,
Survey
of
Computer
Use,
1997,
which
estimates
that
52
percent
of
households
have
computers.

March
19,
2004
Page
48
4.2.4
Incremental
Cost
Difference
Between
the
Subtitle
C
Baseline
and
the
Final
Rule,
Including
Currently
Unregulated
Monitors
and
Televisions
To
help
understand
how
the
final
rule
might
be
affected
by
capacity
issues,
the
total
cost
of
compliance
under
the
Subtitle
C
baseline
and
the
final
rule
is
calculated
including
CRTs
from
conditionally
exempt
small
quantity
generators
(
CESQG)
and
households.
It
is
assumed
that
20
million
unregulated
television
CRTs
are
disposed
and
16.97
million
unregulated
computer
monitor
CRTs
are
disposed
from
households
and
CESQGs.
37
Exhibit
4­
9
contains
a
summary
of
the
costs
under
the
baseline
and
the
final
rule
by
cost
category.
Disposal
costs
are
higher
under
the
final
rule
than
the
baseline
because
it
is
assumed
that
a
greater
percentage
of
unregulated
CRTs
are
sent
to
collectors,
which
increases
the
number
of
CRTs
that
have
a
non­
zero
disposal
cost
under
the
final
rule.

Exhibit
4­
9:
Costs
of
Final
Rule
Relative
to
Subtitle
C
Baseline,
Including
Unregulated
Monitors
and
Televisions
Cost
Category
Baseline
Final
Rule
Saving
(
Cost)

Administrative
$
2,545,000
$
1,045,000
$
1,500,000
Disposal
$
28,118,000
$
29,369,000
$
(
1,251,000)

Transportation
$
8,925,000
$
9,768,000
$
(
843,000)

Storage
$
799,000
$
1,517,000
$
(
718,000)

Total
$
40,387,000
$
41,699,000
$
(
1,312,000)

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

The
analysis
estimates
that
57,600
tons
of
CRT
glass
are
sent
to
glass
processors
and
that,
of
this,
56,500
tons
of
CRT
glass
are
sent
to
CRT
glass
manufacturers.
The
quantity
of
CRTs
sent
to
glass
processors
may
be
above
the
capacity
limit
for
glass
processors,
since
the
capacity
of
one
of
the
processors
is
not
precisely
known.
The
quantity
sent
to
CRT
glass
manufacturers
is
below
the
capacity
limits
for
CRT
glass
manufacturers.
As
the
CRT
recycling
infrastructure
grows
and
additional
unregulated
CRTs
are
recycled,
the
capacities
of
both
glass
processors
and
glass
manufacturers
may
be
exceeded.
This
analysis
does
not
attempt
to
predict
when
this
might
occur.
March
19,
2004
Page
49
5.0
Cost
Results
and
Sensitivity
Analysis
for
Subtitle
D
Management
Baseline
The
incremental
annual
savings
attributable
to
the
final
rule
are
calculated
by
subtracting
the
estimated
costs
under
the
final
rule
from
the
estimated
costs
under
the
Subtitle
D
baseline.

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

Exhibit
5­
1:
Subtitle
D
Baseline
Compliance
Costs
Average
Costs
per
Generator
Number
of
Regulated
Generators
Average
Costs
per
Potentially
Regulated
Generator
Number
of
Potentially
Regulated
Generators
Total
Cost
Admin.
Storage
Transp.
Disposal
Except
Subtitle
D
Subtitle
D
Disposal
Transp.
Disposal
Except
Subtitle
D
Subtitle
D
Disposal
Original
Users
(
Generating
No
Non­
CRT
Hazardous
Waste)

SQG
$
633
$
1,137
$
120
$
1,160
$
491
242
$
120
$
1,160
$
491
3,214
$
6,547,000
LQG
$
1,338
$
3,502
$
791
$
10,714
$
4,532
6
$
791
$
10,714
$
4,532
82
$
1,440,000
Subtotal
$
7,987,000
Original
Users
Also
Generating
Non­
CRT
Hazardous
Waste
SQG
$
92
$
333
$
74
$
771
$
143
55
$
74
$
771
$
143
496
$
568,000
LQG
$
389
$
92
$
211
$
739
$
137
17
$
211
$
739
$
137
149
$
189,000
Subtotal
$
757,000
Collectors
SQG
$
625
$
0
$
237
$
135
$
71
10
$
237
$
135
$
71
90
$
51,000
LQG
$
1,270
$
0
$
637
$
236
$
134
85
$
637
$
236
$
134
415
$
612,000
Subtotal
$
663,000
Glass
Processors
$
1,408
$
0
$
2,228
$
(
24,144)
N/
A
5
N/
A
N/
A
N/
A
N/
A
$
(
103,000)

Total
Baseline
Compliance
Costs
$
9,304,000
Note:
Total
cost
numbers
rounded
to
nearest
thousand.
Costs
may
not
add
due
to
rounding.
38
The
lower
bound
assumes
a
six
year
monitor
life
and
an
average
monitor
weight
of
35
pounds.

39
The
upper
bound
assumes
a
two
year
monitor
life
and
an
average
monitor
weight
of
45
pounds.

40
The
best
estimate
assumes
a
3.5
year
monitor
life
and
an
average
monitor
weight
of
40.6
pounds.

March
19,
2004
Page
50
5.2
Final
Rule
5.2.1
Costs
Under
the
Final
Rule
The
total
applicable
cost
of
compliance
under
the
final
rule
is
calculated
for
all
of
the
entities
described
in
Section
5.1,
and
for
all
of
the
entities
that
were
formerly
generators
but
that
no
longer
are
required
to
comply
with
the
hazardous
waste
regulations.
These
are
called
"
former
generators."
Exhibit
5­
2
presents
the
cost
per
establishment
for
administrative,
storage,
transportation,
and
disposal,
and
for
the
total
cost
of
compliance
under
the
final
rule.
Administrative
costs
are
assumed
to
be
the
same
for
all
generators
in
each
size
category
(
small
or
large).
The
other
costs
vary
across
the
categories
(
based
on
RCRA
requirements
for
different
types
of
generators,
on
the
average
number
of
CRTs
discarded,
and
on
the
disposal
method
used
by
that
generator).
So
Exhibit
5­
2
presents
the
average
cost
for
each
group
of
generators.
As
discussed
in
section
3.11,
generators
sending
CRTs
to
Subtitle
D
landfills
only
incur
a
disposal
cost.

The
average
transportation
and
disposal
cost
for
SQGs
and
LQGs
changes
between
the
baseline
and
the
final
rule
because,
in
the
baseline,
six
CRT
management
options
(
collector,
reuse,
processor,
smelter,
hazardous
waste
landfill,
and
municipal
landfill)
are
available
while
in
the
final
rule
only
one
disposal
option
(
hazardous
waste
landfill)
is
available
for
regulated
generators
and
five
of
the
CRT
management
options
are
available
(
collector,
reuse,
processor,
smelter,
and
municipal
landfill)
for
former
generators.
The
reason
for
the
changes
in
average
collector
costs
is
similar.
Under
the
baseline,
six
CRT
management
options
are
available
(
reuse,
processor,
smelter,
hazardous
waste
landfill,
municipal
landfill,
and
export).
Under
the
final
rule,
the
same
six
CRT
management
options
are
available
for
regulated
collectors,
while
former
generators
have
five
CRT
management
options
(
reuse,
municipal
landfill,
processor,
smelter,
and
export).

5.2.2
Incremental
Cost
Difference
Between
the
Subtitle
D
Baseline
and
the
Final
Rule
The
final
rule
generates
a
net
incremental
savings
relative
to
the
baseline,
due
primarily
to
reduced
administrative
requirements
and
savings
from
reduced
transportation
and
disposal
costs.
Savings
from
the
final
rule
accrue
to
former
generators
that
would
no
longer
be
regulated.
The
range
of
potential
savings
under
the
final
rule
is
estimated
to
be
from
a
net
savings
of
743,00038
to
a
net
savings
of
$
1,821,000,39
with
a
best
estimate
of
a
savings
of
$
1,146,000.40
Exhibit
5­
3
summarizes
the
costs
under
the
baseline
and
the
final
rule
by
cost
category.
March
19,
2004
Page
51
Exhibit
5­
2:
Final
Rule
Compliance
Costs
Under
the
Subtitle
D
Baseline
Average
Costs
per
Generator
Number
of
Regulated
Generators
Average
Costs
per
Potentially
Regulated
Generator
Number
of
Potentially
Regulated
Generators
Total
Cost
Admin.
Storage
Transp.
Disposal
Except
Subtitle
D
Subtitle
D
Disposal
Transp.
Disposal
Except
Subtitle
D
Subtitle
D
Disposal
Original
Users
(
Generating
No
Non­
CRT
Hazardous
Waste)

Former
SQG
$
93
$
1,156
$
120
$
1,022
$
467
173
$
120
$
1,022
$
467
3,214
$
5,668,000
Former
LQG
$
93
$
3,058
$
802
$
9,464
$
4,327
4
$
802
$
9,464
$
4,327
82
$
1,268,000
Subtotal
$
6,936,000
Original
Users
Also
Generating
Non­
CRT
Hazardous
Waste
Former
SQG
$
93
$
672
$
47
$
297
$
136
44
$
47
$
297
$
136
496
$
293,000
Former
LQG
$
93
$
643
$
47
$
284
$
130
14
$
47
$
284
$
130
149
$
85,000
Subtotal
$
378,000
Collectors
Former
SQG
$
18
0
$
0
$
131
$
291
$
91
8
$
131
$
291
$
91
90
$
52,000
Former
LQG
$
169
$
0
$
193
$
371
$
200
75
$
193
$
371
$
200
415
$
387,000
Subtotal
$
439,000
Total
Cost
to
Regulated
Generators
$
402,000
Total
Compliance
Costs
under
the
Final
Rule
$
8,155,000
Note:
Total
cost
numbers
rounded
to
nearest
thousand.
Costs
may
not
add
due
to
rounding.

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

Administrative
$
294,000
$
102,000
$
192,000
Disposal
Except
Subtitle
D
$
5,509,000
$
4,943,000
$
566,000
Subtitle
D
Disposal
$
2,269,000
$
2,159,000
$
110,000
Transportation
$
916,000
$
683,000
$
233,000
Storage
$
313,000
$
268,000
$
45,000
Total
$
9,301,000
$
8,155,000
$
1,146,000
Note:
Cost
numbers
rounded
to
nearest
thousand.
Costs
may
not
add
due
to
rounding.

5.2.3
Sensitivity
Analysis
for
the
Final
Rule
Individual
sensitivity
and
bounding
analysis
is
conducted
on
the
difference
between
the
Subtitle
D
baseline
and
the
final
rule
for
the
following
three
parameters:
monitor
weight,
monitor
lifetime
and
storage
costs.
The
individual
sensitivity
analysis
is
conducted
by
changing
one
parameter
at
a
time
while
holding
all
other
parameters
at
their
best
estimate
value.
Exhibit
5­
4
contains
the
upper
and
lower
bounds
and
the
best
estimate
values
for
the
three
parameters
as
well
as
the
percent
change
of
the
lower
and
upper
bounds
from
the
best
estimate.
The
upper
and
lower
bounds
were
selected
because
they
represent
probable
limits
on
the
selected
parameters.
March
19,
2004
Page
52
Exhibit
5­
4:
Parameter
Values
for
Individual
Sensitivity
Analysis
Lower
Bound
%
Change
from
Best
Estimate
Best
Estimate
Upper
Bound
%
Change
from
Best
Estimate
Monitor
Weight
35
lbs.
­
14
%
40.6
lbs.
45
lbs.
11
%

Monitor
Life
2
years
­
43
%
3.5
years
6
years
71
%

Storage
Cost
$
0
­
100
%
$
8.45
$
15
78
%

Exhibit
5­
5
contains
the
model
results
for
each
individual
change.
Exhibit
5­
6
plots
the
data
in
Exhibit
5­
5
from
the
individual
sensitivity
analysis
for
the
three
parameters.
The
graph
illustrates
that
the
analysis
is
most
sensitive
to
the
monitor
weight
and
monitor
lifetime.
To
determine
a
potential
maximum
upper
bound
on
the
savings,
a
combined
sensitivity
analysis
is
conducted
using
a
monitor
weight
of
45
pounds,
a
monitor
lifetime
of
two
years,
and
storage
cost
of
$
15
per
square
foot.
The
savings
under
the
combined
sensitivity
analysis
is
$
1,915,000.

Sensitivity
analysis
is
also
conducted
for
disposal
costs
above
and
below
the
best
estimate
values.
By
changing
the
cost
for
disposal
to
a
hazardous
waste
landfill
to
$
800
and
$
1700
per
ton
for
whole
CRTs
(
from
a
best
estimate
of
$
1,548),
and
to
$
50
and
$
250
per
ton
for
crushed
CRTs
(
from
a
best
estimate
of
$
165),
the
savings
ranged
from
$
186,000
to
$
1,344,000.
By
changing
the
cost
for
disposal
to
a
reclaimer
to
$
150
and
$
500
per
ton
for
whole
CRTs
(
from
a
best
estimate
of
$
300),
to
$
100
and
$
300
per
ton
for
bare
CRTs
(
from
a
best
estimate
of
$
211),
and
to
$
75
and
$
250
per
ton
for
crushed
CRTs
(
from
a
best
estimate
of
$
153),
the
savings
ranged
from
$
1,387,000
to
$
830,000.
By
changing
the
cost
for
disposal
to
a
collector
to
$
100
and
$
350
per
ton
(
from
a
best
estimate
of
$
274),
the
savings
ranged
from
$
1,574,000
to
$
959,000.
The
sensitivity
analysis
on
disposal
costs
shows
that
the
model
is
moderately
sensitive
to
hazardous
waste,
reclaimer,
and
collector
disposal
costs.

Exhibit
5­
5:
Individual
Sensitivity
Analysis
Results
Lower
Bound
Best
Estimate
Upper
Bound
Monitor
Weight
$
1,096,000
$
1,146,000
$
1,176,000
Monitor
Life
$
1,798,000
$
1,146,000
$
819,000
Storage
Cost
$
1,101,000
$
1,146,000
$
1,181,000
Note:
Cost
numbers
rounded
to
nearest
thousand.
41
The
number
of
televisions
disposed
of
is
based
on
the
assumption
that
there
are
100
million
households
each
with
two
televisions
and
that
the
TVs
are
discarded
after
ten
years.
The
20
million
TVs
discarded
is
also
consistent
with
the
number
of
televisions
sold
in
1991,
which
was
19.5
million.
The
number
of
computer
monitor
CRTs
disposed
of
is
based
on
data
from
the
US
Census,
Survey
of
Computer
Use,
1997,
which
estimates
that
52
percent
of
households
have
computers.

March
19,
2004
Page
53
$
600,000
$
800,000
$
1,000,000
$
1,200,000
$
1,400,000
$
1,600,000
$
1,800,000
$
2,000,000
­
150%
­
100%
­
50%
0%
50%
100%

Percent
Change
from
Best
Estimate
Total
Cost
Difference
($)

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

5.2.4
Incremental
Cost
Difference
Between
the
Subtitle
D
Baseline
and
the
Final
Rule,
Including
Currently
Unregulated
Monitors
and
Televisions
To
help
understand
how
the
final
rule
might
be
affected
by
capacity
issues,
the
total
cost
of
compliance
under
the
Subtitle
D
baseline
and
the
final
rule
is
also
calculated
including
CRTs
from
households
and
CESQGs.
It
is
assumed
that
20
million
unregulated
television
CRTs
are
disposed
and
16.97
million
unregulated
computer
monitor
CRTs
are
disposed
from
households
and
CESQGs.
41
Exhibit
5­
7
contains
a
summary
of
the
costs
under
the
baseline
and
the
final
rule
by
cost
category.
Transportation
and
disposal
costs
are
higher
under
the
final
rule
than
the
baseline
because
it
is
assumed
that
a
greater
percentage
of
unregulated
CRTs
are
sent
to
March
19,
2004
Page
54
collectors,
which
increases
the
number
of
CRTs
that
have
a
non­
zero
disposal
cost
under
the
final
rule.

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

Administrative
$
318,000
$
171,000
$
147,000
Disposal
Except
Subtitle
D
$
7,986,000
$
7,311,000
$
675,000
Subtitle
D
Disposal
$
3,818,000
$
3,580,000
$
238,000
Transportation
$
1,315,000
$
1,865,000
$
550,000
Storage
$
313,000
$
268,000
$
45,000
Total
$
13,750,000
$
13,195,000
$
555,000
Note:
Cost
numbers
rounded
to
nearest
thousand.
Costs
may
not
add
due
to
rounding.

