
            Regulatory Impact Assessment of the Potential Costs, Benefits, and Other Impacts of the Final Hazardous Waste Generator Improvements Rule





                                       
                                 Prepared for
                  U.S. Environmental Protection Agency (EPA)
              Office of Resource Conservation and Recovery (ORCR)
                 1200 Pennsylvania Avenue NW (Mailstop 5305P)
                           Washington DC, 20460 USA

                                             
                                      September 2016




                                             

ACKNOWLEDGEMENTS
The U.S. Environmental Protection Agency (EPA) recognizes Industrial Economics, Inc. (IEc), for the overall organization and development of this report.  IEc was contracted to perform this work by the Economics and Risk Analysis Staff of EPA's Office of Resource Conservation and Recovery under EPA Contract Number EP-W-12-013.  Chris McMinimy, Laura Stanley, Rachel Horton, and Jim O'Leary provided guidance and review.
TABLE OF CONTENTS
EXECUTIVE SUMMARY

Chapter 1  |  INTRODUCTION
1.1  Overview  1-1
1.2  Background and Need for Regulatory Action  1-1
1.3  Summary of the Final Rule  1-2
1.4  Report Organization  1-5

Chapter 2  |  POTENTIALLY IMPACTED UNIVERSE
2.1  Introduction  2-1
2.2  Universe of Facilities Affected by the Final Rule  2-1
	2.2.1  Estimating the Number of LQGs  2-2
	2.2.2  Estimating the Number of SQGs  2-3
	2.2.3  Estimating the Number of VSQGs  2-4
2.3  Hazardous Waste Generation of Potentially Affected Facilities  2-9
	2.3.1  LQG Hazardous Waste Generation  2-9
	2.3.2  SQG Hazardous Waste Generation  2-16
	2.3.3  VSQG Hazardous Waste Generation  2-17
	2.3.4  Aggregate Generation of Hazardous Waste Among Facilities Potentially Affected by the Rule  2-18
2.4  Management of Hazardous Waste  2-19

Chapter 3  |  ASSESSMENT OF COSTS
3.1  Introduction  3-1
3.2  Estimating Costs as a Range  3-1
3.3  Cost Methodology  3-3
	3.3.1  General Assumptions  3-3
	3.3.2  Re-Notification  3-6
	3.3.3  Labeling/Marketing  3-9
	3.3.4  Closure  3-11
	3.3.5  Emergency Response Preparedness  3-15
	3.3.6  Transfer Facility Requirements  3-19
	3.3.7  BR Requirements  3-22
	3.3.8  BR Requirements for Recycling Facilities  3-23
	3.3.9  Prohibitions on Storage of Restricted Waste for TSDFs  3-24
	3.3.10  Drip Pad and Containment Building Requirements  3-25
	3.3.11  Intra-Organizational Transfers (Voluntary)  3-26
	3.3.12  Episodic Generation (Voluntary)  3-30
	3.3.13  Special Requirements for Ignitable and Reactive Wastes (Voluntary)  3-36
3.4  Results  3-38
3.5  Analytic Limitations  3-45

Chapter 4  |  ASSESSMENT OF BENEFITS
4.1  Introduction  4-1
4.2  Monetized Benefits  4-1
	4.2.1  Drip Pad and Containment Building Requirements for SQGs  4-1
	4.2.2  Intra-organizational Transfers of Hazardous Waste from VSQGs to LQGs  4-5
	4.2.3  Generators that Temporarily Change Generator Status Due to an Episodic Event  4-12
4.3  Non-Quantified Benefits  4-16
	4.3.1  SQG Re-Notification  4-16
     4.3.2  Marking and Labeling of Containers for SQGs and LQGs  4-17
     4.3.3  LQG Closure Conditions  4-17
     4.3.4  Strengthening of the Preparedness, Prevention, and Emergency Response Conditions for LQGs  4-18
     4.3.5  Transfer Facility Requirements  4-18
     4.3.6  Biennial Reporting Requirements  4-18
     4.3.7  Prohibitions on Storage of Restricted Waste  4-18
	4.3.8  Intra-organization Transfers of Hazardous Waste from VSQGs to LQGs (Voluntary)  4-19
	4.3.9  Generators that Temporarily Change Generator Status Due to an Episodic Event (Voluntary) 4-20
	4.3.10 Special Requirements for Ignitable and Reactive Wastes (Voluntary) 4-20

Chapter 5  |  SUMMARY OF REGULATORY BENEFITS and COSTS

Chapter 6  |  EQUITY CONSIDERATIoNS AND OTHER IMPACTS
6.1  Regulatory Planning and Review  6-1
6.2  Regulatory Flexibility  6-2
6.3  Employment Impact Analysis  6-8
6.4  Unfunded Mandates Analysis  6-9
6.5  Federalism Analysis  6-10
6.6  Tribal Governments Analysis  6-10
6.7  Energy Impact Analysis  6-11
6.8  Environmental Justice Analysis  6-11
6.9  Children's Health Protection Analysis  6-12



APPENDIX a  |  DETAILED COST AND BENEFIT IMPACTS BY YEAR

APPENDIX B  |  Summary of 2013 BR Data













EXECUTIVE SUMMARY
This document presents EPA's analysis of the costs, benefits, and economic impacts of the final Hazardous Waste Generator Improvements Rule.  This final rule has the dual purposes of enhancing protection of human health and the environment and improving the efficiency of the hazardous waste generator standards.  EPA is publishing this Regulatory Impact Assessment (RIA) in conjunction with the final rule.  The net benefits of the final rule are summarized in Exhibit ES-1.  
exhibit ES-1:  Net Benefits of the proposed rule (annualized over 20 years)
                            REGULATORY REQUIREMENTS
                            3 PERCENT DISCOUNT RATE
                               ($2015, MILLIONS)
                            7 PERCENT DISCOUNT RATE
                               ($2015, MILLIONS)
                               ANNUALIZED COSTS 
                             ANNUALIZED BENEFITS 
                                 NET BENEFITS
                               ANNUALIZED COSTS
                        ANNUALIZED BENEFITSNET BENEFITS
Mandatory Provisions of the Final Rule
                                  $3.8 - $9.1
                                  $0.9 - $0.9
                               ($2.9)  -  ($8.3)
                                  $4.0 - $8.7
                                  $0.9 - $0.9
                               ($3.1)  -  ($7.9)
Voluntary Provisions of the Final Rule
                                  $1.9 - $4.5
                                 $7.4 - $13.5
                                  $5.5 - $9.0
                                  $1.9 - $4.6
                                 $7.4 - $13.5
                                  $5.5 - $8.9
Mandatory and Voluntary Provisions of the Final Rule Combined
                                 $5.7 - $13.6
                                 $8.3 - $14.3
                                 $2.6  -  $0.7
                                 $5.9 - $13.3
                                 $8.3 - $14.4
                                 $2.4  -  $1.1
Notes:
 Due to limitations in the available data, benefits associated with several provisions of the final rule (mandatory and voluntary) could not be monetized. Net benefits for these provisions are therefore presented as negative. These negative values, however, do not reflect the benefits that EPA was unable to monetize. EPA provides a qualitative discussion of the non-quantified benefits in Chapter 4. In excluding these benefits, the negative values in the exhibits underestimate the net benefits associated with the rule's mandatory and voluntary provisions.
Ranges are presented to reflect the low-end and high-end scenarios described later in this report. Numbers in parentheses indicate a net cost, as opposed to a net benefit. 
ES.1 Summary of the Final Rule
EPA is promulgating several changes to the hazardous waste generator regulations.  Specifically, EPA is  (1) revising different components of the hazardous waste regulatory program; (2) addressing gaps in the current regulations; (3) providing greater flexibility for hazardous waste generators to manage their hazardous waste in a cost-effective manner; (4) reorganizing the hazardous waste generator regulations to improve their usability among regulated facilities; and (5) making technical corrections and conforming changes to address inadvertent errors, remove obsolete programs, and improve the readability of the regulations. These specific provisions are summarized below.  While the majority of the requirements are mandatory, three provisions of the rule are intended to provide greater flexibility to certain classes of hazardous waste generators and are thus voluntary.  For a detailed discussion of all the changes to the generator regulations that EPA is promulgating, please refer to the Preamble to the final rule.
 SQG re-notification:  To ensure that regulatory agencies have information on facilities generating hazardous waste, EPA is requiring that SQGs re-notify EPA of their hazardous waste generation activities every four years.  For each re-notification, a facility need only review its previous notification and either make changes if necessary or confirm that the information remains accurate.
 Marking and labeling of containers, tanks, and containment buildings for SQGs and LQGs:  Current regulation requires that SQGs and LQGs label containers and tanks with the words, "Hazardous Waste."  While this wording provides some information regarding a container's contents, it does not indicate the specific hazards associated with these contents or the risks that a waste may pose to human health and the environment.  EPA is therefore requiring that SQGs and LQGs mark containers and tanks with (1) the words "Hazardous Waste" and (2) an indication of the hazards of a container's contents (e.g., the applicable hazardous waste characteristics).  Similarly, EPA is also requiring that SQGs and LQGs mark containment buildings with (1) the words "Hazardous Waste" and (2) an indication of the associated hazards (e.g., the applicable hazardous waste characteristics). 
 LQG closure conditions:  EPA is strengthening the closure regulations for LQGs that accumulate hazardous wastes in containers in central accumulation areas (CAAs).  Specifically, EPA is requiring that if the generator cannot demonstrate that any contaminated soils can be practicably removed or decontaminated, then the generator must close the waste accumulation unit(s) and perform post-closure care in accordance with the closure and post-closure care requirements that apply to landfills (§ 265.310).  In addition, for the purposes of closure, post-closure, and financial responsibility, such a waste accumulation unit is then considered to be a landfill, and the generator must meet all of the requirements for landfills specified in subparts G and H of part 265. 
Also related to closure, EPA is requiring LQGs to notify EPA or their authorized state within 30 days prior to closure.  EPA is also requiring that such generators subsequently notify within 90 days after closure that they have either clean closed or -- if they cannot clean close -- that they have closed as a landfill.  LQGs must also document in their operating record if they close any waste accumulation units prior to the facility closure.
 Strengthening of the preparedness, prevention, and emergency response conditions for LQGs:  To improve the ability of emergency response teams to respond to an emergency, EPA is requiring any that all new LQGs submit a quick reference guide to their contingency plan to emergency management authorities.  In addition, EPA is requiring any LQG that makes a change to its existing contingency plan to prepare and submit a quick reference guide to emergency responders. 
 Transfer facility requirements:  Transporters that store manifested shipments of hazardous waste in containers at a transfer facility for a period of ten days or less are not subject to the regulation under parts 264, 265, 267, 268, and 270.  However, EPA is changing the marking and labeling requirements for transporters using a transfer facility when consolidating the contents of two or more containers with the same hazardous waste into a new container, or when combining and consolidating two different hazardous wastes that are compatible with each other.  In this case, the transporter must label all containers with (1) the words "Hazardous Waste" and (2) the applicable EPA hazardous waste codes.
 Biennial reporting requirements:  EPA is requiring that LQGs report all of the hazardous waste that they generate for the entire reporting year, not just waste for the month(s) during which they were LQGs.  Current regulation at the Federal level is unclear on this issue, and a limited number of states currently require LQGs to report the amount of hazardous waste generated for only those months that they were LQGs.
 Recycling facility reporting requirements:  Under the existing regulations in CFR 261.6, which identifies the requirements for recyclable materials, certain classes of recycling facilities are exempt from the BR reporting requirements so long as they are not required to be permitted as a TSDF.  The final rulemaking adds the BR reporting requirements to CFR 261.6 (c) (2).
 Prohibitions on storage of restricted waste for hazardous waste treatment, storage, and disposal facilities (TSDFs):  Consistent with the marking and labeling requirements for SQGs and LQGs, EPA is requiring that TSDFs mark containers holding hazardous waste with (1) the words "Hazardous Waste" and (2) an indication of the hazards of a container's contents.  Under existing regulations, TSDFs must already mark containers holding hazardous waste with a description of the contents of the container.
 Drip pad and containment building requirements:  Under the existing regulations, EPA has consistently interpreted the requirements for LQGs that accumulate hazardous waste on drip pads or in containment buildings for 90 days or less without a permit or interim status to also apply to SQGs.  Therefore, SQGs that use drip pads or containment buildings must comply with the LQG 90-day accumulation limit (as opposed to the SQG 180-day accumulation limit) as well as the requirements that apply to LQGs for personnel training, development of a full contingency plan, and biennial reporting.  Under the final rule, EPA believes a more effective and efficient approach is to require SQGs that accumulate hazardous waste in containment buildings to comply with the 90-day accumulation limit and SQGs that accumulate hazardous waste on drip pads to comply with the 180-day accumulation limit, but to otherwise comply with the less stringent requirements for SQGs.
 Intra-organization transfers of hazardous waste from VSQGs to LQGs (voluntary):  To afford greater flexibility to VSQGs, EPA is allowing VSQGs to send their hazardous waste voluntarily to an LQG under the control of the same person, provided that both the VSQG(s) and LQG comply with certain conditions.  The VSQG conditions are as follows: 
 A participating VSQG must label containers with the words "VSQG Hazardous Waste" and an indication of the hazards of a container's contents. 
 VSQGs must comply with all applicable Department of Transportation regulations when sending their hazardous waste to an LQG. 
      The conditions for LQGs receiving hazardous waste from one or more VSQGs controlled by the same person include the following:
 LQGs must submit a notification to EPA or their authorized state identifying the names, addresses, and contact information for the VSQGs that will be transferring hazardous waste to the LQG.
 LQGs must maintain records of all hazardous waste received from VSQGs that include the name, address, and contact information for each VSQG, as well as information on the quantity of each waste shipment received.
 LQGs must mark shipments from VSQGs with the date the hazardous waste was received from the VSQG.
 LQGs must manage all incoming VSQG hazardous waste in compliance with the regulations applicable to their LQG status.
 Hazardous waste received from VSQGs must be included in the receiving LQG's BR submissions. 
 Generators that temporarily change generator status due to an episodic event (voluntary):  To provide greater flexibility to VSQGs and SQGs that generate much of their hazardous waste on an episodic basis, EPA is allowing a VSQG or an SQG to voluntarily maintain its existing regulatory status in the event of a planned or unplanned episodic event in which the facility generates a quantity of hazardous waste in a calendar month that would otherwise elevate the facility to a more stringent regulatory status.  To take advantage of this provision, an SQG or VSQG is subject to the following conditions:
 Limit of no more than one planned and one unplanned episodic event per calendar year (each lasting no more than 60 days);
 Notify EPA or the authorized state at least 30 calendar days prior to initiating a planned episodic event or within 72 hours after an unplanned episodic event;
 VSQGs must obtain a RCRA ID number;
 Accumulation standards: VSQGs must mark containers with the date the episodic event began; label containers "Episodic Hazardous Waste"; manage hazardous waste in a manner that minimizes the possibility of a fire, explosion, or release of hazardous waste; ensure that tanks are in good condition and compatible with the hazardous waste stored within; and identify an emergency coordinator for the duration of the event.  SQGs must mark the container or tank log book with the date the episodic event began; label the container or write in the tank log book "Episodic Hazardous Waste"; mark the container or write in the tank log book words that indicate the hazards of the contents; and comply with the applicable accumulation conditions in §262, subpart L.
 Hazardous waste generated from the episodic event must be managed on-site or shipped off-site via hazardous waste manifest to a permitted TSDF.  For purposes of analysis, this RIA assumes that VSQGs and SQGs will not seek to obtain a RCRA storage or treatment permit, but will instead ship their hazardous waste off-site to a permitted TSDF.
 Complete and maintain records that include (1) the beginning and end dates of the event, (2) a description of the event, (3) the types and quantities of hazardous wastes generated at the event, (4) a description of how the hazardous waste was managed, and (5) name(s) of hazardous waste transporters that transported the waste to a permitted TSDF.
 Special requirements for ignitable and reactive wastes (voluntary):  Current regulation requires that LQGs must locate containers holding ignitable or reactive waste at least 15 meters from the facility's property line.  In urban environments, LQGs may find it impossible to meet this requirement due to the relatively small footprint of many properties in these areas.  To provide flexibility to LQGs, EPA will allow LQGs to voluntarily apply for a facility-specific waiver from their primary emergency authority if they are unable to meet the hazardous waste accumulation property line requirement.
ES.2 Universe of Facilities Affected by the Final Rule
The final rule may affect a wide range of facility types across a number of industries.  For an individual facility, the cost impact of the final rule will depend, in part, on its generator status under RCRA (i.e., LQG, SQG, or VSQGs).  Based on data from EPA's BR database, the Agency's RCRAInfo database, and a limited number of states, Exhibit ES-2 describes the total number of LQGs, SQGs, and VSQGs by state.  As indicated in the exhibit, EPA estimates that the combined total number of hazardous waste generators is between approximately 424,000 and 677,000.  For the facilities represented in Exhibit ES-2, the impacts of the rule will depend, in part, on the amount of hazardous waste that they generate on an annual basis.  Based on data from the 2013 BR database and select states, Exhibit ES-3 presents the average generation of hazardous waste on a per-facility level for LQGs, SQGs, and VSQGs.  For both the tonnage of hazardous waste generated and number of waste streams generated, the exhibit presents both the median and mean values from the available data.  
EXHIBIT ES-2:  UNIVERSE OF FACILITIES POTENTIALLY AFFECTED BY THE Final RULE BY STATE AND GENERATOR STATUS
                                   STATE[A]
                                Number of LQGs
                                      [B]
                                Number of SQGs
                                Number of VSQGs
                          TOTAL NUMBER OF GENERATORS
LOW-END
                                      [C]
                                   High-End
                                      [D]
                                    Low-End
                                      [E]
                                   High-End
                                      [F]
                                    Low-End
                                      [G]
                                   High-End
                                      [H]
Alabama
                                                                             27
                                                                             95
                                                                            148
                                                                            692
                                                                          1,078
                                                                            814
                                                                          1,253
Alaska
                                                                            386
                                                                            625
                                                                            674
                                                                          4,554
                                                                          9,998
                                                                          5,565
                                                                         11,058
Arizona
                                                                            101
                                                                            275
                                                                            275
                                                                          1,383
                                                                          1,383
                                                                          1,759
                                                                          1,759
Arkansas
                                                                            210
                                                                            582
                                                                            860
                                                                          4,241
                                                                          6,267
                                                                          5,033
                                                                          7,337
California
                                                                          2,775
                                                                          7,031
                                                                         11,722
                                                                         51,233
                                                                         85,415
                                                                         61,039
                                                                         99,912
Colorado
                                                                            108
                                                                            428
                                                                            453
                                                                          2,797
                                                                          3,301
                                                                          3,333
                                                                          3,862
Connecticut
                                                                            416
                                                                            726
                                                                          1,026
                                                                          5,290
                                                                         10,775
                                                                          6,432
                                                                         12,217
Delaware
                                                                             36
                                                                             65
                                                                             67
                                                                            474
                                                                            932
                                                                            575
                                                                          1,035
District of Columbia
                                                                             60
                                                                            168
                                                                            214
                                                                          1,224
                                                                          1,559
                                                                          1,452
                                                                          1,833
Florida
                                                                            386
                                                                          3,700
                                                                          3,700
                                                                         16,800
                                                                         16,800
                                                                         20,886
                                                                         20,886
Georgia
                                                                            517
                                                                          1,017
                                                                          1,161
                                                                          7,411
                                                                         13,391
                                                                          8,945
                                                                         15,069
Guam
                                                                              9
                                                                              7
                                                                             13
                                                                             51
                                                                            233
                                                                             67
                                                                            255
Hawaii
                                                                             23
                                                                            138
                                                                            191
                                                                            596
                                                                          1,392
                                                                            757
                                                                          1,606
Idaho
                                                                            144
                                                                            694
                                                                            767
                                                                          3,730
                                                                          5,589
                                                                          4,568
                                                                          6,500
Illinois
                                                                             23
                                                                            101
                                                                            104
                                                                            596
                                                                            758
                                                                            720
                                                                            885
Indiana
                                                                            836
                                                                          3,036
                                                                          4,787
                                                                         21,654
                                                                         34,882
                                                                         25,526
                                                                         40,505
Iowa
                                                                            710
                                                                            966
                                                                            975
                                                                          7,039
                                                                         18,390
                                                                          8,715
                                                                         20,075
Kansas
                                                                            213
                                                                            569
                                                                            572
                                                                          4,146
                                                                          5,517
                                                                          4,928
                                                                          6,302
Kentucky
                                                                            297
                                                                            427
                                                                            427
                                                                          3,111
                                                                          7,693
                                                                          3,835
                                                                          8,417
Louisiana
                                                                            368
                                                                            855
                                                                          1,239
                                                                          6,230
                                                                          9,532
                                                                          7,453
                                                                         11,139
Maine
                                                                            415
                                                                          2,596
                                                                          2,596
                                                                         15,426
                                                                         15,426
                                                                         18,437
                                                                         18,437
Maryland
                                                                            469
                                                                            921
                                                                          1,590
                                                                          6,711
                                                                         12,148
                                                                          8,101
                                                                         14,207
Massachusetts
                                                                             87
                                                                            319
                                                                            319
                                                                          3,804
                                                                          3,804
                                                                          4,210
                                                                          4,210
Michigan
                                                                            493
                                                                          1,856
                                                                          1,991
                                                                         12,770
                                                                         14,508
                                                                         15,119
                                                                         16,992
Minnesota
                                                                            340
                                                                          1,437
                                                                          1,437
                                                                         20,910
                                                                         20,910
                                                                         22,687
                                                                         22,687
Mississippi
                                                                            330
                                                                          1,385
                                                                          1,663
                                                                          8,548
                                                                         12,118
                                                                         10,263
                                                                         14,111
Missouri
                                                                            164
                                                                            252
                                                                            272
                                                                          1,836
                                                                          4,248
                                                                          2,252
                                                                          4,684
Montana
                                                                             62
                                                                             92
                                                                             97
                                                                            670
                                                                          1,606
                                                                            824
                                                                          1,765
Navajo Nation
                                                                            675
                                                                          1,343
                                                                          1,616
                                                                          9,786
                                                                         17,484
                                                                         11,804
                                                                         19,775
Nebraska
                                                                             26
                                                                             77
                                                                             83
                                                                            561
                                                                            673
                                                                            664
                                                                            782
Nevada
                                                                              0
                                                                              3
                                                                              4
                                                                             22
                                                                             29
                                                                             25
                                                                             33
New Hampshire
                                                                             69
                                                                            226
                                                                            296
                                                                          1,647
                                                                          2,157
                                                                          1,942
                                                                          2,522
New Jersey
                                                                            134
                                                                            201
                                                                            201
                                                                          1,940
                                                                          1,940
                                                                          2,275
                                                                          2,275
New Mexico
                                                                            711
                                                                            631
                                                                            631
                                                                          6,859
                                                                          6,859
                                                                          8,201
                                                                          8,201
New York
                                                                             41
                                                                            200
                                                                            250
                                                                          1,062
                                                                          1,822
                                                                          1,303
                                                                          2,113
North Carolina
                                                                              1
                                                                              7
                                                                             10
                                                                             26
                                                                             73
                                                                             34
                                                                             84
North Dakota
                                                                             94
                                                                            233
                                                                            279
                                                                          1,698
                                                                          2,435
                                                                          2,025
                                                                          2,808
Northern Marianas
                                                                          3,095
                                                                          2,998
                                                                          4,063
                                                                         21,846
                                                                         80,167
                                                                         27,939
                                                                         87,325
Ohio
                                                                            975
                                                                          1,978
                                                                          3,082
                                                                         14,413
                                                                         25,255
                                                                         17,366
                                                                         29,312
Oklahoma
                                                                            170
                                                                            382
                                                                            458
                                                                          2,784
                                                                          4,403
                                                                          3,336
                                                                          5,031
Oregon
                                                                            210
                                                                            270
                                                                            271
                                                                          1,967
                                                                          5,439
                                                                          2,447
                                                                          5,920
Pennsylvania
                                                                          1,004
                                                                          2,777
                                                                          4,157
                                                                         20,235
                                                                         30,291
                                                                         24,016
                                                                         35,452
Puerto Rico
                                                                             94
                                                                            134
                                                                            167
                                                                            976
                                                                          2,435
                                                                          1,204
                                                                          2,696
Rhode Island
                                                                            103
                                                                            930
                                                                          1,445
                                                                          2,668
                                                                         10,529
                                                                          3,701
                                                                         12,077
South Carolina
                                                                            386
                                                                            636
                                                                            648
                                                                          4,634
                                                                          9,998
                                                                          5,656
                                                                         11,032
South Dakota
                                                                             31
                                                                            151
                                                                            246
                                                                            803
                                                                          1,793
                                                                            985
                                                                          2,070
Tennessee
                                                                            363
                                                                            638
                                                                            677
                                                                          4,649
                                                                          9,402
                                                                          5,650
                                                                         10,442
Texas
                                                                              0
                                                                              2
                                                                              2
                                                                             15
                                                                             15
                                                                             17
                                                                             17
Trust Territories
                                                                            970
                                                                          1,836
                                                                          2,041
                                                                         13,378
                                                                         25,125
                                                                         16,184
                                                                         28,136
Utah
                                                                            127
                                                                            226
                                                                            247
                                                                          1,647
                                                                          3,290
                                                                          2,000
                                                                          3,664
Vermont
                                                                            397
                                                                          1,312
                                                                          1,671
                                                                          9,560
                                                                         12,176
                                                                         11,269
                                                                         14,244
Virgin Islands
                                                                              1
                                                                              6
                                                                             13
                                                                             26
                                                                             95
                                                                             33
                                                                            109
Virginia
                                                                             43
                                                                            175
                                                                            233
                                                                          1,114
                                                                          1,698
                                                                          1,332
                                                                          1,974
Washington
                                                                            456
                                                                            617
                                                                            617
                                                                          1,541
                                                                          1,541
                                                                          2,614
                                                                          2,614
West Virginia
                                                                            424
                                                                          1,080
                                                                          1,080
                                                                         10,442
                                                                         10,442
                                                                         11,946
                                                                         11,946
Wisconsin
                                                                            144
                                                                            363
                                                                            364
                                                                          2,645
                                                                          3,730
                                                                          3,152
                                                                          4,238
Wyoming
                                                                             22
                                                                             92
                                                                            118
                                                                            570
                                                                            860
                                                                            684
                                                                          1,000
TOTAL
                                                                         20,771
                                                                         49,887
                                                                         64,310
                                                                        353,441
                                                                        591,809
                                                                        424,099
                                                                        676,890

EXHIBIT ES-3:  PER FACILITY GENERATION OF HAZARDOUS WASTE, BY FACILITY TYPE 
                                GENERATOR TYPE
                 HAZARDOUS WASTE GENERATED PER FACILITY (TONS)
                 AVERAGE NUMBER OF WASTE STREAMS PER FACILITY
LQG
                           Median: 7.6
Mean: 1,692.3
                              Median: 6 
Mean: 13
SQG
                                 Median: 1.32
                                  Mean: 2.19
                                   Median: 6
                                    Mean: 7
VSQG
                           Median: 0.13 
Mean: 0.25
                                   Median: 5
                                    Mean: 6
Sources: 
LQG estimates derived from the 2013 Biennial Report (BR) database.  SQG estimates reflect data from the States of Maine and Washington, as well as the limited SQG-specific data included in the 2013 BR database.  VSQG estimates are based on data from Maine, New Jersey, and Washington, as well as data from the 2013 BR database.

Exhibit ES-4 reports the aggregate hazardous waste generation of facilities potentially affected by the rulemaking.  In total, this RIA estimates that between approximately 424,000 and 677,000 facilities may be affected by the final rule.  Due to uncertainty regarding the hazardous waste generation of SQGs and VSQGs, this RIA bounds these generation quantities using the median and mean values reported above.  Using this approach, facilities in the affected universe, in aggregate, generate between 35.2 and 35.4 million tons of hazardous waste per year.  While there is uncertainty about the actual number of SQG and VSQG facilities as well as their hazardous waste generation, the vast majority of hazardous waste (approximately 99 percent) is generated by LQGs.  Therefore, in terms of volume, the difference between the low-end and high-end scenarios contemplated in this RIA is approximately 178,000 tons of hazardous waste or less than 1 percent of all hazardous waste managed by facilities in the affected universe.
ES.3 Assessment of Costs
To assess the costs of the final rule, this RIA estimates the unit costs (e.g., disposal cost per ton of waste) associated with each provision of the rule and applies these values to the number of facilities affected by each rule provision.  To address uncertainty regarding the number of facilities in the regulated universe, the amount of hazardous waste that they generate, and several of the cost-related inputs used in the analysis, this RIA presents both low-end and high-end estimates of the costs associated with the final rule.  The low-end cost estimates reflect low-end estimates of (1) the number of facilities in the regulated universe, (2) the number of waste streams per facility, and (3) the annual generation of hazardous waste among regulated facilities.  The low-end estimates also reflect the low-end assumptions regarding any cost-related inputs for which a range of data inputs were available, such as the number of labor hours required for compliance activities.  Similarly, the high-end cost estimates developed in this RIA reflect the high-end estimates for these variables. 
Exhibit ES-5 reports the total annualized costs of the final rule by provision for both the mandatory and voluntary provisions of the rule.  These costs are reported using discount rates of both 3 percent and 7 percent.  As the exhibit shows, the most significant costs under the mandatory requirements of the final rule are associated with the marking/labeling requirements.  Among the voluntary provisions, the estimated costs are highest for the intra-organizational transfer provision. 
Exhibit ES-6 presents the distribution of the total costs of the rule across the three RCRA generator categories (i.e., LQGs, SQGs, and VSQGs) for the mandatory and voluntary provisions combined using discount rates of 3 percent and 7 percent.  On a per-facility basis, the average annualized incremental costs of the rule are between $2 and $3 for VSQGs, between $57 and $94 for SQGs, and between $119 and $268 for LQGs (using a 7 percent discount rate).  While all generators are subject to the final rule, only a subset will incur costs for a given rule provision.  Therefore, the average costs reported may not be reflective of the actual costs that an individual facility may experience.

