MEMORANDUM
July 2, 2018
SUBJECT: Long-Term Care Facility Summary Data and Hazardous Waste Generation Data
TO: EPA Docket EPA - HQ - RCRA - 2007 - 0932

This memorandum to the record contains two tables. The first table presents summary data on the number of long-term care facilities and beds at long-term care facilities from a Centers for Disease Control and Prevention report on long-term care providers in the United States. EPA used this data to estimate that long-term care facilities in the United States have an average of 58 beds. The second table presents data on the volume of hazardous waste generated annually at long-term care facilities that submitted a biennial hazardous waste report between 2001 and 2015 and submitted their report using a NAICS code beginning with 623 (Nursing and Residential Care Facilities). Data on the hazardous waste generated at long-term care facilities is limited because most long-term care facilities that generate hazardous waste are estimated to be very small quantity generators and are not federally required to submit biennial hazardous waste reports. Using this limited data, EPA estimates the average long-term care facility that submitted a biennial hazardous waste report generated 2.3005 tons (2,086 kg) of hazardous waste annually, or 0.1917 tons (173 kg) per month assuming that hazardous waste generation is distributed evenly throughout the year. Therefore, assuming the average long-term care facility has 58 beds, EPA estimates that the average long-term care facility that submitted a biennial hazardous waste report generated approximately 0.0033 tons (2.99 kg) of hazardous waste per bed per month. Extrapolating this data, EPA estimates the average long-term care facility will generate less than 100 kg of hazardous waste per month when it has 33 beds or fewer. Because the data are very limited and do not account for acute hazardous waste, EPA has conservatively chosen 20 beds as a reasonable cutoff for establishing a rebuttable presumption for the generator category of long-term care facilities. Long-term care facilities with more than 20 beds may still qualify as very small quantity generators (VSQGs), but they will not be presumed to be VSQGs.




Table 1: Long-term care services providers, by organization characteristics and sector: United States, 2013-2014[1]
Characteristic
Adult day services center
Home health agency
Hospice
Nursing home
Residential care community
Total
Number of providers
4,800
12,400
4,000
15,600
30,200
50,600[2]
Total number of beds or licensed maximum capacity
289,400


1,633,300
1,000,000
2,922,700
Average number of beds or licensed maximum capacity
62


106
33
57.76
Notes:
 Source: "Long-Term Care Providers and Services Users in the United States: Data From the National Study of Long-Term Care Providers, 2013-2014," Centers for Disease Control and Prevention, Vital and Health Statistics, Vol. 3 No. 38 February 2016.
 Total excludes "Home health agency" and "Hospice" number of providers because number of beds not available.



Table 2: Long Term Care Facility Hazardous Waste Generation Data
STATE
HANDLER ID
HANDLER NAME
Total Annual HW Generation Tons
IL
ILR000177774
ANN M KILEY DEVELOPMENTAL CTR
1.63
AR
AR4360010298
CENTRAL ARKANSAS VETERENS HEALTHCARE SYS
2.71
NY
NYD986881050
GLENDALE NURSING HOME
1.20
IA
IAD984590182
GLENWOOD RESOURCE CENTER
0.93
DE
DED984076463
GOVERNOR BACON HEALTH CENTER
3.17
MI
MIK189246531
LS BRINKER
1.13
NY
NYR000135665
MASONIC CARE COMMUNITY OF NEW YORK
5
MT
MTD986070852
MONTANA DEVELOPMENTAL CENTER
2.63
NY
NYR000201483
RIVERSIDE - SCHOOL 60
3.08
CA
CAD060125242
SONOMA DEVELOPMENTAL CENTER
3.91
NY
NY0001508795
ST ANNS HOME
1.87
AR
ARD983269705
ST. BERNARDS MEDICAL CENTER
1.33
DC
DC8210021160
US SOLIDERS AND AIRMENS HOME
1.91
NY
NYD098352305
WILTON DEVELOPMENT CENTER
1.71
Average Annual HW Tons


2.3005
Notes:
 Source: RCRAInfo Biennial Reports database. Data includes facilities that submitted biennial reports between 2001 and 2015 and reported using a NAICS code beginning with 623. The data were manually reviewed to remove hospitals from the sample.
 An average is used for facilities that provided more than one year of data.
 The overall volume of hazardous waste generated is reported, including hazardous waste pharmaceuticals and non-pharmaceutical hazardous waste (excluding acute generation).
 The sample excludes statistical outliers (values above Q3+1.5 interquartile range). 