The
analysis
estimates
that
10,296
tons
of
CRT
glass
is
sent
to
glass
processors
and
that,
of
this,
10,090
tons
of
CRT
glass
is
sent
to
CRT
glass
manufacturers.
These
quantities
are
below
the
capacity
limits
for
glass
processors
and
CRT
glass
manufacturers.
As
the
CRT
recycling
infrastructure
grows
and
additional
unregulated
CRTs
are
recycled,
the
capacities
of
both
glass
processors
and
glass
manufacturers
are
expected
to
be
exceeded.
This
analysis
does
not
attempt
to
predict
when
this
might
occur.

6.0
Economic
Impacts
This
section
presents
the
estimated
first­
order
economic
impacts
associated
with
the
incremental
cost
savings
from
the
final
rule
over
the
Subtitle
C
management
baseline
using
the
cost
to
sales
ratio.
As
noted
in
Section
3.10,
the
impacts
analysis
is
likely
to
overstate
economic
impacts
(
whether
costs
or
savings)
because
the
sales
data
used
in
the
analysis
represent
average
values
for
each
NAICS
code
as
a
whole,
whereas
the
estimated
compliance
costs
arise
only
for
the
entities
that
are
large
enough
to
be
considered
an
SQG
or
LQG
in
the
baseline.
Such
entities
are
likely
to
have
an
average
sales
value
higher
than
the
average
for
the
industry
as
a
whole.

Final
Rule
Exhibit
6­
1
shows
the
impacts
of
the
cost
savings
for
original
users
that
were
baseline
small
quantity
generators
(
SQGs).
Their
average
savings
is
$
523
per
year,
due
primarily
to
reduced
administrative
requirements
and
transportation
savings.
The
highest
impact
on
SQGs
is
on
the
"
Agriculture
and
Forestry
Support
Activities"
sector
(
NAICS
code
115).
Establishments
in
NAICS
code
115
have
average
annual
sales
of
$
207,796.
The
incremental
cost
savings
represents
0.25
percent
of
the
average
annual
sales.
Establishments
in
all
but
two
other
NAICS
codes
have
impacts
of
less
than
0.17
percent
of
the
average
annual
sales.
March
19,
2004
Page
55
Exhibit
6­
1:
Estimated
Impact
of
Savings
Under
the
Final
Rule
on
Former
SQGs
that
were
Baseline
SQGs
Industry
NAICS
Code
Average
Sales
per
Establishment
Number
of
Baseline
Potential
SQGs
Savings
(
Cost)
Impact
of
Final
Rule
Agriculture
and
forestry
support
activities
115
$
207,796
1
0.25%

Oil
and
gas
extraction
211
$
12,372,169
12
0.00%

Mining
(
except
oil
and
gas)
212
$
6,975,044
7
0.01%

Mining
support
activities
213
$
2,130,480
18
0.02%

Utilities
221
$
26,539,891
191
0.00%

Construction
of
Buildings
233
$
1,941,561
124
0.03%

Heavy
construction
234
$
3,073,613
128
0.02%

Special
trade
contractors
235
$
822,155
66
0.06%

Food
manufacturing
311
$
16,083,560
183
0.00%

Beverage
and
tobacco
product
manufacturing
312
$
35,589,804
13
0.00%

Textile
mills
313
$
12,495,595
18
0.00%

Textile
product
mills
314
$
3,934,732
8
0.01%

Apparel
manufacturing
315
$
4,009,878
12
0.01%

Leather
and
allied
product
manufacturing
316
$
5,828,594
4
0.01%

Wood
product
manufacturing
321
$
5,123,862
11
0.01%

Paper
manufacturing
322
$
25,548,751
159
0.00%

Printing
and
related
support
activities
323
$
2,282,249
126
0.02%

Petroleum
and
coal
products
manufacturing
324
$
81,771,350
45
0.00%

Chemical
manufacturing
325
$
31,052,871
251
0.00%

Plastics
and
rubber
products
manufacturing
326
$
9,499,747
54
0.01%

Nonmetallic
mineral
product
manufacturing
327
$
5,310,358
24
0.01%

Primary
metal
manufacturing
331
$
33,403,082
187
0.00%

Fabricated
metal
product
manufacturing
332
$
3,892,010
232
0.01%

Machinery
manufacturing
333
$
8,816,473
371
0.01%

Computer
and
electronic
product
manufacturing
334
$
25,090,707
587
0.00%

Electrical
equipment,
appliance,
and
component
manufacturing
335
$
16,096,992
225
0.00%

Transportation
equipment
manufacturing
336
$
44,066,228
573
0.00%

Furniture
and
related
product
manufacturing
337
$
3,080,236
36
0.02%

Miscellaneous
manufacturing
339
$
3,201,646
171
0.02%

Wholesale
trade,
durable
goods
421
$
7,500,000
278
0.01%

Wholesale
trade,
nondurable
goods
422
$
11,570,217
302
0.00%

Motor
vehicle
and
parts
dealers
441
$
5,262,595
19
0.01%

Electronics
and
appliance
stores
443
$
1,580,738
9
0.03%

Building
material
and
garden
equipment
and
support
dealers
444
$
2,443,873
6
0.02%

Health
and
personal
care
stores
446
$
1,419,091
6
0.04%

Clothing
and
clothing
accessories
stores
448
$
870,988
76
0.06%

Sporting
goods,
hobby,
book,
and
music
stores
451
$
896,773
5
0.06%

General
merchandise
stores
452
$
9,135,619
13
0.01%
Exhibit
6­
1:
Estimated
Impact
of
Savings
Under
the
Final
Rule
on
Former
SQGs
that
were
Baseline
SQGs
(
continued)

Industry
NAICS
Code
Average
Sales
per
Establishment
Number
of
Baseline
Potential
SQGs
Savings
(
Cost)
Impact
of
Final
Rule
March
19,
2004
Page
56
Miscellaneous
store
retailers
453
$
601,589
2
0.09%

Nonstore
retailers
454
$
2,767,561
123
0.02%

Air
transportation
481
$
5,627,858
147
0.01%

Water
transportation
483
$
12,503,471
20
0.00%

Truck
transportation
484
$
1,360,579
50
0.04%

Transit
and
ground
passenger
transportation
485
$
861,326
9
0.06%

Transportation
support
activities
488
$
1,296,112
62
0.04%

Couriers
and
messengers
492
$
3,656,878
61
0.01%

Warehousing
and
storage
493
$
1,640,438
6
0.03%

Publishing
industries
511
$
5,281,904
320
0.01%

Motion
picture
and
sound
recording
industries
512
$
2,518,714
34
0.01%

Broadcasting
and
telecommunications
513
$
7,964,942
513
0.01%

Information
and
data
processing
services
514
$
2,815,523
159
0.02%

Monetary
authorities
­
central
bank
521
$
585,275,214
14
0.00%

Credit
intermediation
and
related
activities
522
$
4,846,604
577
0.01%

Security,
commodity
contracts
and
like
activity
523
$
5,046,461
344
0.01%

Insurance
carriers
and
related
activities
524
$
6,226,293
590
0.01%

Funds,
trusts,
and
other
financial
vehicles
(
part)
525
$
11,153,790
11
0.00%

Real
estate
531
$
691,518
85
0.08%

Rental
and
leasing
services
532
$
1,184,681
65
0.04%

Lessors
of
other
nonfinancial
intangible
asset
533
$
5,236,571
14
0.01%

Professional,
scientific
and
technical
services
541
$
941,878
938
0.06%

Management
of
companies
and
enterprises
551
$
1,954,248
2,342
0.03%

Administrative
and
support
services
561
$
986,793
1,938
0.05%

Waste
management
and
remediation
services
562
$
2,403,813
20
0.02%

Educational
services
611
$
442,036
684
0.12%

Ambulatory
health
care
services
621
$
704,253
426
0.07%

Hospitals
622
$
29,848,609
2,721
0.00%

Nursing
and
residential
care
facilities
623
$
1,700,862
18
0.03%

Social
assistance
624
$
222,242
24
0.24%

Performing
arts,
spectator
sports
and
related
industries
711
$
1,262,184
68
0.04%

Museums,
historical
sites
and
like
institutions
712
$
614,591
19
0.09%

Amusement,
gambling
and
recreation
industries
713
$
980,233
90
0.05%

Food
services
and
drinking
places
722
$
517,434
89
0.10%

Repair
and
maintenance
811
$
446,578
30
0.12%

Personal
and
laundry
services
812
$
312,045
4
0.17%

Religious,
grant
making,
civic,
prof
and
like
organizations
813
$
1,041,506
113
0.05%
March
19,
2004
Page
57
Exhibit
6­
2
presents
the
results
for
original
users
that
were
baseline
large
quantity
generators
(
LQGs).
Their
average
savings
is
$
1,091
per
year,
due
to
reduced
administrative
requirements,
and
transportation
and
disposal
costs.
The
LQGs
under
the
baseline
are
in
27
NAICS
codes.
The
highest
impact
for
LQGs
is
on
the
Educational
Services
category
(
NAICS
Code
611).
The
maximum
incremental
cost
savings
represents
0.25
percent
of
the
average
annual
sales.
Establishments
in
all
other
SIC
codes
have
impacts
of
less
than
0.16
percent
of
the
average
annual
sales.

Exhibit
6­
2:
Estimated
Impact
of
Savings
Under
the
Final
Rule
on
Former
LQGs
that
were
Baseline
LQGs
Industry
NAICS
Code
Average
Sales
per
Establishment
Number
of
Baseline
Potential
SQGs
Savings
(
Cost)
Impact
of
Final
Rule
Mining
support
activities
213
$
2,130,480
1
0.05%

Utilities
221
$
26,539,891
1
0.00%

Heavy
construction
234
$
3,073,613
3
0.04%

Food
manufacturing
311
$
16,083,560
2
0.01%

Chemical
manufacturing
325
$
31,052,871
7
0.00%

Primary
metal
manufacturing
331
$
33,403,082
4
0.00%

Machinery
manufacturing
333
$
8,816,473
2
0.01%

Computer
and
electronic
product
manufacturing
334
$
25,090,707
22
0.00%

Transportation
equipment
manufacturing
336
$
44,066,228
40
0.00%

Furniture
and
related
product
manufacturing
337
$
3,080,236
1
0.04%

Wholesale
trade,
durable
goods
421
$
7,500,000
1
0.01%

Wholesale
trade,
nondurable
goods
422
$
11,570,217
5
0.01%

Air
transportation
481
$
5,627,858
23
0.02%

Truck
transportation
484
$
1,360,579
4
0.08%

Transportation
support
activities
488
$
1,296,112
2
0.08%

Couriers
and
messengers
492
$
3,656,878
27
0.03%

Publishing
industries
511
$
5,281,904
4
0.02%

Broadcasting
and
telecommunications
513
$
7,964,942
1
0.01%

Information
and
data
processing
services
514
$
2,815,523
2
0.04%

Security,
commodity
contracts
and
like
activity
523
$
5,046,461
25
0.02%

Insurance
carriers
and
related
activities
524
$
6,226,293
51
0.02%

Professional,
scientific
and
technical
services
541
$
941,878
22
0.12%

Management
of
companies
and
enterprises
551
$
1,954,248
75
0.06%

Educational
services
611
$
442,036
35
0.25%

Ambulatory
health
care
services
621
$
704,253
3
0.15%

Hospitals
622
$
29,848,609
71
0.00%

Religious,
grant
making,
civic,
prof
and
like
organizations
813
$
1,041,506
4
0.10%

7.0
Qualitative
Environmental
Benefits
March
19,
2004
Page
58
The
shift
of
waste
CRTs
from
landfills
and
incinerators
to
glass
processors,
and
thus
to
CRT
glass
manufacturers
and
to
smelters,
has
four
major
potential
qualitative
environmental
benefits.
The
four
potential
qualitative
benefits
are
(
1)
increase
in
the
availability
of
landfill
space;
(
2)
increase
in
resource
efficiency;
(
3)
increase
in
recycling
by
non­
regulated
entities;
and
(
4)
reduction
of
lead
emissions
from
incinerators.
This
section
discusses
these
four
qualitative
environmental
benefits.

Landfill
Capacity
A
qualitative
benefit
of
the
final
rule
is
the
shift
of
CRTs
from
Subtitle
C
and
D
landfills
to
CRT
glass
processors
and
smelters.
The
analysis
estimates
that
approximately
2,859
tons
or
423,000
cubic
feet
of
CRTs
will
be
redirected
away
from
landfills
each
year
under
the
final
rule.
This
additional
space
can
be
used
for
other
waste.
By
not
disposing
of
CRTs
in
Subtitle
C
and
D
landfills,
the
landfill
capacity
will
not
be
reached
as
quickly
and
new
landfills
will
not
be
needed
as
soon.
This
unused
Subtitle
C
and
D
landfill
capacity
is
seen
as
a
minor
qualitative
benefit,
because
so
few
regulated
CRTs
currently
are
being
sent
to
these
landfills.

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

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

Reduction
of
Lead
Emissions
Exposure
to
lead
may
result
in
health
problems
to
adults
and
children.
These
effects
include
hypertension,
stroke,
cancer
in
adults
and
decreased
IQ
and
gestational
age,
reduced
birth
weight,
and
other
neurological
effects
in
infants
and
children.
By
shifting
disposal
of
CRTs
from
municipal
waste
incinerators,
the
total
lead
emitted
from
CRT
incineration
can
be
reduced.
However,
the
benefits
of
reducing
lead
emissions
from
CRT
incineration
are
reported
to
be
42
Macauley
et
al.,
2001,
page
51.

43
Macauley
et
al.,
2001,
page
45.

March
19,
2004
Page
59
small.
42
One
report
estimates
that
the
value
of
the
health
effects
due
to
a
complete
ban
on
incineration
of
any
CRTs
is
on
the
order
of
$
5
million.
43
8.0
Other
Administrative
Requirements
This
section
describes
the
Agency's
response
to
other
rulemaking
requirements
established
by
statute
and
executive
order,
within
the
context
of
the
final
rule
for
CRTs.

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

Because
CRTs
are
ubiquitous,
it
is
not
certain
whether
the
environmental
problems
addressed
by
the
final
rule
could
disproportionately
affect
minority
or
low
income
communities.
CRTs
are
used
throughout
the
country
and
many
are
located
within
highly
populated
areas.
Because
the
final
rule
establishes
general
environmental
performance
requirements
to
minimizes
breakage,
and
helps
prevent
the
release
of
glass
particulates,
the
Agency
does
not
believe
that
this
rule
will
increase
risks
from
CRT
wastes.

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

An
analysis
of
the
costs
and
benefits
of
the
final
rule
was
conducted
and
it
was
determined
that
this
rule
does
not
include
a
federal
mandate
that
may
result
in
estimated
costs
of
$
100
million
or
more
to
either
state,
local,
or
tribal
governments
in
the
aggregate.
The
private
sector
also
is
not
expected
to
incur
costs
exceeding
$
100
million
per
year.
44
An
economically
significant
rule
is
defined
by
Executive
Order
12866
as
any
rulemaking
that
has
an
annual
effect
on
the
economy
of
$
100
million
or
more,
or
adversely
affects
in
a
material
way
the
economy,
a
sector
of
the
economy,
productivity,
competition,
jobs,
the
environment,
public
health,
or
safety,
or
State,
local,
or
tribal
governments
or
communities.

March
19,
2004
Page
60
8.3
Protection
of
Children
from
Environmental
Health
Risks
and
Safety
Risks
Executive
Order
13045,
entitled
"
Protection
of
Children
from
Environmental
Health
Risks
and
Safety
Risks"
requires
all
economically
significant
rules44
that
concern
an
environmental
health
risk
or
safety
risk
that
may
disproportionately
affect
children
to
comply
with
requirements
of
the
Executive
Order.
Because
the
EPA
does
not
consider
the
final
rule
to
be
economically
significant,
it
is
not
subject
to
Executive
Order
13045.
Because
this
rulemaking
establishes
general
environmental
performance
requirements,
minimizes
breakage,
and
prevents
of
release
of
glass
particulates,
the
EPA
believes
that
the
final
rule
will
not
result
in
increased
exposures
to
children.
For
these
reasons,
the
environmental
health
risks
or
safety
risks
addressed
by
this
action
do
not
have
a
disproportionate
effect
on
children.