EXHIBIT ES-4:  AGGREGATE ANNUAL HAZARDOUS WASTE GENERATION BY GENERATOR STATUS (TONS)
                                   SCENARIO
                                      [A]
                                     LQGs
                                     SQGs
                                     VSQGs
                                     TOTAL

                            NUMBER OF FACILITIES[B]
                   TOTAL HAZARDOUS WASTE GENERATED(TONS)[C]
                            NUMBER OF FACILITIES[D]
                   TOTAL HAZARDOUS WASTE GENERATED(TONS)[E]
                            NUMBER OF FACILITIES[F]
                   TOTAL HAZARDOUS WASTE GENERATED(TONS)[G]
                            NUMBER OF FACILITIES[H]
                   TOTAL HAZARDOUS WASTE GENERATED(TONS)[I]
Low-end Estimate
                                    20,771
                                  35,151,000
                                    49,887
                                    66,000
                                    353,441
                                    46,000
                                    424,099
                                  35,263,000
High-end Estimate
                                       
                                       
                                    64,310
                                    141,000
                                    591,809
                                    148,000
                                    676,890
                                  35,441,000
Notes:
 For SQGs, the low-end estimate assumes each facility generates, on average, approximately 1.32 tons/year of hazardous waste. The high-end estimate assumes that SQGs generate, on average, approximately 2.19 tons/year of hazardous waste.
 For VSQGs, the low-end estimate assumes each facility generates, on average, approximately 0.13 tons/year of hazardous waste. The high-end estimate assumes that VSQGs generate, on average, approximately 0.25 tons/year of hazardous waste.


EXHIBIT ES-5:  TOTAL ANNUALIZED COSTS OF THE FINAL RULE BY REQUIREMENT ($2015 ANNUALIZED OVER 20 YEARS)
                                  REQUIREMENT
                              LOW IMPACT SCENARIO
                             HIGH IMPACT SCENARIO
                                       
                        ANNUALIZED COSTS(UNDISCOUNTED)
                  ANNUALIZED COSTS(USING A 3% DISCOUNT RATE)
                  ANNUALIZED COSTS(USING A 7% DISCOUNT RATE)
                        ANNUALIZED COSTS(UNDISCOUNTED)
                  ANNUALIZED COSTS(USING A 3% DISCOUNT RATE)
                  ANNUALIZED COSTS(USING A 7% DISCOUNT RATE)
MANDATORY PROVISIONS OF THE FINAL RULE
Re-notification
                                                                       $459,000
                                                                       $480,000
                                                                       $507,000
                                                                       $594,000
                                                                       $621,000
                                                                       $656,000
Labeling
                                                                     $2,640,000
                                                                     $2,750,000
                                                                     $2,920,000
                                                                     $5,340,000
                                                                     $5,450,000
                                                                     $5,610,000
Closure
                                                                        $44,500
                                                                        $44,500
                                                                        $44,500
                                                                     $3,200,000
                                                                     $2,330,000
                                                                     $1,710,000
Emergency Response Preparedness
                                                                       $471,000
                                                                       $475,000
                                                                       $481,000
                                                                       $661,000
                                                                       $666,000
                                                                       $672,000
Transfer Facility
                                                                         $4,470
                                                                         $4,470
                                                                         $4,470
                                                                         $8,280
                                                                         $8,280
                                                                         $8,280
BR Requirements
                                                                         $7,000
                                                                         $7,100
                                                                         $7,240
                                                                        $68,800
                                                                        $69,800
                                                                        $71,100
Recycling
                                                                         $2,060
                                                                         $2,090
                                                                         $2,130
                                                                         $5,590
                                                                         $5,670
                                                                         $5,780
Prohibitions on Storage
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
Drip Pads and Containment Buildings
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
SUB-TOTAL: Mandatory Rule Provisions
                                                                     $3,630,000
                                                                     $3,760,000
                                                                     $3,960,000
                                                                     $9,870,000
                                                                     $9,150,000
                                                                     $8,740,000
VOLUNTARY PROVISIONS OF THE FINAL RULE
Intra-organizational Transfers
                                                                     $1,610,000
                                                                     $1,640,000
                                                                     $1,680,000
                                                                     $2,930,000
                                                                     $2,980,000
                                                                     $3,050,000
Episodic Generation
                                                                       $260,000
                                                                       $260,000
                                                                       $260,000
                                                                     $1,390,000
                                                                     $1,390,000
                                                                     $1,390,000
Ignitable and Reactive Waste
                                                                            $50
                                                                            $60
                                                                            $60
                                                                        $97,000
                                                                       $105,000
                                                                       $118,000
SUB-TOTAL: Voluntary Rule Provisions
                                                                     $1,870,000
                                                                     $1,900,000
                                                                     $1,940,000
                                                                     $4,420,000
                                                                     $4,480,000
                                                                     $4,560,000
MANDATORY AND VOLUNTARY PROVISIONS OF THE FINAL RULE COMBINED
TOTAL: Mandatory and Voluntary Provisions Combined
                                                                     $5,500,000
                                                                     $5,660,000
                                                                     $5,900,000
                                                                    $14,300,000
                                                                    $13,600,000
                                                                    $13,300,000
Notes:
All cost estimates are rounded to three significant digits and may not sum due to rounding.
EXHIBIT ES-6:  TOTAL ANNUALIZED COSTS OF THE FINAL RULE BY GENERATOR STATUS ($2015 ANNUALIZED OVER 20 YEARS)
                               GENERATOR STATUS
                              LOW IMPACT SCENARIO
                             HIGH IMPACT SCENARIO
                         NUMBER OF AFFECTED FACILITIES
                        ANNUALIZED COSTS(UNDISCOUNTED)
                  ANNUALIZED COSTS(USING A 3% DISCOUNT RATE)
                  ANNUALIZED COSTS(USING A 7% DISCOUNT RATE)
                         NUMBER OF AFFECTED FACILITIES
                        ANNUALIZED COSTS(UNDISCOUNTED)
                  ANNUALIZED COSTS(USING A 3% DISCOUNT RATE)
                  ANNUALIZED COSTS(USING A 7% DISCOUNT RATE)
MANDATORY PROVISIONS OF THE FINAL RULE
LQG
                                                                         20,771
                                                                       $872,000
                                                                       $983,000
                                                                     $1,150,000
                                                                         20,771
                                                                     $4,280,000
                                                                     $3,520,000
                                                                     $1,150,000
SQG
                                                                         49,887
                                                                     $2,760,000
                                                                     $2,780,000
                                                                     $2,810,000
                                                                         64,310
                                                                     $5,590,000
                                                                     $5,620,000
                                                                     $5,660,000
VSQG
                                                                        353,441
                                                                           $370
                                                                           $370
                                                                           $380
                                                                        591,809
                                                                         $2,540
                                                                         $2,580
                                                                         $2,630
Recycling Facility
                                                                             10
                                                                         $2,060
                                                                         $2,090
                                                                         $2,130
                                                                             20
                                                                         $5,590
                                                                         $5,670
                                                                         $5,780
SUB-TOTAL
                                                                        424,109
                                                                     $3,630,000
                                                                     $3,760,000
                                                                     $3,960,000
                                                                        676,910
                                                                     $9,870,000
                                                                     $9,150,000
                                                                     $8,740,000
VOLUNTARY PROVISIONS OF THE FINAL RULE
LQG
                                                                         20,771
                                                                     $1,250,000
                                                                     $1,280,000
                                                                     $1,320,000
                                                                         20,771
                                                                     $2,350,000
                                                                     $2,410,000
                                                                     $2,500,000
SQG
                                                                         49,887
                                                                        $36,100
                                                                        $36,100
                                                                        $36,100
                                                                         64,310
                                                                       $403,000
                                                                       $403,000
                                                                       $403,000
VSQG
                                                                        353,441
                                                                       $585,000
                                                                       $585,000
                                                                       $585,000
                                                                        591,809
                                                                     $1,660,000
                                                                     $1,660,000
                                                                     $1,660,000
Recycling Facility
                                                                             10
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             20
                                                                             $0
                                                                             $0
                                                                             $0
SUB-TOTAL
                                                                        424,109
                                                                     $1,870,000
                                                                     $1,900,000
                                                                     $1,940,000
                                                                        676,910
                                                                     $4,420,000
                                                                     $4,480,000
                                                                     $4,560,000
MANDATORY AND VOLUNTARY PROVISIONS OF THE FINAL RULE COMBINED
LQG
                                                                         20,771
                                                                     $2,120,000
                                                                     $2,260,000
                                                                     $2,470,000
                                                                         20,771
                                                                     $6,630,000
                                                                     $5,930,000
                                                                     $5,570,000
SQG
                                                                         49,887
                                                                     $2,790,000
                                                                     $2,820,000
                                                                     $2,850,000
                                                                         64,310
                                                                     $5,990,000
                                                                     $6,020,000
                                                                     $6,060,000
VSQG
                                                                        353,441
                                                                       $586,000
                                                                       $586,000
                                                                       $586,000
                                                                        591,809
                                                                     $1,660,000
                                                                     $1,660,000
                                                                     $1,660,000
Recycling Facility
                                                                             10
                                                                         $2,060
                                                                         $2,090
                                                                         $2,130
                                                                             20
                                                                         $5,590
                                                                         $5,670
                                                                         $5,780
TOTAL
                                                                        424,109
                                                                     $5,500,000
                                                                     $5,660,000
                                                                     $5,900,000
                                                                        676,910
                                                                    $14,300,000
                                                                    $13,600,000
                                                                    $13,300,000
Notes:
All annualized cost estimates are rounded to three significant digits and may not sum due to rounding.
     ES.4 Assessment of Benefits
The final Hazardous Waste Generator Improvements Rule may yield a variety of benefits as generators change several of their waste management practices to comply with the final rule requirements.  These benefits reflect the rule's focus on enhancing protection of human health and the environment and improving the efficiency of the RCRA hazardous waste generator standards.  Ideally, this RIA would quantify and monetize each of the rule's benefits.  However, only some categories of benefits are quantifiable.  For the majority of benefits, sufficient data are not available to support a detailed quantitative analysis.  For example, quantifying benefits associated with improved emergency response due to more detailed container labeling would require data on the annual number of emergencies at generator sites, the current risks associated with these incidents, the extent to which more detailed labeling would affect the procedures of emergency responders, and the reduction in risk associated with these changes.  Detailed data on these items are not readily available. 
For those benefit categories for which detailed data are available, this RIA quantifies and monetizes benefits.  In instances where quantitative data are not available, this RIA provides a qualitative characterization of benefits.
ES.4.1 Monetized Benefits
The available data support the monetization of benefits for one mandatory provision (drip pad and containment building requirements for SQGs) and two voluntary provisions of the final rule (the intra-organizational consolidation of VSQG waste at an LQG and the flexibility afforded SQGs and VSQGs that cross the threshold to a more stringent regulatory status due to episodic generation events).  The benefits associated with each of these provisions are as follows:
Drip Pad and Containment Building Requirements for SQGs:  Under existing regulations, SQGs that accumulate hazardous waste on drip pads or in containment buildings for 90 days or less without a permit or interim status must comply with all of the LQG conditions associated with the accumulation of hazardous waste or else obtain a Part B permit for their drip pads or containment buildings.  The additional flexibility afforded SQGs to comply with the LQG 90-day accumulation limit for hazardous waste accumulated in containment buildings (as opposed to the SQG 180-day accumulation limit) and the 180-day accumulation limit for hazardous waste accumulated on drip pads, but to otherwise comply with the less stringent requirements for SQGs, will result in a cost savings associated with no longer being subject to the LQG requirements for personnel training, emergency response preparedness, and biennial reporting.
Intra-organizational Transfers:  Allowing VSQGs to send their hazardous waste to an LQG under the control of the same person may result in a net cost savings from reduced management costs related to both disposal and transportation.  With respect to disposal, organizations will realize a cost-savings associated with managing waste quantities in bulk.  Specifically, industry sources estimate that stand-alone VSQG facilities incur an average cost premium of approximately 10 percent to dispose of their hazardous waste relative to LQGs.  Organizations consolidating VSQG waste to LQGs may also reduce the costs they incur shipping hazardous waste to treatment, storage, and disposal facilities (TSDFs) due to the higher transport costs typically incurred by VSQGs on a per-ton basis compared to LQGs.  
This provision of the final rule will also lead to cost savings for the limited number of organizations that currently transfer hazardous waste from VSQGs that they own and/or operate to LQGs within the organization.  Under the final rule, LQGs owned by these organizations will no longer need to obtain a RCRA storage permit or financial assurance (assuming that they do not receive hazardous waste from SQGs, other LQGs, or VSQG facilities owned by other organizations) and will avoid the costs associated with these items.
Episodic Generation:  As noted above, EPA will allow a VSQG or SQG to retain its existing regulatory status in the event of a planned or unplanned episodic event that would otherwise elevate the facility to a more stringent status.  This provision will result in a cost savings for VSQGs and SQGs that avoid the cost increase associated with such a change in generator status.  These costs are related to the RCRA generator requirements for training, inspections, manifests, contingency plan updating, and biennial reporting.  
Using both 3 percent and 7 percent discount rates, Exhibit ES-7 reports the estimated monetized benefits of the final rule for the provisions outlined above for which the monetization of benefits was feasible.  Due to limitations in the available data, benefits associated with several mandatory provisions and one voluntary provision of the rule could not be monetized.  As indicated in the exhibit, the estimated quantifiable benefits of the final rule range from $8.3 to $14.4 million per year using a 7 percent discount rate.  Of the provisions for which benefits are monetized, benefits are greatest for the intra-organizational transfer provision of the rule.  The benefits realized by individual organizations under this provision, however, will vary depending on the number of facilities that are able to consolidate their wastes.
Exhibit ES-7:   Summary of monetized benefits ($2015 annualized over 20 years)
                                  REQUIREMENT
                              ANNUALIZED BENEFITS
                                (UNDISCOUNTED)
                              ANNUALIZED BENEFITS
                          (USING A 3% DISCOUNT RATE)
                              ANNUALIZED BENEFITS
                          (USING A 7% DISCOUNT RATE)
LOW IMPACT ESTIMATE
Drip Pads and Containment Buildings (Mandatory)
                                                                       $855,000
                                                                       $856,000
                                                                       $857,000
Intra-organizational Transfers (Voluntary)
                                                                     $4,210,000
                                                                     $4,210,000
                                                                     $4,210,000
Episodic Generation (Voluntary)
                                                                     $3,220,000
                                                                     $3,230,000
                                                                     $3,230,000
TOTAL
                                                                     $8,290,000
                                                                     $8,300,000
                                                                     $8,300,000
HIGH IMPACT ESTIMATE
Drip Pads and Containment Buildings (Mandatory)
                                                                       $858,000
                                                                       $859,000
                                                                       $860,000
Intra-organizational Transfers (Voluntary)
                                                                     $6,940,000
                                                                     $6,940,000
                                                                     $6,940,000
Episodic Generation (Voluntary)
                                                                     $6,540,000
                                                                     $6,550,000
                                                                     $6,560,000
TOTAL
                                                                    $14,300,000
                                                                    $14,300,000
                                                                    $14,400,000

ES.4.2 Non-Monetized Benefits
In addition to the monetized benefits presented above, the final rule may yield a variety of other non-quantifiable benefits.  By rule provision, these benefits include the following:
SQG and LQG re-notification: The data made available to EPA through re-notification will be more accurate and up-to-date than EPA's current generator data, allowing the Agency to observe changes in facilities' operations over time.  Using this information, EPA can conduct more precise and meaningful reviews of waste generation activity.  Similarly, the information collected through re-notification will help EPA and the states target their outreach, enforcement, and compliance assistance efforts.  
Marking and labeling of containers for SQGs and LQGs: Including more detailed information on container labels will help increase awareness of the hazards of a container's contents among the various individuals in the waste management chain, which may in turn prevent improper treatment, transportation, and disposal of hazardous waste.  The more detailed information that EPA requires for display on container labels will also enhance the ability of emergency responders to limit adverse impacts from exposure to hazardous materials.  
LQG Closure: The final closure requirements for LQGs will ensure the containment of any contaminants left in place after the closure of an LQG storing waste in containers. In addition, the final notification requirements for LQG closure will (1) provide regulatory authorities with information about the location and specifics of hazardous waste sites planned for closure; (2) allow the authorities to confirm that the unit is properly closed in compliance with the applicable closure regulations; and (3) allow the authorities to monitor the unit during the post-closure period, alerting regulators in cases where generators may have abandoned the site or closed it improperly, or where other complications may have developed at the site.
Strengthening of the preparedness, prevention, and emergency response conditions for LQGs. EPA's requirement that new LQGs submit a quick reference guide to their contingency plan to emergency management authorities and that any LQG that makes a change to its existing contingency plan prepare and submit a quick reference guide to emergency responders will allow first responders to more easily discern the layout of a facility, the location of hazardous wastes, what those wastes are, and what chemicals to use (or not use) near those wastes.  To the extent that first responders are able to respond more quickly and effectively based on this information, this provision of the final rule may prevent lethal outcomes and injuries among fire fighters, other first responders, and facility employees, and may also reduce exposure risk for local populations and ecosystems. 
Transfer facility requirements: EPA is changing the marking and labeling requirements for transporters storing bulk/mixed hazardous wastes at a transfer facility to be consistent with the final requirements for generators.  As discussed above, including this information on the container will alert facility workers of the hazards of a container's contents, which may help prevent the improper treatment of this material.  Displaying this information on the containers may also help first responders limit exposure to local populations and ecosystems in the event of a fire or other emergency.
Biennial reporting requirements: The enhanced requirements that EPA is requiring for biennial reporting will make the BR more complete and consistent, allowing the Agency and the states to base their policy, programmatic, and enforcement decisions on more reliable hazardous waste generation and management data. 
Prohibitions on storage of restricted waste for TSDFs: The final labeling requirements for TSDFs will result in benefits similar to those described above for generator labeling.
VSQG consolidation: Because LQGs are subject to more stringent waste handling requirements than VSQGs, transferring waste from VSQGs to LQGs under the control of the same person will improve the oversight and management of hazardous waste generated by VSQGs.  In addition, to the extent that consolidating VSQGs currently dispose of their hazardous waste in Subtitle D landfills, the consolidation of VSQG waste to an LQG will divert the waste to more environmentally protective disposal at a Subtitle C facility.
Episodic generation: In addition to the cost savings associated with avoided SQG- or LQG-specific activities (as estimated above), this provision of the rule may result in additional cost savings associated with facilities maintaining a more consistent RCRA generator status over time.  Changing status from one month to the next imposes an administrative burden on facilities as they re-visit the requirements for different generator status categories and implement measures to ensure compliance.  If facilities are able to maintain a more consistent generator status over time, they will not need to re-visit the generator requirements as frequently or make as many changes to their internal controls to ensure compliance with RCRA.
Special requirements for ignitable and reactive wastes: Facilities able to obtain a waiver from the prohibition on locating containers holding ignitable or reactive waste less than 15 meters (50 feet) from a facility's property line may avoid costs associated with relocation or the reconfiguration of their facilities.
ES.5 Comparison of Costs and Benefits 
Exhibits ES-8 and ES-9 present the net benefits of the final rule based on discount rates of 3 percent and 7 percent, respectively.  The exhibits present net benefits separately for the mandatory and voluntary provisions of the rule and also examine net benefits for the mandatory and voluntary provisions combined.  As indicated above, benefits could not be monetized for many of the rule's mandatory provisions.  Net benefits for these provisions are therefore presented as negative.  These negative values, however, do not reflect the benefits presented in Chapter 4 that EPA was unable to monetize.  In excluding these benefits, the negative values in the exhibits represent underestimates of the net benefits associated with the rule's mandatory provisions.  
For the voluntary provisions of the rule, this RIA estimates positive net benefits ranging from $5.5 to $8.9 million per year using a discount rate of 7 percent.  For both the low impact and high impact scenarios, the positive net benefits for these provisions reflect the net benefits associated with the intra-organizational transfers and episodic generation provisions.  As discussed above, organizations that opt into the former are expected to experience cost savings associated with reduced transportation and hazardous waste disposal costs.  The net benefits of the episodic generation provision are also expected to be much higher under the high impact scenario than the low impact scenario.  This difference reflects the assumption in this RIA (stated in Chapter 4) that 50 percent of episodic generators are assumed to meet the rule conditions for taking advantage of this provision (i.e., no more than two episodic events per year lasting no more than 60 days each) under the low impact scenario while all episodic generators are assumed to meet these conditions under the high impact scenario. 
EXHIBIT ES-8:  NET BENEFITS OF THE FINAL RULE ($2015 ANNUALIZED OVER 20 YEARS, USING A 3% DISCOUNT RATE)
                                  REQUIREMENT
                               LOW-END SCENARIO
                               HIGH-END SCENARIO
                               ANNUALIZED COSTS
                              ANNUALIZED BENEFITS
                                 NET BENEFITS
                               ANNUALIZED COSTS
                              ANNUALIZED BENEFITS
                                 NET BENEFITS
MANDATORY PROVISIONS OF THE FINAL RULE
Re-notification
                                                                      $480,000 
                                 Not monetized
                                      --
                                                                      $621,000 
                                 Not monetized
                                      --
Labeling
                                                                    $2,750,000 
                                                                               
                                                                               
                                                                    $5,450,000 
                                                                               
                                                                               
Closure
                                                                       $44,500 
                                                                               
                                                                               
                                                                    $2,330,000 
                                                                               
                                                                               
Emergency Response Preparedness
                                                                      $475,000 
                                                                               
                                                                               
                                                                      $666,000 
                                                                               
                                                                               
Transfer Facility
                                                                        $4,470 
                                                                               
                                                                               
                                                                        $8,280 
                                                                               
                                                                               
BR Requirements
                                                                        $7,100 
                                                                               
                                                                               
                                                                       $69,800 
                                                                               
                                                                               
Recycling
                                                                         $2,090
                                                                               
                                                                               
                                                                         $5,670
                                                                               
                                                                               
Prohibitions on Storage
                                                                            $0 
                                                                               
                                                                               
                                                                            $0 
                                                                               
                                                                               
Drip Pads and Containment Buildings
                                                                            $0 
                                                                      $856,000 
                                                                       $856,000
                                                                            $0 
                                                                      $859,000 
                                                                       $859,000
SUB-TOTAL: Mandatory Rule Provisions
                                                                    $3,760,000 
                                                                      $856,000 
                                                                   ($2,910,000)
                                                                     $9,150,000
                                                                      $859,000 
                                                                   ($8,290,000)
VOLUNTARY PROVISIONS OF THE FINAL RULE
Intra-organizational Transfers
                                                                    $1,640,000 
                                                                    $4,210,000 
                                                                    $2,570,000 
                                                                    $2,980,000 
                                                                    $6,940,000 
                                                                    $3,960,000 
Episodic Generation
                                                                      $260,000 
                                                                    $3,230,000 
                                                                    $2,970,000 
                                                                    $1,390,000 
                                                                    $6,550,000 
                                                                    $5,150,000 
Ignitable and Reactive Waste
                                                                           $60 
                                                                  Not monetized
                                                                          ($60)
                                                                      $105,000 
                                                                  Not monetized
                                                                     ($105,000)
SUB-TOTAL: Voluntary Rule Provisions
                                                                    $1,900,000 
                                                                    $7,440,000 
                                                                    $5,540,000 
                                                                    $4,480,000 
                                                                   $13,500,000 
                                                                    $9,010,000 
MANDATORY AND VOLUNTARY PROVISIONS OF THE FINAL RULE COMBINED
TOTAL: Mandatory and Voluntary Provisions Combined
                                                                    $5,660,000 
                                                                    $8,300,000 
                                                                    $2,630,000 
                                                                   $13,600,000 
                                                                   $14,300,000 
                                                                       $722,000
Notes:
All estimates are rounded to three significant digits and may not sum due to rounding.
EXHIBIT ES-9:  NET BENEFITS OF THE FINAL RULE ($2015 ANNUALIZED OVER 20 YEARS, USING A 7% DISCOUNT RATE)
                                  REQUIREMENT
                               LOW-END SCENARIO
                               HIGH-END SCENARIO
                               ANNUALIZED COSTS
                              ANNUALIZED BENEFITS
                                 NET BENEFITS
                               ANNUALIZED COSTS
                              ANNUALIZED BENEFITS
                                 NET BENEFITS
MANDATORY PROVISIONS OF THE FINAL RULE
Re-notification
                                                                       $507,000
                                 Not monetized
                                      --
                                                                       $656,000
                                 Not monetized
                                      --
Labeling
                                                                     $2,920,000
                                                                               
                                                                               
                                                                     $5,610,000
                                                                               
                                                                               
Closure
                                                                        $44,500
                                                                               
                                                                               
                                                                     $1,710,000
                                                                               
                                                                               
Emergency Response Preparedness
                                                                       $481,000
                                                                               
                                                                               
                                                                       $672,000
                                                                               
                                                                               
Transfer Facility
                                                                         $4,470
                                                                               
                                                                               
                                                                         $8,280
                                                                               
                                                                               
BR Requirements
                                                                         $7,240
                                                                               
                                                                               
                                                                        $71,100
                                                                               
                                                                               
Recycling
                                                                         $2,130
                                                                               
                                                                               
                                                                         $5,780
                                                                               
                                                                               
Prohibitions on Storage
                                                                             $0
                                                                               
                                                                               
                                                                             $0
                                                                               
                                                                               
Drip Pads and Containment Buildings
                                                                             $0
                                                                       $857,000
                                                                       $857,000
                                                                             $0
                                                                       $860,000
                                                                       $860,000
SUB-TOTAL: Mandatory Rule Provisions
                                                                     $3,960,000
                                                                       $857,000
                                                                   ($3,110,000)
                                                                     $8,740,000
                                                                       $860,000
                                                                   ($7,880,000)
VOLUNTARY PROVISIONS OF THE FINAL RULE
Intra-organizational Transfers
                                                                     $1,680,000
                                                                     $4,210,000
                                                                    $2,530,000 
                                                                     $3,050,000
                                                                     $6,940,000
                                                                    $3,890,000 
Episodic Generation
                                                                       $260,000
                                                                     $3,230,000
                                                                     $2,970,000
                                                                     $1,390,000
                                                                     $6,560,000
                                                                     $5,170,000
Ignitable and Reactive Waste
                                                                           $60 
                                                                  Not monetized
                                                                          ($60)
                                                                      $118,000 
                                                                  Not monetized
                                                                     ($118,000)
SUB-TOTAL: Voluntary Rule Provisions
                                                                     $1,940,000
                                                                     $7,450,000
                                                                     $5,510,000
                                                                     $4,560,000
                                                                    $13,500,000
                                                                     $8,940,000
MANDATORY AND VOLUNTARY PROVISIONS OF THE FINAL RULE COMBINED
TOTAL: Mandatory and Voluntary Provisions Combined
                                                                    $5,900,000 
                                                                     $8,300,000
                                                                     $2,400,000
                                                                   $13,300,000 
                                                                    $14,400,000
                                                                     $1,060,000
Notes:
All estimates are rounded to three significant digits and may not sum due to rounding.