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

9.0
Discussion
of
Findings
and
Summary
The
main
conclusion
of
this
analysis
is
that
both
the
overall
savings
and
the
savings
for
individual
establishments
are
small,
and
that
the
results
are
sensitive
to
a
few
key
parameters
(
CRT
life
in
businesses,
the
average
weight
of
CRTs,
storage
costs,
and
the
number
of
color
CRT
monitors
discarded
to
become
an
SQG).
A
second
conclusion
is
that
the
glass
processing
capacity
is
insufficient;
however,
the
CRT
glass
manufacturer
capacity
is
adequate
to
handle
all
regulated
CRTs.
If
this
rule
induces
significantly
more
unregulated
CRTs
to
be
recycled
than
is
modeled
in
this
analysis,
then
the
CRT
glass
manufacturer
capacity
would
become
inadequate
to
handle
this
larger
volume
of
CRT
glass.
However,
the
analysis
anticipates
that
the
lead
and
copper
smelter
capacities
on
top
of
the
CRT
glass
manufacturer
capacity
would
be
sufficient
to
handle
all
CRTs
generated
by
all
original
users.

The
final
rule,
as
modeled
in
this
analysis,
is
expected
to
impact
approximately
3,900
establishments
in
76
different
three­
digit
NAICS
codes.
Under
the
Subtitle
C
baseline
the
March
19,
2004
Page
61
final
rule
will
lead
to
total
savings
of
approximately
$
5,090,000
for
current
generators
that
elect
not
to
send
their
discarded
CRTs
for
disposal.
These
savings
are
due
primarily
to
reduced
administrative,
disposal,
and
transportation
costs.
Under
the
Subtitle
D
baseline
the
final
rule
will
lead
to
a
total
savings
of
approximately
$
1,146,000,
due
to
increased
disposal
costs.

Relative
to
the
Subtitle
C
baseline,
the
economic
impacts
on
the
entities
in
the
regulated
community
are
expected
to
be
negligible
because
the
rule
provides
savings
for
all
entities
managing
CRTs.
A
significant
benefit
of
the
final
rule
is
the
possible
increase
in
glass­
to­
glass
recycling
by
the
non­
regulated
community.
Appendices
Appendix
A­
1:
Number
of
Establishments
by
Establishment
Employment
Size
Category
Appendix
A­
2:
Number
of
Employees
by
Establishment
Employment
Size
Category
Appendix
B:
Computer
Use
By
Employees
Appendix
C:
Crosswalk
of
SIC
and
NAICS
Codes
Appendix
D:
Computer
Use
Percentages
by
NAICS
Code
Appendix
E:
Disposal
Cost
Source
Details
Appendix
F:
Flow
of
CRTs
Under
Subtitle
C
(
Number)

Flow
of
CRTs
Under
Subtitle
C
(
Tons)

Flow
of
CRTs
Under
Subtitle
D
(
Number)

Flow
of
CRTs
Under
Subtitle
D
(
Tons)

Appendix
G:
Average
Shipment
Sizes
for
Each
Type
of
Establishment
Distributing
CRTs
to
Each
CRT
Management
Option
Number
of
Shipments
Each
Year
Under
Subtitle
C
Appendix
H:
Average
Annual
Sales
per
Establishment
by
2­
Digit
SIC
Code
Appendix
I:
Detailed
Sensitivity
Analysis
Results
on
All
Parameters
Tested
Appendix
J:
Telephone
Contacts
Appendix
K:
Bibliography
1
Source:
United
States
Bureau
of
the
Census;
County
Business
Patterns:
2001.

March
19,
2004
Page
A­
1
Appendix
A­
1
Number
of
Establishments
by
Establishment
Employment
Size
Category1
Industry
NAICS
Code
Total
Establishments
Number
of
Establishments
1
to
4
5
to
9
10
to
19
20
to
49
50
to
99
100
to
249
250
to
499
500
to
999
1,000
to
1,499
1,500
to
2,499
2,500
to
4,999
5,000
or
more
Forestry
and
Logging
113
12,795
7,852
2,821
1,470
535
91
18
8
0
0
0
0
0
Fishing,
hunting,
and
trapping
114
2,636
2,255
203
93
61
11
11
1
1
0
0
0
0
Agriculture
and
forestry
support
activities
115
11,016
7,532
1,736
851
544
225
95
26
6
0
1
0
0
Oil
and
gas
extraction
211
7,691
4,948
1,167
747
511
176
102
28
10
2
0
0
0
Mining
(
except
oil
and
gas)
212
7,323
2,616
1,246
1,414
1,266
414
240
86
34
3
4
0
0
Mining
support
activities
213
9,305
5,166
1,389
1,155
928
333
227
65
23
6
10
2
1
Utilities
221
17,702
7,242
2,888
2,375
2,532
1,305
902
266
130
45
9
7
1
Building,
developing
and
general
contracting
233
215,806
146,821
35,424
18,835
10,258
2,833
1,229
280
87
25
8
4
2
Heavy
construction
234
40,476
17,629
7,714
6,406
5,321
1,906
1,080
289
80
24
10
14
3
Special
trade
contractors
235
442,616
276,284
79,113
46,544
28,124
8,021
3,564
714
186
37
22
7
0
Food
manufacturing
311
26,785
9,410
4,508
3,968
3,794
1,968
1,764
823
365
113
54
16
2
Beverage
and
tobacco
product
manufacturing
312
3,212
1,211
473
405
491
250
223
106
40
4
6
3
0
Textile
mills
313
4,452
1,453
632
544
572
400
508
249
76
11
5
2
0
Textile
product
mills
314
6,966
3,039
1,228
995
890
384
273
105
44
6
2
0
0
Apparel
manufacturing
315
16,152
6,915
2,630
2,259
2,367
1,006
688
194
81
11
1
0
0
Leather
and
allied
product
manufacturing
316
1,763
781
282
219
220
116
96
34
11
2
2
0
0
Wood
product
manufacturing
321
17,289
5,482
2,922
3,037
3,049
1,432
1,091
220
45
6
1
4
0
Paper
manufacturing
322
5,739
734
445
682
1,276
1,021
1,178
244
112
36
9
2
0
Printing
and
related
support
activities
323
37,895
16,452
8,268
5,522
4,342
1,796
1,110
279
100
18
8
0
0
Petroleum
and
coal
products
manufacturing
324
2,253
847
442
294
310
140
127
48
33
11
1
0
0
Chemical
manufacturing
325
13,361
3,619
2,032
2,061
2,490
1,387
1,123
391
163
51
26
11
7
Appendix
A­
1
Number
of
Establishments
by
Establishment
Employment
Size
Category
(
continued)

Industry
NAICS
Code
Total
Establishments
Number
of
Establishments
1
to
4
5
to
9
10
to
19
20
to
49
50
to
99
100
to
249
250
to
499
500
to
999
1,000
to
1,499
1,500
to
2,499
2,500
to
4,999
5,000
or
more
March
19,
2004
Page
A­
2
Plastics
and
rubber
products
manufacturing
326
15,981
3,193
1,908
2,434
3,447
2,300
1,938
534
175
35
17
2
0
Nonmetallic
mineral
product
manufacturing
327
16,732
4,835
3,018
3,255
3,289
1,219
817
219
56
19
5
0
0
Primary
metal
manufacturing
331
6,684
1,790
841
832
1,125
786
772
347
128
30
17
12
4
Fabricated
metal
product
manufacturing
332
60,791
19,143
11,365
11,101
10,773
4,714
2,762
701
197
24
9
2
0
Machinery
manufacturing
333
28,922
8,273
4,692
5,002
5,261
2,546
1,903
603
267
52
38
14
2
Computer
and
electronic
product
manufacturing
334
16,764
4,868
2,294
2,306
2,766
1,736
1,559
626
368
100
73
46
22
Electrical
equipment,
appliance,
and
component
manufacturing
335
6,940
1,786
996
951
1,141
727
758
356
163
30
22
10
0
Transportation
equipment
manufacturing
336
12,627
3,451
1,735
1,649
1,926
1,179
1,330
744
338
87
72
76
40
Furniture
and
related
product
manufacturing
337
20,593
8,724
3,911
3,063
2,533
1,109
785
307
124
17
13
6
1
Miscellaneous
manufacturing
339
30,718
15,394
5,658
3,807
3,103
1,343
939
303
125
27
16
3
0
Wholesale
trade,
durable
goods
421
283,435
142,395
58,187
42,124
28,139
7,987
3,580
744
213
41
17
7
1
Wholesale
trade,
nondurable
goods
422
155,489
80,014
28,645
21,616
15,721
5,293
3,141
752
225
49
15
13
5
Motor
vehicle
and
parts
dealers
441
125,728
52,891
29,143
20,533
14,398
6,115
2,468
161
17
0
2
0
0
Furniture
and
home
furnishing
stores
442
65,766
33,117
16,152
10,504
4,764
887
296
41
5
0
0
0
0
Electronics
and
appliance
stores
443
47,747
25,590
13,571
4,915
1,974
1,151
500
37
7
0
0
2
0
Building
material
and
garden
equipment
and
support
dealers
444
94,135
39,268
23,879
17,559
9,378
1,769
2,075
201
5
1
0
0
0
Food
and
beverage
stores
445
156,261
80,175
28,227
17,128
12,550
9,760
7,837
556
28
0
0
0
0
Health
and
personal
care
stores
446
81,898
32,512
19,105
16,111
11,499
2,344
294
27
5
1
0
0
0
Gasoline
stations
447
118,892
44,358
43,595
24,614
5,448
714
157
5
1
0
0
0
0
Clothing
and
clothing
accessories
stores
448
151,668
64,428
47,166
26,257
10,894
2,422
386
39
66
9
1
0
0
Appendix
A­
1
Number
of
Establishments
by
Establishment
Employment
Size
Category
(
continued)

Industry
NAICS
Code
Total
Establishments
Number
of
Establishments
1
to
4
5
to
9
10
to
19
20
to
49
50
to
99
100
to
249
250
to
499
500
to
999
1,000
to
1,499
1,500
to
2,499
2,500
to
4,999
5,000
or
more
March
19,
2004
Page
A­
3
Sporting
goods,
hobby,
book,
and
music
stores
451
64,453
30,713
15,893
10,128
5,910
1,590
188
26
5
0
0
0
0
General
merchandise
stores
452
41,169
9,975
11,574
4,209
3,191
3,163
6,216
2,465
363
9
2
2
0
Miscellaneous
store
retailers
453
129,311
75,709
29,171
15,458
8,144
638
162
27
2
0
0
0
0
Nonstore
retailers
454
42,922
23,699
8,671
5,869
3,133
818
461
148
90
15
15
3
0
Air
transportation
481
5,451
2,179
799
744
814
387
260
98
69
30
24
24
23
Water
transportation
483
1,871
842
274
248
250
127
74
36
11
5
2
2
0
Truck
transportation
484
109,814
67,981
15,668
11,704
9,313
3,132
1,511
326
125
24
22
4
4
Transit
and
ground
passenger
transportation
485
16,466
7,683
2,419
2,130
2,257
1,100
706
132
30
4
3
1
1
Scenic
and
sightseeing
transportation
487
2,380
1,632
270
234
154
56
25
7
2
0
0
0
0
Transportation
support
activities
488
31,876
16,721
6,469
4,138
2,837
972
528
147
44
10
7
1
2
Couriers
and
messengers
492
12,855
6,586
1,784
1,475
1,535
713
584
90
17
4
6
34
27
Warehousing
and
storage
493
7,185
3,151
1,231
1,031
1,056
449
217
44
3
2
1
0
0
Publishing
industries
511
32,111
14,341
5,343
4,461
4,092
1,831
1,257
462
208
57
39
16
4
Motion
picture
and
sound
recording
industries
512
22,782
14,032
2,837
2,385
2,316
802
332
44
22
6
3
3
0
Broadcasting
and
telecommunications
513
59,675
27,939
9,783
8,137
6,976
3,292
2,335
699
359
86
47
21
1
Information
and
data
processing
services
514
22,725
12,252
3,408
2,732
2,247
978
696
251
118
23
13
5
2
Monetary
authorities
­
central
bank
521
74
11
4
6
3
9
17
10
4
8
2
0
0
Credit
intermediation
and
related
activities
522
180,764
71,727
51,747
33,110
16,470
4,310
2,133
686
386
104
56
31
4
Security,
commodity
contracts
and
like
activity
523
76,918
53,211
10,043
6,180
4,678
1,619
818
195
96
28
25
16
9
Insurance
carriers
and
related
activities
524
164,832
113,385
25,427
11,701
7,924
3,004
2,014
736
394
105
91
43
8
Funds,
trusts,
and
other
financial
vehicles
(
part)
525
2,440
1,456
435
306
136
61
22
13
9
1
1
0
0
Appendix
A­
1
Number
of
Establishments
by
Establishment
Employment
Size
Category
(
continued)

Industry
NAICS
Code
Total
Establishments
Number
of
Establishments
1
to
4
5
to
9
10
to
19
20
to
49
50
to
99
100
to
249
250
to
499
500
to
999
1,000
to
1,499
1,500
to
2,499
2,500
to
4,999
5,000
or
more
March
19,
2004
Page
A­
4
Real
estate
531
241,115
182,302
34,256
14,384
6,807
2,043
1,009
229
71
8
3
3
0
Rental
and
leasing
services
532
63,759
28,308
17,934
12,167
3,967
837
374
107
46
14
3
2
0
Lessors
of
other
nonfinancial
intangible
asset
533
2,129
1,368
295
206
163
51
32
13
1
0
0
0
0
Professional,
scientific
and
technical
services
541
736,454
502,589
110,591
63,939
37,654
12,062
6,749
1,910
650
161
84
43
22
Management
of
companies
and
enterprises
551
47,559
17,528
7,064
6,764
7,028
3,809
2,949
1,298
702
197
145
57
18
Administrative
and
support
services
561
345,916
199,136
53,208
34,983
27,950
14,157
10,940
3,522
1,289
300
215
134
82
Waste
management
and
remediation
services
562
16,749
7,719
3,113
2,392
2,147
839
449
70
13
4
2
1
0
Educational
services
611
70,878
32,968
11,134
9,479
9,779
4,005
2,162
632
371
139
127
47
35
Ambulatory
health
care
services
621
466,914
242,788
120,363
61,406
29,796
7,614
3,662
856
305
65
41
15
3
Hospitals
622
7,138
448
138
118
215
581
1,545
1,301
1,193
628
565
335
71
Nursing
and
residential
care
facilities
623
65,088
16,041
11,763
11,304
9,304
7,761
7,883
895
118
14
4
0
0
Social
assistance
624
132,230
55,139
25,845
25,214
18,800
4,451
2,250
427
80
15
7
2
0
Performing
arts,
spectator
sports
and
related
industries
711
34,840
25,988
3,863
2,125
1,535
616
492
153
48
14
6
0
0
Museums,
historical
sites
and
like
institutions
712
6,032
3,301
1,026
717
540
235
136
58
12
3
4
0
0
Amusement,
gambling
and
recreation
industries
713
65,089
32,019
10,068
8,871
8,716
3,577
1,382
262
104
46
25
12
7
Accommodation
721
60,196
25,725
8,184
11,226
9,328
2,706
1,984
616
267
67
58
26
9
Food
services
and
drinking
places
722
488,373
174,751
83,500
90,447
104,145
29,163
5,877
401
82
4
3
0
0
Repair
and
maintenance
811
230,867
149,353
48,982
22,134
8,399
1,426
464
79
19
7
4
0
0
Personal
and
laundry
services
812
196,810
122,977
40,958
21,744
8,386
1,730
877
110
24
4
0
0
0
Appendix
A­
1
Number
of
Establishments
by
Establishment
Employment
Size
Category
(
continued)

Industry
NAICS
Code
Total
Establishments
Number
of
Establishments
1
to
4
5
to
9
10
to
19
20
to
49
50
to
99
100
to
249
250
to
499
500
to
999
1,000
to
1,499
1,500
to
2,499
2,500
to
4,999
5,000
or
more
March
19,
2004
Page
A­
5
Religious,
grant
making,
civic,
prof
and
like
organizations
813
291,725
168,749
62,741
32,395
19,648
5,572
2,129
374
85
13
10
5
4
1
Source:
United
States
Bureau
of
the
Census;
County
Business
Patterns:
2001.

March
19,
2004
Page
A­
6
Appendix
A­
2
Number
of
Employees
by
Establishment
Employment
Size
Category1
Industry
NAICS
Code
Total
Employees
Number
of
Employees
1
to
4
5
to
9
10
to
19
20
to
49
50
to
99
100
to
249
250
to
499
500
to
999
1,000
or
more
Forestry
and
Logging
113
77,984
13,581
18,762
19,367
15,159
6,097
2,880
2,880
0
0
Fishing,
hunting,
and
trapping
114
9,954
2,259
1,314
1,116
1,830
770
1,760
360
740
0
Agriculture
and
forestry
support
activities
115
95,538
11,407
11,444
11,430
16,411
15,487
14,228
9,360
4,440
0
Oil
and
gas
extraction
211
87,980
8,305
7,002
10,198
15,847
12,320
15,266
9,586
7,187
0
Mining
(
except
oil
and
gas)
212
200,735
4,439
7,476
19,596
38,205
28,514
37,505
30,704
22,076
0
Mining
support
activities
213
196,850
8,359
9,217
15,701
28,623
22,971
33,278
22,827
16,231
39,643
Utilities
221
654,484
14,105
19,278
32,871
79,740
91,063
135,792
91,495
92,199
97,941
Building,
developing
and
general
contracting
233
1,616,973
234,429
230,063
250,834
303,223
192,187
179,394
92,580
57,714
76,549
Heavy
construction
234
901,207
29,426
51,609
87,564
161,651
131,250
161,388
99,735
55,579
123,005
Special
trade
contractors
235
3,973,814
451,091
518,547
624,209
839,708
544,591
526,582
241,260
123,001
104,825
Food
manufacturing
311
1,470,146
16,559
30,247
54,654
118,236
139,092
278,078
286,600
246,627
300,053
Beverage
and
tobacco
product
manufacturing
312
170,864
1,933
3,173
5,449
15,555
17,613
35,552
36,500
26,882
28,207
Textile
mills
313
308,490
2,648
4,259
7,593
17,915
28,924
80,957
86,384
51,320
28,490
Textile
product
mills
314
202,022
5,602
8,146
13,555
27,478
26,732
41,982
37,847
29,605
11,075
Apparel
manufacturing
315
441,742
9,904
17,723
30,990
73,646
69,732
104,888
65,691
54,411
14,757
Leather
and
allied
product
manufacturing
316
60,567
1,306
1,896
2,986
6,711
8,015
15,299
11,651
7,033
5,670
Wood
product
manufacturing
321
557,507
9,517
19,968
41,992
94,847
99,527
165,718
73,823
28,621
23,494
Paper
manufacturing
322
533,251
1,305
3,049
9,681
42,138
73,246
178,197
84,253
78,346
63,036
Printing
and
related
support
activities
323
784,520
33,134
54,783
74,827
134,276
124,097
165,560
94,508
68,595
34,740
Petroleum
and
coal
products
manufacturing
324
103,570
1,867
2,887
3,924
9,891
10,106
20,528
16,593
22,824
14,950
Chemical
manufacturing
325
869,761
6,739
13,693
28,518
78,886
96,726
175,648
136,319
112,900
220,232
Appendix
A­
2
Number
of
Employees
by
Establishment
Employment
Size
Category
(
continued)

Industry
NAICS
Code
Total
Employees
Number
of
Employees
1
to
4
5
to
9
10
to
19
20
to
49
50
to
99
100
to
249
250
to
499
500
to
999
1,000
or
more
March
19,
2004
Page
A­
7
Plastics
and
rubber
products
manufacturing
326
1,002,503
5,983
12,964
34,145
110,394
163,918
297,569
181,032
114,412
82,086
Nonmetallic
mineral
product
manufacturing
327
524,230
9,223
20,529
45,089
101,166
84,056
123,107
72,545
36,181
32,334
Primary
metal
manufacturing
331
572,512
2,876
5,713
11,602
36,210
55,708
121,323
119,185
85,501
134,396
Fabricated
metal
product
manufacturing
332
1,761,358
37,719
76,797
153,120
334,190
325,490
415,059
235,958
133,641
49,384
Machinery
manufacturing
333
1,332,854
16,214
33,944
69,078
164,356
177,917
294,137
208,414
183,415
185,379
Computer
and
electronic
product
manufacturing
334
1,593,307
8,606
15,533
32,208
88,918
123,647
242,292
218,261
257,526
606,316
Electrical
equipment,
appliance,
and
component
manufacturing
335
575,413
3,159
6,731
13,198
36,529
52,049
119,264
123,010
109,085
112,388
Transportation
equipment
manufacturing
336
1,753,445
6,241
11,611
22,999
61,007
84,695
213,249
262,189
230,950
860,504
Furniture
and
related
product
manufacturing
337
619,197
16,055
26,221
41,761
78,240
77,627
120,666
105,061
82,920
70,646
Miscellaneous
manufacturing
339
713,165
28,369
37,308
52,239
95,599
94,352
142,230
107,527
83,974
71,567
Wholesale
trade,
durable
goods
421
3,633,480
263,343
387,245
571,074
842,630
541,859
521,683
252,059
140,826
112,761
Wholesale
trade,
nondurable
goods
422
2,508,609
140,739
189,847
293,347
477,552
362,937
472,861
254,304
148,849
168,173
Motor
vehicle
and
parts
dealers
441
1,850,218
98,464
196,631
273,875
448,263
422,015
345,604
51,097
12,580
0
Furniture
and
home
furnishing
stores
442
567,318
63,280
107,973
139,296
139,525
59,526
40,304
14,301
3,113
0
Electronics
and
appliance
stores
443
425,736
48,993
88,633
63,850
58,564
77,683
64,222
11,617
5,180
0
Building
material
and
garden
equipment
and
support
dealers
444
1,249,126
80,521
159,375
236,777
272,149
117,415
318,792
59,993
3,700
0
Food
and
beverage
stores
445
2,963,801
137,765
186,267
230,230
398,192
700,339
1,124,024
169,490
17,494
0
Health
and
personal
care
stores
446
958,072
67,691
125,866
223,670
335,871
152,619
38,593
8,956
3,700
0
Gasoline
stations
447
927,284
95,305
295,241
317,538
148,275
47,658
20,793
1,800
740
0
Clothing
and
clothing
accessories
stores
448
1,392,626
127,179
313,183
345,696
325,864
155,656
53,071
13,438
45,968
12,571
Appendix
A­
2
Number
of
Employees
by
Establishment
Employment
Size
Category
(
continued)

Industry
NAICS
Code
Total
Employees
Number
of
Employees
1
to
4
5
to
9
10
to
19
20
to
49
50
to
99
100
to
249
250
to
499
500
to
999
1,000
or
more
March
19,
2004
Page
A­
8
Sporting
goods,
hobby,
book,
and
music
stores
451
622,261
56,668
106,851
133,516
185,760
102,286
25,623
8,301
3,256
0
General
merchandise
stores
452
2,525,974
29,925
76,619
55,369
95,205
242,965
974,005
830,632
211,924
0
Miscellaneous
store
retailers
453
841,594
139,635
192,792
203,714
230,162
41,625
23,257
9,720
1,480
0
Nonstore
retailers
454
566,279
71,097
57,414
79,823
91,904
55,012
70,717
51,456
62,302
0
Air
transportation
481
608,986
3,505
5,341
10,287
24,916
26,842
40,791
35,589
46,743
414,972
Water
transportation
483
70,462
2,526
1,644
3,451
7,618
9,052
11,187
12,495
8,140
0
Truck
transportation
484
1,397,865
100,924
103,601
159,754
282,488
214,329
223,039
109,261
83,619
120,850
Transit
and
ground
passenger
transportation
485
391,561
11,571
16,204
29,268
70,850
77,034
104,273
43,607
20,168
18,586
Scenic
and
sightseeing
transportation
487
23,414
4,896
1,620
3,198
4,921
3,991
3,604
2,520
1,480
0
Transportation
support
activities
488
484,611
30,040
42,576
55,793
85,104
66,420
79,828
51,314
28,869
44,667
Couriers
and
messengers
492
577,575
10,326
11,717
20,459
47,530
49,511
88,135
40,500
15,300
110,700
Warehousing
and
storage
493
145,266
6,063
8,256
14,202
32,408
31,133
31,929
14,734
2,220
0
Publishing
industries
511
1,100,931
25,098
35,624
61,192
126,164
127,460
194,094
156,585
143,047
231,667
Motion
picture
and
sound
recording
industries
512
297,143
18,424
18,786
33,172
70,389
54,633
47,412
14,842
14,914
24,571
Broadcasting
and
telecommunications
513
1,777,015
46,191
65,752
111,057
216,573
228,707
256,711
239,780
244,611
267,633
Information
and
data
processing
services
514
579,609
19,315
22,640
36,975
69,356
68,046
107,756
85,922
78,147
91,452
Monetary
authorities
­
central
bank
521
23,552
12
26
89
90
628
2,956
3,356
2,920
0
Credit
intermediation
and
related
activities
522
2,917,625
146,571
347,561
440,226
484,740
291,687
326,009
240,878
275,742
364,211
Security,
commodity
contracts
and
like
activity
523
947,060
85,410
65,110
83,464
142,214
111,259
120,455
67,421
67,764
203,963
Insurance
carriers
and
related
activities
524
2,326,133
205,889
162,821
156,249
241,917
208,170
307,758
256,109
272,592
514,628
Funds,
trusts,
and
other
financial
vehicles
(
part)
525
34,030
2,033
2,849
4,300
4,080
4,275
3,525
3,899
5,794
0
Real
estate
531
1,335,298
289,239
220,828
189,150
202,710
139,353
148,818
75,719
52,540
0
Appendix
A­
2
Number
of
Employees
by
Establishment
Employment
Size
Category
(
continued)

Industry
NAICS
Code
Total
Employees
Number
of
Employees
1
to
4
5
to
9
10
to
19
20
to
49
50
to
99
100
to
249
250
to
499
500
to
999
1,000
or
more
March
19,
2004
Page
A­
9
Rental
and
leasing
services
532
625,714
53,931
107,604
160,284
113,759
56,832
54,043
36,155
34,040
29,876
Lessors
of
other
nonfinancial
intangible
asset
533
25,661
2,081
1,770
2,743
4,890
3,452
5,084
4,541
740
0
Professional,
scientific
and
technical
services
541
7,156,579
775,447
723,799
857,281
1,126,526
827,766
1,020,532
647,170
440,038
738,020
Management
of
companies
and
enterprises
551
2,879,223
30,391
47,272
93,225
220,016
266,112
459,747
452,726
479,468
830,266
Administrative
and
support
services
561
8,761,451
306,337
350,168
474,723
859,305
993,789
1,668,079
1,201,600
871,016
2,036,434
Waste
management
and
remediation
services
562
300,536
13,864
20,712
32,625
66,362
57,382
66,242
22,480
8,113
12,756
Educational
services
611
2,612,430
52,192
74,244
130,304
305,091
276,610
324,219
221,509
257,064
971,197
Ambulatory
health
care
services
621
4,736,631
471,165
791,600
811,206
877,574
517,062
544,347
288,347
288,171
204,223
Hospitals
622
5,085,005
554
966
1,648
7,384
43,738
261,720
467,860
857,775
3,443,360
Nursing
and
residential
care
facilities
623
2,671,457
30,022
80,939
153,189
292,973
562,546
1,160,805
285,799
76,314
28,870
Social
assistance
624
2,041,633
98,622
174,476
346,949
553,252
299,657
335,504
143,914
53,847
35,412
Performing
arts,
spectator
sports
and
related
industries
711
361,745
31,634
25,335
38,348
46,545
42,389
74,420
52,742
33,105
27,227
Museums,
historical
sites
and
like
institutions
712
113,545
5,719
6,745
9,756
16,596
16,514
20,475
19,485
7,375
10,880
Amusement,
gambling
and
recreation
industries
713
1,305,072
45,663
67,347
121,300
270,989
243,285
198,840
89,278
71,692
196,678
Accommodation
721
1,752,782
38,141
49,104
158,017
276,306
187,954
303,747
210,086
208,260
18,000
Food
services
and
drinking
places
722
8,219,519
285,988
521,875
1,268,156
3,185,715
1,932,332
790,310
129,544
69,700
0
Repair
and
maintenance
811
1,343,180
277,043
317,418
289,788
243,235
93,707
66,768
26,079
13,884
15,258
Personal
and
laundry
services
812
1,311,522
214,153
269,883
286,907
239,468
117,066
127,642
35,725
16,084
4,594
Religious,
grant
making,
civic,
prof
and
like
organizations
813
2,715,777
332,499
409,995
433,274
586,856
375,812
307,506
127,756
56,945
85,134
March
19,
2004
Page
B­
1
Appendix
B
Computer
Use
By
Employees
SIC
Code
SIC
Category
Number
of
Respondents
Employed
Respondents
Using
a
Computer
at
Work
Estimated
Computer
Use
per
Employee
01
Agricultural
production,
crops
1,066,228
198,191
18.6%

02
Agricultural
production,
livestock
1,002,077
229,868
22.9%

074
Veterinary
services
194,334
145,802
75.0%

078
Landscape
and
horticultural
services
963,202
224,532
23.3%

071,
072,
075,
076
Agricultural
services,
n.
e.
c.
195,574
74,463
38.1%

08
Forestry
84,648
47,395
56.0%

09
Fishing,
hunting,
and
trapping
82,248
26,574
32.3%

10
Metal
mining
26,578
9,525
35.8%

12
Coal
mining
88,972
20,942
23.5%

13
Oil
and
gas
extraction
382,634
209,465
54.7%

14
Nonmetallic
mining
and
quarrying,
except
fuel
76,093
16,987
22.3%

15,
16,
17
Construction
9,937,582
2,542,591
25.6%

201
Meat
products
382,688
66,014
17.3%

202
Dairy
products
128,392
55,046
42.9%

203
Canned,
frozen
and
preserved
fruits
and
vegetables
172,134
51,721
30.0%

204
Grain
mill
products
139,464
80,270
57.6%

205
Bakery
products
176,128
34,327
19.5%

206
Sugar
and
confectionery
products
75,322
42,126
55.9%

208
Beverage
industries
167,310
87,611
52.4%

207,
209
Miscellaneous
food
preparations
and
kindred
products
208,018
69,590
33.5%

21
Tobacco
manufactures
50,697
15,307
30.2%

225
Knitting
mills
65,220
15,827
24.3%

226
Dyeing
and
finishing
textiles,
except
wool
and
knit
goods
41,399
10,183
24.6%

227
Carpets
and
rugs
103,560
30,515
29.5%

221­
224,
228
Yarn,
thread,
and
fabric
mills
258,274
85,200
33.0%

229
Miscellaneous
textile
mill
products
36,511
9,391
25.7%

231­
238
Apparel
and
accessories,
except
knit
399,814
112,164
28.1%

239
Miscellaneous
fabricated
textile
products
133,403
38,346
28.7%

261­
263
Pulp,
paper,
and
paperboard
mills
192,720
102,844
53.4%

267
Miscellaneous
paper
and
pulp
products
150,882
80,261
53.2%

265
Paperboard
containers
and
boxes
156,113
62,099
39.8%

271
Newspaper
publishing
and
printing
444,789
237,545
53.4%

272­
279
Printing,
publishing,
and
allied
industries,
except
newspapers
1,291,122
851,863
66.0%

282
Plastics,
synthetics,
and
resins
128,947
61,203
47.5%

283
Drugs
412,646
361,301
87.6%

284
Soaps
and
cosmetics
171,455
88,418
51.6%

285
Paints,
varnishes,
and
rel.
products
49,289
33,195
67.3%
Appendix
B
Computer
Use
by
Employees
(
continued)

SIC
Code
SIC
Category
Number
of
Respondents
Employed
Respondents
Using
a
Computer
at
Work
Estimated
Computer
Use
per
Employee
March
19,
2004
Page
B­
2
287
Agricultural
chemicals
41,867
32,517
77.7%

281,
286,
289
Industrial
and
miscellaneous
chemicals
434,566
313,072
72.0%

291
Petroleum
refining
114,922
97,121
84.5%

295,
299
Miscellaneous
petroleum
and
coal
products
18,842
15,956
84.7%

301
Tires
and
inner
tubes
110,228
43,374
39.3%

302­
306
Other
rubber
products,
and
plastics
footwear
and
belting
111,819
56,779
50.8%