ES.6 Equity Considerations and Other Impacts
As required by applicable statutes and executive orders, this RIA examines equity considerations and other regulatory concerns associated with the final rule.  Specifically, this RIA considers the following (discussed further in Chapter 6): 
 Regulatory planning and review: This action is a "significant regulatory action" in that it may raise novel legal or policy issues arising out of legal mandates, the President's priorities, or the principles set forth in the Executive Order.  Therefore, it was submitted to the Office of Management and Budget (OMB) for review.  
 Regulatory flexibility: EPA estimates that the final rule will not have significant economic impacts on a substantial number of small entities under the Regulatory Flexibility Act. 
 Unfunded mandates: Signed into law on March 22, 1995, the Unfunded Mandates Reform Act (UMRA) requires federal agencies, unless otherwise prohibited by law, to assess the effects of their regulatory actions on state, local, and tribal governments and on the private sector, to determine whether any final rulemaking may result in "any Federal mandate that may result in the expenditure by state, local, and tribal governments, in the aggregate, or by the private sector, of $100 million or more in any one year."  Based on the magnitude of the final rule's estimated cost impacts, the rule is not estimated to result in annual expenditures exceeding $100 million for either the private sector or state, local, and tribal governments in the aggregate.  
 Federalism: EPA estimates that the final rule will not have substantial direct effects on the states, on the relationship between the national government and the states, or on the distribution of power and responsibilities among the various levels of government.
 Tribal governments: EPA estimates that the final rule will not impose a substantial burden on tribal governments.
 Environmental justice: EPA does not expect that the final rule will result in disproportionately high or adverse impacts for minority or low-income populations.  Overall, the Agency anticipates that the rule will reduce any adverse effects associated with the management of hazardous waste, thus benefiting minority and low-income populations.  
 Children's health protection: The rule is not expected to result in a disproportionate adverse health impact on children.  
 Energy Impacts: The final rule is not expected to have a significant adverse effect on energy supply, distribution, or use.  In addition, no measurable adverse impacts are expected on energy prices or foreign supplies.
 Employment impacts: EPA qualitatively describes employment impacts as insufficient data are available to quantify the potential impact of the final rule on employment.  
CHAPTER 1  |  Introduction
1.1 Overview
This document presents EPA's analysis of the costs, benefits, and economic impacts of the Final Hazardous Waste Generator Improvements Rule.  This final rule has the dual purposes of enhancing protection of human health and the environment and improving the efficiency of the hazardous waste generator standards.  EPA is publishing this Regulatory Impact Assessment (RIA) in conjunction with the final rule.
1.2 Background and Need for Regulatory Action
Under the statutory authority of the Resource Conservation and Recovery Act (RCRA), EPA originally promulgated the hazardous waste generator regulatory program in 1980.  Since that time, the basic regulatory framework of the program has remained intact except for three major changes.  First, pursuant to the Hazardous and Solid Waste Amendments (HSWA) of 1984, the Agency established regulations in 1986 that distinguished between generators generating more than 100 kilograms and less than 1,000 kilograms of hazardous waste in a calendar month (small quantity generators, or SQGs) and generators generating 100 kilograms or less in a calendar month (very small quantity generators, or VSQGs).  Prior to the 1986 rule, VSQGs did not exist as a separate generator class, and all facilities generating less than 1,000 kilograms of hazardous waste in a calendar month were subject to the same requirements.  Second, and also as a result of HSWA, EPA established Land Disposal Restriction (LDR) regulations.  The Agency's LDR program established treatment standards for hazardous wastes, and specified requirements that generators, transporters, and owners or operators of treatment, storage, and disposal facilities (TSDFs) that manage restricted wastes destined for land disposal must meet.  Third, EPA modified the Uniform Hazardous Waste Manifest regulations in 2005 to standardize the content and appearance of the manifest form, make the forms available from a greater number of sources, and adopt new procedures for tracking certain types of hazardous waste shipments.
Over the course of the last 30 years, the Agency has become aware of ambiguities and gaps in the regulations, which, if corrected, could make the program more effective in protecting human health and the environment.  For example, current regulations do not require that hazardous waste container labels include information on the specific hazards of container contents or what risk these wastes could pose to human health and the environment when such waste is being accumulated on-site.
EPA has also become increasingly aware of certain inflexibilities in the generator regulations over the last 30 years.  For example, some generators, particularly those located in urban environments, may find it infeasible to meet the requirement that containers holding ignitable or reactive waste be placed at least 15 meters (~50 feet) back from the facility's property line.  In addition, current regulations require that a VSQG or SQG that experiences an episodic generation event resulting in the generation of more than 1,000 kilograms of hazardous waste in a calendar month comply with the regulatory requirements for large quantity generators (LQGs).  Requiring VSQGs or SQGs that rarely exceed their normal regulatory status to meet the full LQG requirements as a result of such episodic events may be burdensome.  To address these shortcomings in the current generator regulations, EPA is implementing several specific changes to the hazardous waste generator program.  These improvements are relatively minor on an individual basis yet address a wide range of issues.  In aggregate, the changes to the program are expected to significantly improve regulatory efficiency and provide further protection of human health and the environment.
1.3 Summary of the Final Rule
EPA is promulgating several changes to the hazardous waste generator regulations.  Specifically, EPA is  (1) revising different components of the hazardous waste regulatory program; (2) addressing gaps in the current regulations; (3) providing greater flexibility for hazardous waste generators to manage their hazardous waste in a cost-effective manner; (4) reorganizing the hazardous waste generator regulations to improve their usability among regulated facilities; and (5) making technical corrections and conforming changes to address inadvertent errors, remove obsolete programs, and improve the readability of the regulations.
Some provisions of the final rule represent substantive changes to the requirements with which hazardous waste generators must comply, while others are simply revisions or minor corrections unlikely to affect the activities of most individual generators.  This RIA focuses on the former, as these provisions are more likely to result in costs, benefits, and/or other economic impacts.  These specific provisions are summarized below.  While the majority of the requirements are mandatory, three provisions of the rule are intended to provide greater flexibility to certain classes of hazardous waste generators and are thus voluntary.  This section first describes the mandatory provisions of the rule, and then discusses the voluntary provisions.  For a detailed discussion of all the changes to the generator regulations that EPA is promulgating, please refer to the Preamble to the final rule.
 SQG re-notification:  To ensure that regulatory agencies have information on facilities generating hazardous waste, EPA is requiring that SQGs re-notify EPA of their hazardous waste generation activities every four years.  For each re-notification, a facility need only review its previous notification and either make changes if necessary or confirm that the information remains accurate.
 Marking and labeling of containers, tanks, and containment buildings for SQGs and LQGs:  Current regulation requires that SQGs and LQGs label containers and tanks with the words, "Hazardous Waste."  While this wording provides some information regarding a container's contents, it does not indicate the specific hazards associated with these contents or the risks that a waste may pose to human health and the environment.  EPA is therefore requiring that SQGs and LQGs mark containers and tanks with (1) the words "Hazardous Waste" and (2) an indication of the hazards of a container's contents (e.g., the applicable hazardous waste characteristics).  Similarly, EPA is also requiring that SQGs and LQGs mark containment buildings with (1) the words "Hazardous Waste" and (2) an indication of the associated hazards (e.g., the applicable hazardous waste characteristics). 
 LQG closure conditions:  EPA is strengthening the closure regulations for LQGs that accumulate hazardous wastes in containers in central accumulation areas (CAAs).  Specifically, EPA is requiring that if the generator cannot demonstrate that any contaminated soils can be practicably removed or decontaminated, then the generator must close the waste accumulation unit(s) and perform post-closure care in accordance with the closure and post-closure care requirements that apply to landfills (§ 265.310). In addition, for the purposes of closure, post-closure, and financial responsibility, such a waste accumulation unit is then considered to be a landfill, and the generator must meet all of the requirements for landfills specified in subparts G and H of part 265. 
Also related to closure, EPA is requiring LQGs to notify EPA or their authorized state within 30 days prior to closure.  EPA is also requiring that such generators subsequently notify within 90 days after closure that they have either clean closed or -- if they cannot clean close -- that they have closed as a landfill.  LQGs must also document in their operating record if they close any waste accumulation units prior to the facility closure.
 Strengthening of the preparedness, prevention, and emergency response conditions for LQGs:  To improve the ability of emergency response teams to respond to an emergency, EPA is requiring any that all new LQGs submit a quick reference guide to their contingency plan to emergency management authorities.  In addition, EPA is requiring any LQG that makes a change to its existing contingency plan to prepare and submit a quick reference guide to emergency responders. 
 Transfer facility requirements:  Transporters that store manifested shipments of hazardous waste in containers at a transfer facility for a period of ten days or less are not subject to the regulation under parts 264, 265, 267, 268, and 270.  However, EPA is changing the marking and labeling requirements for transporters using a transfer facility when consolidating the contents of two or more containers with the same hazardous waste into a new container, or when combining and consolidating two different hazardous wastes that are compatible with each other.  In this case, the transporter must label all containers with (1) the words "Hazardous Waste" and (2) the applicable EPA hazardous waste codes.
 Biennial reporting requirements:  EPA is requiring that LQGs report all of the hazardous waste that they generate for the entire reporting year, not just waste for the month(s) during which they were LQGs.  Current regulation at the Federal level is unclear on this issue, and a limited number of states currently require LQGs to report the amount of hazardous waste generated for only those months that they were LQGs.
 Recycling facility reporting requirements:  Under the existing regulations in CFR 261.6, which identifies the requirements for recyclable materials, certain classes of recycling facilities are exempt from the BR reporting requirements so long as they are not required to be permitted as a TSDF.  The final rulemaking adds the BR reporting requirements to CFR 261.6 (c) (2).
 Prohibitions on storage of restricted waste for TSDFs:  Consistent with the marking and labeling requirements for SQGs and LQGs, EPA is requiring that TSDFs mark containers holding hazardous waste with (1) the words "Hazardous Waste" and (2) an indication of the hazards of a container's contents.  Under existing regulations, TSDFs must already mark containers holding hazardous waste with a description of the contents of the container.
 Drip pad and containment building requirements:  Under the existing regulations, EPA has consistently interpreted the requirements for LQGs that accumulate hazardous waste on drip pads or in containment buildings for 90 days or less without a permit or interim status to also apply to SQGs.  Therefore, SQGs that use drip pads or containment buildings must comply with the LQG 90-day accumulation limit (as opposed to the SQG 180-day accumulation limit) as well as the requirements that apply to LQGs for personnel training, development of a full contingency plan, and biennial reporting.  Under the final rule, EPA believes a more effective and efficient approach is to require SQGs that accumulate hazardous waste in containment buildings to comply with the 90-day accumulation limit and SQGs that accumulate hazardous waste on drip pads to comply with the 180-day accumulation limit, but to otherwise comply with the less stringent requirements for SQGs.
 Intra-organization transfers of hazardous waste from VSQGs to LQGs (voluntary):  To afford greater flexibility to VSQGs, EPA is allowing VSQGs to send their hazardous waste voluntarily to an LQG under the ownership of the same organization, provided that both the VSQG(s) and LQG comply with certain conditions.  The VSQG conditions are as follows: 
 A participating VSQG must label containers with the words "VSQG Hazardous Waste" and an indication of the hazards of a container's contents. 
 VSQGs must comply with all applicable Department of Transportation regulations when sending their hazardous waste to an LQG. 
      The conditions for LQGs receiving hazardous waste from one or more VSQGs controlled by the same person include the following:
 LQGs must submit a notification to EPA or their authorized state identifying the names, addresses, and contact information for the VSQGs that will be transferring hazardous waste to the LQG.
 LQGs must maintain records of all hazardous waste received from VSQGs that include the name, address, and contact information for each VSQG, as well as information on the quantity of each waste shipment received.
 LQGs must mark shipments from VSQGs with the date the hazardous waste was received from the VSQG.
 LQGs must manage all incoming VSQG hazardous waste in compliance with the regulations applicable to their LQG status.
 Hazardous waste received from VSQGs must be included in the receiving LQG's BR submissions. 
 Generators that temporarily change generator status due to an episodic event (voluntary):  To provide greater flexibility to VSQGs and SQGs that generate much of their hazardous waste on an episodic basis, EPA is allowing a VSQG or an SQG to voluntarily maintain its existing regulatory status in the event of a planned or unplanned episodic event in which the facility generates a quantity of hazardous waste in a calendar month that would otherwise elevate the facility to a more stringent regulatory status.  To take advantage of this provision, an SQG or VSQG is subject to the following conditions:
 Limit of no more than one planned and one unplanned episodic event per calendar year (each lasting no more than 60 days);
 Notify EPA or the authorized state at least 30 calendar days prior to initiating a planned episodic event or within 72 hours after an unplanned episodic event;
 VSQGs must obtain a RCRA ID number;
 Accumulation standards: VSQGs must mark containers with the date the episodic event began; label containers "Episodic Hazardous Waste"; manage hazardous waste in a manner that minimizes the possibility of a fire, explosion, or release of hazardous waste; ensure that tanks are in good condition and compatible with the hazardous waste stored within; and identify an emergency coordinator for the duration of the event.  SQGs must mark the container or tank log book with the date the episodic event began; label the container or write in the tank log book "Episodic Hazardous Waste"; mark the container or write in the tank log book words that indicate the hazards of the contents; and comply with the applicable accumulation conditions in §262, subpart L.
 Hazardous waste generated from the episodic event must be managed on-site or shipped off-site via hazardous waste manifest to a permitted TSDF.  For purposes of analysis, this RIA assumes that VSQGs and SQGs would not seek to obtain a RCRA storage or treatment permit, but would instead ship their hazardous waste off-site to a permitted TSDF.
 Complete and maintain records that include (1) the beginning and end dates of the event, (2) a description of the event, (3) the types and quantities of hazardous wastes generated at the event, (4) a description of how the hazardous waste was managed, and (5) name(s) of hazardous waste transporters that transported the waste to a permitted TSDF.
 Special requirements for ignitable and reactive wastes (voluntary):  Current regulation requires that LQGs must locate containers holding ignitable or reactive waste at least 15 meters from the facility's property line.  In urban environments, LQGs may find it impossible to meet this requirement due to the relatively small footprint of many properties in these areas.  To provide flexibility to LQGs, EPA will allow LQGs to voluntarily apply for a facility-specific waiver from their primary emergency authority if they are unable to meet the hazardous waste accumulation property line requirement.
1.4 Report Organization
To support development of the final rule, EPA developed this RIA examining the rule's costs, benefits, and other economic impacts.  The data, methods, and results of this analysis are presented in the following chapters:
 Chapter 2: Characterization of the Regulated Universe.  This chapter describes the universe of facilities potentially affected by the rule.  Specifically, this chapter presents EPA's estimates of the number of LQGs, SQGs, and VSQGs in the United States and its territories, outlines the quantity of hazardous waste generated by these facilities, and characterizes the management of this waste across various management methods.  
 Chapter 3: Assessment of Costs.  Chapter 3 includes EPA's assessment of the rule's cost impacts.  This chapter (1) identifies portions of the generator universe affected by individual rule provisions, (2) characterizes the regulatory baseline, (3) describes the data and methods employed for the assessment of the rule's cost impacts, and (4) presents the results of the cost analysis.
 Chapter 4: Assessment of Benefits.  After presenting the rule's cost impacts, the focus shifts to EPA's assessment of the rule's benefits in Chapter 4.  To the extent possible, these benefits are quantified.  Benefits that EPA was unable to quantify are addressed qualitatively.
 Chapter 5: Comparison of Costs and Benefits.  To synthesize the results presented in Chapters 3 and 4 and help readers understand the rule's benefits in the context of its costs, and vice versa, this RIA includes a brief chapter comparing the costs and benefits of the final rule.
 Chapter 6: Equity Considerations and Other Impacts.  This chapter assesses distributional and other impacts of the final rule, including impacts to small entities, environmental justice implications, children's health, impacts to Tribal Governments, energy use and distribution effects resulting from the rule, and joint impacts with other rules.
CHAPTER 2  |  Potentially Impacted Universe
2.1 Introduction
This chapter provides an overview of the universe of facilities that may be potentially affected by the final Hazardous Waste Generator Improvements Rule.  The rule may affect a wide range of facility types across a number of industries.  The information in this chapter provides context for the analysis of the costs and benefits associated with the final rule.  The specific information presented in this chapter includes the following:
 Number of facilities affected by the final rule: The costs and benefits of the final rule depend significantly on the number of hazardous waste generators in the U.S.  Using data compiled at the national and state level, this chapter provides estimates of the number of large quantity generators (LQGs), small quantity generators (SQGs), and very small quantity generators (VSQGs) in the U.S. 
 Hazardous waste generation among affected facilities: The impacts associated with some provisions of the rule depend on the amount of hazardous waste generated by affected facilities.  This chapter presents separate estimates of hazardous waste generation on a per facility basis for LQGs, SQGs, and VSQGs.
 Number of waste streams generated per facility: The costs and benefits of some rule provisions depend not only on the amount of hazardous waste generated (i.e., tonnage) but also the number of waste streams generated.  Similar to hazardous waste generation quantities, this RIA estimates the number of waste streams per generator on a per facility basis for LQGs, SQGs, and VSQGs.
 Management methods: To provide additional context for the facilities affected by the rule, this chapter also summarizes how generators manage their hazardous waste (e.g., incineration, land treatment, etc.).
2.2 Universe of Facilities Affected by the Final Rule
This section characterizes those establishments in the United State that are generators of RCRA hazardous waste.  As described in more detail in Chapter 3, the cost of the final rule for individual facilities will depend, in part, on their generator status under RCRA (i.e., LQG, SQG, or VSQG).  Therefore, to assess the rule's cost impacts, this RIA first estimates the count of potentially affected facilities within each of the generator status categories.  Exhibit 2-1 describes the generation thresholds for LQGs, SQGs, and VSQGs.

EXHIBIT 2-1:  RCRA SUBTITLE C HAZARDOUS WASTE GENERATION THRESHOLDS[1]
                                     VSQG
                                      SQG
                                      LQG
 Less than or equal to 100 kg of hazardous waste per month, and 
 Less than or equal to 1 kg of acute hazardous waste per month.
 Greater than 100 kg and less than 1,000 kg of hazardous waste per calendar month, and
 Less than or equal to 1 kg of acute hazardous waste per month.
 Greater than or equal to 1,000 kg of hazardous waste in a calendar month, or
 Greater than 1 kg of acute hazardous waste per month.
Notes:
 Any facility that generates greater than a total of 100 kilograms of any residue or contaminated soil, waste, or other debris resulting from the clean-up of a spill, into or on any land or water, of any acute hazardous wastes listed in §§ 261.31, or 261.33(e) would be considered an LQG.

There is considerable uncertainty regarding the number of facilities that generate hazardous waste in the United States and its territories.  The LQG universe is relatively well defined because LQGs are required to report their hazardous waste generation on a biennial basis to the EPA and/or state regulatory agencies.  SQGs are required to submit a one-time notification of their hazardous waste generation activity to EPA in order to obtain a RCRA ID for purposes of disposing hazardous waste, but they are not required to re-notify EPA of subsequent changes to their activities.  VSQGs are not required to notify nor report their hazardous waste generation to EPA.  While there are very limited to no Federal reporting requirements for SQGs and VSQGs, some states have hazardous waste reporting requirements for these facility types.  The remainder of this section describes the methodology used to estimate the number of facilities that may be affected by the final rule by generator status category for LQGs, SQGs, and VSQGs.  
This RIA relies primarily on EPA's BR database and EPA's RCRAInfo database to estimate the number LQGs and SQGs in the potentially affected universe.  The BR database is the Agency's primary repository for waste generation and management information reported by LQGs and some SQGs, while RCRAInfo is the program management database that EPA uses to maintain records related to the RCRA program.  Both databases are based on information reported by state agencies, and they represent the most comprehensive information sources available on generators of hazardous waste.  
2.2.1 Estimating the Number of LQGs
This RIA relies on the BR database to estimate the number of LQGs that may be affected by the final rule.  Based on the 2013 BR data submissions by state agencies, EPA estimates that there are 20,771 LQG facilities in the United States.  More than half of the LQGs nationwide are located in just eight states: New York, California, Pennsylvania, Ohio, Texas, Illinois, New Jersey, and Indiana.  Geographically, LQGs are heavily concentrated in the Mid-Atlantic, the Midwest, and the Pacific Coast.  However, the number of LQGs varies considerably by state.  New York has the largest number of LQGs (3,095), while Wyoming has the smallest (22).
2.2.2 Estimating the Number of SQGs
When a facility determines for the first time they have generated the SQG amount of hazardous waste in a single calendar month, they are required to notify State agencies and EPA of their SQG regulatory status to obtain a RCRA ID to manage that hazardous waste.  However, they are not required to re-notify EPA of subsequent changes in their generator status, address, ownership, or operating status (e.g., whether they have closed).  Consequently, there is no way to determine if the status of an SQG has changed over time.  SQGs are also not subject to Federal requirements for reporting hazardous waste generation to EPA on a regular basis (i.e., submitting BR reports).
Despite the lack of data reported by SQGs, some SQG information is available in the BR database, as TSDFs are required to submit a waste received (WR) form indicating any facilities (including SQGs) that shipped them hazardous waste with a hazardous waste manifest.  The WR form includes the RCRA ID of the facility that shipped the hazardous waste to the TSDF along with information about the type and quantity of hazardous waste.  Based on data in the WR form, this RIA develops two approaches to estimate the universe of SQGs that may be affected by the final rule.  The first approach yields a low-end estimate of the number of SQGs, while the second provides a high-end estimate.  Both approaches are described below. 
Low-end Estimate of the Number of SQGs
To derive a low-end estimate of the number of SQGs, EPA relied on information in the 2013 BR and RCRAInfo databases.  Specifically, EPA used the WR form in the BR database to identify all facilities that shipped hazardous waste off-site to a TSDF in 2013 and compared this list against the Site ID form in RCRAInfo to identify active SQGs in 2013.  EPA then also included any new SQGs that notified after July 1 and, therefore, did not have to ship their hazardous waste off-site to a TSDF in 2013.  Furthermore, as part of EPA's data collection effort, several states provided information on the number of SQGs statewide.  Therefore, where state-level data were provided, EPA relied on this information rather than estimates derived from the BR and RCRAInfo databases.  Using this approach, EPA developed a low-end estimate of approximately 49,900 SQGs in the United States and its territories.  EPA considers this a low end estimate because it may not capture SQGs that manage hazardous waste on-site or shipments from SQGs that TSDFs failed to report in the BR database.  
High-end Estimate of the Number of SQGs
Due to the uncertainty described above, EPA used an alternative approach to derive a high-end estimate for the number of SQGs.  This approach is similar to the methodology employed in deriving the low-end estimate, but instead uses WR forms from any of the years 2009, 2011, or 2013 to identify any SQGs that shipped hazardous waste off-site in any of those three BR cycles.  EPA then also included any new SQGs that notified after July 1 and, therefore, did not have to ship their hazardous waste off-site to a TSDF in 2013.  This yields an estimate of the number of facilities that were SQGs sometime between 2009 and 2013.  Because some facilities may have been SQGs for one of these years but not all years, this approach may lead to overestimation of the number of SQGs.  Due to the potential for overestimation, the RIA uses this approach to develop the high-end estimate for SQGs.  EPA used this approach for states from which no SQG counts were obtained, but continued to rely on the state estimates that were obtained otherwise.  Using this alternative approach, EPA developed a high-end estimate of approximately 64,300 SQGs in the United States and its territories.
2.2.3 Estimating the Number of VSQGs
Estimating the number of VSQGs nationwide is complicated by the fact that EPA and most states do not have mandatory notification or reporting requirements for VSQGs.  To estimate the size of the VSQG universe, this RIA extrapolates from the limited data collected from nine states.   These states are located across the country, providing broad geographic representation across different regions and reflecting a mix of large and small states.  Using the data for these nine states, EPA's initial step in estimating the number of VSQGs nationwide was to compile VSQG counts for each of the nine states.  EPA then calculated the ratio of (1) VSQGs to SQGs and (2) VSQGs to LQGs in aggregate across the nine states.  Exhibit 2-2 summarizes the data for each state and the corresponding ratio values developed.  As shown in the exhibit, these ratios vary considerably across states.
For states where data on the number of VSQGs are unavailable, the ratios calculated in the last row of Exhibit 2-2 (7.3 and 25.9 ratio of VSQGs to SQGs and LQGs respectively) are multiplied by the number of SQGs and LQGs in the state to estimate low-end and high-end estimates of the number of VSQGs.  Specifically, this RIA estimates the low-end VSQG value for each state as the lower of (a) the product of the low-end SQG estimate for that state and the VSQG-to-SQG ratio in Exhibit 2-2 and (b) the product of the LQG estimate for the state and the VSQG-to-LQG ratio in Exhibit 2-2.  Similarly, the high-end VSQG estimate for a given state is estimated as the higher of (a) the high-end SQG estimate for the state multiplied by the VSQG-to-SQG ratio in Exhibit 2-2 and (b) the product of the LQG estimate for the state and the VSQG-to-LQG ratio in Exhibit 2-2.
Using the methodology described above, EPA estimates that there are between approximately 353,000 and 592,000 VSQGs in the United States.  Therefore, EPA estimates that the combined total number of hazardous waste generators is between approximately 424,000 and 677,000.  Exhibit 2-3 reports the total number of LQGs, SQGs, and VSQGs by State.  
EXHIBIT 2-2: NUMBER OF VSQG FACILITIES BY STATE AND CALCULATION OF RATIOS USED IN EXTRAPOLATION FOR NATIONAL ESTIMATES
                                     State
                                      [A]
                               Number of LQGs[1]
                                      [B]
                               Number of SQGs[2]
                                      [C]
                              Number of VSQGs[2]
                                      [D]
                            Ratio of VSQGs to SQGs
                                    [E=D/C]
                            Ratio of VSQGs to LQGs
                                    [F=D/B]
                                       
                                       

                                       
                                       
                                       
Arkansas
                                      101
                                      275
                                     1,383
                                      5.0
                                     13.7
Florida
                                      386
                                     3,700
                                    16,800
                                      4.5
                                     43.5
Maine
                                      87
                                      319
                                     3,804
                                     11.9
                                     43.7
Massachusetts
                                      415
                                     2,596
                                    15,426
                                      5.9
                                     37.2
Minnesota
                                      340
                                     1,437
                                    20,910
                                     14.6
                                     61.5
New Hampshire
                                      134
                                      201
                                     1,940
                                      9.7
                                     14.5
New Jersey
                                      711
                                      631
                                     6,859
                                     10.9
                                      9.6
Washington
                                      456
                                      617
                                     1,541
                                      2.5
                                      3.4
Wisconsin
                                      424
                                     1,080
                                    10,442
                                      9.7
                                     24.6
TOTAL
                                     3,054
                                    10,856
                                    79,105
                                      7.3
                                     25.9
Notes:
 U.S. EPA, National Biennial RCRA Hazardous Waste Report (based on analysis of 2013 BR flat files). Documents and data are available at ftp://ftp.epa.gov/rcrainfodata/br_2013/.
 SQG and VSQG estimates for Arkansas, Florida, Maine, New Hampshire, New Jersey, Washington, and Wisconsin reflect data collected by EPA and provided via email on December 18th, 2015. Massachusetts estimates reflect data from "List of Massachusetts Hazardous Waste Generators and Their IDs" accessed at http://www.mass.gov/eea/agencies/massdep/recycle/hazardous/hwgen.html on December 28, 2015. Minnesota estimates reflect data provided by Regina Small of the Minnesota Pollution Control Agency on January 15, 2016.