308
Miscellaneous
plastics
products
507,087
247,382
48.8%

311
Leather
tanning
and
finishing
15,701
1,863
11.9%

313,
314
Footwear,
except
rubber
and
plastic
38,017
21,945
57.7%

315­
317,
319
Leather
products,
except
footwear
44,246
28,081
63.5%

241
Logging
80,838
7,709
9.5%

242,
243
Sawmills,
planing
mills,
and
millwork
395,892
120,107
30.3%

245
Wood
buildings
and
mobile
homes
79,504
16,496
20.7%

244,
249
Miscellaneous
wood
products
173,838
48,310
27.8%

25
Furniture
and
fixtures
678,233
227,807
33.6%

321­
323
Glass
and
glass
products
134,337
57,526
42.8%

324,
327
Cement,
concrete,
gypsum,
and
plaster
products
194,337
67,623
34.8%

325
Structural
clay
products
29,401
6,632
22.6%

326
Pottery
and
related
products
30,523
13,709
44.9%

328,
329
Miscellaneous
nonmetallic
mineral
and
stone
products
102,090
48,913
47.9%

331
Blast
furnaces,
steelworks,
rolling
and
finishing
mills
325,891
142,186
43.6%

332
Iron
and
steel
foundries
72,693
29,182
40.1%

3334,
part
334,
3353­
3355,
3363,
3365
Primary
aluminum
industries
107,100
56,086
52.4%

3331,
3339,
part
334,
3351,
3356,
3357,
3364,
3366,
3369,
339
Other
primary
metal
industries
204,305
111,817
54.7%

342
Cutlery,
handtools,
and
general
hardware
129,857
73,242
56.4%

344
Fabricated
structural
metal
products
580,540
243,614
42.0%

345
Screw
machine
products
50,103
18,201
36.3%

346
Metal
forgings
and
stampings
101,349
49,079
48.4%

348
Ordnance
45,455
31,648
69.6%

341,
343,
347,
349
Misc
fabricated
metal
products
332,803
164,645
49.5%

351
Engines
and
turbines
59,827
36,215
60.5%

352
Farm
machinery
and
equipment
101,336
58,805
58.0%

353
Construction
and
material
handling
machines
152,804
85,441
55.9%

354
Metalworking
machinery
264,137
116,119
44.0%
Appendix
B
Computer
Use
by
Employees
(
continued)

SIC
Code
SIC
Category
Number
of
Respondents
Employed
Respondents
Using
a
Computer
at
Work
Estimated
Computer
Use
per
Employee
March
19,
2004
Page
B­
3
3578,
3579
Office
and
accounting
machines
25,005
16,292
65.2%

3571­
3577
Computers
and
rel.
equipment
493,301
412,267
83.6%

355,
356,
358,
359
Machinery,
except
electrical,
n.
e.
c.
1,022,410
514,760
50.3%

363
Household
appliances
128,442
48,197
37.5%

365,
366
Radio,
TV,
and
communication
equipment
345,377
276,495
80.1%

361,
362,
364,
367,
369
Electrical
machinery,
equipment,
and
supplies,
n.
e.
c.
1,115,370
660,020
59.2%

371
Motor
vehicles
and
motor
vehicle
equipment
1,281,117
545,402
42.6%

372
Aircraft
and
parts
389,929
258,454
66.3%

373
Ship
and
boat
building
and
repairing
187,598
59,012
31.5%

374
Railroad
locomotives
and
equipment
16,189
4,412
27.3%

376
Guided
missiles,
space
vehicles,
and
parts
248,473
208,568
83.9%

375,
379
Cycles
and
miscellaneous
transportation
equipment
87,435
48,458
55.4%

381,
382
except
3827
Scientific
and
controlling
instruments
213,280
171,724
80.5%

3827,
384,
385
Medical,
dental,
and
optical
instruments
and
supplies
420,590
283,944
67.5%

386
Photographic
equipment
and
supplies
83,274
68,592
82.4%

387
Watches,
clocks,
and
clockwork
operated
devices
7,076
2,526
35.7%

394
Toys,
amusement,
and
sporting
goods
118,422
59,680
50.4%

39
except
394
Miscellaneous
manufacturing
industries
446,280
220,781
49.5%

40
Railroads
275,000
139,479
50.7%

41,
except
412
Bus
service
and
urban
transit
662,013
179,609
27.1%

412
Taxicab
service
130,412
31,432
24.1%

421,
423
Trucking
service
2,565,072
848,235
33.1%

422
Warehousing
and
storage
199,241
97,531
49.0%

43
U.
S.
Postal
Service
941,134
303,259
32.2%

44
Water
transportation
221,104
92,861
42.0%

45
Air
transportation
861,943
530,130
61.5%

46
Pipe
lines,
except
natural
gas
9,420
5,598
59.4%

47
Services
incidental
to
transportation
441,258
326,261
73.9%

483,
484
Radio
and
television
broadcasting
and
cable
438,429
335,223
76.5%

481
Telephone
communications
1,622,836
1,335,964
82.3%

482,
489
Telegraph
and
miscellaneous
communications
services
20,288
20,288
100.0%

491
Electric
light
and
power
590,252
398,196
67.5%

492,
496
Gas
and
steam
supply
systems
95,515
59,032
61.8%

493
Electric
and
gas,
and
other
combinations
142,107
82,964
58.4%

494,
497
Water
supply
and
irrigation
244,765
142,147
58.1%

495
Sanitary
services
297,928
143,024
48.0%

501
Motor
vehicles
and
equipment
286,822
166,037
57.9%
Appendix
B
Computer
Use
by
Employees
(
continued)

SIC
Code
SIC
Category
Number
of
Respondents
Employed
Respondents
Using
a
Computer
at
Work
Estimated
Computer
Use
per
Employee
March
19,
2004
Page
B­
4
502
Furniture
and
home
furnishings
80,193
50,624
63.1%

503
Lumber
and
construction
materials
176,329
81,945
46.5%

504
Professional
and
commercial
equipment
and
supplies
416,020
320,252
77.0%

505
Metals
and
minerals,
except
petroleum
76,020
43,175
56.8%

506
Electrical
goods
308,293
205,028
66.5%

507
Hardware,
plumbing
and
heating
supplies
308,113
206,666
67.1%

508
Machinery,
equipment,
and
supplies
548,883
386,784
70.5%

5093
Scrap
and
waste
materials
148,741
50,887
34.2%

509
except
5093
Miscellaneous
wholesale,
durable
goods
145,712
87,244
59.9%

511
Paper
and
paper
products
138,599
90,189
65.1%

512,
516
Drugs,
chemicals
and
allied
products
269,886
194,519
72.1%

513
Apparel,
fabrics,
and
notions
110,251
60,728
55.1%

514
Groceries
and
related
products
941,119
386,118
41.0%

515
Farm­
product
raw
materials
81,297
47,214
58.1%

517
Petroleum
products
99,128
58,821
59.3%

518
Alcoholic
beverages
186,398
72,463
38.9%

5191
Farm
supplies
125,573
58,056
46.2%

5192­
5199
Misc
wholesale,
nondurable
goods
393,529
266,201
67.6%

521,
523
Lumber
and
building
material
retailing
722,104
381,859
52.9%

525
Hardware
stores
238,814
123,571
51.7%

526
Stores,
Retail
nurseries
and
garden
131,818
56,012
42.5%

527
Mobile
home
dealers
41,006
13,351
32.6%

531
Department
stores
2,182,717
871,984
39.9%

533
Variety
stores
169,372
51,155
30.2%

539
Stores,
misc
general
merchandise
238,209
103,403
43.4%

541
Grocery
stores
3,010,091
856,978
28.5%

545
Stores,
dairy
products
21,988
0
0.0%

546
Retail
bakeries
234,841
39,597
16.9%

542,
543,
544,
549
Food
stores,
n.
e.
c.
244,277
81,076
33.2%

551,
552
Motor
vehicle
dealers
1,258,728
710,272
56.4%

553
Stores,
Auto
and
home
supply
523,267
244,012
46.6%

554
Gasoline
service
stations
354,671
142,401
40.2%

555,
556,
557,
559
Miscellaneous
vehicle
dealers
115,198
65,688
57.0%

56,
except
566
Stores,
apparel
and
accessory,
except
shoe
736,236
280,490
38.1%

566
Shoe
stores
146,327
65,531
44.8%

571
Stores,
furniture
and
home
furnishings
626,998
306,490
48.9%

572
Stores,
household
appliance
91,138
28,752
31.5%

5731,
5734
Stores,
radio,
TV,
and
computer
631,512
474,455
75.1%
Appendix
B
Computer
Use
by
Employees
(
continued)

SIC
Code
SIC
Category
Number
of
Respondents
Employed
Respondents
Using
a
Computer
at
Work
Estimated
Computer
Use
per
Employee
March
19,
2004
Page
B­
5
5735,
5736
Music
stores
141,342
87,164
61.7%

58
Eating
and
drinking
places
7,163,241
1,692,492
23.6%

591
Drug
stores
703,823
466,353
66.3%

592
Liquor
stores
156,637
50,001
31.9%

5941,
5945,
5946
Stores,
sporting
goods,
bicycles,
and
hobby
478,305
275,599
57.6%

5942,
5943
Stores,
Book
and
stationery
306,983
184,808
60.2%

5944
Jewelry
stores
188,600
98,642
52.3%

5947
Gift,
novelty,
and
souvenir
shops
193,571
95,205
49.2%

5949
Sewing,
needlework
and
piece
goods
stores
54,182
15,820
29.2%

5961
Catalog
and
mail
order
houses
176,541
135,703
76.9%

5962
Vending
machine
operators
76,572
14,533
19.0%

5963
Direct
selling
establishments
307,394
150,271
48.9%

598
Fuel
dealers
158,442
86,752
54.8%

5992
Retail
florists
165,487
56,147
33.9%

593,
5948,
5993­
5995,
5999
Stores,
Miscellaneous
retail
1,002,604
506,483
50.5%

60
except
603
and
606
Banking
1,926,499
1,623,336
84.3%

603,
606
Savings
institutions,
including
credit
unions
247,366
224,640
90.8%

61
Credit
agencies,
n.
e.
c.
791,561
680,038
85.9%

62,
67
Security,
commodity
brokerage,
and
investment
companies
963,874
879,108
91.2%

63,
64
Insurance
2,398,268
2,079,439
86.7%

65
Real
estate,
including
real
estate­
insurance
offices
2,329,504
1,516,875
65.1%

731
Advertising
301,174
266,098
88.4%

734
Services
to
dwellings
and
other
buildings
1,078,920
220,731
20.5%

736
Personnel
supply
services
1,026,400
573,473
55.9%

737
Computer
and
data
processing
services
2,315,315
2,094,763
90.5%

7381,
7382
Detective
and
protective
services
682,357
316,314
46.4%

732,
733,
735,
7383­
7389
Business
services,
n.
e.
c.
2,315,104
1,587,809
68.6%

751
Automotive
rental
and
leasing,
w/
out
drivers
159,834
107,269
67.1%

752,
7542
Automotive
parking
and
carwashes
206,769
37,536
18.2%

753,
7549
Automotive
repair
and
rel.
services
1,155,258
454,354
39.3%

762,
7694
Electrical
repair
shops
106,690
51,355
48.1%

763,
764,
7692,
7699
Misc
repair
services
618,165
195,784
31.7%

88
Private
Households
805,087
76,051
9.4%

701
Hotels
and
motels
1,451,312
599,840
41.3%

702,
703,
704
Lodging
places,
except
hotels
and
motels
115,668
50,757
43.9%
Appendix
B
Computer
Use
by
Employees
(
continued)

SIC
Code
SIC
Category
Number
of
Respondents
Employed
Respondents
Using
a
Computer
at
Work
Estimated
Computer
Use
per
Employee
March
19,
2004
Page
B­
6
721
except
part
7219
Laundry,
cleaning,
and
garment
services
482,166
115,759
24.0%

723
Beauty
shops
917,938
195,291
21.3%

724
Barber
shops
91,566
13,028
14.2%

726
Funeral
service
and
crematories
120,657
76,186
63.1%

725
Shoe
repair
shops
7,791
2,425
31.1%

7219
Dressmaking
shops
43,844
19,731
45.0%

722,
729
Misc
personal
services
439,120
240,328
54.7%

781­
783,
792
Theaters
and
motion
pictures
701,103
458,769
65.4%

784
Video
tape
rental
88,162
64,282
72.9%

793
Bowling
centers
35,015
7,952
22.7%

791,
794,
799
Miscellaneous
entertainment
and
recreation
services
1,856,946
715,213
38.5%

801,
803
Physicians
offices
and
clinics
1,707,623
1,238,021
72.5%

802
Dentists
offices
and
clinics
726,852
437,738
60.2%

8041
Chiropractors
offices
and
clinics
105,753
81,395
77.0%

8042
Optometrists
offices
and
clinics
66,811
38,002
56.9%

8043,
8049
Health
practitioners
offices
and
clinics,
n.
e.
c.
155,559
103,772
66.7%

806
Hospitals
5,140,181
3,707,851
72.1%

805
Nursing
and
personal
care
facilities
1,739,795
480,917
27.6%

807,
808,
809
Health
services,
n.
e.
c.
2,240,538
1,312,150
58.6%

81
Legal
services
1,466,437
1,291,702
88.1%

821
Elementary
and
secondary
schools
7,854,025
5,220,634
66.5%

822
Colleges
and
universities
3,057,299
2,418,162
79.1%

824
Vocational
schools
58,155
47,170
81.1%

823
Libraries
175,256
147,021
83.9%

829
Educational
services,
n.
e.
c.
318,989
194,273
60.9%

833
Job
training
and
vocational
rehabilitation
services
293,797
87,638
29.8%

part
835
Child
day
care
services
1,143,613
367,184
32.1%

part
835
Family
child
care
homes
428,458
96,365
22.5%

836
Residential
care
facilities,
w/
out
nursing
584,787
251,010
42.9%

832,
839
Social
services,
n.
e.
c.
1,127,347
790,297
70.1%

84
Museums,
art
galleries,
and
zoos
137,208
100,240
73.1%

863
Labor
unions
51,610
30,476
59.1%

866
Religious
organizations
968,410
634,526
65.5%

861,
862,
864,
865,
869
Membership
organizations,
n.
e.
c.
323,880
233,891
72.2%

871
Engineering,
architectural,
and
surveying
services
935,392
775,907
82.9%

872
Accounting,
auditing,
and
bookkeeping
services
711,791
653,517
91.8%

873
Research,
development,
and
testing
services
702,147
580,426
82.7%

874
Management
and
public
relations
services
1,082,597
897,468
82.9%
Appendix
B
Computer
Use
by
Employees
(
continued)

SIC
Code
SIC
Category
Number
of
Respondents
Employed
Respondents
Using
a
Computer
at
Work
Estimated
Computer
Use
per
Employee
March
19,
2004
Page
B­
7
899
Miscellaneous
professional
and
rel.
services
283,339
203,620
71.9%
March
19,
2004
Page
C­
1
Appendix
C
Crosswalk
of
SIC
and
NAICS
Codes
SIC
Corresponding
NAICS
Codes
01
111
02
112
074
541
078
541,
561
071­
072,
075,
076
115,
311,
812
08
111,
113,
115
09
111­
112,
114
10
212­
213
12
212­
213
13
211,
213
14
212­
213
15­
17
233­
235
201
311
202
311
203
311
204
311
205
311
206
311
208
311­
312
207,
209
111,
311­
312
21
312
225
313,
315
226
313
227
314
221­
224,
228
313
229
313­
314
231­
238
315
239
313­
315,
336,
339
261­
263
322
267
322,
326
265
322
271
511
272­
279
323,
511­
512
282
325
283
325
284
325
285
325
287
325
281,
286,
289
211,
311,
325,
331
291
324
Appendix
C
Crosswalk
of
SIC
and
NAICS
Codes
(
continued)

SIC
Corresponding
NAICS
Codes
March
19,
2004
Page
C­
2
295,
299
324
301
326
302­
306
316,
326,
339
308
325­
326,
337
311
316
313­
314
316,
321
315­
317,
319
315­
316
241
113
242,
243
321
245
321
244,
249
321,
333
25
336­
337,
339
321­
323
327
324,
327
327
325
327
326
327
328­
329
327,
212
331
331
332
331
3334,
part
334,
3353­
3355,
3363,
3365
331
3331,
3339,
part
334,
3351,
3356,
3357,
3364,
3366,
3369,
339
331
342
332
344
332
345
332
346
332
348
332
341,
343,
347,
349
332,
337,
339
351
333
352
332­
333
353
332­
333
354
331,
333,
335
3578­
3579
333­
334,
339
3571­
3577
334
355­
356,
358­
359
334
363
333,
335
365­
366
334,
512
361,
362,
364,
367,
369
332,
334­
336
371
336
Appendix
C
Crosswalk
of
SIC
and
NAICS
Codes
(
continued)

SIC
Corresponding
NAICS
Codes
March
19,
2004
Page
C­
3
372
332,
336
373
336,
488,
811
374
333,
336
376
336,
541
375,
379
336
381,
382
except
3827
334
3827,
384,
385
322,
333­
334,
339
386
325,
333
387
334
394
336,
339
39
except
394
325,
488
41,
except
412
485,
487
412
485
421,
423
484,
488,
492
422
493,
531
43
491
44
483,
487­
488,
532
45
481,
488,
492,
561,
621
47
488,
532,
561,
722
483­
484
513
481
513
482,
489
513
491
221
492,
496
221
493
221
494,
497
321
495
221,
488,
562
501
421,
441
502
421,
442
503
421,
444
504
421,
443,
446,
453
505
421
506
421,
444
507
421,
444
508
421,
444,
446
5093
421
509
except
5093
421
511
422
512,
516
422
Appendix
C
Crosswalk
of
SIC
and
NAICS
Codes
(
continued)

SIC
Corresponding
NAICS
Codes
March
19,
2004
Page
C­
4
513
313,
422
514
312,
422
515
422
517
422,
454
518
422
5191
444
5192­
5199
422,
444,
541
521,
523
444
525
444
526
444
527
453
531
452
533
452
539
452
541
445,
447
545
445
546
311,
445,
722
542,
543,
544,
549
311,
445­
446
551,
552
441
553
441,
452
554
447
555,
556,
557,
559
441
56,
except
566
315,
448
566
448
571
337,
442,
451
572
443
5731,
5734
441,
443
5735,
5736
451
58
722
591
446
592
445
5941,
5945,
5946
443,
451
5942,
5943
451,
453
5944
448
5947
453
5949
451
5961
454
5962
454
5963
454,
722
Appendix
C
Crosswalk
of
SIC
and
NAICS
Codes
(
continued)

SIC
Corresponding
NAICS
Codes
March
19,
2004
Page
C­
5
598
454
5992
453
593,
5948,
5993­
5995,
5999
339,
446,
448,
451,
453,
522
60
except
603
and
606
521­
522
603,
606
522
61
522­
523
62,
67
523,
525,
533,
551,
813
63­
64
523­
525
65
233,
531,
711,
812
731
541
734
561
736
541,
561
737
334,
443,
511,
514,
532,
541,
811
7381,
7382
561
732,
733,
735,
7383­
7389
234,
313­
314,
323,
325,
421,
491,
511­
512,
514,
522,
532,
541,
561­
562,
711,
812
751
532
752,
7542
811,
812
753,
7549
326,
488,
811
762,
7694
335,
443,
811
763­
764,
7692,
7699
115,
235,
442,
451,
488,
561­
562,
711,
811
88
81
701
721
702­
704
721
721
except
part
7219
561,
812
723
611,
812
724
611,
812
726
812
725
811­
812
7219
811­
812
722,
729
512,
532
781­
783,
792
334,
421,
512,
514,
532,
541,
561,
711
784
532
793
713
791,
794,
799
487,
532,
561,
611,
711,
712­
713
801,
803
621
802
621
8041
621
8042
621
Appendix
C
Crosswalk
of
SIC
and
NAICS
Codes
(
continued)

SIC
Corresponding
NAICS
Codes
March
19,
2004
Page
C­
6
8043,
8049
621
806
622
805
623
807­
809
339,
621,
541
81
541
821
611
822
611
824
611
823
514
829
611
833
624
part
835
624
836
623
832,
839
624,
813,
922
84
712
863
813
866
813
861­
862,
864­
865,
869
561,
813,
912
871
541
872
541
873
541
874
233­
234,
541,
561,
611
899
512,
541,
711
96
488,
926­
927
97
928
1
Derived
from
Data
provided
by
the
United
States
Bureau
of
the
Census.

March
19,
2004
Page
D­
1
Appendix
D
Computer
Use
Percentages
by
NAICS
Code1
Industry
NAICS
Code
Percentage
of
Employees
Using
Computers
Forestry
and
Logging
113
32.8%

Fishing,
hunting,
and
trapping
114
32.3%

Agriculture
and
forestry
support
activities
115
40.0%

Oil
and
gas
extraction
211
63.4%

Mining
(
except
oil
and
gas)
212
32.4%

Mining
support
activities
213
34.1%

Utilities
221
58.9%

Building,
developing
and
general
contracting
233
57.9%

Heavy
construction
234
59.0%

Special
trade
contractors
235
28.6%

Food
manufacturing
311
38.7%

Beverage
and
tobacco
product
manufacturing
312
39.3%

Textile
mills
313
35.6%

Textile
product
mills
314
38.1%

Apparel
manufacturing
315
31.6%

Leather
and
allied
product
manufacturing
316
46.0%

Wood
product
manufacturing
321
38.9%

Paper
manufacturing
322
53.4%

Printing
and
related
support
activities
323
67.3%

Petroleum
and
coal
products
manufacturing
324
84.6%

Chemical
manufacturing
325
65.3%

Plastics
and
rubber
products
manufacturing
326
46.3%

Nonmetallic
mineral
product
manufacturing
327
38.6%

Primary
metal
manufacturing
331
51.1%

Fabricated
metal
product
manufacturing
332
54.2%

Machinery
manufacturing
333
52.6%

Computer
and
electronic
product
manufacturing
334
67.8%

Electrical
equipment,
appliance,
and
component
manufacturing
335
47.2%

Transportation
equipment
manufacturing
336
47.9%

Furniture
and
related
product
manufacturing
337
45.2%

Miscellaneous
manufacturing
339
50.5%

Wholesale
trade,
durable
goods
421
61.1%

Wholesale
trade,
nondurable
goods
422
57.1%

Motor
vehicle
and
parts
dealers
441
58.6%
Appendix
D
Computer
Use
Percentages
by
NAICS
Code
(
continued)

Industry
NAICS
Code
Percentage
of
Employees
Using
Computers
March
19,
2004
Page
D­
2
Furniture
and
home
furnishing
stores
442
47.9%

Electronics
and
appliance
stores
443
63.3%

Building
material
and
garden
equipment
and
support
dealers
444
56.8%

Food
and
beverage
stores
445
22.1%

Health
and
personal
care
stores
446
59.5%

Gasoline
stations
447
34.3%

Clothing
and
clothing
accessories
stores
448
46.4%

Sporting
goods,
hobby,
book,
and
music
stores
451
48.5%

General
merchandise
stores
452
40.0%

Miscellaneous
store
retailers
453
50.6%

Nonstore
retailers
454
51.8%

Air
transportation
481
61.5%

Water
transportation
483
42.0%

Truck
transportation
484
33.1%

Transit
and
ground
passenger
transportation
485
25.6%

Scenic
and
sightseeing
transportation
487
35.9%

Transportation
support
activities
488
49.4%

Couriers
and
messengers
492
47.3%

Warehousing
and
storage
493
49.0%

Publishing
industries
511
69.6%

Motion
picture
and
sound
recording
industries
512
67.8%

Broadcasting
and
telecommunications
513
86.3%

Information
and
data
processing
services
514
75.4%

Monetary
authorities
­
central
bank
521
84.3%

Credit
intermediation
and
related
activities
522
76.0%

Security,
commodity
contracts
and
like
activity
523
87.9%

Insurance
carriers
and
related
activities
524
86.7%

Funds,
trusts,
and
other
financial
vehicles
(
part)
525
89.0%

Real
estate
531
57.0%

Rental
and
leasing
services
532
63.7%

Lessors
of
other
nonfinancial
intangible
asset
533
91.2%

Professional,
scientific
and
technical
services
541
73.3%

Management
of
companies
and
enterprises
551
91.2%

Administrative
and
support
services
561
53.5%

Waste
management
and
remediation
services
562
49.4%
Appendix
D
Computer
Use
Percentages
by
NAICS
Code
(
continued)

Industry
NAICS
Code
Percentage
of
Employees
Using
Computers
March
19,
2004
Page
D­
3
Educational
services
611
53.7%

Ambulatory
health
care
services
621
64.8%

Hospitals
622
72.1%

Nursing
and
residential
care
facilities
623
35.3%

Social
assistance
624
41.0%

Performing
arts,
spectator
sports
and
related
industries
711
58.5%

Museums,
historical
sites
and
like
institutions
712
55.8%

Amusement,
gambling
and
recreation
industries
713
30.6%

Accommodation
721
42.6%

Food
services
and
drinking
places
722
40.8%

Repair
and
maintenance
811
41.9%

Personal
and
laundry
services
812
41.6%

Religious,
grant
making,
civic,
prof
and
like
organizations
813
71.6%
March
19,
2004
Page
E­
1
Appendix
E
Disposal
Cost
Source
Details
Disposal
Option
Source
Source
Cost
per
Ton
Year
of
cost
estimate
Cost
(
Price
Paid)
per
Ton
(
2001$)

Collectors
1
$
240
1998
2
$
400
2001
3
$
0
2001
4
$
383
1997
Average
$
250
1998
$
271
Export
4
$
100
1999
$
107
Reuse
None
$
0
2001
$
0
Treatment
and
Subtitle
C
or
D
Landfill
Disposal
Whole
CRTs
5
$
1,196
1998
6
$
1,300
2001
7
$
1,500
2001
Value
used
in
analysis
$
1,500
2001
$
1,500
Crushed
CRTs
7
$
160
2001
8
$
100
2000
9
$
125
2000
Value
used
in
analysis
$
160
2001
$
160
Subtitle
D
Landfill
Disposal
8
$
40
2000
$
41
Reclaimer
4
$
667
1997
8
$
200
2000
8
$
420
2000
10
$
200
2003
10
$
350
2003
11
$
140
1998
12
$
200
1997
Appendix
E
Disposal
Cost
Source
Details
(
continued)

Disposal
Option
Source
Source
Cost
per
Ton
Year
of
cost
estimate
Cost
(
Price
Paid)
per
Ton
(
2001$)

March
19,
2004
Page
E­
2
12
$
500
1997
13
$
200
1997
13
$
300
1997
14
$
200
1998
Whole
CRTs
­
Average
$
284
2000
$
295
Whole
bare
CRTs
­
Average
$
200
2000
$
207
Crushed
CRTs
­
Average
$
140
1998
$
152
Glass
Processor
Broken
CRTs
with
no
metal
15,16
$
0
2001
$
0
Broken
CRTs
with
metal
$
100
2001
$
100
Whole
bare
CRTs
$
192
2001
$
192
Broken
mixed
color
and
monochrome
CRTs
$
325
2001
$
325
Whole
CRTs
$
333
2001
$
333
CRT
Glass
Manufacturer
15
($
175)
2001
($
175)
Appendix
E
Disposal
Cost
Source
Details
(
continued)

March
19,
2004
Page
E­
3
Source
Number
Source
Title
1
DMC
Recycling
Inc,
1998.

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

3
WasteNot
Recycling,
2001.

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

5
Personal
communications
with
Chem
Waste
Management,
1998.

6
Personal
communications
with
Clean
Harbors
of
Braintree,
2001.

7
Personal
communications
with
Envirosafe
Services
of
Ohio,
2001.

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

9
ETC's
landfill
cost
survey,
2000.

10
Personal
communications
with
Noranda,
1998
and
2003.

11
Personal
communications
with
Doe
Run,
1998.

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

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

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

15
Personal
communications
with
Greg
Voorhees
of
Envirocycle,
2001.

16
Price
list
from
Envirocycle,
2001.
March
19,
2004
Page
F­
1
Appendix
F
Flow
of
CRTs
Under
Subtitle
C
(
Number)

Total
Number
of
CRTs
Number
following
each
path
To
Collector
To
Reuse
To
MSW
(
Subtitle
D)
To
HW
(
Subtitle
C)
To
Reclaime
r
To
Glass
Processo
r
To
Exporter
To
CRT
Manufacturer
Baseline
Original
Users
SQGs
CRT
only
2,480,660
1,885,302
49,613
­
49,613
372,099
124,033
SQGs
all
HW
114,915
86,186
­
­
28,729
­
­

LQGs
CRT
only
583,540
443,490
11,671
­
11,671
87,531
29,177
LQGs
all
HW
33,182
24,887
­
­
8,296
­
­

Collectors
SQGs
203,322
40,664
­
4,066
46,764
50,831
60,997
LQGs
2,236,543
447,309
­
223,654
223,654
670,963
670,963
Glass
Processor
Funnel
299,612
5,992
293,620
Panel
575,391
11,508
563,883
All
CRTs
2,439,865
549,257
­
326,029
747,548
875,003
731,959
857,503
Final
Rule
Original
Users
SQGs
CRT
only
49,668
­
­
­
49,668
­
­

SQGs
all
HW
2,295
­
­
­
2,295
­
­

LQGs
CRT
only
11,991
­
­
­
11,991
­
­

LQGs
all
HW
679
­
­
­
679
­
­

Former
SQG
­
CRT
2,430,992
1,896,174
48,620
­
­
364,649
121,550
Former
SQG
­
HW
112,620
87,844
2,252
­
­
16,893
5,631
Former
LQG
­
CRT
571,549
445,809
11,431
­
­
85,732
28,577
Former
LQG
­
HW
32,503
25,352
650
­
­
4,875
1,625
Appendix
F
Flow
of
CRTs
Under
Subtitle
C
(
Number)

(
continued)

Total
Number
of
CRTs
Number
following
each
path
To
Collector
To
Reuse
To
MSW
(
Subtitle
D)
To
HW
(
Subtitle
C)
To
Reclaime
r
To
Glass
Processo
r
To
Exporter
To
CRT
Manufacturer
March
19,
2004
Page
F­
2
Collectors
SQGs
4,092
­
­
4,092
­
­
­

LQGs
45,012
­
­
45,012
­
­
­

Former
SQG
200,506
40,101
­
­
50,127
50,127
60,152
Former
LQG
2,205,569
441,114
­
­
374,947
992,506
397,002
Glass
Processor
Funnel
410,900
8,218
402,682
Panel
789,115
15,782
773,333
All
CRTs
2,455,179
544,168
­
113,736
921,223
1,200,016
457,154
1,176,015
Bolded
entries
include
the
weight
of
the
CRT
glass
only.
Non­
bolded
entries
include
the
weight
of
the
entire
monitor.
March
19,
2004
Page
F­
3
Appendix
F
Flow
of
CRTs
Under
Subtitle
C
(
Tons)

Total
Number
of
CRTs
Number
following
each
path
To
Collector
To
Reuse
To
MSW
(
Subtitle
D)
To
HW
(
Subtitle
C)
To
Reclaimer
To
Glass
Processor
To
Exporter
To
CRT
Manufacturer
Baseline
Original
Users
SQGs
CRT
only
50,357
38,272
1,007
­
1,007
7,554
2,518
SQGs
all
HW
2,333
1,750
­
­
583
­
­

LQGs
CRT
only
11,846
9,003
237
­
237
1,777
592
LQGs
all
HW
674
505
­
­
168
­
­

Collectors
SQGs
4,127
825
­
50
570
619
1,238
LQGs
45,402
9,080
­
2,724
2,724
8,172
13,621
Glass
Processor
Funnel
3,649
73
3,576
Panel
7,008
140
6,868
All
CRTs
49,529
11,150
­
4,769
12,837
10,658
14,859
10,444
Final
Rule
Original
Users
SQGs
CRT
only
1,008
­
­
­
1,008
­
­

SQGs
all
HW
47
­
­
­
47
­
­

LQGs
CRT
only
243
­
­
­
243
­
­

LQGs
all
HW
14
­
­
­
14
­
­

Former
SQG
­
CRT
49,349
38,492
987
­
­
7,402
2,467
Former
SQG
­
HW
2,286
1,783
46
­
­
343
114
Former
LQG
­
CRT
11,602
9,050
232
­
­
1,740
580
Former
LQG
­
HW
660
515
13
­
­
99
33
Collectors
Appendix
F
Flow
of
CRTs
Under
Subtitle
C
(
Tons)

(
continued)

Total
Number
of
CRTs
Number
following
each
path
To
Collector
To
Reuse
To
MSW
(
Subtitle
D)
To
HW
(
Subtitle
C)
To
Reclaimer
To
Glass
Processor
To
Exporter
To
CRT
Manufacturer
March
19,
2004
Page
F­
4
SQGs
83
­
­
50
­
­
­