EXHIBIT 2-3:  UNIVERSE OF FACILITIES POTENTIALLY AFFECTED BY THE Final RULE BY STATE AND GENERATOR STATUS
                                   STATE[A]
                                Number of LQGs
                                      [B]
                                Number of SQGs
                              Number of VSQGs[1]
                          TOTAL NUMBER OF GENERATORS
LOW-END
                                      [C]
                                   High-End
                                      [D]
                                    Low-End
                                      [E]
                                   High-End
                                      [F]
                                    Low-End
                                      [G]
                                   High-End
                                      [H]
Alabama
                                                                             27
                                                                             95
                                                                            148
                                                                            692
                                                                          1,078
                                                                            814
                                                                          1,253
Alaska
                                                                            386
                                                                            625
                                                                            674
                                                                          4,554
                                                                          9,998
                                                                          5,565
                                                                         11,058
Arizona
                                                                            101
                                                                            275
                                                                            275
                                                                          1,383
                                                                          1,383
                                                                          1,759
                                                                          1,759
Arkansas
                                                                            210
                                                                            582
                                                                            860
                                                                          4,241
                                                                          6,267
                                                                          5,033
                                                                          7,337
California
                                                                          2,775
                                                                          7,031
                                                                         11,722
                                                                         51,233
                                                                         85,415
                                                                         61,039
                                                                         99,912
Colorado
                                                                            108
                                                                            428
                                                                            453
                                                                          2,797
                                                                          3,301
                                                                          3,333
                                                                          3,862
Connecticut
                                                                            416
                                                                            726
                                                                          1,026
                                                                          5,290
                                                                         10,775
                                                                          6,432
                                                                         12,217
Delaware
                                                                             36
                                                                             65
                                                                             67
                                                                            474
                                                                            932
                                                                            575
                                                                          1,035
District of Columbia
                                                                             60
                                                                            168
                                                                            214
                                                                          1,224
                                                                          1,559
                                                                          1,452
                                                                          1,833
Florida
                                                                            386
                                                                          3,700
                                                                          3,700
                                                                         16,800
                                                                         16,800
                                                                         20,886
                                                                         20,886
Georgia
                                                                            517
                                                                          1,017
                                                                          1,161
                                                                          7,411
                                                                         13,391
                                                                          8,945
                                                                         15,069
Guam
                                                                              9
                                                                              7
                                                                             13
                                                                             51
                                                                            233
                                                                             67
                                                                            255
Hawaii
                                                                             23
                                                                            138
                                                                            191
                                                                            596
                                                                          1,392
                                                                            757
                                                                          1,606
Idaho
                                                                            144
                                                                            694
                                                                            767
                                                                          3,730
                                                                          5,589
                                                                          4,568
                                                                          6,500
Illinois
                                                                             23
                                                                            101
                                                                            104
                                                                            596
                                                                            758
                                                                            720
                                                                            885
Indiana
                                                                            836
                                                                          3,036
                                                                          4,787
                                                                         21,654
                                                                         34,882
                                                                         25,526
                                                                         40,505
Iowa
                                                                            710
                                                                            966
                                                                            975
                                                                          7,039
                                                                         18,390
                                                                          8,715
                                                                         20,075
Kansas
                                                                            213
                                                                            569
                                                                            572
                                                                          4,146
                                                                          5,517
                                                                          4,928
                                                                          6,302
Kentucky
                                                                            297
                                                                            427
                                                                            427
                                                                          3,111
                                                                          7,693
                                                                          3,835
                                                                          8,417
Louisiana
                                                                            368
                                                                            855
                                                                          1,239
                                                                          6,230
                                                                          9,532
                                                                          7,453
                                                                         11,139
Maine
                                                                            415
                                                                          2,596
                                                                          2,596
                                                                         15,426
                                                                         15,426
                                                                         18,437
                                                                         18,437
Maryland
                                                                            469
                                                                            921
                                                                          1,590
                                                                          6,711
                                                                         12,148
                                                                          8,101
                                                                         14,207
Massachusetts
                                                                             87
                                                                            319
                                                                            319
                                                                          3,804
                                                                          3,804
                                                                          4,210
                                                                          4,210
Michigan
                                                                            493
                                                                          1,856
                                                                          1,991
                                                                         12,770
                                                                         14,508
                                                                         15,119
                                                                         16,992
Minnesota
                                                                            340
                                                                          1,437
                                                                          1,437
                                                                         20,910
                                                                         20,910
                                                                         22,687
                                                                         22,687
Mississippi
                                                                            330
                                                                          1,385
                                                                          1,663
                                                                          8,548
                                                                         12,118
                                                                         10,263
                                                                         14,111
Missouri
                                                                            164
                                                                            252
                                                                            272
                                                                          1,836
                                                                          4,248
                                                                          2,252
                                                                          4,684
Montana
                                                                             62
                                                                             92
                                                                             97
                                                                            670
                                                                          1,606
                                                                            824
                                                                          1,765
Navajo Nation
                                                                            675
                                                                          1,343
                                                                          1,616
                                                                          9,786
                                                                         17,484
                                                                         11,804
                                                                         19,775
Nebraska
                                                                             26
                                                                             77
                                                                             83
                                                                            561
                                                                            673
                                                                            664
                                                                            782
Nevada
                                                                              0
                                                                              3
                                                                              4
                                                                             22
                                                                             29
                                                                             25
                                                                             33
New Hampshire
                                                                             69
                                                                            226
                                                                            296
                                                                          1,647
                                                                          2,157
                                                                          1,942
                                                                          2,522
New Jersey
                                                                            134
                                                                            201
                                                                            201
                                                                          1,940
                                                                          1,940
                                                                          2,275
                                                                          2,275
New Mexico
                                                                            711
                                                                            631
                                                                            631
                                                                          6,859
                                                                          6,859
                                                                          8,201
                                                                          8,201
New York
                                                                             41
                                                                            200
                                                                            250
                                                                          1,062
                                                                          1,822
                                                                          1,303
                                                                          2,113
North Carolina
                                                                              1
                                                                              7
                                                                             10
                                                                             26
                                                                             73
                                                                             34
                                                                             84
North Dakota
                                                                             94
                                                                            233
                                                                            279
                                                                          1,698
                                                                          2,435
                                                                          2,025
                                                                          2,808
Northern Marianas
                                                                          3,095
                                                                          2,998
                                                                          4,063
                                                                         21,846
                                                                         80,167
                                                                         27,939
                                                                         87,325
Ohio
                                                                            975
                                                                          1,978
                                                                          3,082
                                                                         14,413
                                                                         25,255
                                                                         17,366
                                                                         29,312
Oklahoma
                                                                            170
                                                                            382
                                                                            458
                                                                          2,784
                                                                          4,403
                                                                          3,336
                                                                          5,031
Oregon
                                                                            210
                                                                            270
                                                                            271
                                                                          1,967
                                                                          5,439
                                                                          2,447
                                                                          5,920
Pennsylvania
                                                                          1,004
                                                                          2,777
                                                                          4,157
                                                                         20,235
                                                                         30,291
                                                                         24,016
                                                                         35,452
Puerto Rico
                                                                             94
                                                                            134
                                                                            167
                                                                            976
                                                                          2,435
                                                                          1,204
                                                                          2,696
Rhode Island
                                                                            103
                                                                            930
                                                                          1,445
                                                                          2,668
                                                                         10,529
                                                                          3,701
                                                                         12,077
South Carolina
                                                                            386
                                                                            636
                                                                            648
                                                                          4,634
                                                                          9,998
                                                                          5,656
                                                                         11,032
South Dakota
                                                                             31
                                                                            151
                                                                            246
                                                                            803
                                                                          1,793
                                                                            985
                                                                          2,070
Tennessee
                                                                            363
                                                                            638
                                                                            677
                                                                          4,649
                                                                          9,402
                                                                          5,650
                                                                         10,442
Texas
                                                                              0
                                                                              2
                                                                              2
                                                                             15
                                                                             15
                                                                             17
                                                                             17
Trust Territories
                                                                            970
                                                                          1,836
                                                                          2,041
                                                                         13,378
                                                                         25,125
                                                                         16,184
                                                                         28,136
Utah
                                                                            127
                                                                            226
                                                                            247
                                                                          1,647
                                                                          3,290
                                                                          2,000
                                                                          3,664
Vermont
                                                                            397
                                                                          1,312
                                                                          1,671
                                                                          9,560
                                                                         12,176
                                                                         11,269
                                                                         14,244
Virgin Islands
                                                                              1
                                                                              6
                                                                             13
                                                                             26
                                                                             95
                                                                             33
                                                                            109
Virginia
                                                                             43
                                                                            175
                                                                            233
                                                                          1,114
                                                                          1,698
                                                                          1,332
                                                                          1,974
Washington
                                                                            456
                                                                            617
                                                                            617
                                                                          1,541
                                                                          1,541
                                                                          2,614
                                                                          2,614
West Virginia
                                                                            424
                                                                          1,080
                                                                          1,080
                                                                         10,442
                                                                         10,442
                                                                         11,946
                                                                         11,946
Wisconsin
                                                                            144
                                                                            363
                                                                            364
                                                                          2,645
                                                                          3,730
                                                                          3,152
                                                                          4,238
Wyoming
                                                                             22
                                                                             92
                                                                            118
                                                                            570
                                                                            860
                                                                            684
                                                                          1,000
TOTAL
                                                                         20,771
                                                                         49,887
                                                                         64,310
                                                                        353,441
                                                                        591,809
                                                                        424,099
                                                                        676,890
Notes: 
 The VSQG values presented in this exhibit may not exactly match the product of the SQG (or LQG) values multiplied by the ratios in Exhibit 2-2 due to rounding.

Exhibits 2-4(A) and 2-4(B) show the geographic distribution of the universe of facilities potentially affected by the final rule across the United States using the low-end and high-end estimates.  
EXHIBIT 2-4(A): GEOGRAPHIC DISTRIBUTION OF FACILITIES USING LOW-END ESTIMATE (2013)
EXHIBIT 2-4(B): GEOGRAPHIC DISTRIBUTION OF FACILITIES USING HIGH-END ESTIMATE (2013)
2.3 Hazardous Waste Generation of Potentially Affected Facilities
This section characterizes the hazardous waste generation of facilities in the regulated universe.  The overall tonnages of hazardous waste and the number of waste streams are relevant to estimating the cost of managing this waste in compliance with the provisions of the final rule.  The methodology for estimating the quantities of hazardous waste generation varies by generator status.  Where possible, this RIA relies on generation data from EPA's 2013 BR database.  The BR database is used to develop annual aggregate and per facility generation estimates for LQG facilities.  For other facility types, however, the data available from the BR database are insufficient to develop nationwide hazardous waste generation estimates.  Consequently, this RIA derives generation estimates for SQGs and VSQGs by combining the limited data available in the BR database with facility-level generation data obtained from individual states. 
2.3.1 LQG Hazardous Waste Generation
EPA's 2013 BR database is the primary data source for estimating hazardous waste generation for LQG facilities.  In 2013, LQGs generated approximately 35.2 million tons of hazardous waste in aggregate.  Combining this value with the LQG facility count presented above suggests that LQGs, on average, generate approximately 1,692 tons of hazardous waste per facility per year.  The BR data also suggest that LQGs reported an average of 13 different waste streams per facility, with a few large facilities reporting several thousand waste streams.  The 50 largest LQGs generated 29.2 million tons of hazardous waste, or 83 percent of the total amount reported in the 2013 BR.
Exhibit 2-5 reports the overall and average per facility hazardous waste quantities generated on an annual basis as well as the average number of waste streams per facility for LQGs by state.  As shown in the exhibit, the Gulf States of Texas, Louisiana, and Mississippi account for approximately 63 percent of all hazardous waste generated by LQGs in the United States.  In contrast, New York and California, which have the largest number of LQG facilities, collectively account for just 5 percent of all hazardous waste generated by LQGs. 
Exhibit 2-6 provides information on the distribution of LQGs by industry.  Facilities in the BR database may be characterized by one or several North American Industry Classification System (NAICS) codes.  To avoid double-counting, this RIA uses the first (or primary) NAICS code listed in the BR database for a facility.  As shown in the exhibit, the five largest industries (in terms of hazardous waste generation) account for approximately 95 percent of all hazardous waste generated by LQGs, while comprising less than 20 percent of all LQGs.  These industries include: chemical manufacturing (NAICS 325); petroleum and coal products manufacturing (NAICS 324); waste management and remediation services (NAICS 562); primary metal manufacturing (NAICS 331); and mining (NAICS 212).  In terms of the number of generators, the largest industries -- accounting for approximately 50 percent of the LQG universe -- include: health and personal care stores (NAICS 446); chemical manufacturing (NAICS 325); utilities (NAICS 221); fabricated metal product manufacturing (NAICS 332); and general merchandise stores (NAICS 452).
Exhibit 2-5:  LQG Hazardous Waste Quantities and Number of Waste Streams Generated by State[1] (2013)
                                   STATE[A]
                      NUMBER OF FACILITIES IN BR DATA[B]
                   TOTAL HAZARDOUS WASTE GENERATED(TONS) [C]
                      PERCENTAGE OF TOTAL HAZARDOUS WASTE
                                      [D]
              HAZARDOUS WASTE GENERATED PER FACILITY(TONS)[E=C/B]
                AVERAGE NUMBER OF WASTE STREAMS PER FACILITY[F]
Alabama
                                                                            386
                                                                        708,436
                                                                           2.0%
                                                                          1,835
                                                                             13
Alaska
                                                                             27
                                                                          2,272
                                                                           0.0%
                                                                             84
                                                                             20
Arizona
                                                                            210
                                                                         73,948
                                                                           0.2%
                                                                            352
                                                                             17
Arkansas
                                                                            101
                                                                        405,592
                                                                           1.2%
                                                                          4,016
                                                                             27
California
                                                                          2,775
                                                                      1,519,549
                                                                           4.3%
                                                                            548
                                                                             13
Colorado
                                                                            108
                                                                         37,000
                                                                           0.1%
                                                                            343
                                                                             60
Connecticut
                                                                            416
                                                                         19,666
                                                                           0.1%
                                                                             47
                                                                             12
Delaware
                                                                             60
                                                                         14,886
                                                                           0.0%
                                                                            248
                                                                             40
District of Columbia
                                                                             36
                                                                            551
                                                                           0.0%
                                                                             15
                                                                              8
Florida
                                                                            386
                                                                        107,387
                                                                           0.3%
                                                                            278
                                                                             16
Georgia
                                                                            517
                                                                        280,866
                                                                           0.8%
                                                                            543
                                                                             11
Guam
                                                                              9
                                                                            165
                                                                           0.0%
                                                                             18
                                                                             70
Hawaii
                                                                             23
                                                                        466,293
                                                                           1.3%
                                                                         20,274
                                                                             35
Idaho
                                                                             23
                                                                          4,624
                                                                           0.0%
                                                                            201
                                                                             28
Illinois
                                                                            836
                                                                        613,053
                                                                           1.7%
                                                                            733
                                                                             10
Indiana
                                                                            710
                                                                      1,026,708
                                                                           2.9%
                                                                          1,446
                                                                             13
Iowa
                                                                            144
                                                                         51,095
                                                                           0.1%
                                                                            355
                                                                              9
Kansas
                                                                            213
                                                                      1,349,985
                                                                           3.8%
                                                                          6,338
                                                                              9
Kentucky
                                                                            297
                                                                        194,945
                                                                           0.6%
                                                                            656
                                                                             27
Louisiana
                                                                            368
                                                                      4,789,750
                                                                          13.6%
                                                                         13,016
                                                                             11
Maine
                                                                             87
                                                                          3,048
                                                                           0.0%
                                                                             35
                                                                              8
Maryland
                                                                            469
                                                                         47,995
                                                                           0.1%
                                                                            102
                                                                              9
Massachusetts
                                                                            415
                                                                         29,285
                                                                           0.1%
                                                                             71
                                                                             14
Michigan
                                                                            493
                                                                        627,889
                                                                           1.8%
                                                                          1,274
                                                                             17
Minnesota
                                                                            340
                                                                        349,886
                                                                           1.0%
                                                                          1,029
                                                                              9
Mississippi
                                                                            164
                                                                      1,590,017
                                                                           4.5%
                                                                          9,695
                                                                              7
Missouri
                                                                            330
                                                                        281,820
                                                                           0.8%
                                                                            854
                                                                             11
Montana
                                                                             62
                                                                          7,065
                                                                           0.0%
                                                                            114
                                                                              9
Navajo Nation
                                                                              1
                                                                              3
                                                                           0.0%
                                                                              3
                                                                              4
Nebraska
                                                                             69
                                                                         29,225
                                                                           0.1%
                                                                            424
                                                                             22
Nevada
                                                                             94
                                                                         14,688
                                                                           0.0%
                                                                            156
                                                                             13
New Hampshire
                                                                            134
                                                                          3,293
                                                                           0.0%
                                                                             25
                                                                             42
New Jersey
                                                                            711
                                                                        396,104
                                                                           1.1%
                                                                            557
                                                                             48
New Mexico
                                                                             41
                                                                        889,256
                                                                           2.5%
                                                                         21,689
                                                                             87
New York
                                                                          3,095
                                                                        234,378
                                                                           0.7%
                                                                             76
                                                                              4
North Carolina
                                                                            675
                                                                         77,163
                                                                           0.2%
                                                                            114
                                                                             22
North Dakota
                                                                             26
                                                                        375,751
                                                                           1.1%
                                                                         14,452
                                                                              6
Northern Marianas
                                                                              0
                                                                              0
                                                                           0.0%
                                                                              0
                                                                              0
Ohio
                                                                            975
                                                                      1,539,561
                                                                           4.4%
                                                                          1,579
                                                                             16
Oklahoma
                                                                            170
                                                                        100,331
                                                                           0.3%
                                                                            590
                                                                              7
Oregon
                                                                            210
                                                                         56,930
                                                                           0.2%
                                                                            271
                                                                             10
Pennsylvania
                                                                          1,004
                                                                        257,716
                                                                           0.7%
                                                                            257
                                                                              8
Puerto Rico
                                                                             94
                                                                         35,902
                                                                           0.1%
                                                                            382
                                                                             22
Rhode Island
                                                                            103
                                                                          6,083
                                                                           0.0%
                                                                             59
                                                                             17
South Carolina
                                                                            386
                                                                        176,950
                                                                           0.5%
                                                                            458
                                                                              8
South Dakota
                                                                             31
                                                                          1,460
                                                                           0.0%
                                                                             47
                                                                              7
Tennessee
                                                                            363
                                                                         97,020
                                                                           0.3%
                                                                            267
                                                                              6
Texas
                                                                            970
                                                                     15,624,473
                                                                          44.4%
                                                                         16,108
                                                                              7
Trust Territories
                                                                              0
                                                                              0
                                                                           0.0%
                                                                              0
                                                                              0
Utah
                                                                            127
                                                                         40,359
                                                                           0.1%
                                                                            318
                                                                             28
Vermont
                                                                             43
                                                                          3,323
                                                                           0.0%
                                                                             77
                                                                             12
Virgin Islands
                                                                              1
                                                                         10,064
                                                                           0.0%
                                                                         10,064
                                                                             17
Virginia
                                                                            397
                                                                         58,641
                                                                           0.2%
                                                                            148
                                                                             12
Washington
                                                                            456
                                                                        258,975
                                                                           0.7%
                                                                            568
                                                                             16
West Virginia
                                                                            144
                                                                         52,027
                                                                           0.1%
                                                                            361
                                                                             10
Wisconsin
                                                                            424
                                                                        204,520
                                                                           0.6%
                                                                            482
                                                                              9
Wyoming
                                                                             22
                                                                          3,493
                                                                           0.0%
                                                                            159
                                                                             13
TOTAL[2]
                                                                         20,771
                                                                     35,151,466
                                                                         100.0%
                                                                          1,692
                                                                             13
Notes:
 Data from U.S. EPA, National Biennial RCRA Hazardous Waste Report (based on analysis of 2013 BR flat files). Documents and data are available at ftp://ftp.epa.gov/rcrainfodata/br_2013/.
 The values in Columns E and F are calculated on a per facility basis as the sum of values across all generators divided by the total number of generators from Column B.

EXHIBIT 2-6:  LQG HAZARDOUS WASTE QUANTITIES AND NUMBER OF WASTE STREAMS GENERATED BY INDUSTRY (2013)
                                   NAICS[A]
                               NAICS DESCRIPTION
                                      [B]
                      NUMBER OF FACILITIES IN BR DATA[C]
                   TOTAL HAZARDOUS WASTE GENERATED(TONS) [D]
                      PERCENTAGE OF TOTAL HAZARDOUS WASTE
                                      [E]
              HAZARDOUS WASTE GENERATED PER FACILITY(TONS)[F=D/C]
                AVERAGE NUMBER OF WASTE STREAMS PER FACILITY[G]
                                      325
Chemical manufacturing
                                                                          2,239
                                                                     18,590,532
                                                                          52.9%
                                                                          8,303
                                                                             13
                                      324
Petroleum and coal products manufacturing
                                                                            192
                                                                      5,848,566
                                                                          16.6%
                                                                         30,461
                                                                             24
                                      562
Waste management and remediation services
                                                                            620
                                                                      4,811,348
                                                                          13.7%
                                                                          7,760
                                                                            145
                                      331
Primary metal manufacturing
                                                                            585
                                                                      2,805,538
                                                                           8.0%
                                                                          4,796
                                                                              7
                                      212
Mining (except oil and gas)
                                                                             40
                                                                      1,261,538
                                                                           3.6%
                                                                         31,538
                                                                             13
                                      332
Fabricated metal product manufacturing
                                                                          1,779
                                                                        349,226
                                                                           1.0%
                                                                            196
                                                                              6
                                      493
Warehousing and storage
                                                                            301
                                                                        222,186
                                                                           0.6%
                                                                            738
                                                                              8
                                      336
Transportation equipment manufacturing
                                                                            867
                                                                        147,618
                                                                           0.4%
                                                                            170
                                                                             11
                                      335
Electrical equipment, appliance, and component manufacturing
                                                                            212
                                                                        130,662
                                                                           0.4%
                                                                            616
                                                                              9
                                      333
Machinery manufacturing
                                                                            371
                                                                        127,663
                                                                           0.4%
                                                                            344
                                                                              8
                                      334
Computer and electronic product manufacturing
                                                                            561
                                                                         97,012
                                                                           0.3%
                                                                            173
                                                                             13
                                      488
Support activities for transportation
                                                                            268
                                                                         79,648
                                                                           0.2%
                                                                            297
                                                                              5
                                      326
Plastics and rubber products manufacturing
                                                                            383
                                                                         56,468
                                                                           0.2%
                                                                            147
                                                                              7
                                      221
Utilities
                                                                          1,825
                                                                         52,270
                                                                           0.1%
                                                                             29
                                                                              3
                                      928
National security and international affairs
                                                                            212
                                                                         48,564
                                                                           0.1%
                                                                            229
                                                                             72
                                      561
Administrative and support services
                                                                             29
                                                                         47,033
                                                                           0.1%
                                                                          1,622
                                                                              9
                                      327
Nonmetallic mineral product manufacturing
                                                                            148
                                                                         46,374
                                                                           0.1%
                                                                            313
                                                                              6
                                      811
Repair and maintenance
                                                                            101
                                                                         43,222
                                                                           0.1%
                                                                            428
                                                                              6
                                      423
Merchant wholesalers, durable goods
                                                                             84
                                                                         42,764
                                                                           0.1%
                                                                            509
                                                                              4
                                      424
Merchant wholesalers, nondurable goods
                                                                            378
                                                                         33,519
                                                                           0.1%
                                                                             89
                                                                              8
                                      339
Miscellaneous manufacturing
                                                                            261
                                                                         28,299
                                                                           0.1%
                                                                            108
                                                                              9
                                      237
Heavy and civil engineering construction
                                                                            159
                                                                         25,920
                                                                           0.1%
                                                                            163
                                                                              2
                                      712
Museums, historical sites, and similar institutions
                                                                             11
                                                                         23,072
                                                                           0.1%
                                                                          2,097
                                                                              6
                                      323
Printing and related support activities
                                                                            242
                                                                         21,182
                                                                           0.1%
                                                                             88
                                                                              4
                                      541
Professional, scientific, and technical services
                                                                            539
                                                                         21,171
                                                                           0.1%
                                                                             39
                                                                             20
                                      531
Real estate
                                                                             42
                                                                         16,309
                                                                           0.0%
                                                                            388
                                                                              5
                                      236
Construction of buildings
                                                                             31
                                                                         13,870
                                                                           0.0%
                                                                            447
                                                                              1
                                      611
Educational services
                                                                            377
                                                                         13,263
                                                                           0.0%
                                                                             35
                                                                             21
                                      211
Oil and gas extraction
                                                                             69
                                                                         12,074
                                                                           0.0%
                                                                            175
                                                                              7
                                      322
Paper manufacturing
                                                                            138
                                                                         11,332
                                                                           0.0%
                                                                             82
                                                                              6
                                      924
Administration of environmental quality programs
                                                                             19
                                                                         10,746
                                                                           0.0%
                                                                            566
                                                                             21
                                      337
Furniture and related product manufacturing
                                                                            152
                                                                          9,992
                                                                           0.0%
                                                                             66
                                                                              3
                                      311
Food manufacturing
                                                                             78
                                                                          9,239
                                                                           0.0%
                                                                            118
                                                                              8
                                      321
Wood product manufacturing
                                                                            156
                                                                          8,612
                                                                           0.0%
                                                                             55
                                                                              3
                                      482
Rail transportation
                                                                             36
                                                                          8,301
                                                                           0.0%
                                                                            231
                                                                              4
                                      486
Pipeline transportation
                                                                            177
                                                                          7,569
                                                                           0.0%
                                                                             43
                                                                              3
                                      622
Hospitals
                                                                            470
                                                                          6,347
                                                                           0.0%
                                                                             14
                                                                             10
                                      425
Wholesale electronic markets and agents and brokers
                                                                              4
                                                                          6,085
                                                                           0.0%
                                                                          1,521
                                                                              3
                                      621
Ambulatory health care services
                                                                            184
                                                                          5,372
                                                                           0.0%
                                                                             29
                                                                              8
                                      922
Justice, public order, and safety activities
                                                                             19
                                                                          4,921
                                                                           0.0%
                                                                            259
                                                                              7
                                      213
Support activities for mining
                                                                             47
                                                                          4,871
                                                                           0.0%
                                                                            104
                                                                              5
                                      313
Textile mills
                                                                             47
                                                                          4,790
                                                                           0.0%
                                                                            102
                                                                              7
                                      532
Rental and leasing services
                                                                             16
                                                                          4,569
                                                                           0.0%
                                                                            286
                                                                              6
                                      812
Personal and laundry services
                                                                            228
                                                                          4,205
                                                                           0.0%
                                                                             18
                                                                              6
                                      483
Water transportation
                                                                             36
                                                                          3,355
                                                                           0.0%
                                                                             93
                                                                              8
                                      238
Specialty trade contractors
                                                                             59
                                                                          3,332
                                                                           0.0%
                                                                             56
                                                                              2
                                      481
Air transportation
                                                                             33
                                                                          2,823
                                                                           0.0%
                                                                             86
                                                                             14
                                      446
Health and personal care stores
                                                                          4,448
                                                                          2,245
                                                                           0.0%
                                                                              1
                                                                              7
                                      921
Executive, legislative, and other general government support
                                                                             30
                                                                          2,140
                                                                           0.0%
                                                                             71
                                                                             12
                                      713
Amusement, gambling, and recreation industries
                                                                             17
                                                                          2,066
                                                                           0.0%
                                                                            122
                                                                              6
                                      485
Transit and ground passenger transportation
                                                                             71
                                                                          1,974
                                                                           0.0%
                                                                             28
                                                                              3
                                      711
Performing arts, spectator sports, and related industries
                                                                              5
                                                                          1,429
                                                                           0.0%
                                                                            286
                                                                              3
                                      927
Space research and technology
                                                                             12
                                                                          1,340
                                                                           0.0%
                                                                            112
                                                                             30
                                      484
Truck transportation
                                                                             49
                                                                          1,155
                                                                           0.0%
                                                                             24
                                                                             13
                                      312
Beverage and tobacco product manufacturing
                                                                             17
                                                                            941
                                                                           0.0%
                                                                             55
                                                                             12
                                      452
General merchandise stores
                                                                            868
                                                                            866
                                                                           0.0%
                                                                              1
                                                                              9
                                      926
Administration of economic programs
                                                                             51
                                                                            804
                                                                           0.0%
                                                                             16
                                                                              2
                                      454
Non-store retailers
                                                                             10
                                                                            496
                                                                           0.0%
                                                                             50
                                                                              7
                                      111
Crop production
                                                                             25
                                                                            457
                                                                           0.0%
                                                                             18
                                                                              3
                                      115
Support activities for agriculture and forestry
                                                                             10
                                                                            336
                                                                           0.0%
                                                                             34
                                                                              2
                                      447
Gasoline stations
                                                                             67
                                                                            317
                                                                           0.0%
                                                                              5
                                                                              3
                                      444
Building material and garden equipment and supplies dealers
                                                                             27
                                                                            235
                                                                           0.0%
                                                                              9
                                                                             10
                                      492
Couriers and messengers
                                                                             22
                                                                            200
                                                                           0.0%
                                                                              9
                                                                             22
                                      316
Leather and allied product manufacturing
                                                                              4
                                                                            161
                                                                           0.0%
                                                                             40
                                                                              7
                                      512
Motion picture and sound recording industries
                                                                              6
                                                                            132
                                                                           0.0%
                                                                             22
                                                                              9
                                      721
Accommodation
                                                                              3
                                                                             98
                                                                           0.0%
                                                                             33
                                                                              1
                                      315
Apparel manufacturing
                                                                              2
                                                                             96
                                                                           0.0%
                                                                             48
                                                                              2
                                      551
Management of companies and enterprises
                                                                              6
                                                                             83
                                                                           0.0%
                                                                             14
                                                                              9
                                      314
Textile product mills
                                                                              9
                                                                             81
                                                                           0.0%
                                                                              9
                                                                              3
                                      441
Motor vehicle and parts dealers
                                                                              8
                                                                             76
                                                                           0.0%
                                                                              9
                                                                              3
                                      517
Telecommunications
                                                                             10
                                                                             71
                                                                           0.0%
                                                                              7
                                                                              1
                                      923
Administration of Human Resource Programs
                                                                              5
                                                                             51
                                                                           0.0%
                                                                             10
                                                                             10
                                      511
Publishing industries (except Internet)
                                                                              6
                                                                             45
                                                                           0.0%
                                                                              7
                                                                              7
                                      445
Food and beverage stores
                                                                            101
                                                                             36
                                                                           0.0%
                                                                              0
                                                                              4
                                      453
Miscellaneous store retailers
                                                                             19
                                                                             35
                                                                           0.0%
                                                                              2
                                                                              8
                                      525
Funds, trusts, and other financial vehicles
                                                                              5
                                                                             34
                                                                           0.0%
                                                                              7
                                                                              1
                                      813
Religious, grant-making, civic, professional, and similar orgs. 
                                                                              6
                                                                             31
                                                                           0.0%
                                                                              5
                                                                              2
                                      722
Food services and drinking places
                                                                              1
                                                                             15
                                                                           0.0%
                                                                             15
                                                                              2
                                      112
Animal production
                                                                              2
                                                                             13
                                                                           0.0%
                                                                              7
                                                                              5
                                      925
Administration of housing programs, urban planning, and community development
                                                                              3
                                                                             11
                                                                           0.0%
                                                                              4
                                                                              1
                                      448
Clothing and clothing accessories stores
                                                                              1
                                                                              5
                                                                           0.0%
                                                                              5
                                                                              1
                                      623
Nursing and residential care facilities
                                                                              2
                                                                              5
                                                                           0.0%
                                                                              2
                                                                              3
                                      522
Credit intermediation and related activities
                                                                              1
                                                                              5
                                                                           0.0%
                                                                              5
                                                                              1
                                      491
Postal Service
                                                                              2
                                                                              3
                                                                           0.0%
                                                                              1
                                                                              1
                                      451
Sporting goods, hobby, musical instrument, and book stores
                                                                              2
                                                                              2
                                                                           0.0%
                                                                              1
                                                                              6
                                      442
Furniture and home furnishings stores
                                                                             12
                                                                              2
                                                                           0.0%
                                                                              0
                                                                             10
                                      524
Insurance carriers and related activities
                                                                              1
                                                                              1
                                                                           0.0%
                                                                              1
                                                                              2
                                                                       TOTAL[2]
                                                                         20,771
                                                                     35,151,466
                                                                         100.0%
                                                                          1,692
                                                                             13
Notes:
 Data from U.S. EPA, National Biennial RCRA Hazardous Waste Report (based on analysis of 2013 BR flat files). Documents and data are available at ftp://ftp.epa.gov/rcrainfodata/br_2013/.
 The values in Columns F and G are calculated on a per facility basis as the sum of values across all generators divided by the total number of generators from Column C.