LQGs
914
­
­
548
­
­
­

Former
SQG
4,070
814
­
­
611
611
1,221
Former
LQG
44,773
8,955
­
­
4,567
12,089
8,059
Glass
Processor
Funnel
5,005
100
4,905
Panel
9,611
192
9,419
All
CRTs
49,840
11,047
­
1,910
15,054
14,616
9,280
14,324
March
19,
2004
Page
F­
5
Appendix
F
Flow
of
CRTs
Under
Subtitle
D
(
Number)

Total
Number
of
CRTs
Number
following
each
path
To
Collector
To
Reuse
To
MSW
(
Subtitle
D)
To
HW
(
Subtitle
C)
To
Reclaimer
To
Glass
Processor
To
Exporter
To
CRT
Manufacturer
Baseline
Original
Users
SQGs
CRT
only
2,480,660
148,840
49,613
1,984,528
49,613
124,033
124,033
SQGs
all
HW
114,915
11,492
­
91,932
11,492
­
­

LQGs
CRT
only
583,540
35,012
11,671
466,832
11,671
29,177
29,177
LQGs
all
HW
33,182
3,318
­
26,546
3,318
­
­

Collectors
SQGs
16,555
3,311
8,278
­
828
828
3,311
LQGs
182,107
36,421
78,306
3,642
9,105
18,211
36,421
Glass
Processor
Funnel
58,980
1,180
57,800
Panel
113,268
2,265
111,003
All
CRTs
198,662
101,016
2,656,421
79,736
166,588
172,248
39,732
168,803
Final
Rule
Original
Users
SQGs
CRT
only
9,905
­
­
­
9,905
­
­

SQGs
all
HW
459
­
­
­
459
­
­

LQGs
CRT
only
2,665
­
­
­
2,665
­
­

LQGs
all
HW
120
­
­
­
120
­
­

Former
SQG
­
CRT
2,470,755
247,076
49,415
1,853,066
­
172,953
148,245
Former
SQG
­
HW
114,456
11,446
2,289
85,842
­
8,012
6,867
Former
LQG
­
CRT
580,875
58,088
11,618
435,657
­
40,661
34,853
Former
LQG
­
HW
33,062
3,306
661
24,797
­
2,314
1,984
Collectors
Appendix
F
Flow
of
CRTs
Under
Subtitle
D
(
Number)

(
continued)

Total
Number
of
CRTs
Number
following
each
path
To
Collector
To
Reuse
To
MSW
(
Subtitle
D)
To
HW
(
Subtitle
C)
To
Reclaimer
To
Glass
Processor
To
Exporter
To
CRT
Manufacturer
March
19,
2004
Page
F­
6
SQGs
533
107
213
11
69
53
80
LQGs
5,865
1,173
2,346
117
469
880
880
Former
SQG
26,126
5,225
10,451
­
3,919
2,613
3,919
Former
LQG
287,390
57,478
114,956
­
28,739
43,109
43,109
Glass
Processor
Funnel
81,701
1,634
80,067
Panel
156,902
3,138
153,764
All
CRTs
319,915
127,966
2,527,328
13,276
261,909
238,603
47,987
233,831
March
19,
2004
Page
F­
7
Appendix
F
Flow
of
CRTs
Under
Subtitle
D
(
Tons)

Total
Number
of
CRTs
Number
following
each
path
To
Collector
To
Reuse
To
MSW
(
Subtitle
D)
To
HW
(
Subtitle
C)
To
Reclaimer
To
Glass
Processor
To
Exporter
To
CRT
Manufacturer
Baseline
Original
Users
SQGs
CRT
only
50,357
3,021
1,007
40,286
1,007
2,518
2,518
SQGs
all
HW
2,333
233
­
1,866
233
­
­

LQGs
CRT
only
11,846
711
237
9,477
237
592
592
LQGs
all
HW
674
67
­
539
67
­
­

Collectors
SQGs
336
67
168
­
10
10
67
LQGs
3,697
739
1,590
44
111
222
739
Glass
Processor
Funnel
718
14
704
Panel
1,380
28
1,352
All
CRTs
4,033
2,051
53,925
1,589
3,273
2,098
807
2,056
Final
Rule
Original
Users
SQGs
CRT
only
201
­
­
­
201
­
­

SQGs
all
HW
9
­
­
­
9
­
­

LQGs
CRT
only
54
­
­
­
54
­
­

LQGs
all
HW
2
­
­
­
2
­
­

Former
SQG
­
CRT
50,156
5,016
1,003
37,617
­
3,511
3,009
Former
SQG
­
HW
2,323
232
46
1,743
­
163
139
Former
LQG
­
CRT
11,792
1,179
236
8,844
­
825
708
Former
LQG
­
HW
671
67
13
503
­
47
40
Collectors
Appendix
F
Flow
of
CRTs
Under
Subtitle
D
(
Number)

(
continued)

Total
Number
of
CRTs
Number
following
each
path
To
Collector
To
Reuse
To
MSW
(
Subtitle
D)
To
HW
(
Subtitle
C)
To
Reclaimer
To
Glass
Processor
To
Exporter
To
CRT
Manufacturer
March
19,
2004
Page
F­
8
SQGs
11
2
4
­
1
1
2
LQGs
119
24
48
1
6
11
18
Former
SQG
530
106
212
­
48
32
80
Former
LQG
5,834
1,167
2,334
­
350
525
875
Glass
Processor
Funnel
995
20
975
Panel
1,911
38
1,873
All
CRTs
6,494
2,598
51,305
268
5,008
2,906
974
2,848
March
19,
2004
Page
G­
1
Appendix
G
Average
Shipment
Sizes
for
Each
Type
of
Establishment
Distributing
CRTs
to
Each
CRT
Management
Option
To
Collector
To
Reuse
To
MSW
(
Subtitle
D)
To
HW
(
Subtitle
C)
To
Reclaimer
To
Glass
Processor
To
Exporter
To
CRT
Manufacturer
Baseline
­
Subtitle
C
Original
Users
SQGs
CRT
only
1.5
1.5
­
1.5
1.5
1.5
SQGs
all
HW
0.4
­
­
0.4
­
­

LQGs
CRT
only
6.8
6.6
­
6.6
6.8
6.7
LQGs
all
HW
0.2
­
­
0.2
­
­

Collectors
SQGs
20.6
­
12.4
12.9
12.9
20.6
LQGs
18.2
­
11.4
11.4
11.4
18.2
Glass
Processor
Funnel
18.2
22.8
Panel
20.0
23.0
Final
Rule
­
Subtitle
C
Original
Users
SQGs
CRT
only
­
­
­
1.5
­
­

SQGs
all
HW
­
­
­
0.4
­
­

LQGs
CRT
only
­
­
­
6.8
­
­

LQGs
all
HW
­
­
­
0.2
­
­

Former
SQG
­
CRT
only
PA
2.9
2.9
­
­
2.9
2.9
Former
SQG
­
HW
PA
0.8
0.8
­
­
0.8
0.8
Former
LQG
­
CRT
only
PA
13.5
12.9
­
­
13.5
13.5
Former
LQG
­
HW
PA
0.8
0.8
­
­
0.8
0.8
Collectors
Appendix
G
Average
Shipment
Sizes
for
Each
Type
of
Establishment
Distributing
CRTs
to
Each
CRT
Management
Option
(
continued)

To
Collector
To
Reuse
To
MSW
(
Subtitle
D)
To
HW
(
Subtitle
C)
To
Reclaimer
To
Glass
Processor
To
Exporter
To
CRT
Manufacturer
March
19,
2004
Page
G­
2
SQGs
12.5
LQGs
11.0
Former
SQG
20.4
­
­
13.0
13.0
20.7
Former
LQG
18.3
­
­
11.4
11.5
18.3
Glass
Processor
Funnel
20.0
22.7
Panel
21.4
22.9
March
19,
2004
Page
G­
3
Appendix
G
Number
of
Shipments
Each
Year
Under
Subtitle
C
Collectors
Reuse
Subtitle
D
Subtitle
C
Reclaimers
Glass
Processors
Exporters
CRT
Glass
Manufacturers
Totals
Baseline
Original
Users
SQGs
CRT
only
26,268
692
­
692
5,185
1,729
X
X
34,566
SQGs
all
HW
4,131
­
­
1,377
­
­
X
X
5,508
LQGs
CRT
only
1,332
36
­
36
263
88
X
X
1,755
LQGs
all
HW
2,493
­
­
831
­
­
X
X
3,324
Collectors
SQGs
X
40
­
4
44
48
60
X
196
LQGs
X
500
­
240
240
718
750
X
2,448
Glass
Processors
Funnel
X
X
X
X
4
X
X
157
161
Panel
X
X
X
X
7
X
X
299
306
Final
Rule
Original
Users
SQGs
CRT
only
­
­
­
692
­
­
X
X
692
SQGs
all
HW
­
­
­
110
­
­
X
X
110
LQGs
CRT
only
­
­
­
36
­
­
X
X
36
LQGs
all
HW
­
­
­
68
­
­
X
X
68
Former
SQG
­
CRT
only
PA
13,210
339
­
­
2,541
847
X
X
16,937
Former
SQG
­
HW
PA
2,106
54
­
­
405
135
X
X
2,700
Former
LQG
­
CRT
only
PA
670
18
­
­
129
43
X
X
860
Former
LQG
­
HW
PA
635
17
­
­
123
41
X
X
816
Collectors
Appendix
G
Number
of
Shipments
Each
Year
Under
Subtitle
C
(
continued)

March
19,
2004
Page
G­
4
SQGs
X
­
­
4
­
­
­
X
4
LQGs
X
­
­
50
­
­
­
X
50
Former
SQGs
X
40
­
­
47
47
59
X
193
Former
LQGs
X
490
­
­
399
1,055
441
X
2,385
Glass
Processors
Funnel
X
X
X
X
5
X
X
216
221
Panel
X
X
X
X
9
X
X
412
421
March
19,
2004
Page
H­
1
Appendix
H
Average
Annual
Sales
per
Establishment
by
3­
Digit
NAICS
Code
Industry
NAICS
Code
Average
Sales
per
Establishment
Forestry
and
Logging
113
$
168,960
Fishing,
hunting,
and
trapping
114
$
129,331
Agriculture
and
forestry
support
activities
115
$
207,796
Oil
and
gas
extraction
211
$
12,372,169
Mining
(
except
oil
and
gas)
212
$
6,975,044
Mining
support
activities
213
$
2,130,480
Utilities
221
$
26,539,891
Construction
of
Buildings
233
$
1,941,561
Heavy
construction
234
$
3,073,613
Special
trade
contractors
235
$
822,155
Food
manufacturing
311
$
16,083,560
Beverage
and
tobacco
product
manufacturing
312
$
35,589,804
Textile
mills
313
$
12,495,595
Textile
product
mills
314
$
3,934,732
Apparel
manufacturing
315
$
4,009,878
Leather
and
allied
product
manufacturing
316
$
5,828,594
Wood
product
manufacturing
321
$
5,123,862
Paper
manufacturing
322
$
25,548,751
Printing
and
related
support
activities
323
$
2,282,249
Petroleum
and
coal
products
manufacturing
324
$
81,771,350
Chemical
manufacturing
325
$
31,052,871
Plastics
and
rubber
products
manufacturing
326
$
9,499,747
Nonmetallic
mineral
product
manufacturing
327
$
5,310,358
Primary
metal
manufacturing
331
$
33,403,082
Fabricated
metal
product
manufacturing
332
$
3,892,010
Machinery
manufacturing
333
$
8,816,473
Computer
and
electronic
product
manufacturing
334
$
25,090,707
Electrical
equipment,
appliance,
and
component
manufacturing
335
$
16,096,992
Transportation
equipment
manufacturing
336
$
44,066,228
Furniture
and
related
product
manufacturing
337
$
3,080,236
Miscellaneous
manufacturing
339
$
3,201,646
Wholesale
trade,
durable
goods
421
$
7,500,000
Wholesale
trade,
nondurable
goods
422
$
11,570,217
Motor
vehicle
and
parts
dealers
441
$
5,262,595
Furniture
and
home
furnishing
stores
442
$
1,107,622
Appendix
H
Average
Annual
Sales
per
Establishment
by
3­
Digit
NAICS
Code
(
continued)

Industry
NAICS
Code
Average
Sales
per
Establishment
March
19,
2004
Page
H­
2
Electronics
and
appliance
stores
443
$
1,580,738
Building
material
and
garden
equipment
and
support
dealers
444
$
2,443,873
Food
and
Beverage
stores
445
$
2,704,975
Health
and
personal
care
stores
446
$
1,419,091
Gasoline
Stations
447
$
1,561,725
Clothing
and
clothing
accessories
stores
448
$
870,988
Sporting
goods,
hobby,
book,
and
music
stores
451
$
896,773
General
merchandise
stores
452
$
9,135,619
Miscellaneous
store
retailers
453
$
601,589
Nonstore
retailers
454
$
2,767,561
Air
transportation
481
$
5,627,858
Water
transportation
483
$
12,503,471
Truck
transportation
484
$
1,360,579
Transit
and
ground
passenger
transportation
485
$
861,326
Scenic
and
sightseeing
transportation
487
$
814,381
Transportation
support
activities
488
$
1,296,112
Couriers
and
messengers
492
$
3,656,878
Warehousing
and
storage
493
$
1,640,438
Publishing
industries
511
$
5,281,904
Motion
picture
and
sound
recording
industries
512
$
2,518,714
Broadcasting
and
telecommunications
513
$
7,964,942
Information
and
data
processing
services
514
$
2,815,523
Monetary
authorities
­
central
bank
521
$
585,275,214
Credit
intermediation
and
related
activities
522
$
4,846,604
Security,
commodity
contracts
and
like
activity
523
$
5,046,461
Insurance
carriers
and
related
activities
524
$
6,226,293
Funds,
trusts,
and
other
financial
vehicles
(
part)
525
$
11,153,790
Real
estate
531
$
691,518
Rental
and
leasing
services
532
$
1,184,681
Lessors
of
other
nonfinancial
intangible
asset
533
$
5,236,571
Professional,
scientific
and
technical
services
541
$
941,878
Management
of
companies
and
enterprises
551
$
1,954,248
Administrative
and
support
services
561
$
986,793
Waste
management
and
remediation
services
562
$
2,403,813
Appendix
H
Average
Annual
Sales
per
Establishment
by
3­
Digit
NAICS
Code
(
continued)

Industry
NAICS
Code
Average
Sales
per
Establishment
March
19,
2004
Page
H­
3
Educational
services
611
$
442,036
Ambulatory
health
care
services
621
$
704,253
Hospitals
622
$
29,848,609
Nursing
and
residential
care
facilities
623
$
1,700,862
Social
assistance
624
$
222,242
Performing
arts,
spectator
sports
and
related
industries
711
$
1,262,184
Museums,
historical
sites
and
like
institutions
712
$
614,591
Amusement,
gambling
and
recreation
industries
713
$
980,233
Accomodation
721
$
1,692,814
Food
services
and
drinking
places
722
$
517,434
Repair
and
maintenance
811
$
446,578
Personal
and
laundry
services
812
$
312,045
Religious,
grant
making,
civic,
prof
and
like
organizations
813
$
1,041,506
Source:
U.
S.
Bureau
of
the
Census
(
1997).
March
19,
2004
Page
I­
1
Appendix
I
Detailed
Sensitivity
Analysis
Results
on
All
Parameters
Tested
Parameter
Names
Sensitivity
Test
Parameter
Values
Percent
Change
from
Best
Estimate
Savings
Under
Final
Rule
Savings
Under
Final
Rule
Using
the
Sensitivity
Test
Parameter
Values
Percent
increase
(
decrease)
in
amount
saved
Percent
color
monitors
disposed
Best
Estimate
98
%
Low
Range
90
%
­
8
%
$
5,090,000
$
4,616,000
­
9
%
High
Range
100
%
2
%
$
5,090,000
$
5,242,000
3
%
Percent
flat
panel
monitors
disposed
Best
Estimate
5
%
Low
Range
0
%
­
100
%
$
5,090,000
$
5,375,000
6
%
High
Range
10
%
50
%
$
5,090,000
$
4,699,000
­
8
%
Entry/
exit
rate
for
establishments
Best
Estimate
1
%
Low
Range
0.10
%
­
90
%
$
5,090,000
$
5,065,000
­
1
%
High
Range
5
%
400
%
$
5,090,000
$
5,201,000
2
%
Percent
laptops
disposed
Best
Estimate
25
%
Low
Range
15
%
­
40
%
$
5,090,000
$
5,535,000
9
%
High
Range
40
%
60
%
$
5,090,000
$
3,802,000
­
25
%
Percent
funnel
glass
(
vs
panel
glass)
Best
Estimate
34
%
Low
Range
30
%
­
12
%
$
5,090,000
$
5,059,000
­
1
%
High
Range
40
%
18
%
$
5,090,000
$
5,129,000
1
%
Percent
of
Collector
shipments
to
Processors
and
Reclaimers
that
include
broken
CRTs
Best
Estimate
100
%
Low
Range
25
%
­
75
%
$
5,090,000
$
5,615,000
10
%
High
Range
100
%
0
%
$
5,090,000
$
5,090,000
0
%
Percent
of
CRTs
sent
to
SQ
Collectors
Best
Estimate
8
%
Low
Range
2
%
­
75
%
$
5,090,000
$
5,172,000
2
%
High
Range
50
%
525
%
$
5,090,000
$
4,968,000
­
2
%
Percent
of
CRTs
sent
to
former
SQ
Collectors
(
Final
Rule
only)
Best
Estimate
98
%
Appendix
I
Detailed
Sensitivity
Analysis
Results
on
All
Parameters
Tested
(
continued)