AS DESCRIBED ABOVE, LQG FACILITIES GENERATE ON AVERAGE APPROXIMATELY 13 WASTE STREAMS PER FACILITY PER YEAR.  HOWEVER, LQG HAZARDOUS WASTE GENERATION DATA IN THE BR ARE HEAVILY SKEWED BASED ON A SMALL NUMBER OF FACILITIES GENERATING THOUSANDS OF DIFFERENT WASTE STREAMS on an annual basis.  In the 2013 BR data, half of the LQGs in the potentially affected universe managed six hazardous waste streams (the median) or less -- while, in total, facilities generated an average of 13 waste streams (the mean).  Of the 20,771 LQGs, 9,590 (or 46.2 percent) generated between 1 and 5 waste streams and 11,032 LQGs (or 53.1 percent) generated 6 or less waste streams.  Therefore, as described later in Chapter 3, this RIA presents a range of cost estimates based on both the median and mean values presented above.
In reporting for the BR, facilities report waste codes for each waste stream to provide information on its contents and properties.  However, the BR data do not include a quantitative analysis of the composition of a waste stream with respect to its reported waste codes (e.g., it does not report what percentage of the waste stream represents waste code F001).  Therefore, it is not possible to determine the exact prevalence of individual constituents in each waste stream.  
Exhibit 2-7 describes the percentage of LQG waste streams associated with each waste code category.  As shown in the exhibit, LQGs reported D waste codes for approximately 89 percent of their waste streams in aggregate.  F waste codes and U waste codes account for the next most frequently reported waste codes among LQGs in the BR data.  Expanding on the data reported in Exhibit 2-7, Exhibit 2-8 reports the waste codes that appear in the highest percentage of all LQG waste streams.  As shown in the exhibit, the 13 most frequently reported waste codes are contained in 90 percent of all LQG waste streams.
EXHIBIT 2-7:  PERCENTAGE OF LQG WASTE STREAMS CONTAINING INDIVIDUAL WASTE CODE CATEGORIES (2013)
                              Waste Code Category
                                      [A]
                          Percentage of Waste Streams
                                    [B][1]
D Waste Codes
                                      89%
F Waste Codes
                                      20%
U Waste Codes
                                      9%
P Waste Codes
                                      6%
K Waste Codes
                                      1%
Lab Packs[2]
                                      1%
TOTAL NUMBER OF LQG WASTE STREAMS
                                    275,081
Notes:
 Waste streams may be comprised of multiple waste codes; therefore rows do not add up to 100 percent.
 Facilities may consolidate different types of hazardous waste in small containers and, in some cases, not report individual waste codes.
EXHIBIT 2-8:  PERCENTAGE OF LQG WASTE STREAMS CONTAINING MOST FREQUENTLY REPORTED WASTE CODES (2013)
                                EPA Waste Code
                                      [A]
                               Waste Description
                                      [B]
                          Percentage of Waste Streams
                                    [C][1]
D001
Ignitable Waste
                                      49%
D002
Corrosive Waste
                                      25%
F003
Non-halogenated Solvents[2]
                                      15%
D007
Chromium
                                      14%
D008
Lead
                                      12%
F005
Non-halogenated Solvents[3]
                                      10%
D011
Silver
                                      8%
D003
Reactive Waste
                                      7%
D006
Cadmium
                                      7%
D009
Mercury
                                      6%
D005
Barium
                                      6%
D018
Benzene
                                      6%
F002
Halogenated Solvents[4]
                                      6%
TOTAL ABOVE LISTED WASTE CODES[5]
                                      90%
Notes:
 The 2013 BR database contains 275,081 waste stream records for LQGs. Waste streams may be comprised of multiple waste codes; therefore rows do not add up to 100 percent.
 F003 wastes include: xylene, acetone, ethyl acetate, ethyl benzene, ethyl ether, methyl isobutyl ketone, n-butyl alcohol, cyclohexanone, and methanol.
 F005 wastes include: toluene, methyl ethyl ketone, carbon disulfide, isobutanol, pyridine, benzene, 2-ethoxyethanol, and 2-nitropropane.
 F002 wastes include: tetrachloroethylene, methylene chloride, trichloroethylene, 1,1,1-trichloroethane, chlorobenzene, 1,1,2-trichloro-1,2,2-trifluoroethane, ortho-dichlorobenzene, trichlorofluoromethane, and 1,1,2-trichloroethane.
 At least one of the waste codes above appear in 90 percent of all waste streams; the remaining 10 percent of waste streams do not contain any of these waste codes.

2.3.2 SQG Hazardous Waste Generation
Due to the limited information in the BR database for non-LQG facilities, this RIA does not rely solely on the BR data to characterize hazardous waste generation for SQGs.  Instead, for SQGs, this RIA relies on the limited data available in the BR database supplemented by facility-level data provided by Maine and Washington.  The data provided by Maine and Washington represent the most complete set of state data for SQG facilities.  
The BR data alone are insufficient for estimating SQG hazardous waste quantities because most states do not require SQGs to submit waste generation data to EPA.  For example, no SQG data are available for eight states, including Mississippi, which is one of the largest states in terms of hazardous waste generation among LQGs.  In addition, there are reporting discrepancies in the BR data regarding generator status and hazardous waste quantities.  Based on the hazardous waste generation thresholds, facilities must generate greater than 100 kg and less than 1,000 kg of hazardous waste in a calendar month (or between 1.3 and 13.2 tons per year) and also generate less than or equal to 1 kg of acute hazardous waste in a calendar month to be considered an SQG.  However, a number of facilities identified as SQGs in the BR data have generation quantities that exceed these thresholds. 
EXHIBIT 2-9 PROVIDES A SUMMARY OF THE BR, MAINE, AND WASHINGTON DATA ON HAZARDOUS WASTE GENERATION FOR SQG FACILITIES.  THE EXHIBIT EXCLUDES FACILITIES THAT ARE REPORTED TO BE SQGS, BUT THAT EXCEED THE RCRA HAZARDOUS WASTE GENERATION THRESHOLDS.  MAINE AND WASHINGTON DATA ARE ALSO EXCLUDED FROM THE BR DATA TO AVOID DOUBLE-COUNTING.  IN TOTAL, THESE DATA REPRESENT 2,625 FACILITIES GENERATING, ON AVERAGE, APPROXIMATELY 2.2 TONS OF HAZARDOUS WASTE PER FACILITY PER YEAR.  RECOGNIZING THE UNCERTAINTY ASSOCIATED WITH THIS AVERAGE VALUE, EXHIBIT 2-9 ALSO REPORTS THE MEDIAN VALUE OF 1.3 TONS OF HAZARDOUS WASTE PER FACILITY PER YEAR.  THE DATA SUGGEST THAT SQG FACILITIES MANAGE, ON AVERAGE, 7.3 waste streams per facility per year (the median number of waste streams is six).
EXHIBIT 2-9:  SQG HAZARDOUS WASTE QUANTITIES AND NUMBER OF WASTE STREAMS GENERATED
                                  Data Source
                                      [A]
                   Number of Facilities with Generation Data
                                      [B]
                    Total Hazardous Waste Generated (Tons)
                                      [C]
                    Hazardous Waste Generated Per Facility 
                                    (Tons)
                                    [D=C/B]
                 Average Number of Waste Streams Per Facility
                                      [E]
2013 BR Data[1] (excluding ME and WA)
                                                                          1,749
                                                                          4,114
                                                                            2.4
                                                                            7.9
Maine DEP[2]
                                                                            317
                                                                            461
                                                                            1.5
                                                                            6.7
Washington DOE[3]
                                                                            559
                                                                          1,183
                                                                            2.1
                                                                            5.8
TOTAL
                                                                          2,625
                                                                          5,757
                                                                           2.2 
                                                                  (Median: 1.3)
                                                                           7.3 
                                                                   (Median: 6) 
Notes:
 Data based on analysis of 2013 BR database. BR data exclude facilities that are reported to be SQGs, but that exceed the RCRA hazardous waste generation thresholds. Maine and Washington data are also excluded to avoid double-counting.
 State data provided via email communication with Cherie Plummer, Maine Department of Environmental Protection, on October 26, 2012. Maine did not report the number of waste streams generated for each facility. However, the BR data contain records for 9 SQGs in Maine that generated an average of 6.7 waste streams per facility per year.
 State data provided via email communication with Jean Newman, Washington Department of Ecology (DOE) on November 8, 2012.

2.3.3 VSQG Hazardous Waste Generation
To estimate hazardous waste generation for VSQGs, this RIA relies on the limited information available in the BR data supplemented by facility-level information provided by Maine, New Jersey, and Washington.  As with SQGs, there is considerable uncertainty regarding the hazardous waste generation quantities of VSQGs.  Based on the hazardous waste generator status thresholds, facilities must generate less than or equal to 100 kg of hazardous waste per month (or less than 1.3 tons per year) and less than 1 kg of acute hazardous waste per month to be considered a VSQG.  Therefore, this analysis excludes facilities in the BR data that are reported to be VSQGs, but exceed these thresholds.
Exhibit 2-10 provides a summary of hazardous waste generation for VSQG facilities.  The BR data exclude facilities that exceed the RCRA hazardous waste thresholds as well as data for Maine, New Jersey, and Washington to avoid double-counting.  In total, these data represent 4,023 facilities generating, on average, approximately 0.25 tons of hazardous waste per facility per year.  The median value is 0.13 tons of hazardous waste per facility per year.  VSQG facilities generated an average of approximately 5.6 waste streams per facility per year (the median number of waste streams is five).
EXHIBIT 2-10:  VSQG HAZARDOUS WASTE QUANTITIES AND NUMBER OF WASTE STREAMS GENERATED
                                  Data Source
                                      [A]
                   Number of Facilities with Generation Data
                                      [B]
                    Total Hazardous Waste Generated (Tons)
                                      [C]
                    Hazardous Waste Generated Per Facility 
                                    (Tons)
                                    [D=C/B]
                 Average Number of Waste Streams Per Facility
                                      [E]
2013 BR Data[1] (excluding ME, NJ, and WA)
                                                                          1,769
                                                                            308
                                                                           0.17
                                                                            7.1
Maine DEP[2]
                                                                            917
                                                                            161
                                                                           0.18
                                                                            4.7
New Jersey DEP[3]
                                                                          1,210
                                                                            498
                                                                           0.41
                                                                            4.4
Washington DOE
                                                                            127
                                                                             42
                                                                           0.33
                                                                            2.6
TOTAL
                                                                          4,023
                                                                          1,009
                                                                          0.25 
                                                                 (Median: 0.13)
                                                                           5.6 
                                                                    (Median: 5)
Notes:
 Data based on analysis of 2013 BR database. BR data exclude facilities that are reported to be VSQGs, but that exceed the RCRA hazardous waste generation thresholds. Maine, New Jersey, and Washington data are also excluded to avoid double-counting.
 State data provided via email communication with Cherie Plummer, Maine Department of Environmental Protection, on October 26, 2012. Maine did not report the number of waste streams generated for each facility. However, the BR data contain records for 3 VSQGs in Maine that generated an average of 4.7 waste streams per facility.
 State data provided via email communication with Mike Hastry, New Jersey Department of Environmental Protection, on October 19, 2012. 
 State data provided via email communication with Jean Newman, Washington Department of Ecology on November 8, 2012.

2.3.4 Aggregate Generation of Hazardous Waste Among Facilities Potentially Affected by the Rule
Exhibit 2-11 reports the aggregate hazardous waste generation of facilities potentially affected by the final rulemaking.  The regulatory universe includes between 424,099 and 676,890 facilities; however, not all are affected by the final rule.  For example, many VSQGs will only be affected if they voluntarily take advantage of the regulatory flexibility (e.g., intra-organizational transfers and episodic generation) provided by the rule.  Due to uncertainty regarding the hazardous waste generation of SQGs and VSQGs, this RIA bounds estimates of these generation quantities using the median value reported above to characterize the low-end estimate and the mean (also reported above) to characterize the high-end estimate.  Using this approach, facilities in the affected universe, in aggregate, generate between 35.2 and 35.4 million tons of hazardous waste per year.  While there is uncertainty about the actual number of SQG and VSQG facilities as well as their hazardous waste generation, the vast majority of hazardous waste (approximately 99 percent) is generated by LQGs.  Therefore, in terms of volume, the difference between the low-end and high-end scenarios is approximately 178,000 tons of hazardous waste or less than 1 percent of all hazardous waste managed by facilities in the affected universe. 
EXHIBIT 2-11:  AGGREGATE ANNUAL HAZARDOUS WASTE GENERATION BY GENERATOR STATUS (TONS)
                                   SCENARIO
                                      [A]
                                     LQGs
                                     SQGs
                                     VSQGs
                                     TOTAL

                            NUMBER OF FACILITIES[B]
                   TOTAL HAZARDOUS WASTE GENERATED(TONS)[C]
                            NUMBER OF FACILITIES[D]
                   TOTAL HAZARDOUS WASTE GENERATED(TONS)[E]
                            NUMBER OF FACILITIES[F]
                   TOTAL HAZARDOUS WASTE GENERATED(TONS)[G]
                            NUMBER OF FACILITIES[H]
                   TOTAL HAZARDOUS WASTE GENERATED(TONS)[I]
Low-end Estimate
                                    20,771
                                  35,151,000
                                    49,887
                                    66,000
                                    353,441
                                    46,000
                                    424,099
                                  35,263,000
High-end Estimate
                                       
                                       
                                    64,310
                                    141,000
                                    591,809
                                    148,000
                                    676,890
                                  35,441,000
Notes:
 For SQGs, the low-end estimate assumes each facility generates, on average, approximately 1.32 tons/year of hazardous waste. The high-end estimate assumes that SQGs generate, on average, approximately 2.19 tons/year of hazardous waste.
 For VSQGs, the low-end estimate assumes each facility generates, on average, approximately 0.13 tons/year of hazardous waste. The high-end estimate assumes that VSQGs generate, on average, approximately 0.25 tons/year of hazardous waste.
2.4 Management of Hazardous Waste
This section describes the management of hazardous waste by facilities in the affected universe.  This RIA uses the 2013 BR database to identify the primary management methods for hazardous waste generated by LQGs and SQGs.  The BR instructions allow facilities to report a number of different management methods, both on-site and off-site.  This RIA summarizes the frequency of 12 categories of on-site and off-site management methods (these are listed in Exhibit 2-12) as reported in the 2013 BR database.
Exhibit 2-12 reports the primary on-site and off-site management methods for LQGs and SQGs.  Overall, LQGs manage approximately 69 percent of their hazardous waste (by weight) on-site and 31 percent off-site.  The primary on-site management methods for LQGs include: deep well or underground injection (58 percent of all waste); biological, chemical, or physical treatment (3 percent); and reclamation and recovery (3 percent).  The primary off-site management methods for LQGs include: reclamation and recovery (19 percent of all waste); landfill or surface impoundment (5 percent); and deep well or underground injection (2 percent).  However, the disproportionate share of deep well or underground injection is almost entirely attributable to the largest five industries in terms of overall hazardous waste generation: chemical manufacturing (NAICS 325); petroleum and coal products manufacturing (NAICS 324); waste management and remediation services (NAICS 562); primary metal manufacturing (NAICS 331); and mining (NAICS 212).  Excluding these industries, less than 1.0 percent of LQG hazardous waste is managed through onsite deep well or underground injection.  This also implies that, excluding these five industries, only 24 percent of hazardous waste generated by LQGs is managed on-site -- with roughly half of that, or 13 percent of overall hazardous waste, discharged to a sewer/publicly owned treatment works (POTW) or National Pollutant Discharge Elimination System (NPDES).  The remaining 76 percent of hazardous waste is managed off-site, including 37 percent managed off-site for reclamation and recovery, 9 percent sent to a landfill or surface impoundment, 9 percent transferred off-site with no treatment or recovery, and the remaining 21 percent managed through other off-site methods.
Overall, SQG facilities manage approximately 80 percent of their hazardous waste off-site and 20 percent on-site.  The primary off-site management methods for SQGs include: stabilization prior to land disposal at another site (36 percent); transfer off-site with no treatment or recovery (12 percent); and landfill or surface impoundment (10 percent).  The primary on-site management method for SQGs is sewering (19 percent of overall waste).  
One source of uncertainty is that, in some cases, LQGs and SQGs that reported to EPA inadvertently submitted identical Waste Generation Management (GM) Forms for off-site and on-site waste management, thereby double-counting the amount of hazardous waste they generate.  It is not possible to determine whether these wastes were managed on-site or off-site.  Because this occurs infrequently and the associated waste quantities are generally small, this RIA includes these wastes in both estimates of waste managed on-site and off-site.  In addition, for a small number of facilities, the waste quantities generated and the waste quantities managed (both on-site and off-site) did not match.  This may be attributable to reporting error or changes in reporting methods.  As this discrepancy accounts for a very small proportion of all hazardous waste generated, no attempt was made to correct for it.
EXHIBIT 2-12:  PERCENTAGE OF TOTAL HAZARDOUS WASTE GENERATED BY MANAGEMENT METHOD (BY WEIGHT)[1] 
                               MANAGEMENT METHOD
                                      [A]
                                  LQGs (ALL)
                                     LQGs
                (EX-5 LARGEST GENERATING INDUSTRIES)SQGs (ALL)
                                    ON-SITE
                                     [B] 
                                 OFF-SITE [C]
                                    ON-SITE
                                     [D] 
                                 OFF-SITE [E]
                                    ON-SITE
                                     [F] 
                                 OFF-SITE [G]
Reclamation and Recovery
                                      3%
                                      19%
                                      4%
                                      37%
                                      0%
                                      8%
Incineration
                                      1%
                                      1%
                                      0%
                                      4%
                                      0%
                                      4%
Biological, Chemical, or Physical Treatment
                                      3%
                                      1%
                                      3%
                                      4%
                                      0%
                                      3%
Stabilization Prior to Land Disposal at Another Site
                                      0%
                                      1%
                                      0%
                                      8%
                                      0%
                                      36%
Neutralization Only
                                      0%
                                      0%
                                      1%
                                      0%
                                      0%
                                      2%
Evaporation
                                      0%
                                      0%
                                      0%
                                      0%
                                      0%
                                      0%
Other Treatment (excluding Onsite Disposal)
                                      1%
                                      0%
                                      0%
                                      0%
                                      0%
                                      0%
Land Treatment or Application
                                      0%
                                      0%
                                      2%
                                      0%
                                      0%
                                      1%
Landfill or Surface Impoundment
                                      1%
                                      5%
                                      0%
                                      9%
                                      0%
                                      10%
Deepwell or Underground Injection
                                      58%
                                      2%
                                      1%
                                      4%
                                      0%
                                      3%
Discharge to Sewer/POTW or NPDES
                                      2%
                                      0%
                                      13%
                                      1%
                                      19%
                                      0%
Transfer Off-site with no Treatment or Recovery
                                      0%
                                      1%
                                      0%
                                      9%
                                      0%
                                      12%
PERCENTAGE OF TOTAL WASTE
                                      69%
                                      31%
                                      24%
                                      76%
                                      20%
                                      80%
Notes:
 Note that Columns B and C (and Columns D and E) are additive and sum to 100 percent for LQGs. Similarly, Columns F and G are additive and sum to 100 percent for SQGs.
 Excluding the five largest industries in terms of overall hazardous waste generation (NAICS 324, 325, 562, 331, and 212) -- which account for the vast majority of on-site deepwell or underground injection -- the primary management methods for other LQGs more closely mirror those for SQGs. The subset of LQGs shown in Columns D and E, excluding the five industries noted above, accounts for 80 percent of LQGs, but only 5 percent of the overall hazardous waste managed by all LQGs.


CHAPTER 3  |  Assessment of Costs
3.1 Introduction
This chapter assesses the costs of managing hazardous waste under the provisions set forth in the final Hazardous Waste Generator Improvements Rule, which are outlined in Chapter 1.  This chapter begins by outlining EPA's approach for addressing several uncertainties related to the rule's cost impacts by estimating these costs as a range.  Following this discussion, the chapter presents a detailed description of the methodology for the cost analysis.  This includes a discussion of EPA's approach for estimating costs based on the limited facility-level data summarized in Chapter 2 and identification of the requirements likely to have the most significant impact on costs.  This chapter then presents the total annualized costs under the final rule, and concludes with a discussion of the analytic limitations associated with the cost analysis.
3.2 Estimating Costs as a Range
To address uncertainties regarding the number of facilities in the regulated universe, the amount of hazardous waste that they generate, and several of the cost-related inputs presented later in this chapter, this RIA presents both low-impact and high-impact estimates of the costs associated with the final rule.  The low-impact cost estimates presented in this chapter reflect the low-end estimates presented in Chapter 2 regarding (1) the number of facilities in the regulated universe, (2) the number of waste streams per facility, and (3) the annual generation of hazardous waste among regulated facilities.  The low-impact estimates also reflect the low-end assumptions regarding any cost-related inputs for which a range of data inputs was available, such as the number of labor hours required for compliance activities.  Similarly, the high-impact cost estimates developed in this chapter reflect the high-end estimates for these variables.  Exhibit 3-1 summarizes the low- and high-end assumptions regarding the number of facilities, the number of waste streams per facility, and the per-facility generation of hazardous waste.  The distinctions between the low- and high-end values for these variables are as follows:
      NUMBER OF FACILITIES:  For SQGs, the low-end estimate reflects the number of SQGs identified on the Biennial Report WR form in 2013, whereas the high-end estimate reflects SQGs identified on the WR form for any of the years 2009, 2011, or 2013.  A more detailed discussion on these estimates can be found in Chapter 2.  For VSQGs, the low-end estimate reflects the lowest value calculated among the VSQG-to-SQG and VSQG-to-LQG ratios presented in Chapter 2, whereas the high-end estimate reflects the highest value.  The estimated number of LQGs is derived from the 2013 BR database and is the same for both the low-end and high-end scenario. 
      Number of waste streams per facility:  Low-end values represent the median number of waste streams reported by generators to EPA or relevant state authorities in the most recent reporting cycle, as presented in Chapter 2.  The high-end values represent the mean number of waste streams in the most recent reporting cycle, which is slightly higher.
      EXHIBIT 3-1:  BASELINE HAZARDOUS WASTE GENERATION ESTIMATES
                               GENERATOR STATUS
                                      [A]
                               LOW-END ESTIMATE
                               HIGH-END ESTIMATE
                            NUMBER OF FACILITIES[B]
         MEDIAN HAZARDOUS WASTE QUANTITY GENERATED PER FACILITY(TONS)
                                      [C]
           MEDIAN NUMBER OF HAZARDOUS WASTE STREAMS PER FACILITY[D]
                            NUMBER OF FACILITIES[E]
          MEAN HAZARDOUS WASTE QUANTITY GENERATED PER FACILITY(TONS)
                                      [F]
            MEAN NUMBER OF HAZARDOUS WASTE STREAMS PER FACILITY[G]
                                      LQG
                                    20,771
                                     7.58
                                       6
                                    20,771
                                   1,692.33
                                      13
                                      SQG
                                    49,887
                                     1.32
                                       6
                                    64,310
                                     2.19
                                       7
                                     VSQG
                                    353,441
                                     0.13
                                       5
                                    591,809
                                     0.25
                                       6
Notes:
 Hazardous waste generation mean and median quantities are derived from the following sources. For LQGs: 2013 BR data; for SQGs: limited 2013 BR data combined with data provided by the States of Maine and Washington; for VSQGs: limited 2013 BR data combined with data provided by the States of Maine, New Jersey, and Washington.
 The median and mean number of waste streams is derived from the following sources. For LQGs: 2013 BR data; for SQGs and VSQGs: limited 2013 BR data combined with data provided by the State of Washington. Maine and New Jersey provided data on waste quantities for SQGs and VSQGs, but did not report information on the number of waste streams managed. Information for these states was collected from the 2013 BR data.


      Annual hazardous waste generation per facility:  Similar to the number of waste streams, the low-end generation values reflect the median values derived from the BR or state data, and the high-end values reflect the mean values estimated from these data sources.
3.3 Cost Methodology
This section presents the methods employed in this RIA to assess the cost impacts of the final rule.  To begin, this section outlines the key assumptions reflected in several components of the cost analysis.  Following this discussion, the chapter provides a detailed accounting of the unit costs associated with each provision of the final rule.  For each provision, this section describes differences in requirements between the baseline and the final rule.  While the majority of the requirements are mandatory, three provisions of the rule are intended to provide greater flexibility to certain classes of hazardous waste generators and are thus voluntary (intra-organizational transfers, episodic generation, and special requirements for ignitable and reactive waste).  This section first reports the costs associated with the mandatory provisions of the rule and then reports costs for the voluntary provisions.  In this section, costs are annualized over a 20-year period using a 7 percent discount rate.  In the results section at the end of this chapter, total costs are also reported on an undiscounted basis and using a 3 percent discount rate.
3.3.1 GENERAL ASSUMPTIONS
The assessment of costs presented in this chapter relies upon several assumptions that influence the estimated costs of managing hazardous waste under the final rule.  Some of these assumptions affect several components of the analysis.  These include assumptions regarding (1) hourly labor costs that determine the costs associated with the various provisions of the rule and (2) the discount rate.  These assumptions are outlined in detail below. 
Hourly Labor Costs
MANY OF THE UNIT COSTS PRESENTED IN THIS CHAPTER REFLECT THE TIME REQUIRED OF MANAGERS, TECHNICIANS, ATTORNEYS, AND OTHER STAFF FOR VARIOUS HAZARDOUS WASTE MANAGEMENT ACTIVITIES and are estimated as a function of the hourly labor costs associated with various professional and clerical positions.  Exhibit 3-2 reports the fully loaded labor costs on a per-hour basis for facility staff, including lawyers and office clerks, who will likely implement the requirements associated with the final rule.  The hourly costs presented in the exhibit reflect unloaded hourly wages reported by the U.S. Bureau of Labor Statistics (BLS) based on a full time employee working 40 hours a week multiplied by a loaded wage rate factor of 1.4825.  This represents the sum of two cost factors: (1) a fringe benefits (e.g., insurance, disability income protection, retirement benefits, sick leave, vacation, etc.) rate of 0.3625 and (2) an overhead rate of 0.12.
EXHIBIT 3-2:  HOURLY LABOR COSTS ($2015)
                            BLS OCCUPATION CATEOGRY
                     MEAN LOADED HOURLY LABOR COSTMANAGERS
                                    $86.15
Technicians
                                    $42.41
Software Developers and Programmers
                                    $70.04
Office Clerks, General
                                    $22.66
Lawyers
                                    $98.11
Source:
 Bureau of Labor Statistics, National Occupational Employment and Wage Estimates, May 2014, accessed at http://www.bls.gov/oes/current/oes_nat.htm#00-0000 on February 18, 2016.
 Inflation factor based on December 2015 cost index using Bureau of Labor Statistics, Employment Cost Index Historical Listing Current-dollar March 2001  -  December 2015, Table 1: Employment Cost Index for Total Compensation, by Occupational Group and Industry (Seasonally Adjusted), accessed at http://www.bls.gov/web/eci/echistrynaics.pdf on February 18, 2016.
 Loaded wage rates calculated using fringe benefit and overhead cost factors from Figure C1 of the May 29, 2003 OMB Circular A-76: Performance of Commercial Activities, accessed at http://www.whitehouse.gov/omb/circulars_a076_a76_incl_tech_correction on February 18, 2016.
Discount Rates
This RIA presents the cost impacts of the rule in present value and annualized terms based on discount rates of 3 and 7 percent over a 20-year forecast period.  The present value represents the value today of a future stream of payments in nominal or real dollar terms.  That is, it is the sum of a series of future cash flows expressed in today's dollars.  Translation of future costs to present value terms requires the following: (a) projected future costs; and (b) the specific years in which these impacts are expected to be incurred.  With these data, the present value of the future stream of impacts (PVc) from year t1 to T is measured in 2015 dollars according to the following standard formula:
                                       
where Ct is the cost of each management activity in year t and r is the discount rate.  
As indicated above, this RIA also expresses cost impacts for each hazardous waste management activity as annualized values.  Annualized values are calculated to provide a comparison of impacts across activities with varying time components and forecast periods.  Annualized future impacts (APVc) are calculated according to the following standard formula:
                                       
where N is the number of years in the forecast period.
Other Assumptions
The hazardous waste generation quantities reported above in Exhibit 3-1 inform several baseline waste management assumptions in this RIA.  Specifically, this RIA relies on the mean and median per facility generation quantities to develop estimates of the number of storage containers used by hazardous waste generators.  Generally, these facilities are assumed to accumulate hazardous waste in 55-gallon drums, which are stored and eventually transported to disposal sites once filled.  This RIA assumes that facilities need to maintain a sufficient number of drums to manage all of their hazardous waste, whether it is managed on-site or off-site.  This RIA assumes that a filled 55-gallon drum holds between 140 and 275 pounds of waste (an average of 207.5 pounds) in solid form or between 250 and 400 pounds of waste in liquid or sludge form (an average of 325 pounds).  Based on 2013 BR data, approximately 90 percent of all hazardous waste managed is in liquid or sludge form and 10 percent is in solid form.  Therefore, this RIA assumes that the average 55-gallon drum holds approximately 313 pounds of hazardous waste, which represents the weighted average of the liquid/sludge and solid values presented above.  With respect to transportation, this RIA assumes that a standard 18-wheeler trailer can carry up to eighty 55-gallon drums.
Based on the waste generation values in Exhibit 3-1, this RIA's drum capacity assumption of 313 pounds per drum implies that a typical VSQG manages five to six partially-filled 55-gallon drums of hazardous waste per year, while a typical SQG manages between approximately 9 and 15 drums per year.   To estimate the number of drums used by LQGs, this RIA applies the 313-pound-per-drum figure to the median LQG generation value from Exhibit 3-1.   Based on this value, the typical LQG manages approximately 49 drums per year.  The median generation value for LQGs is likely to be more representative than the mean because the latter is skewed by a limited number of larger facilities, which are more likely to use storage tanks than drums.
3.3.2 RE-NOTIFICATION
Under the final rule, LQGs are required to re-notify EPA of their hazardous waste generation activities every other year and SQGs are required to re-notify every four years.  LQGs are already required to re-notify EPA of their hazardous waste generator status through the BR.  Therefore, this requirement only represents an incremental cost for SQGs.  However, 12 states and the District of Colombia already require SQGs to re-notify.  There are approximately 6,300 to 7,900 SQGs in states that currently require SQG re-notification; thus, the final rule will impact between approximately 43,600 and 56,400 SQGs in states that do not currently require re-notification. 
Specifically, for each re-notification, a facility will need to review its previous notification and either make changes, if necessary, or confirm that the information remains accurate.  EPA estimates that the initial cost of notification is approximately $47.98 per facility and the cost of re-notification is approximately $34.05 (in 2015 dollars).  Because facilities that must record changes in their re-notification form may require additional time to collect this information, this RIA assumes that these facilities are likely to incur costs similar to the initial notification, while facilities that need only confirm that the previous information is still accurate are likely to incur typical re-notification costs. 
To estimate the number of facilities that may take additional time to complete the re-notification, EPA analyzed BR data for approximately 18,450 facilities that submitted multiple BR records between 2003 and 2011 to assess whether those facilities reported changes in their general facility information between reporting periods.  These include changes to a facility's: (1) physical location; (2) mailing address; (3) emergency contact information; (4) ownership; and (5) generator status.  
Identifying changes between reporting years is complicated by the fact that facilities may report the same information differently each year.  Thus, the most significant challenge in identifying actual information changes is eliminating false mismatches, which occur as a result of: misspellings, typos, abbreviations, acronyms, nicknames, titles, prefixes, suffixes, and word order.  These false mismatches may account for the majority of changes in physical location and mailing address, which tend to occur less frequently than changes in contact information.  Address mismatches are particularly challenging because zip codes may change while street addresses do not, and generators may alternate between listing adjoining or enveloping towns/cities/metro-areas/counties in different reporting years.  For example, a facility may list its location as Phoenix one year, but in Glendale (a Phoenix suburb) the next. Considering these and other irregularities in the reporting of facility information in the BR, this RIA uses the following approach to identify changes between reporting years:
 For contact and owner names, remove titles, prefixes, and suffixes to more easily identify actual matches. 
 Use a computer algorithm to calculate the "Levenshtein distance" between any two entries for a generator. Then eliminate matches where the Levenshtein distance is less than four or where less than 30 percent of the text characters change from one year to the next, because these are highly likely to be identical entries, but for typos, misspellings, etc.
 For contact and owner names, eliminate mismatches where the last name does not change but the first name (or remaining part of the name) is a variation on another entry. For example, "Bill Rogers" and "William Rogers" or "EI Dupont", "EI Dupont De Nemours", and "E I Dupont De Nemours & Co."
 Use a search and replace algorithm to clean the data of common typos or abbreviations, for example changing "PHX, ARIZONA" to "PHOENIX, ARIZONA." 
 Finally, review any remaining changes between reporting years manually to identify and remove the remaining false mismatches.
This methodology attempts to remove false mismatches that appear to be changes but are likely due to input error or inconsistent reporting methods over time.  For all of the information changes identified, a manual check of the records was performed to ensure the accuracy of the results.  However, this methodology is limited by the sheer volume of data and limitless possibilities for variation in user data entry.  For contact and owner names, a limitation of this approach is that name changes that may occur due to marriage or divorce (i.e., an individual's surname changes while their first name does not) are not easily verified.  These types of name-changes occur for a non-trivial percentage of facilities (approximately 200 per year, or five percent of all name changes in the BR data).  Another limitation of this approach is that many facilities submitted BR records in only one year, making it impossible to identify potential changes for these facilities.  
Based on this approach, this RIA estimates that approximately 35.2 percent of facilities had at least one change in their general facility information between biennial reporting periods, with the most common reason being a change in the primary contact name or a change in ownership.  Exhibit 3-3 reports the percentage of facilities that reported changes in their generator information to EPA across multiple BR reporting periods.
Based on the 2003-2011 BR data, over a four year period approximately 42 percent of SQGs will have no change in their general facility information and will incur standard re-notification costs every four years, while the remaining 58 percent of SQGs may require additional time to report changes in generator information as part of their re-notification.  Therefore, the average per facility cost of re-notification is approximately $42.13 every four years.  This represents an incremental cost for SQGs in states that do not currently require re-notification, but this cost is already incurred by LQGs and a subset of SQGs in states with reporting requirements in the baseline.
EXHIBIT 3-3:  PERCENTAGE OF FACILTIES REPORTING A CHANGE IN THEIR GENERATOR INFORMATION TO EPA (ON A BIENNIAL BASIS)REASON FOR reporting Change in Generator Information
                           Percentage of Facilities
Physical Location Change
                                     0.05%
Mailing Address Change
                                     3.9%
Emergency Contact Name Change
                                     33.0%
Owner Change
                                     8.2%
Generator Status Change
                                     4.7%
At Least One Change for Any Reason
                                   35.2%[2]
Notes:
 Source: EPA's BR database records from 2003 to 2011.
 This value is less than the sum of the values associated with individual reasons for reporting a change in generator information because some facilities may have multiple reasons for reporting a change.

Exhibit 3-4 reports the unit costs and aggregate annualized costs of re-notification under this provision of the rule by facility type.  All of the SQG costs are incurred every four years, starting in the first year after the promulgation of the final rule.
EXHIBIT 3-4:  ANNUALIZED UNIT COSTS AND AGGREGATE COSTS FOR RE-NOTIFICATION ($2015 ANNUALIZED OVER 20 YEARS, USING A 7% DISCOUNT RATE)
                               GENERATOR STATUS
                                      [A]
                              LOW IMPACT ESTIMATE
NUMBER OF AFFECTED FACILITIES LIKELY TO INCUR COSTS
                                      [B]
                         ANNUALIZED COST PER FACILITY
                           AGGREGATE ANNUALIZED COST
                            TOTAL ANNAULIZED COSTS
                                    [G=E+F]
ONE-TIME COSTS
                                      [C]
                                RECURRING COSTS
                                      [D]
                                ONE-TIME COSTS
                                   [E=BxC]
                                RECURRING COSTS
                                   [F=BxD]

LQG
                                       0
                                     $0.00
                                     $0.00
                                      $0
                                      $0
                                      $0
SQG
                                    43,604
                                     $0.00
                                   $11.63[a]
                                      $0
                                   $507,000
                                   $507,000
VSQG
                                       0
                                     $0.00
                                     $0.00
                                      $0
                                      $0
                                      $0
TOTAL
                                    43,604
                                      N/A
                                      N/A
                                      $0
                                   $507,000
                                   $507,000
                               GENERATOR STATUS
                                      [A]
                             HIGH IMPACT ESTIMATE
              NUMBER OF AFFECTED FACILITIES LIKELY TO INCUR COSTS
                                      [B]
                         ANNUALIZED COST PER FACILITY
                           AGGREGATE ANNUALIZED COST
                            TOTAL ANNUALIZED COSTS
                                    [G=E+F]
                                ONE-TIME COSTS
                                      [C]
                                RECURRING COSTS
                                      [D]
                                ONE-TIME COSTS
                                   [E=BxC]
                                RECURRING COSTS
                                   [F=BxD]

LQG
                                       0
                                     $0.00
                                     $0.00
                                      $0
                                      $0
                                      $0
SQG
                                    56,390
                                     $0.00
                                   $11.63[a]
                                      $0
                                   $656,000
                                   $656,000
VSQG
                                       0
                                     $0.00
                                     $0.00
                                      $0
                                      $0
                                      $0
TOTAL
                                    56,390
                                      N/A
                                      N/A
                                      $0
                                   $656,000
                                   $656,000
Notes:
All aggregate cost estimates are rounded to three significant digits and may not sum due to rounding.
 This figure represents the annualized cost of re-notification (a weighted average of $34.05 for standard re-notification and $47.98 for re-notification with data modifications -- see the main text for details on the weighting).  Approximately 42 percent of facilities are assumed to have standard re-notification costs, while 58 percent of facilities are assumed to have at least one reason for modification to their re-notification submission.  Applying these values as weights yields a weighted average cost of $42.13 incurred every four years, or $11.63 on an annualized basis.

3.3.3 LABELING/MARKING
Current RCRA regulations require that LQGs and SQGs label containers and tanks with the words "Hazardous Waste."  The final rule would expand this policy to require facilities to provide container and tank labeling, including: (1) the words "Hazardous Waste" and (2) an indication of the hazards of a container's contents (e.g., the applicable hazardous waste characteristics).  Similarly, EPA is also requiring that SQGs and LQGs mark areas near containment buildings with (1) the words "Hazardous Waste" and (2) an indication of the associated hazards. This represents an incremental cost for all LQGs and SQGs. The final rule does not change the labeling requirements for hazardous waste accumulated on drip pads.
This RIA assumes that LQGs generally use a computerized labeling system or rely on an environmental services company to maintain a labeling/tracking database.  Furthermore, it is assumed that all of the necessary information to be included on the label is already maintained in a database in the baseline and that the current labels used by LQGs are large enough to fit the additional information that must be included on labels under the final rule.  Therefore, the one-time programming and testing costs to accommodate the new enhanced label format for containers, tanks, and areas near containment buildings which requires 10 hours of a programmer's time, represents the only cost for LQGs that choose to reprogram their computerized labeling system.  Using the hourly labor costs for programmers as presented in Exhibit 3-2, this represents an initial one-time cost of approximately $700 per LQG to modify existing labels with the additional data element.  After incurring this initial cost, LQGs will realize no additional costs in subsequent years.
Furthermore, this RIA assumes that LQGs can use Department of Transportation (DOT) labels to comply with the requirement to provide labeling that indicates the hazards of a container's contents.  EPA estimates that LQGs that (1) manage their waste off-site and (2) have few, predictable waste streams are likely to take advantage of this option.  LQGs transporting waste off-site must already apply DOT labels to their containers.  These facilities either apply the labels before shipment or rely on a transporter service to apply the labels before shipment.  LQGs that currently label their waste when it is ready for shipment or rely on a transporter service to apply the labels before shipment will now have to apply labels at the point of generation.  This would not represent an additional cost beyond what is represented in the baseline.  In some instances, when LQGs apply DOT labels at the point of generation rather than relying on a transporter service, it would shift the cost from transporter services to LQGs.  LQGs that currently rely on a transporter service to apply DOT labels to containers would likely apply their own DOT labels to their waste at the point of generation when they have few, predictable waste streams and would not need to rely on the specialized knowledge of the transporter service.  LQGs with many unpredictable waste streams are more likely to continue to rely on the transporter service to apply DOT labels and are likely to invest in updating their computerized labeling systems (as outlined above) to comply with the requirement to provide labeling that indicates the hazards of the content.
This RIA assumes that LQGs with 6 waste streams (the median number of waste streams for LQGs) or less that ship all of their waste off-site would use DOT labels to comply with the requirement to provide labeling that indicates the hazards of the container's content.  Based on the 2013 BR database, 10,483 LQGs have 6 waste streams or less and ship all of their waste off-site (approximately half of the LQG universe).  Therefore, EPA estimates that 10,483 LQGs rely on DOT labeling to comply with the labeling requirements under the final rule.  The remaining 10,288 LQGs are assumed to upgrade their computerized labeling system to comply with the labeling requirements.
In contrast, this RIA assumes that SQGs rely on a manual process rather than an automated system to label their containers.  EPA estimates that it takes about 0.25 hours (or 15 minutes) of a technician's time to apply labels to containers in a primary storage area.  Based on label price information for two label suppliers this RIA estimates that the average cost of a simple label containing the words "Hazardous Waste" with a blank space to indicate the hazards of a container's contents is approximately $0.06 per label.  These costs are already incurred in the baseline.  Additionally, EPA assumes it takes about 0.08 hours (or 5 minutes) of a technician's time per container to write additional information on the label indicating the hazards of the container's contents, which represents an incremental cost of approximately $3.52 per container.  
This cost would be applied to containers in SQGs' primary accumulation areas, as well as their satellite accumulation areas (SAAs).  As indicated in the assumptions section above, EPA estimates that SQGs use 9 to 15 containers in their primary accumulation areas each year.  The number of containers in SQGs' SAAs (that are not simply moved to primary accumulation areas), however, is highly uncertain and likely to vary significantly across facilities.  In the absence of information on the number of containers in SAAs, this RIA assumes that the number is approximately half that in primary accumulation areas (or approximately 4 to 7 containers).  Based on this assumption, the cost per container for SQGs is applied to 13 to 22 containers per SQG.  With a cost of $3.52 per container, this translates to additional labeling costs of $46 to $77 per SQG each year.  The requirements for SQGs that accumulate hazardous waste in containment buildings or tanks are slightly different in that these generators will use their inventory logs to comply with the labeling/marking provision.  This RIA assumes that the costs for these generators are similar to the costs for SQGs that accumulate hazardous waste in containers -- approximately $46 to $77 per SQG per year.  Unlike the system upgrade costs presented above for LQGs, the labeling/marking costs for SQGs represent an annual recurring cost incurred by SQGs.
EXHIBIT 3-5 REPORTS THE UNIT COSTS AND AGGREGATE ANNUALIZED COSTS OF LABELING/MARKING CONTAINERS BY FACILITY TYPE.  COSTS ARE ALSO BROKEN OUT BY ONE-TIME COSTS (I.E., FIRST YEAR ONLY) AND RECURRING COSTS (I.E., ANNUAL COSTS).
EXHIBIT 3-5:  ANNUALIZED UNIT COSTS AND AGGREGATE COSTS FOR LABELING/MARKING ($2015 ANNUALIZED OVER 20 YEARS, USING A 7% DISCOUNT RATE)
                               GENERATOR STATUS
                                      [A]
                              LOW IMPACT ESTIMATE
NUMBER OF AFFECTED FACILITIES LIKELY TO INCUR COSTS
                                      [B]
                         ANNUALIZED COST PER FACILITY
                           AGGREGATE ANNUALIZED COST
                            TOTAL ANNUALIZED COSTS
                                    [G=E+F]
ONE-TIME COSTS
                                      [C]
                                RECURRING COSTS
                                      [D]
                                ONE-TIME COSTS
                                   [E=BxC]
                                RECURRING COSTS
                                   [F=BxD]

LQG
                                    10,288
                                   $61.79[a]
                                     $0.00
                                   $636,000
                                      $0
                                   $636,000
SQG
                                    49,887
                                     $0.00
                                   $45.73[b]
                                      $0
                                  $2,280,000
                                  $2,280,000
VSQG
                                       0
                                     $0.00
                                     $0.00
                                      $0
                                      $0
                                      $0
TOTAL
                                    60,175
                                      N/A
                                      N/A
                                   $636,000
                                  $2,280,000
                                  $2,920,000
                               GENERATOR STATUS
                                      [A]
                             HIGH IMPACT ESTIMATE
              NUMBER OF AFFECTED FACILITIES LIKELY TO INCUR COSTS
                                      [B]
                         ANNUALIZED COST PER FACILITY
                           AGGREGATE ANNUALIZED COST
                            TOTAL ANNUALIZED COSTS
                                    [G=E+F]
                                ONE-TIME COSTS
                                      [C]
                                RECURRING COSTS
                                      [D]
                                ONE-TIME COSTS
                                   [E=BxC]
                                RECURRING COSTS
                                   [F=BxD]

LQG
                                    10,288
                                   $61.79[a]
                                     $0.00
                                   $636,000
                                      $0
                                   $636,000
SQG
                                    64,310
                                     $0.00
                                   $77.39[c]
                                      $0
                                  $4,980,000
                                  $4,980,000
VSQG
                                       0
                                     $0.00
                                     $0.00
                                      $0
                                      $0
                                      $0
TOTAL
                                    74,598
                                      N/A
                                      N/A
                                   $636,000
                                  $4,980,000
                                  $5,610,000
Notes:
All aggregate cost estimates are rounded to three significant digits and may not sum due to rounding.
 This figure represents a first-year labor cost of $700.39 ($61.79 on an annualized basis) for 10 hours of a programmer's time.
 This figure represents an additional labor cost of $3.52 (five minutes of a technician's time) per 55-gallon drum. This RIA assumes that SQGs manage an average of 13 drums per year in the low impact scenario. The annualized cost of $45.73 per facility is split between labeling in primary accumulation areas ($30.49 per facility) and satellite accumulation areas ($15.24 per facility). Thus, the total annualized cost for SQGs of approximately $2.3 million is divided between primary accumulation areas ($1.5 million) and SAAs ($0.8 million).  
 This figure represents an additional labor cost of $3.52 (five minutes of a technician's time) per 55-gallon drum. This RIA assumes that SQGs manage an average of 22 drums per year in the high impact scenario. The annualized cost of $77.39 per facility is split between labeling in primary accumulation areas ($51.59 per facility) and satellite accumulation areas ($25.80 per facility). Thus, the total annualized cost for SQGs of approximately $5.0 million is divided between primary accumulation areas ($3.3 million) and SAAs ($1.7 million).

3.3.4 CLOSURE
Under existing regulations, LQGs must comply with general closure provisions, which require removing and decontaminating all contaminated equipment, structures, and soil to minimize the need for further maintenance and prevent post-closure release of hazardous waste or constituents into the environment.  LQGs storing or treating waste in tanks, drip pads, and containment buildings are also subject to closure requirements specific to these types of units.  No such unit-specific requirements exist, however, for CAAs.  In addition, LQGs are not currently subject to closure notification or financial assurance requirements.  The closure requirements for SQGs are less stringent than for LQGs in that SQGs are only subject to certain requirements for accumulating hazardous waste in tanks, while there are no specific requirements for SQGs managing hazardous waste in containers.  There are no closure requirements for VSQGs.  
The final rule will strengthen the closure requirements for LQGs.  Specifically, the rule stipulates that if an LQG cannot demonstrate that any contaminated soils in a CAA can be practicably removed or decontaminated, then the LQG must close the waste accumulation unit and perform post-closure care in accordance with the closure and post-closure care requirements that apply to landfills (§ 265.310).  In addition, EPA is requiring LQGs to notify EPA or their authorized state agency at least 30 days prior to closure.  EPA is also requiring that such generators subsequently notify within 90 days after closure that they have either clean closed or, if they cannot clean close, that they have closed as a landfill.  
The costs of this provision depend on four factors.  First, for all LQGs that close, the costs depend on the cost of notifying EPA of a closure.  Then, for LQGs that close CAAs and cannot demonstrate that contaminated soils in these areas can be practicably removed or decontaminated, the costs also depend on (1) the average number of LQGs with CAAs that close annually, (2) the percentage of these facilities that will be required to close as a landfill, and (3) the per-facility cost of closing as a landfill.  This RIA's approach for estimating these items is as follows: 
Cost of Notifying EPA of a Closure:  All LQGs that close will incur costs associated with the final rule's notification requirements for LQGs.  Consistent with the unit costs presented above for re-notification, the cost per notification is estimated to be $47.98 per facility.  For the two closure notification requirements (one 30 days prior to notification and another no later than 90 days following closure), this cost is $95.97 per LQG closure.
Average number of LQG closures per year:  Because EPA does not currently require notification for LQG closures at the unit or facility level, comprehensive data on the number of closures occurring each year are not available.  EPA contacted several states to determine if any possess data on LQG closures, and the only state in possession of such data was Connecticut.  Although Connecticut does not currently require facilities to submit notification of closure, the state maintains data on changes in generator status dating back to 1996 that were used to estimate the number of closures. A status change is documented when a hazardous waste generator with an EPA ID number informs the State that it is changing its generator status, for example, from LQG to SQG or SQG to VSQG.  A change from any generator status non-handler is considered a closure.  For closures, Connecticut requires hazardous waste generators to confirm on a status change application form that they closed any storage areas that they ceased using in accordance with the state closure requirements. 
In addition to tracking LQG generator status changes, Connecticut also documented the number of SQGs that changed their generator status to VSQG and the number of SQGs and VSQGs that changed their generator status to non-handler.  Virtually all of the VSQGs that have EPA ID numbers were formerly LQGs or SQGs.  Exhibit 3-6 reports the number of generator status changes and closures in Connecticut between 1996 and 2012.  Over this time period, Connecticut had a total generator universe of approximately 400 LQGs, 1,700 SQGs, and 2,800 VSQGs.
EXHIBIT 3-6:  CONNECTICUT HAZARDOUS WASTE GENERATOR STATUS CHANGES AND CLOSURES FROM 1996 TO 2012
                                Original Status
                                 Ending Status
                           Number of Status Changes
LQG
SQG
                                      199
LQG
VSQG
                                      87
LQG
Non-Handler
                                      152
SQG
VSQG
                                      141
SQG
Non-Handler
                                      231
VSQG
Non-Handler
                                      29
TOTAL GENERATOR STATUS CHANGES
                                      839
TOTAL CLOSURES
                                      412
AVERAGE CLOSURES PER YEAR (all generators)
                                     24.2
AVERAGE LQG CLOSURES PER YEAR
                                      8.9
 
As shown in the exhibit, Connecticut had 152 LQG closures (approximately 9 per year) between 1996 and 2012.  This represents an annual LQG closure rate of approximately 2.2 percent.  Applying this to the 20,771 LQGs in the regulated universe, this RIA estimates there are approximately 464 LQG closures annually.  One limitation is that data are only available at the facility-level, not at the unit level.  Therefore, EPA cannot reliably estimate how many LQGs would be required to document individual waste accumulation unit closures without closing the facility.
Percent of LQGs Closing as a Landfill:  As noted above, the requirement for closing an LQG as a landfill (i.e., with contamination in place) will apply only to LQGs that are unable to remove or decontaminate contaminated soils from their accumulation areas.  Data on the number of closures that meet this criterion are unavailable.  In addition, enforcement personnel contacted in state agencies that implement RCRA are unaware of any LQGs that closed without decontaminating their accumulation areas and suspect that such an occurrence is rare.  Based on this input and the lack of data on closure with contamination in place, this RIA assumes that between zero and one percent of LQGs close with contamination in place in their accumulation areas.   Applying this range to the estimated 464 LQG closures per year, this RIA estimates between zero and five LQGs close as a landfill each year under the final rule.
Additional Costs of Closing as a Landfill:  The additional cost of an LQG closing its CAA as a landfill is uncertain, as EPA is unaware of any documented cases of LQGs closing with contamination remaining in their CAA.  For the purposes of estimating these costs, this RIA assumes that an LQG needs to demolish its concrete floor and stabilize it for disposal, install a new concrete floor, and conduct groundwater monitoring near the facility.  EPA estimated each of these costs using 2010 Remedial Action Cost Engineering and Requirements (RACER) software as follows:
Demolition of Concrete Floor: The estimated cost of demolishing concrete flooring is approximately $829 per facility. 
Floor Disposal: The estimated cost of floor disposal, including transportation, is approximately $2,734 per facility.
New Concrete Floor: The estimated cost of laying a new concrete floor is approximately $3,365 per facility.
Groundwater Monitoring (installation): For each LQG closing as a landfill, this RIA assumes that three monitoring wells would be drilled near each facility: two downslope and one in the immediate vicinity of the facility.  The cost of drilling monitoring wells varies, based largely on well depth.  Under the conservative assumption that a deep well would be necessary for each site, this RIA applies an installation cost of approximately $16,960 per well, plus professional labor management costs of approximately $10,227 and design costs of approximately $2,312, which translates to total well installation costs of $63,421 per LQG closing as a landfill.
Groundwater Monitoring (sampling): Sampling of the three wells drilled near each site is assumed to occur semi-annually, the minimum required under RCRA.  The cost per semi-annual sampling for all three wells combined is an estimated $17,752 per year.  However, the first year sampling costs are estimated to be higher due to the initial design and development of the monitoring systems and the benchmark establishment of recordkeeping and other requirements.  Therefore, the increased cost of first year sampling is estimated to be $28,035 in addition to the regular annual sampling cost of $17,752.  As required under RCRA, monitoring is expected to continue for 30 years after closure.  To capture this recurring cost, this RIA estimates the present value of monitoring for each LQG closing as a landfill.  This value is approximately $386,000 using a 3 percent discount rate and $264,000 using a 7 percent discount rate.
Combining these various cost elements for LQGs closing as a landfill, this RIA estimates the net present value of the closure and post-closure monitoring costs to be $334,089 (using a seven percent discount rate) for every LQG that closes as a landfill.
Exhibit 3-7 reports the unit costs and aggregate annualized costs of closure, including costs associated with the failure to clean close, by facility type.  While closure notification and most closure activities -- with the exception of groundwater monitoring -- are one-time costs on a per facility basis, they are reported as recurring costs of the final rule because a percentage of the LQG universe is expected to close each year.
EXHIBIT 3-7:  ANNUALIZED UNIT COSTS AND AGGREGATE COSTS FOR CLOSURE ($2015 ANNUALIZED OVER 20 YEARS, USING A 7% DISCOUNT RATE)
                               GENERATOR STATUS
                                      [A]
                              LOW IMPACT ESTIMATE
NUMBER OF AFFECTED FACILITIES LIKELY TO INCUR COSTS
                                    [B][a]
                         ANNUALIZED COST PER FACILITY
                           AGGREGATE ANNUALIZED COST
                            TOTAL ANNUALIZED COSTS
                                    [G=E+F]
ONE-TIME COSTS
                                      [C]
                                RECURRING COSTS
                                      [D]
                                ONE-TIME COSTS
                                   [E=BxC]
                                RECURRING COSTS
                                   [F=BxD]

LQG
                                    464 (0)
                                     $0.00
                                   $95.97[b]
                                      $0
                                    $44,500
                                    $44,500
SQG
                                       0
                                     $0.00
                                     $0.00
                                      $0
                                      $0
                                      $0
VSQG
                                       0
                                     $0.00
                                     $0.00
                                      $0
                                      $0
                                      $0
TOTAL
                                    464 (0)
                                      N/A
                                      N/A
                                      $0
                                    $44,500
                                    $44,500
                               GENERATOR STATUS
                                      [A]
                             HIGH IMPACT ESTIMATE
              NUMBER OF AFFECTED FACILITIES LIKELY TO INCUR COSTS
                                    [B][a]
                         ANNUALIZED COST PER FACILITY
                           AGGREGATE ANNUALIZED COST
                            TOTAL ANNUALIZED COSTS
                                    [G=E+F]
                                ONE-TIME COSTS
                                      [C]
                                RECURRING COSTS
                                      [D]
                                ONE-TIME COSTS
                                   [E=BxC]
                                RECURRING COSTS
                                   [F=BxD]

LQG
                                    464 (5)
                                     $0.00
                                   $3,696[c]
                                      $0
                                  $1,710,000
                                  $1,710,000
SQG
                                       0
                                     $0.00
                                     $0.00
                                      $0
                                      $0
                                      $0
VSQG
                                       0
                                     $0.00
                                     $0.00
                                      $0
                                      $0
                                      $0
TOTAL
                                    464 (5)
                                      N/A
                                      N/A
                                      $0
                                  $1,710,000
                                  $1,710,000
Notes:
All aggregate cost estimates are rounded to three significant digits and may not sum due to rounding.
 This RIA assumes 464 LQGs close each year. The values in parentheses in this column represent the estimated number of LQGs that cannot clean close.  The low impact scenario assumes that zero facilities fail to clean close, while the high impact scenario assumes that five facilities fail to clean close each year.  
 This figure reflects the cost of writing and submitting two closure notifications ($47.98 each) per facility to a Regional Administrator (30-days prior to closure and within 90 days following closure).
 This figure reflects multiple costs, including two closure notifications per facility (as described in note b above), and is reported as a weighted average across all affected facilities -- including those that are able to clean close and those that are not. For facilities that fail to clean close, it includes the following costs: (1) concrete floor demolition, $829; (2) floor stabilization and disposal, $2,734; (3) laying a new concrete floor, $3,365; (4) installation of three groundwater monitoring wells, $63,421 = $10,227 labor + $2,312 design + $16,960 installation per well x 3 wells; and (5) the present discounted value of groundwater monitoring for 30 years, $263,741.  Based on these values, the cost per facility that clean closes is $95.97 and the cost per facility that does not clean close is $334,185.  Therefore, the total annualized costs are calculated as follows: (464 x $95.97) + (5 x $334,185) = $1,714,976, which translates to an average per facility cost of approximately $3,696.