Parameter
Names
Sensitivity
Test
Parameter
Values
Percent
Change
from
Best
Estimate
Savings
Under
Final
Rule
Savings
Under
Final
Rule
Using
the
Sensitivity
Test
Parameter
Values
Percent
increase
(
decrease)
in
amount
saved
March
19,
2004
Page
I­
2
Low
Range
50
%
­
49
%
$
5,090,000
$
1,949,000
­
62
%
High
Range
99
%
1
%
$
5,090,000
$
5,149,000
1
%
Percent
of
original
users
sending
to
reuse
Best
Estimate
2
%
Low
Range
0
%
­
100
%
$
5,090,000
$
5,503,000
8
%
High
Range
15
%
650
%
$
5,090,000
$
2,193,000
­
57
%
Percent
of
CRTs
sent
for
export
(
Baseline
only)
Best
Estimate
30
%
Low
Range
10
%
­
67
%
$
5,090,000
$
4,047,000
­
21
%
High
Range
50
%
67
%
$
5,090,000
$
6,132,000
21
%
Percent
of
CRTs
sent
for
export
(
Final
Rule
only)
Best
Estimate
30
%
or
18
%
Low
Range
5
%
­
83
%
or
­
72
%
$
5,090,000
$
5,851,000
15
%

High
Range
30
%
0
%
or
66
%
$
5,090,000
$
4,492,000
­
12
%
Maximum
shipment
weight
(
in
tons)
for
whole
CRTs
Best
Estimate
22
Low
Range
18
­
18
%
$
5,090,000
$
5,086,000
0
%
High
Range
24
9
%
$
5,090,000
$
5,004,000
­
2
%
Maximum
shipment
weight
(
in
tons)
for
crushed
CRTs
Best
Estimate
23
Low
Range
20
­
13
%
$
5,090,000
$
5,207,000
2
%
High
Range
25
9
%
$
5,090,000
$
5,022,000
­
1
%
Shipping
Distances
(
in
miles):
to
Handler
Best
Estimate
20
Low
Range
5
­
75
%
$
5,090,000
$
5,091,000
0
%
High
Range
50
150
%
$
5,090,000
$
5,088,000
0
%
to
Reuse
Appendix
I
Detailed
Sensitivity
Analysis
Results
on
All
Parameters
Tested
(
continued)

Parameter
Names
Sensitivity
Test
Parameter
Values
Percent
Change
from
Best
Estimate
Savings
Under
Final
Rule
Savings
Under
Final
Rule
Using
the
Sensitivity
Test
Parameter
Values
Percent
increase
(
decrease)
in
amount
saved
March
19,
2004
Page
I­
3
Best
Estimate
20
Low
Range
5
­
75
%
$
5,090,000
$
5,089,000
0
%
High
Range
50
150
%
$
5,090,000
$
5,090,000
0
%
to
Subtitle
C
Landfill
Best
Estimate
250
Low
Range
100
­
60
%
$
5,090,000
$
4,988,000
­
2
%
High
Range
500
100
%
$
5,090,000
$
5,260,000
3
%
to
Glass
Processor
Best
Estimate
200
Low
Range
100
­
50
%
$
5,090,000
$
5,013,000
­
2
%
High
Range
400
100
%
$
5,090,000
$
5,244,000
3
%
to
CRT
Glass
Manufacturer
Best
Estimate
100
Low
Range
50
­
50
%
$
5,090,000
$
5,096,000
0
%
High
Range
200
100
%
$
5,090,000
$
5,077,000
0
%
to
Reclaimer
(
from
Generator
or
Collectors)
Best
Estimate
300
Low
Range
100
­
67
%
$
5,090,000
$
4,974,000
­
2
%
High
Range
500
67
%
$
5,090,000
$
5,205,000
2
%
to
Reclaimer
(
from
Glass
Processors)
Best
Estimate
350
Low
Range
200
­
43
%
$
5,090,000
$
5,090,000
0
%
High
Range
500
43
%
$
5,090,000
$
5,090,000
0
%
Costs
for
Disposal
to
Glass
Processor
(
per
ton):
Broken
CRTs,
no
metal
Best
Estimate
$
0
Low
Range
$
0
N/
A
$
5,090,000
$
5,090,000
0
%
High
Range
$
10.00
N/
A
$
5,090,000
$
5,067,000
0
%
Broken
CRTs,
with
metal
Appendix
I
Detailed
Sensitivity
Analysis
Results
on
All
Parameters
Tested
(
continued)

Parameter
Names
Sensitivity
Test
Parameter
Values
Percent
Change
from
Best
Estimate
Savings
Under
Final
Rule
Savings
Under
Final
Rule
Using
the
Sensitivity
Test
Parameter
Values
Percent
increase
(
decrease)
in
amount
saved
March
19,
2004
Page
I­
4
Best
Estimate
$
104.00
Low
Range
$
50.00
­
52
%
$
5,090,000
$
5,117,000
1
%
High
Range
$
150.00
44
%
$
5,090,000
$
5,066,000
­
1
%
Whole
Bare
CRTs
Best
Estimate
$
200.00
Low
Range
$
100.00
­
50
%
$
5,090,000
$
5,117,000
1
%
High
Range
$
300.00
50
%
$
5,090,000
$
5,062,000
­
1
%
Broken
mixed
color/
monochrome
Best
Estimate
$
338.00
Low
Range
$
250.00
­
26
%
$
5,090,000
$
5,134,000
1
%
High
Range
$
400.00
18
%
$
5,090,000
$
5,058,000
­
1
%
Whole
CRTs
with
casing
Best
Estimate
$
347.00
Low
Range
$
200.00
­
42
%
$
5,090,000
$
5,106,000
0
%
High
Range
$
450.00
30
%
$
5,090,000
$
5,078,000
0
%
Exporter,
Disposal
Best
Estimate
$
108.00
Low
Range
$
0
­
100
%
$
5,090,000
$
4,488,000
­
12
%
High
Range
$
200.00
85
%
$
5,090,000
$
5,604,000
10
%
CRT
Glass
Manufacturer,
Disposal
Best
Estimate
$
(
182.00)
Low
Range
$
(
250.00)
37
%
$
5,090,000
$
5,183,000
2
%
High
Range
$
0
­
100
%
$
5,090,000
$
4,851,000
­
5
%
Number
of
TVs
from
unregulated
users
Best
Estimate
20,000,000
Low
Range
15,000,000
­
25
%
($
1,312,000)
($
379,000)
71
%
High
Range
30,000,000
50
%
($
1,312,000)
($
3,219,000)
­
145
%
Number
of
monitors
from
unregulated
users
Best
Estimate
9,194,354
Appendix
I
Detailed
Sensitivity
Analysis
Results
on
All
Parameters
Tested
(
continued)

Parameter
Names
Sensitivity
Test
Parameter
Values
Percent
Change
from
Best
Estimate
Savings
Under
Final
Rule
Savings
Under
Final
Rule
Using
the
Sensitivity
Test
Parameter
Values
Percent
increase
(
decrease)
in
amount
saved
March
19,
2004
Page
I­
5
Low
Range
5,000,000
­
46
%
($
1,312,000)
($
665,000)
49
%
High
Range
20,000,000
118
%
($
1,312,000)
($
3,092,000)
­
136
%
March
19,
2004
Page
J­
1
Appendix
J
Telephone
Contacts
Contacts
made
by
Sue
Chotikajan:

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

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

Responses:

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

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

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

C
All
CRT
glass
is
sent
to
CRT
glass
manufacturers.

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

C
The
total
number
of
CRTs
processed
annually
is
approximately
5,000
monitors.

C
Since
I.
G.,
Inc.
is
only
processing
CRTs
as
a
sideline,
we
do
not
track
down
the
types
of
monitors
processed.
March
19,
2004
Page
J­
2
Jim
Weber,
Federal
Prison
Industries,
Ohio,
(
330)
424
 
7448
(
ext.
1313).
November
6,
1998.

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

Responses:

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

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

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

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

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

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

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

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

Questions:
(
1)
Where
do
you
get
your
discarded
CRTs?
(
2)
What
types
of
industries/
manufacturers
are
your
sources
(
TV
and
computer
manufacturers
or
post­
consumer)?
March
19,
2004
Page
J­
3
(
3)
How
much
do
you
charge
for
taking
discarded
CRTs
(
Specifically
for
a
30
pound
monitor)?
(
4)
What
do
you
with
the
glass?
Is
it
landfilled,
sent
to
smelters,
or
sent
to
CRT
glass
manufacturers?
(
5)
What
is
the
percentage
of
this
allocation?
(
6)
What
is
the
cost
sent
to
each?
(
7)
What
is
the
total
number
of
CRTs
processed
annually
and
total
weight
processed?
(
8)
Do
you
have
information
on
the
number
of
color
vs.
monochrome
monitors
processed?

Responses:

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

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

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

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

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

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

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

C
All
the
glass
from
CRTs
that
DMC
recycles
is
sent
to
a
lead
smelter.
Typically
they
ship
the
glass
by
rail
in
quantities
of
about
100,000
pounds
(
50
tons).

C
The
primary
lead
smelter
uses
the
glass
silicate
in
place
of
a
commercial
fluxing
agent
and
recovers
the
lead.

C
DMC's
recycling
process
entails
5
steps
to
breakup
and
separate
the
computer
monitor
materials:
(
1)
shredding;
(
2)
ferrous
separation;
(
3)
pulverizing
the
glass;
(
4)
sifting
the
glass;
(
5)
containerizing
the
copper,
aluminum,
and
plastic.

Contacts
made
by
Tom
Uden:
March
19,
2004
Page
J­
4
Robert
Bouma,
Noranda,
Toronto,
Ontario,
(
416)
982­
7237.
November
4,
1998.

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

Responses:

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

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

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

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

C
CRT
glass
direct
from
OEMs
(
broken
in
manufacturing
for
example)
is
an
ideal
input
for
their
lead
smelter
in
New
Brunswick.
The
glass
must
be
clean,
because
plastic
fouls
the
sulfuric
acid
plant
that
is
part
of
the
process.
March
19,
2004
Page
J­
5
Cliff
Asbury,
Doe
Run,
Glover,
MO,
(
573)
546­
7492,
x­
237.
November
10,
1998.

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

Responses:

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

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

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

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

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

C
Mr.
Asbury
mentioned
three
brokers/
processors:

C
Asset
Recovery,
MN;
612­
602­
0789,
Bruce
Janovic.
This
may
be
an
affiliate
of
Digital
Corp.

C
DMC,
NH;
603­
772­
7236,
Mike
Mogliano.

C
SEER,
FL;
800­
376­
7888,
Mike
Flynn.

C
Mr.
Asbury
expressed
concern
that
the
current
CSI
proposal
favors
glass­
to­
glass
recycling.
Doe
Run
does
not
want
to
lose
CRTs
as
an
input
and
revenue
generator.
[
CRTs
may
represent
an
important
revenue
source,
especially
when
the
price
of
lead
is
low.]
March
19,
2004
Page
J­
6
Mike
Flynn,
SEER
(
Secure
Environmental
Electronic
Recovery),
Tampa,
FL.
(
888)
600­
7337.
November
11,
1998.

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

Responses:

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

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

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

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

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

C
Florida
recently
adopted
Universal
Waste
Regulations,
and
SEER
is
a
Universal
Waste
Handler
and
Transporter.
This
allows
them
to
handle
batteries
and
mercury
switches.
Mr.
Flynn
claimed
that
when
the
CRTs
are
brought
to
SEER,
they
are
in
monitor
format
and
are
therefore
still
potentially
a
viable
product.
They
are
therefore
exempt
from
RCRA
manifest
and
other
requirements.
When
they
are
sent
to
Doe
Run,
they
are
exempt
March
19,
2004
Page
J­
7
because
they
are
primary
process
feed.
He
is
not
sure
what
the
RCRA
status
of
shipping
to
Envirocycle
would
be;
he
intends
to
find
out
next
week.

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

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

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

Responses:

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

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

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

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

C
Contacts:
CWM
Model
City
NY
(
716)
754­
8231
Jill
Knickerbocker
CWM
Emelle
AL
(
205)
652­
9721
Dr.
Jim
Street
CWM
Lake
Charles
LA
(
318)
583­
2144
Chuck
Grant
Heather
McCarthy,
Clean
Harbors
of
Braintree.
May
9
and
24,
2001.
March
19,
2004
Page
J­
8
Questions:
(
1)
Have
you
mostly
received
CRTs
from
the
users,
brokers,
or
other
types
of
businesses?
(
2)
Are
the
CRTs
mostly
sent
to
you
whole
or
crushed?
(
3)
What
are
your
rates
for
stabilization
and
disposal
of
bulk
waste?
(
4)
Can
you
estimate
how
many
CRTs
or
how
many
tons
of
CRTs
your
facility
has
processed
in
the
last
year?
(
5)
Does
your
company
provide
transportation
services?

Responses:

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

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

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

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

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

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

Responses:

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

C
CRTs
sometimes
are
received
whole,
but
mostly
crushed
in
roll
off
containers.
March
19,
2004
Page
J­
9
C
The
rate
for
crushed
CRTs
in
a
roll­
off
container
is
$
160
per
ton.
The
rate
for
whole
monitors
is
$
360
per
cubic
yard.
The
rate
for
whole
CRTs
in
drums
is
$
150
per
drum.
Envirosafe
does
not
have
a
minimum
charge
for
shipments
of
CRTs.

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

C
Envirosafe
subcontracts
out
transportation.

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

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

Responses:

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

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

C
For
monitors
that
are
17
inches
or
less,
they
charge
$
6
to
$
7.50
per
monitor.
For
monitors
that
are
larger
than
17
inches,
they
charge
$
9.50
per
monitor.
For
bare
CRTs,
they
charge
$
4.00
per
bare
CRT.

C
The
facility
processed
40,000
CRTs
in
the
last
year.
This
includes
both
TVs
and
monitors.

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

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

Jack
Hope,
WasteNot
Recycling,
Sterling,
VA.
(
703)
787­
0200.
May
15,
2001.
March
19,
2004
Page
J­
10
Questions:
(
1)
What
do
you
do
with
the
CRTs
you
receive?
(
2)
Who
do
you
receive
CRTs
from?
e.
g.,
the
users,
brokers,
or
other
types
of
businesses?
(
3)
What
are
your
rates
for
processing
monitors?
(
4)
Can
you
estimate
how
many
CRTs
or
how
many
tons
of
CRTs
your
facility
has
processed
in
the
last
year?

Responses:

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

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

C
There
is
no
charge
for
donating
monitors.

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

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

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

Responses:

C
None.

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

C
Envirocycle
is
currently
operating
at
about
20
percent
of
its
capacity
in
its
Halstead,
PA
facility.
Envirocycle's
current
operating
tempo
is
about
1.5
million
pounds
per
month
C
The
North
Carolina
facility
will
not
be
opened.
Two
other
locations
are
being
pursued
and
will
be
open
by
the
end
of
the
year.
One
facility
will
be
located
in
the
north
east
and
the
other
will
be
on
the
west
coast.
March
19,
2004
Page
J­
11
C
Envirocycle
charges
about
$
5
to
$
6
per
monitor
for
whole
monitors.
The
actual
price
paid
is
volume
dependant.

C
About
50
to
60
percent
of
the
glass
received
is
"
dirty­
mix
with
no
metals."
This
glass
comes
from
other
demanufacturing
facilities.
Envirocycle
still
receives
about
the
same
amount
of
CRT
glass
from
OEMs
as
in
1996.
March
19,
2004
Page
K­
1
Appendix
K
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