3.3.5 EMERGENCY RESPONSE PREPAREDNESS
Under the existing RCRA requirements for prevention, preparedness, and emergency response, LQGs must prepare a contingency plan, attempt to coordinate with local response agencies, and update the plan as needed.  In addition, under the existing requirements SQGs must coordinate with local emergency response authorities.  Under the final rule, LQGs and SQGs must maintain records documenting these arrangements with local emergency responders, or if no arrangement exists, that attempts were made to set up this arrangement.  Currently, EPA estimates that 10 percent of facilities have failed to make arrangements with local emergency responders.  If these facilities document in their operating record that they attempted to make arrangements with state or local authorities, they will be in compliance under the final rule.
Requirements for Existing LQGs and SQGs.  In the first year after the promulgation of the final rule, LQGs and SQGs that do not have arrangements with local emergency responders will have to document their previous attempt to make arrangements.  EPA estimates it takes about 30 minutes (or 0.5 hours) of administrative time for an LQG to re-submit a contingency plan or an SQG to provide information about their facility to local emergency management authorities if they attempt to make arrangements when they have previously been unable to do so.  EPA also estimates it takes all LQGs and SQGs about 6 minutes (or 0.1 hours) of administrative time to document active arrangements with local emergency responders.  Therefore, the average one-time labor cost for a facility without existing arrangements is $13.60 and the average labor cost for a facility with existing arrangements is $2.27.
After the promulgation of the final rule, any LQG that has to update their contingency plan is be required to develop and submit a quick reference guide to their contingency plan to emergency management authorities.  Under existing regulations, any of the following circumstances require an LQG to update their contingency plan:
 Any revision to the applicable regulations following the promulgation of the rule;
 The list of emergency coordinators changes;
 The facility changes its design, operations, or maintenance in a way that necessitates a change in emergency response;
 The facility list of emergency equipment changes; or
 The existing contingency plan fails during an emergency.
There is uncertainty associated with the frequency of events that require an LQG to update their contingency plan as well as the number of potentially affected generators.  Furthermore, only a subset of LQGs will be required to update their contingency plans for facility-specific reasons.  EPA estimates that the most common is a change in the emergency coordinator(s).  Based on an analysis of BR reporting, approximately 33 percent of facilities reported a change in their emergency contact(s) between reporting periods (every two years).  Therefore, EPA estimates that approximately 16.5 percent of LQGs, on average, will be required to update their contingency plans each year following the promulgation of the rule.  The frequency of additional events that necessitate a change in a facility's contingency plan is unknown.  A subset of LQGs may have multiple reasons to update their contingency plans and is already included in the 16.5 percent.  Based on this analysis, 3,427 LQGs (of 20,771 total LQGs) will have to update their contingency plan and submit a quick reference guide each year.
The cost to prepare a stand-alone quick reference guide is estimated as a range.  For the high end of the range, EPA estimates that the cost of developing the quick reference guide is similar to the annual cost to review and update a facility's contingency plan.  EPA assumes it takes approximately 1.5 hours of a technician's time and 1.5 hours of an office clerk's time to perform these activities and 0.5 hours of administrative time to submit the plan to emergency management authorities.  Based on the labor cost values in Exhibit 3-2, these labor hour estimates translate to a cost of approximately $97 per facility to write the guide and a cost of $11.33 to submit it.  For the low end cost estimate, this RIA assumes that LQGs will use the template that EPA released with the final rule to copy and paste information from their more detailed contingency plan.  This process is assumed to reduce the time burden from three hours to two hours (with the cost split between a technician and an office clerk), which reduces the cost to write the guide to approximately $65.  Thus, the total estimated cost of preparing a quick reference guide ranges from $78 to $111 per LQG, including recordkeeping costs of $2.27 or approximately six minutes of administrative time for maintaining documentation of these arrangements.
Requirements for New LQGs.  In addition, the final rule will require all new LQGs to submit a quick reference guide to their contingency plan to emergency management authorities to improve the ability of emergency response teams to respond to an emergency.  As described above in the requirements for existing LQGs, the total cost of preparing a quick reference guide represents an initial one-time cost for each new LQG ranging from $78 to $111 per facility. 
This RIA estimates the annual number of new LQGs using EPA's RCRAInfo database to identify facilities that: (1) submitted an initial RCRA Subtitle C Site Identification Form as an LQG to obtain an EPA ID number; (2) submitted a subsequent RCRA Subtitle C Site Identification Form to change a facility's generator status from VSQG or SQG to LQG; or (3) submitted a BR Hazardous Waste Report Form to change a facility's generator status from VSQG or SQG to LQG.  Using data from 2000 to 2013, EPA estimates that there are approximately 2,350 new facilities entering into the LQG universe every year.[,]  
Requirements for New SQGs.  Under the final rule, new SQGs will have to document their arrangements with emergency management authorities -- or document their attempt to make these arrangements -- and will incur one-time costs similar to facilities with existing arrangements.  New facilities entering into the SQG universe are already required to attempt to make arrangements with local emergency responders; therefore, they will not incur additional costs relative to the baseline beyond documenting these arrangements.  SQGs will not be required to develop a separate quick reference guide.
To estimate the number of new SQGs per year, this RIA applies a similar approach as described above for estimating the number of new LQGs.  Specifically, this RIA estimates the annual number of new SQGs based on initial notifications and changes in generator status from VSQG to SQG as reported in RCRAInfo.  EPA estimates that approximately 2,610 new facilities enter into the SQG universe each year.
Exhibit 3-8 reports the unit costs and aggregate annualized costs for this provision of the rule by facility type.  The exhibit reports one-time costs for existing facilities and recurring costs for the segment of the regulated universe consisting of new LQGs and SQGs each year.  While emergency response preparedness costs are one-time costs on a per facility basis, they are reported as recurring costs because a percentage of the regulated universe is comprised of new facilities entering into the LQG and SQG universe each year.
EXHIBIT 3-8:  ANNUALIZED UNIT COSTS AND AGGREGATE COSTS FOR EMERGENCY RESPONSE PREPAREDNESS ($2015 ANNUALIZED OVER 20 YEARS, USING A 7% DISCOUNT RATE)
                               GENERATOR STATUS
                                      [A]
                              LOW IMPACT ESTIMATE
NUMBER OF AFFECTED FACILITIES LIKELY TO INCUR COSTS[a]
                                      [B]
                         ANNUALIZED COST PER FACILITY
                           AGGREGATE ANNUALIZED COST
                            TOTAL ANNUALIZED COSTS
                                    [G=E+F]
ONE-TIME COSTS[b]
                                      [C]
                              RECURRING COSTS[c]
                                      [D]
                                ONE-TIME COSTS
                                   [E=BxC]
                                RECURRING COSTS
                                   [F=BxD]

LQG
                                20,771 (5,780)
                                     $0.30
                                   $78.47[d]
                                    $6,230
                                   $454,000
                                   $460,000
SQG
                                49,887 (2,610)
                                     $0.30
                                     $2.27
                                    $15,000
                                    $5,910
                                    $20,900
VSQG
                                       0
                                     $0.00
                                     $0.00
                                      $0
                                      $0
                                      $0
TOTAL
                                70,658 (8,390)
                                      N/A
                                      N/A
                                    $21,200
                                   $459,000
                                   $481,000
                               GENERATOR STATUS
                                      [A]
                             HIGH IMPACT ESTIMATE
            NUMBER OF AFFECTED FACILITIES LIKELY TO INCUR COSTS[a]
                                      [B]
                         ANNUALIZED COST PER FACILITY
                           AGGREGATE ANNUALIZED COST
                            TOTAL ANNUALIZED COSTS
                                    [G=E+F]
                               ONE-TIME COSTS[b]
                                      [C]
                              RECURRING COSTS[c]
                                      [D]
                                ONE-TIME COSTS
                                   [E=BxC]
                                RECURRING COSTS
                                   [F=BxD]

LQG
                                20,771 (5,780)
                                     $0.30
                                  $110.90[e]
                                    $6,230
                                   $641,000
                                   $647,000
SQG
                                64,310 (2,610)
                                     $0.30
                                     $2.27
                                    $19,300
                                    $5,910
                                    $25,200
VSQG
                                       0
                                     $0.00
                                     $0.00
                                      $0
                                      $0
                                      $0
TOTAL
                                85,081 (8,390)
                                      N/A
                                      N/A
                                    $25,500
                                   $647,000
                                   $672,000
Notes:
All aggregate cost estimates are rounded to three significant digits and may not sum due to rounding.
 The first value in Column B represents the estimated number of existing facilities that will have to document their arrangements with emergency responders in the first year after the rule's implementation. The value in parentheses represents the estimated number of facilities that will have to submit a quick reference guide (new LQGs and existing LQGs with changes to their contingency plan) or information about their facility (new SQGs) to emergency management authorities each year.
 The one-time costs represent a weighted-average first-year cost of $2.27 for 90 percent of LQGs and SQGs with existing arrangements and $13.60 for 10 percent LQGs and SQGs without existing arrangements. Thus, the weighted-average one-time cost is $3.40 per facility ($0.30 on an annualized basis).
 The recurring costs for LQGs vary by scenario and are described in detail below. The recurring costs for SQGs are identical to the first-year costs for facilities with existing arrangements with emergency responders. These costs are reported on a recurring basis because a percentage of the regulated universe is comprised of new facilities entering into the SQG universe each year.
 The low impact scenario assumes it takes 1 hour of a technician's time and 1 hour of an office clerk's time to prepare a quick reference guide, plus 30 minutes of administrative time to submit it to the local emergency management authority. It also assumes it takes six minutes of administrative time to document active arrangements. Thus, the total estimated cost is $78.47 per LQG.
 The high impact scenario assumes it takes 1.5 hours of a technician's time and 1.5 hours of an office clerk's time to prepare a quick reference guide, plus 30 minutes of administrative time to submit it to the local emergency management authority. It also assumes it takes six minutes of administrative time to document active arrangements. Thus, the total estimated cost is $110.90 per LQG.
3.3.6 TRANSFER FACILTIY REQUIREMENTS
Transporters that store manifested shipments of hazardous waste in containers at a transfer facility for a period of ten days or less are not subject to the regulation under parts 264, 265, 267, 268, and 270.  However, the final rule will change the labeling/marking requirements for transporters using a transfer facility when consolidating the contents of two or more containers with the same hazardous waste into a new container or when combining and consolidating two different hazardous wastes that are compatible with each other.  In this case, the transporter must label all containers with (1) the words "Hazardous Waste" and (2) the applicable EPA hazardous waste codes.
While this provision will require transporters to label bulk/mixed wastes, the final rule's labeling/marking requirements, as outlined above, will assure that all hazardous wastes that transporters receive from SQGs and LQGs meet these labeling requirements.  Thus, transporters will only incur additional costs under this provision for consolidating waste received from VSQGs, which are not otherwise required to comply with the labeling/marking provision of the final rule.  Furthermore, EPA estimates that the vast majority of hazardous waste containers held at transfer facilities for ten days or less are simply held temporarily and then shipped out.  
Based on the above, the costs that transporters will incur depend on the number of VSQGs that send their waste to transfer facilities, the number of containers that are consolidated, and the labeling costs associated with bulk/mixed wastes.  As an initial step in estimating the number of VSQGs in the regulated universe that send their hazardous waste to transfer facilities, this RIA assumes that the VSQGs engaged in this practice will include a subset of (1) those VSQGs located in states that do not allow VSQGs to manage their hazardous waste as MSW and (2) those VSQGs located in other states (i.e., states that allow VSQGs to dispose of hazardous waste in MSW landfills), but that choose to manage their hazardous waste at a permitted TSDF.  Industry and state agency data suggest that 32 states and the District of Columbia currently allow VSQGs to manage their hazardous waste through MSW landfill disposal.  These states are estimated to account for between 157,000 and 294,000 VSQGs.  This RIA assumes that 10 percent of these VSQGs manage their hazardous waste at a TSDF.  In the remaining states that have landfill bans, which account for between 196,000 and 297,000 VSQGs, this RIA assumes that all VSQGs send their waste to a TSDF, bringing the total number of VSQGs managing their hazardous waste at a TSDF to 212,000 to 327,000 facilities.  Of these VSQGs, this RIA estimates that approximately 12 percent send their hazardous waste to a transfer facility, consistent with the percentage of SQGs in the 2013 BR database that send their waste to such a facility.  In the absence of data specific to VSQGs, the SQG percentage is assumed to apply to VSQGs as well.  Based on this assumption, an estimated 25,000 to 39,000 VSQGs send their hazardous waste to a transfer facility each year.
EPA estimates that there are 264 transfer facilities nationwide.  These facilities are a subset of generators in the regulated universe because they may consolidate hazardous waste and are therefore subject to the same requirements as generators.  According to 2013 BR data, the vast majority of these facilities (approximately 97 percent) are LQGs.  Furthermore, EPA estimates that transfer facilities that self-identified as SQGs or VSQGs, are in fact LQGs based on the amount of hazardous waste they generate each year.  Specifically, the waste generation quantities reported for each of these facilities exceeds the upper limit for an SQG.  
The transfer facility costs associated with complying with the requirements for new consolidated wastes from LQGs and SQGs are already incurred in the baseline.  Therefore, the only incremental cost of complying with the final rule is the labeling of bulk/mixed hazardous waste received from VSQGs.  Based on the number of VSQGs and the number of transfer facilities in the regulated universe, each transfer facility is assumed to manage waste for between 96 and 149 VSQGs each year, on average.  And each VSQG is estimated to generate between 5 and 6 containers of hazardous waste each year, for a total of between 482 and 892 containers per transfer facility per year.  EPA estimates that only 1 percent of these containers will be consolidated -- or between 5 and 9 containers per transfer facility per year.
The cost of labeling bulk/mixed hazardous waste received from VSQGs is estimated to be $3.52 per container, which reflects five minutes of a technician's time to write the required information on each container.  VSQGs are already required to apply simple labels with the words "hazardous waste" to all containers sent to a TSDF in the baseline.  The costs of this provision represent labeling costs above and beyond those incurred in the baseline.
Exhibit 3-9 reports the annualized unit and aggregate costs of enhanced labeling under the transfer facility requirements of the final rule by facility type.  The estimated cost per transfer facility to comply with the additional marking and labeling requirements ranges from $17 to $31 per year.
EXHIBIT 3-9:  ANNUALIZED UNIT AND AGGREGATE COSTS FOR TRANSFER FACILITY REQUIREMENTS ($2015 ANNUALIZED OVER 20 YEARS, USING A 7% DISCOUNT RATE)
                               GENERATOR STATUS
                                      [A]
                              LOW IMPACT ESTIMATE
NUMBER OF AFFECTED FACILITIES LIKELY TO INCUR COSTS
                                      [B]
                         ANNUALIZED COST PER FACILITY
                           AGGREGATE ANNUALIZED COST
                            TOTAL ANNUALIZED COSTS
                                    [G=E+F]
ONE-TIME COSTS
                                      [C]
                              RECURRING COSTS[a]
                                      [D]
                                ONE-TIME COSTS
                                   [E=BxC]
                                RECURRING COSTS
                                   [F=BxD]

LQG
                                      264
                                     $0.00
                                      $17
                                      $0
                                    $4,470
                                    $4,470
SQG
                                       0
                                     $0.00
                                      $17
                                      $0
                                      $0
                                      $0
VSQG
                                       0
                                     $0.00
                                      $17
                                      $0
                                      $0
                                      $0
TOTAL
                                      264
                                      N/A
                                      N/A
                                      $0
                                    $4,470
                                    $4,470
                               GENERATOR STATUS
                                      [A]
                             HIGH IMPACT ESTIMATE
              NUMBER OF AFFECTED FACILITIES LIKELY TO INCUR COSTS
                                      [B]
                         ANNUALIZED COST PER FACILITY
                           AGGREGATE ANNUALIZED COST
                            TOTAL ANNUALIZED COSTS
                                    [G=E+F]
                                ONE-TIME COSTS
                                      [C]
                              RECURRING COSTS[a]
                                      [D]
                                ONE-TIME COSTS
                                   [E=BxC]
                                RECURRING COSTS
                                   [F=BxD]

LQG
                                      264
                                     $0.00
                                      $31
                                      $0
                                    $8,280
                                    $8,280
SQG
                                       0
                                     $0.00
                                      $31
                                      $0
                                      $0
                                      $0
VSQG
                                       0
                                     $0.00
                                      $31
                                      $0
                                      $0
                                      $0
TOTAL
                                      264
                                      N/A
                                      N/A
                                      $0
                                    $8,280
                                    $8,280
Notes:
All aggregate cost estimates are rounded to three significant digits and may not sum due to rounding.
 This figure represents the cost of labeling containers of bulk/mixed waste, which reflects 5 minutes of a technician's time to write the required information on each container.
3.3.7 BR REQUIREMENTS
The final rule makes a clarifying change to the biennial reporting requirements for LQGs.  Specifically, it requires LQGs to report all of the hazardous waste that they generate for the entire reporting year, not just quantities for the month(s) during which they were LQGs.  Existing regulation is unclear on this issue and a limited number of states currently require LQGs to report the amount of hazardous waste generated for only those months that they were LQGs.
Report all waste generated for the year and not just the months that a facility is an LQG.  As noted above, EPA is requiring that facilities qualifying for LQG status for part of the year report their waste generation for the full year.  Anecdotal accounts suggest that LQGs in some states complete biennial reports only for the months during which they cross the LQG threshold during the year.  In addition, in a survey of 26 states, three states reported that they did not require one-time or short-term LQGs to report the amount of hazardous waste they generate for the entire calendar year.   Idaho and West Virginia reported that they required these facilities to report the amount of hazardous waste they generated only for the months they were LQGs.  South Carolina reported that it required facilities to report the amount of hazardous waste they generated for the remainder of the calendar year after they exceeded the monthly LQG generation threshold.  EPA is unaware of any other states in which this reporting gap exists.
Limited information is available on episodic generation in Idaho, South Carolina, and West Virginia.  In these three states there are 553 LQGs, between 1,100 and 1,116 SQGs, and between 9,423 and 17,333 VSQGs.  For the 553 LQGs, the costs of the rule are estimated as a range.  The low end of the range assumes that these facilities report for two months of the year in the baseline and that their baseline reporting covers all of their waste streams, but underreports generation for those waste streams.  Therefore, for the low scenario, the cost for these facilities is the cost to gather additional information on the existing waste streams.  This cost is estimated to be $21 per facility.  The high end assumes that the number of waste streams that these facilities report in the baseline covers two months of the year and that this temporal coverage is proportional to the number of waste streams reported in the baseline.  Thus, if the mean number of waste streams generated by LQGs is 13, this RIA assumes that 3 are reported in the baseline and 10 are newly reported under the rule, at a cost of $21.02 per waste stream.
This requirement of the rule will also affect VSQGs and SQGs that become LQGs in these three states.  Data from EPA's RCRAInfo database suggest that nationwide 1.4 to 1.8 percent of SQGs and 0.1 to 0.2 percent of VSQGs each year notify EPA of a change in their generator status to LQG (i.e., submitting BR records as an LQG when they were previously an VSQG or SQG).  Applying this to the number of SQGs and VSQGs in West Virginia, Idaho, and South Carolina, this RIA estimates that the three states combined are home to 14 to 19 SQG episodic generators and 7 to 22 VSQG episodic generators.  This RIA conservatively assumes that all these episodic generators have just one month-long episodic event each year that exceeds the monthly LQG generation threshold.  Furthermore, these facilities are assumed to submit BR reports for one to two waste streams in the baseline (1/12 of the baseline values of 6 and 13 for LQGs).  Therefore, the cost of BR reporting for SQGs and VSQGs that are episodic generators in these states is the time and materials to prepare an additional GM form for each of the unreported waste streams, between 5 and 11 per facility -- approximately $105 to $231 per facility per reporting year.
Exhibit 3-10 reports the annualized unit and aggregate costs of BR reporting under the final rule by facility type.  All of the reported costs are incurred on a biennial basis in even-numbered years.  Therefore, there are no one-time costs associated with this provision of the rule.
EXHIBIT 3-10:  ANNUALIZED UNIT AND AGGREGATE COSTS FOR BR REQUIREMENTS ($2015 ANNUALIZED OVER 20 YEARS, USING A 7% DISCOUNT RATE)
                               GENERATOR STATUS
                                      [A]
                              LOW IMPACT ESTIMATE
NUMBER OF AFFECTED FACILITIES LIKELY TO INCUR COSTS
                                      [B]
                         ANNUALIZED COST PER FACILITY
                           AGGREGATE ANNUALIZED COST
                            TOTAL ANNUALIZED COSTS
                                    [G=E+F]
ONE-TIME COSTS
                                      [C]
                                RECURRING COSTS
                                      [D]
                                ONE-TIME COSTS
                                   [E=BxC]
                                RECURRING COSTS
                                   [F=BxD]

LQG
                                      553
                                     $0.00
                                   $11.02[a]
                                      $0
                                    $6,100
                                    $6,100
SQG
                                      14
                                     $0.00
                                   $54.33[b]
                                      $0
                                     $761
                                     $761
VSQG
                                       7
                                     $0.00
                                   $54.33[b]
                                      $0
                                     $380
                                     $380
TOTAL
                                      574
                                      N/A
                                      N/A
                                      $0
                                    $7,240
                                    $7,240
                               GENERATOR STATUS
                                      [A]
                             HIGH IMPACT ESTIMATE
              NUMBER OF AFFECTED FACILITIES LIKELY TO INCUR COSTS
                                      [B]
                         ANNUALIZED COST PER FACILITY
                           AGGREGATE ANNUALIZED COST
                            TOTAL ANNUALIZED COSTS
                                    [G=E+F]
                                ONE-TIME COSTS
                                      [C]
                                RECURRING COSTS
                                      [D]
                                ONE-TIME COSTS
                                   [E=BxC]
                                RECURRING COSTS
                                   [F=BxD]

LQG
                                      553
                                     $0.00
                                    $119.67
                                      $0
                                    $66,200
                                    $66,200
SQG
                                      19
                                     $0.00
                                  $119.52[b]
                                      $0
                                    $2,270
                                    $2,270
VSQG
                                      22
                                     $0.00
                                  $119.52[b]
                                      $0
                                    $2,630
                                    $2,630
TOTAL
                                      594
                                      N/A
                                      N/A
                                      $0
                                    $71,100
                                    $71,100
Notes:
All aggregate cost estimates are rounded to three significant digits and may not sum due to rounding.
 This figure represents data collection labor costs totaling $21.33 per facility on a biennial basis in even numbered years ($11.02 on an annualized basis) for 533 LQGs in states that require short-term LQGs to report the amount of hazardous waste they generate only for the months they are LQGs. In addition, the high-end estimate assumes that 10 additional GM forms must be submitted at an average cost of $21.02 per GM form ($10.87 on an annualized basis).
 This figure represents a labor cost of $21.02 per GM form ($10.87 on an annualized basis) x 5 additional GM forms per SQG and VSQG in the low impact scenario (or 11 additional GM forms in the high impact scenario). These costs are incurred on a biennial basis in even-numbered years.

3.3.8 BR REQUIREMENTS FOR RECYCLING FACILITIES
The final rule requires recyclers of hazardous waste who do not store before recycling to submit a biennial report to EPA.  Under the existing regulations in 40 CFR 261.6, which identifies the requirements for recyclable materials, certain classes of recycling facilities are exempt from the BR reporting requirements so long as they are not required to be permitted as a TSDF.  The final rulemaking adds the BR requirement to 40 CFR 261.6 (c) (2).  However, many recycling facilities currently submit biennial reports to EPA under 40 CFR 265.75 because they are TSDFs or are otherwise considered to be LQGs and thus are subject to 40 CFR 262, which identifies the standards applicable to generators of hazardous waste.  In addition, EPA estimates that there are between 10 and 20 recycling facilities currently subject to CFR 261 that would have to submit a BR under the final rule.
The fixed costs of preparing a biennial report by the affected recycling facilities include the time to read the instructions, complete the site ID form, submit the report to EPA or State authorities, and maintain a copy of the report for three years.  EPA estimates that the cost of these activities is approximately $286 per facility.  Additionally, the variable cost of completing a GM form for each waste stream included in the BR submission is $21.02. EPA estimates that, similar to LQGs, these recycling facilities manage between six (the median) and thirteen (the mean) waste streams per year. Exhibit 3-11 reports the annualized unit and aggregate costs of BR reporting requirements for recycling facilities under the final rule. 
EXHIBIT 3-11:  ANNUALIZED UNIT AND AGGREGATE COSTS FOR BR REQUIREMENTS FOR RECYCLING FACILITIES ($2015 ANNUALIZED OVER 20 YEARS, USING A 7% DISCOUNT RATE)
                               GENERATOR STATUS
                                      [A]
                              LOW IMPACT ESTIMATE
NUMBER OF AFFECTED FACILITIES LIKELY TO INCUR COSTS
                                      [B]
                         ANNUALIZED COST PER FACILITY
                           AGGREGATE ANNUALIZED COST
                            TOTAL ANNUALIZED COSTS
                                    [G=E+F]
ONE-TIME COSTS
                                      [C]
                                RECURRING COSTS
                                      [D]
                                ONE-TIME COSTS
                                   [E=BxC]
                                RECURRING COSTS
                                   [F=BxD]

Recycling Facility
                                      10
                                     $0.00
                                  $212.83[a]
                                      $0
                                    $2,130
                                    $2,130
                               GENERATOR STATUS
                                      [A]
                             HIGH IMPACT ESTIMATE
              NUMBER OF AFFECTED FACILITIES LIKELY TO INCUR COSTS
                                      [B]
                         ANNUALIZED COST PER FACILITY
                           AGGREGATE ANNUALIZED COST
                            TOTAL ANNUALIZED COSTS
                                    [G=E+F]
                                ONE-TIME COSTS
                                      [C]
                                RECURRING COSTS
                                      [D]
                                ONE-TIME COSTS
                                   [E=BxC]
                                RECURRING COSTS
                                   [F=BxD]

Recycling Facility
                                      20
                                     $0.00
                                  $288.89[b]
                                      $0
                                    $5,780
                                    $5,780
Notes:
All aggregate cost estimates are rounded to three significant digits and may not sum due to rounding.
 This figure represents data collection labor costs totaling $286 per facility plus an average cost of $21.02 per GM form x 6 GM forms per facility on a biennial basis in even numbered years for a total cost of $411.74 ($212.83 on an annualized basis) for the low-impact estimate.
 This figure represents data collection labor costs totaling $286 per facility plus an average cost of $21.02 per GM form x 13 GM forms per facility on a biennial basis in even numbered years for a total cost of $558.88 ($288.89 on an annualized basis) for the high-impact estimate.

3.3.9 PROHIBITIONS ON STORAGE OF RESTRICTED WASTE FOR TSDFs
Consistent with the marking and labeling requirements for SQGs and LQGs, EPA is requiring that TSDFs mark containers holding hazardous waste with (1) the words "Hazardous Waste" and (2) an indication of the hazards of a container's contents.  Under existing regulations, TSDFs must already mark containers holding hazardous waste with a description of the contents of the container.  
Wastes subject to the requirements of this provision will likely be in compliance due to the labeling/marking and transfer facility requirements outlined above.  This RIA therefore estimates no additional costs for this provision.
3.3.10 DRIP PAD AND CONTAINMENT BUILDING REQUIREMENTS
Under the existing regulations, EPA has consistently interpreted the requirements for LQGs subject to 40 CFR Part 265 Subparts W and DD to also apply to SQGs that accumulate hazardous waste on drip pads or in containment buildings for 90 days or less without a permit or interim status.  Although there are no explicit requirements for SQGs, EPA intended for SQGs to comply with all of the LQG conditions for an exemption associated with the accumulation of hazardous waste, as well as any associated independent requirements for LQGs or else obtain a Part B permit for their drip pads or containment buildings.  While SQGs may normally accumulate hazardous waste in primary accumulation areas or SAAs for 180 days, the maximum generator accumulation time period for drip pads or containment buildings is 90 days.  The current regulations also imply that generators using drip pads or containment buildings must comply with the requirements that apply to LQGs for personnel training, emergency response preparedness, and biennial reporting.  In contrast, if an SQG accumulates hazardous waste in containers, it can comply with the less stringent requirements for SQGs, including accumulation of hazardous waste for up to 180 days.
Under the final rule, EPA believes a more effective and efficient approach is to require SQGs that accumulate hazardous waste in containment buildings to comply with the LQG 90-day accumulation limit (as opposed to the SQG 180-day accumulation limit) and SQGs that accumulate hazardous waste on drip pads to comply with the 180-day accumulation limit, but to otherwise comply with the less stringent requirements for SQGs.  Only hazardous waste that is accumulated in containment buildings must be managed in compliance with the LQG accumulation limits.  
EPA estimates that there are 12 SQGs and 22 LQGs that accumulate hazardous waste in containment buildings.  EPA also estimates that there are 295 SQGs and 95 LQGs that accumulate hazardous waste on drip pads.  Under the final rule, LQGs and SQGs that accumulate hazardous waste in containment buildings must comply with the labeling requirements described in the previous section on labeling/marking.  The costs associated with this requirement are reported above and are not repeated here to avoid double-counting.  
Under the existing technical requirements for drip pads (40 CFR 265.444) and containment buildings (40 CFR 265.1101), LQGs and SQGs that accumulate hazardous waste on drip pads or in containment buildings are required to conduct weekly inspections and, in the case of containment buildings, document the results in their operating record.  In situations when a release from a drip pad or a containment building occurs, generators are required to notify their authorized state within 24 hours after discovery.  Thus, there are no incremental costs associated with the inspection documentation requirements under the final rule as these requirements already exist under current regulations.  Furthermore, SQGs that accumulate hazardous waste on drip pads or in containment buildings will realize a net cost savings, as described in the discussion of benefits in Chapter 4.
3.3.11 INTRA-ORGANIZATIONAL TRANSFERS (VOLUNTARY)
To afford greater flexibility to VSQGs, the final rule will allow VSQGs to send their hazardous waste to an LQG under the control of the same person, provided that both the VSQG(s) and LQG comply with certain conditions.  The VSQG conditions are as follows:
       A participating VSQG must label containers with the words "VSQG Hazardous Waste" and an indication of the hazards of a container's contents (e.g., the applicable hazardous waste characteristic). 
       VSQGs must comply with all applicable DOT regulations when sending their hazardous waste to an LQG. 
The final conditions for LQGs receiving hazardous waste from one or more VSQGs under the same organizational structure include the following:
       LQGs must submit a notification to EPA or their authorized state identifying the names, addresses, and contact information for the VSQGs that will be transferring hazardous waste to the LQG.
       LQGs must maintain records of all hazardous waste received from VSQGs that include the name, address, and contact information for each VSQG, as well as information on the quantity of each waste shipment received.
       LQGs mark shipments from VSQGs with the date the hazardous waste was received from the VSQG.
       LQGs will be required to manage all incoming VSQG hazardous waste in compliance with the regulations applicable to their LQG status.
       Hazardous waste received from VSQGs needs to be included in the receiving LQG's BR submissions. 
Estimating the costs associated with this portion of the final rule requires information on (1) the number of VSQGs that may consolidate to an LQG and the number of LQGs that may receive VSQG waste, (2) the per facility costs for affected VSQGs, and (3) the per facility costs for LQGs receiving VSQG waste.  
Number of VSQGs and LQGs opting for this rule provision: The number of entities that may take advantage of the flexibility provided by this portion of the final rule is uncertain.  The sources of this uncertainty include the lack of information indicating the extent to which eligible facilities will take advantage of this rule provision and the limited data available on the number of VSQGs that are eligible (i.e., are owned by organizations that also own at least one LQG).  With respect to the former, the VSQGs that take advantage of this rule provision may be split into two groups:
 VSQGs in states that allow MSW landfill disposal of VSQG hazardous waste but send their hazardous waste to a permitted TSDF: As indicated in the discussion regarding the final rule's transfer facility provision, industry and state data suggest that 32 states and the District of Columbia currently allow VSQGs to manage their hazardous waste through MSW landfill disposal.  Facilities in these states are estimated to account for between 45 and 50 percent of the potentially affected universe of VSQGs, or between 157,000 and 294,000 VSQGs.  This RIA assumes that 90 percent of the VSQGs in these states dispose of their hazardous waste as MSW and that 10 percent send their hazardous waste to a permitted TSDF.  The VSQG facilities that dispose of their hazardous waste in MSW landfills are assumed to continue to manage their hazardous waste as MSW (and not consolidate their waste through LQGs owned by the same organization) because of the relatively low cost of this disposal option.  Of the remaining 15,700 to 29,400 VSQGs that are located in states that allow the MSW landfill disposal of VSQG hazardous waste, but choose to send their waste to a TSDF, this RIA assumes that VSQGs owned by organizations that also own LQGs consolidate their waste to an LQG.
 VSQGs in states that prohibit MSW landfill disposal of VSQG hazardous waste: In states that prohibit the MSW landfill disposal of VSQG hazardous waste, all VSQGs owned by organizations that also own one or more LQGs are assumed to consolidate their VSQG hazardous waste to an LQG.  These states account for an estimated 196,000 to 297,000 VSQGs.
Combined, these two groups represent between 212,000 and 327,000 VSQGs.
To estimate the percentage of VSQGs owned by companies that also own at least one LQG, this RIA relies on facility-level data collected from Florida, Maine, Massachusetts, New Hampshire, Oregon, and Wisconsin.  Each of these states provided the name, address, and generator status of active hazardous waste generators within their borders, but lacked information on the ownership structure of facilities.  Absent this ownership information, a matching algorithm based on facility names was used to identify the ultimate owner.  First, generators in each state that had the same organization name were identified.  Then, organizations owning multiple generators (including at least one VSQG facility and one LQG facility) within the same state were identified.  For bordering states (i.e., Maine-Massachusetts-New Hampshire), facilities located in adjacent states were also included in the analysis.  Three of the states analyzed (Florida, New Hampshire, and Oregon) allow VSQGs to dispose of waste in MSW landfills.  For these states, 90 percent of all VSQGs are assumed to use MSW disposal and 10 percent are assumed to send waste to a TSDF.  For the other three states, all VSQGs are assumed to send waste to a TSDF.  Furthermore, for all states, VSQGs that are part of a larger organization are assumed to manage their waste at a TSDF.  Finally, we divide the number of VSQGs that are part of a larger organization that could potentially consolidate waste by the number of VSQGs that send waste to a TSDF in the baseline.  This RIA then applies this percentage to the total number of VSQGs nationwide that send waste to a TSDF. 
The limitations of this approach are: (1) some states did not have information on the generator status of all facilities (e.g., Massachusetts only reported generator status for approximately 80 percent of facilities); (2) facility names do not necessarily identify the ultimate owner, therefore it is difficult to determine whether generators are owned by the same organization; and (3) the states used to estimate the percentage of VSQGs that could consolidate their waste may not be representative of other states in the U.S. 
Based on this review of the state data, an estimated 9.7 percent of VSQGs that manage their waste at TSDFs are part of an organization that owns multiple generators (including at least one LQG) in the same state or a bordering state.  Similarly, LQGs that are part of an organization that owns multiple generators (including at least one VSQG) in the same or a bordering state -- and could potentially serve as a consolidation facility -- account for approximately 33.7 percent of all LQGs.  Therefore, this RIA estimates that between 20,569 and 31,738 VSQGs could potentially manage their waste through consolidation with an LQG facility under the control of the same person and approximately 3,537 LQGs could potentially act as consolidators.  Thus, on average, each LQG could potentially consolidate waste for between approximately 6 and 9 VSQGs.  The facility-level costs of intra-organizational consolidation are described below.
VSQG costs per facility:  Under the requirements of the rule, VSQGs will incur two specific costs if they send their hazardous waste to an LQG owned by the same organization: (1) costs associated with labeling their containers consistent with the requirements outlined above and (2) costs related to transporting their hazardous waste to an LQG.  VSQGs are required to apply simple labels with the words "hazardous waste" to all containers sent to a TSDF in the baseline.  The labeling costs described above represent the incremental cost above and beyond the current RCRA requirements for VSQGs in the baseline.  Based on the average quantity of waste and number of waste streams per VSQG presented in Chapter 2 this RIA estimates that the average VSQG generates between five and six partially-filled 55-gallon drums of hazardous waste per year.  Consistent with the VSQG labeling costs presented above for the final rule's transfer facility provision, the cost of labeling each drum in compliance with the rule's requirements is approximately $3.52, or five minutes of a technician's time per drum to write by hand the hazards of a container.  Combined, these tally to labeling costs of between $17.59 and $21.11 per VSQG. 
With respect to the cost of transporting hazardous waste to an LQG, VSQGs are assumed to comply with all existing DOT regulations.  This RIA assumes that large organizations will rely on an existing fleet of hazmat trucks to transport waste from a VSQG to an LQG or rely on a hazardous waste transporter within their own delivery network.  These trucks are already required to comply with all DOT regulations.  Furthermore, VSQGs that currently send their waste to a TSDF will likely incur similar transportation costs to send that waste to an LQG consolidation facility if they used another authorized carrier.  Therefore, the transportation costs for a VSQG will be similar to the baseline, i.e., there are zero incremental transportation costs. 
LQG costs per facility:  LQGs that receive waste from VSQGs owned by the same organization will incur costs associated with notifying EPA of the transfer, marking the date that waste is received from a VSQG, maintaining records of the waste received, and including the waste received from VSQGs in their BR submission.
The additional burden for LQGs to notify EPA or a state authority of intra-organizational consolidation is assumed to be a one-time cost of $47.58 per LQG facility, consistent with the cost of a generator notifying EPA of its own generation activity.  To estimate the costs associated with marking the date that VSQG-generated waste is received by an LQG, this RIA assumes it takes two minutes of a technician's time per shipment to mark the shipments received from VSQGs, which translates to $8.18 to $12.63 per LQG receiving VSQG waste (based on the range of 6 to 9 VSQGs consolidating to an LQG).  Similarly, this RIA assumes that it requires approximately six minutes of a technician's time to maintain records of all waste received, which represents a cost of $4.22 per LQG. 
To estimate the costs associated with LQGs reporting the additional waste from VSQGs in their BR submissions, this RIA assumes that each additional waste stream received from VSQGs will require one additional GM form, at an estimated cost of $21.02 per form.  Based on a range of five to six waste streams per VSQG (see Exhibit 3-1), this translates to additional BR reporting costs of $105.10 to $126.12 per VSQG from which an LQG receives hazardous waste (on a biennial basis).  This RIA conservatively assumes that there is no duplication of waste streams between VSQGs owned by the same company and/or between VSQGs and the LQG that is consolidating the waste, and that similar waste streams are not combined.  As noted above, each eligible LQG is estimated to receive hazardous waste from 6 to 9 VSQGs.
Combined, these requirements for LQGs -- notification, marking shipments from VSQGs with the date received, maintaining records of waste received, and BR reporting -- result in annualized costs of approximately $349 to $635 per facility (using a seven percent discount rate) for eligible LQGs.
Total cost of intra-organizational transfers: Exhibit 3-11 reports the annualized unit and aggregate costs of VSQG consolidation under this voluntary provision of the final rule.  Costs are also broken out by one-time and recurring costs (e.g., annual and biennial costs).  
The intra-organizational transfer provision of the final rule may also result in cost savings for some entities.  Specifically, the potential cost savings may include a lower average cost of hazardous waste disposal.  These cost savings, and other benefits of the rule, are discussed in greater detail in Chapter 4 of this RIA.
EXHIBIT 3-12:  ANNUALIZED UNIT AND AGGREGATE COSTS FOR INTRA-ORGANIZATIONAL TRANSFERS ($2015 ANNUALIZED OVER 20 YEARS, USING A 7% DISCOUNT RATE)
                               GENERATOR STATUS
                                      [A]
                              LOW IMPACT ESTIMATE
NUMBER OF AFFECTED FACILITIES LIKELY TO INCUR COSTS
                                      [B]
                         ANNUALIZED COST PER FACILITY
                           AGGREGATE ANNUALIZED COST
                            TOTAL ANNUALIZED COSTS
                                    [G=E+F]
ONE-TIME COSTS
                                      [C]
                                RECURRING COSTS
                                      [D]
                                ONE-TIME COSTS
                                   [E=BxC]
                                RECURRING COSTS
                                   [F=BxD]

LQG[a]
                                     3,537
                                   $24.62[b]
                                  $348.65[c]
                                    $87,100
                                  $1,230,000
                                  $1,320,000
SQG
                                       0
                                     $0.00
                                     $0.00
                                      $0
                                      $0
                                      $0
VSQG
                                    20,569
                                     $0.00
                                   $17.59[d]
                                      $0
                                   $362,000
                                   $362,000
TOTAL
                                    24,106
                                      N/A
                                      N/A
                                    $87,100
                                  $1,590,000
                                  $1,680,000
                               GENERATOR STATUS
                                      [A]
                             HIGH IMPACT ESTIMATE
              NUMBER OF AFFECTED FACILITIES LIKELY TO INCUR COSTS
                                      [B]
                         ANNUALIZED COST PER FACILITY
                           AGGREGATE ANNUALIZED COST
                            TOTAL ANNUALIZED COSTS
                                    [G=E+F]
                                ONE-TIME COSTS
                                      [C]
                                RECURRING COSTS
                                      [D]
                                ONE-TIME COSTS
                                   [E=BxC]
                                RECURRING COSTS
                                   [F=BxD]

LQG[e]
                                     3,537
                                   $37.98[f]
                                  $635.47[g]
                                   $134,000
                                  $2,250,000
                                  $2,380,000
SQG
                                       0
                                     $0.00
                                     $0.00
                                      $0
                                      $0
                                      $0
VSQG
                                    31,738
                                     $0.00
                                   $21.11[h]
                                      $0
                                   $670,000
                                   $670,000
TOTAL
                                    35,275
                                      N/A
                                      N/A
                                   $134,000
                                  $2,920,000
                                  $3,050,000
Notes:
All aggregate cost estimates are rounded to three significant digits and may not sum due to rounding.
 LQGs that can consolidate hazardous waste are assumed to manage waste for an average of 5.8 VSQGs in the low impact scenario.
 This represents a first-year cost of $279.04 per facility ($24.62 on an annualized basis) for notification ($47.98 per VSQG x 5.8 VSQGs per LQG).
 This represents the sum of three recurring costs multiplied by 5.8 VSQGs per LQG facility: (1) an annual cost of $1.41 for labeling; (2) an annual cost of $4.22 for recordkeeping; and (3) a cost of $105.10 for BR submissions ($54.33 on an annualized basis), which is incurred every even-numbered year when reporting is required. Thus, the total annualized cost is $348.65 per facility.
 This represents the VSQG cost of labeling five drums per year with the hazards of the container's contents (a cost of $3.52 per container).
 LQGs that can consolidate hazardous waste are assumed to manage waste for an average of 9.0 VSQGs in the high impact scenario.
 This represents a first-year cost of $430.57 per facility ($37.98 on an annualized basis) for notification ($47.98 per VSQG x 9.0 VSQGs per LQG).
 This represents the sum of three recurring costs multiplied by 9.0 VSQGs per LQG facility: (1) an annual cost of $1.41 for labeling; (2) an annual cost of $4.22 for recordkeeping; and (3) a cost of $126.12 for BR submissions ($65.19 on an annualized basis), which is incurred every even-numbered year when reporting is required. Thus, the total annualized cost is $635.47 per facility.
 This represents the VSQG cost of labeling six drums per year with the hazards of the container's contents (a cost of $3.52 per container).

3.3.12 EPISODIC GENERATION (VOLUNTARY)
To provide greater flexibility to VSQGs and SQGs that generate much of their hazardous waste on an episodic basis, the final rule will allow a VSQG or an SQG to maintain its existing regulatory status in the event of a planned or unplanned episodic event in which the facility generates a quantity of hazardous waste in a calendar month that would otherwise elevate the facility to a more stringent regulatory status.  To take advantage of this provision, an SQG or VSQG will be subject to the following conditions:
 A limit of one planned and one unplanned episodic events  per calendar year each lasting no more than 60 days (generators must petition for a second episodic event);
 Notification to EPA or the authorized state at least 30 calendar days prior to initiating a planned episodic event or within 72 hours of an unplanned episodic event;
 VSQGs must obtain a RCRA ID number;
 Facilities must meet the following accumulation standards: 
             VSQGs must mark containers with the date the episodic event began; label containers "Episodic Hazardous Waste;" manage hazardous waste in a manner that minimizes the possibility of a fire, explosion, or release of hazardous waste; ensure that tanks are in good condition and compatible with the hazardous waste stored within; and identify an emergency coordinator for the duration of the event;
             SQGs must mark the container or tank log book with the date the episodic event began; label the container or write in the tank log book "Episodic Hazardous Waste"; mark the container or write in the tank log book words that indicate the hazards of the contents; and comply with the applicable accumulation conditions for SQGs;
 Hazardous waste generated from the episodic event must be managed on-site or manifested and shipped off-site to a permitted TSDF;
 Facilities must complete and maintain records that include (1) the beginning and end dates of the event, (2) a description of the event, (3) the types and quantities of hazardous wastes generated at the event, (4) a description of how the hazardous waste was managed, and (5) name(s) of hazardous waste transporters that transported the waste to a permitted TSDF.
This RIA assumes that facilities already ensure containers are in good condition and compatible with the hazardous waste stored within them and manage hazardous waste in a manner that minimizes the possibility of a fire, explosion, or a release.  Furthermore, this RIA assumes that facilities that do not take advantage of the flexibility provided by the episodic generation provision of the final rule will experience no change in costs relative to the baseline. 
The costs associated with this portion of the rule depend on the following variables: (1) the estimated number of episodic generators in the regulated universe, (2) the average quantity of hazardous waste associated with each episodic event, (3) the number of waste streams associated with each event, and (4) the costs associated with the various activities included in the conditions outlined above. 
Number of episodic generators:  To estimate the number of episodic generators in the potentially affected universe, this RIA relies on data from EPA's RCRAInfo database.  Specifically, changes in generator status identified in RCRAInfo are assumed to be indicative of episodic generation events.  RCRAInfo data from 2000 to 2013 are used to identify facilities that: (1) initially submitted a RCRA Subtitle C Site Identification Form to obtain an EPA ID number as an SQG and later re-notified EPA to indicate a change in their generator status from SQG to LQG; (2) obtained an EPA ID number as a VSQG and later re-notified EPA to indicate a change in their generator status from VSQG to LQG; or (3) obtained an EPA ID number as a VSQG and then reported a change in their generator status from VSQG to SQG.  Using this method, EPA estimates that approximately 2,500 facilities report a change in their generator status each year.  These data suggest that 1.3 to 1.7 percent of SQGs and 0.2 to 0.4 percent of VSQGs nationwide report a change in their generator status annually.  
Of these episodic generators, the number meeting the eligibility conditions for this provision of the final rule (e.g., no more than two episodic generation events per year lasting 60 days or less each) is uncertain.  Neither EPA nor any state agencies maintain data on monthly generation of hazardous waste.  To address this uncertainty, this RIA estimates the number of eligible facilities as a range.  The low end of the range assumes that 50 percent of the episodic generators characterized above will be eligible, while the high end assumes that all episodic generators will be eligible.  Based on these assumptions, Exhibit 3-12 reports the estimated breakdown of changes in generator status by category. 
EXHIBIT 3-13:  NUMBER OF GENERATOR STATUS CHANGES IN THE POTENTIALLY AFFECTED UNIVERSE PER YEAR
                      Reported Change in Generator Status
                       Number of Facilities Per Year[1]
                                       
                                    Low end
                                   High end
SQG-to-LQG
                                      419
                                      837
VSQG-to-LQG
                                      264
                                      527
VSQG-to-SQG
                                      590
                                     1,180
TOTAL
                                     1,273
                                     2,544
Notes:
 Based on analysis of EPA's RCRAInfo database from 2000 to 2013.

Furthermore, while there is limited information on the number of unplanned episodic events, EPA estimates that between 25 percent and 50 percent of generators that experience a planned or unplanned episodic event may petition EPA to allow a second episodic event in the same calendar year.
Generation of hazardous waste during episodic events:  This RIA relies on EPA's BR database to estimate the average hazardous waste generation quantities associated with episodic events.  Data from 2005 to 2011 were analyzed to identify facilities that submitted multiple BR records, reporting as an SQG in one or more years and an LQG in at least one year.  These data suggest that facilities that changed their generator status generated, on average, approximately three times as much waste in years when they crossed the LQG threshold relative to the baseline.  This RIA assumes that, on average, the amount of hazardous waste generation associated with episodic events for SQGs is reflected by this 3-to-1 ratio.  Similar data are unavailable for VSQGs.  In the absence of such information, this RIA assumes that the 3-to-1 ratio for SQGs also applies to VSQGs.  Based on this assumption, this RIA estimates that an episodic event for facilities crossing the LQG threshold will involve 4.0 to 6.6 tons of hazardous waste, requiring 26 to 43 drums, and that events surpassing the SQG threshold will yield 0.4 to 0.8 tons of hazardous waste, requiring five to six drums.  
Number of waste streams generated during episodic events:  This RIA assumes a range for the number of waste streams associated with episodic events.  At the low-end of the range, this analysis assumes an episodic generation event involves a single project-specific waste stream (e.g., asbestos removal).  As the high-end, this analysis conservatively assumes an episodic generator manages as many waste streams as a typical LQG (in the case of SQG-to-LQG or VSQG-to-LQG events) or an SQG (in the case of VSQG-to-SQG events), as represented by the mean values presented in Exhibit 3-1.
Unit costs for rule conditions:  The costs incurred by facilities to comply with the conditions set forth in this voluntary provision of the final rule include those associated with (1) obtaining an EPA ID number (if a facility does not already have an EPA ID number), (2) notifying EPA or a state agency of an episodic event, (3) completing and maintaining records of waste streams associated with an episodic event, (4) marking containers consistent with the enhanced labeling provisions of the rule, and (5) completing a manifest for episodic waste sent offsite (an additional cost for VSQGs only). 
VSQGs are not required to have an EPA ID number.  Therefore, facilities that experience a change in their generator status from VSQG-to-SQG or VSQG-to-LQG are assumed to incur a one-time notification cost to obtain an EPA ID number.  These costs are described earlier in this chapter under re-notification.  Additionally, the cost, for any generator, to notify EPA or a state agency of an episodic event is assumed to be similar to the initial cost of notifying EPA of waste generation activity to obtain an EPA ID number (i.e., $47.98, as presented above in the re-notification section).
The costs to complete and maintain records of hazardous waste management vary with the number of waste streams generated during episodic events.  This RIA assumes these costs are similar to the variable costs of preparing a GM form -- approximately $21.02 per waste stream.  Similarly, labeling costs vary with the generation of hazardous waste during episodic events.  These costs are described earlier in this chapter under labeling/marking, but are also assumed to include an additional 30 seconds of a technician's time to mark the date the episodic event began.  As described above, SQGs and LQGs must already comply with the enhanced labeling provisions of the rule.  Therefore, the only additional cost associated with this voluntary provision of the final rule is the additional marking of the date the episodic event occurred for VSQGs.
The rule's manifesting requirements will result in additional costs for VSQGs, as these facilities are not required to manifest in the baseline.  Specifically, the shipment of hazardous waste generated during the episodic event will result in additional costs of approximately $10.22 per VSQG that takes advantage of the episodic generation provision.
Finally, VSQGs that do not already have a contingency plan are required to identify the name(s), address(es), and contact information for all emergency coordinators and submit this information to relevant local emergency responders.  This RIA assumes that the cost to prepare this information is approximately one-fifth of the total time required to collect all data required in a contingency plan, plus the cost of submitting this information.  Therefore, the cost of identifying emergency coordinators and submitting the relevant information is assumed to be approximately $32.75.
Costs associated with secondary episodic events:  As described above, EPA estimates that between 25 percent and 50 percent of generators that experience a planned or unplanned episodic event may petition EPA to allow a second episodic event in the same calendar year.  EPA estimates that facilities petitioning EPA to allow a second event will have to meet the following requirements: (1) notifying EPA or a state agency of an episodic event, (2) completing and maintaining records of waste streams associated with an episodic event, (3) marking containers consistent with the enhanced labeling provisions of the rule, and (4) completing a manifest for episodic waste sent offsite (an additional cost for VSQGs only).  For VSQGs, the incremental costs associated with the secondary episodic event may be slightly lower relative to the first event because these facilities will have already obtained an EPA ID number and provided emergency contact information to EPA during the first episodic event.  Therefore, this RIA does not double-count these costs for the secondary episodic event.
Exhibit 3-13 shows the annualized unit and aggregate costs of the episodic generation requirements under this voluntary provision of the final rule by facility type.  All of the costs are incurred on an annual basis by SQGs and VSQGs that choose to take advantage of this provision of the rule.  A single facility may experience an episodic event in one or multiple years.
The episodic generation provision of the final rule may also result in significant cost savings for qualified facilities.  Facilities that experience one-time or short-term episodic events within a single calendar month each year may avoid the costs associated with compliance under the more stringent generator status requirements.  These cost savings, and other benefits of the rule, are discussed in greater detail in Chapter 4 of this RIA.

EXHIBIT 3-14:  ANNUALIZED UNIT AND AGGREGATE COSTS FOR EPISODIC GENERATION ($2015 ANNUALIZED OVER 20 YEARS, USING A 7% DISCOUNT RATE)
                               GENERATOR STATUS
                                      [A]
                              LOW IMPACT ESTIMATE
NUMBER OF AFFECTED FACILITIES LIKELY TO INCUR COSTS
                                      [B]
                         ANNUALIZED COST PER FACILITY
                           AGGREGATE ANNUALIZED COST
                            TOTAL ANNUALIZED COSTS
                                    [G=E+F]
ONE-TIME COSTS
                                      [C]
                                RECURRING COSTS
                                      [D]
                                ONE-TIME COSTS
                                   [E=BxC]
                                RECURRING COSTS
                                   [F=BxD]

LQG
                                       0
                                     $0.00
                                     $0.00
                                      $0
                                      $0
                                      $0
SQG
                                      419
                                     $0.00
                                   $86.25[a]
                                      $0
                                    $36,100
                                    $36,100
VSQG[b]
                                      854
                                     $0.00
                                  $261.58[c]
                                      $0
                                   $223,000
                                   $223,000
TOTAL
                                     1,273
                                      N/A
                                      N/A
                                      $0
                                   $260,000
                                   $260,000
                               GENERATOR STATUS
                                      [A]
                             HIGH IMPACT ESTIMATE
              NUMBER OF AFFECTED FACILITIES LIKELY TO INCUR COSTS
                                      [B]
                         ANNUALIZED COST PER FACILITY
                           AGGREGATE ANNUALIZED COST
                            TOTAL ANNUALIZED COSTS
                                    [G=E+F]
                                ONE-TIME COSTS
                                      [C]
                                RECURRING COSTS
                                      [D]
                                ONE-TIME COSTS
                                   [E=BxC]
                                RECURRING COSTS
                                   [F=BxD]

LQG
                                       0
                                     $0.00
                                     $0.00
                                      $0
                                      $0
                                      $0
SQG
                                      837
                                     $0.00
                                  $481.85[a]
                                      $0
                                   $403,000
                                   $403,000
VSQG[b]
                                     1,707
                                     $0.00
                                  $580.33[d]
                                      $0
                                   $991,000
                                   $991,000
TOTAL
                                     2,544
                                      N/A
                                      N/A
                                      $0
                                  $1,390,000
                                  $1,390,000
Notes:
All aggregate cost estimates are rounded to three significant digits and may not sum due to rounding.
 SQGs incur two types of costs: (1) labor costs of $47.98 to notify EPA of an episodic event and (2) recordkeeping costs of $21.02 per waste stream x 1 waste stream in the low impact scenario (or 13 waste streams in the high impact scenario). EPA also estimates that 25 percent of generators may petition for a second unplanned episodic event in the low impact scenario (or 50 percent of generators in the high impact scenario) and incur similar costs for the second episodic event.
 This RIA assumes that between 854 and 1,707 VSQGs may take advantage of this provision of the rule. Of these, approximately 31% will otherwise be required to change their generator status from VSQG-to-LQG and 69% will otherwise be required to change their generator status from VSQG-to-SQG.
 This figure represents a weighted average cost across all VSQGs; costs vary according to whether a facility will otherwise change its generator status from VSQG-to-LQG or VSQG-to-SQG and whether a facility will petition EPA to allow a second unplanned episodic event. VSQGs incur six types of costs: (1) labor costs of $47.98 to notify EPA of an episodic event; (2) recordkeeping costs of $21.02 per waste stream x 1 waste stream in the low impact scenario; (3) labor costs of $47.98 to obtain an EPA ID number; (4) for VSQG-to-LQG: enhanced labeling costs of $42.21 for 1 hour of a technician's time for an entire storage area and approximately $3.87 for five and half minutes of a technician's time plus $0.06 per label per container x twenty-six 55-gallon drums in the low impact scenario; for VSQG-to-SQG: enhanced labeling costs of $10.55 for 15 minutes of a technician's time for an entire storage area and approximately $3.87 for five and half minutes of a technician's time plus $0.06 per label per container x five 55-gallon drums in the low impact scenario; (5) manifest costs of $10.22 for a single shipment within 45 days of the episodic event; and (6) labor costs of $32.75 to identify emergency coordinators. EPA also estimates that 25 percent of generators may petition for a second unplanned episodic event in the low impact scenario.
 This figure represents a weighted average cost across all VSQGs; costs vary according to whether a facility will otherwise change its generator status from VSQG-to-LQG or VSQG-to-SQG and whether a facility will petition EPA to allow a second unplanned episodic event. VSQGs incur six types of costs: (1) labor costs of $47.98 to notify EPA of an episodic event; (2) recordkeeping costs of $21.02 per waste stream x 13 waste streams for VSQG-to-LQG facilities and 7 waste streams for VSQG-to-SQG facilities in the high impact scenario; (3) labor costs of $47.98 to obtain an EPA ID number; (4) for VSQG-to-LQG: enhanced labeling costs of $42.21 for 1 hour of a technician's time for an entire storage area and approximately $3.87 for five and half minutes of a technician's time plus $0.06 per label per container x forty-three 55-gallon drums in the high impact scenario; for VSQG-to-SQG: enhanced labeling costs of $10.55 for 15 minutes of a technician's time for an entire storage area and approximately $3.87 for five and half minutes of a technician's time plus $0.06 per label per container x six 55-gallon drums in the high impact scenario; (5) manifest costs of $10.22 for a single shipment within 45 days of the episodic event; and (6) labor costs of $32.75 to identify emergency coordinators. EPA also estimates that 50 percent of generators may petition for a second unplanned episodic event in the high impact scenario.
3.3.13 SPECIAL REQUIREMENTS FOR IGNITABLE AND REACTIVE WASTES (VOLUNTARY)
Current RCRA regulations require that LQGs must locate containers holding ignitable or reactive waste at least 15 meters from the facility's property line.  In urban environments, LQGs may experience difficulty meeting this requirement due to the relatively small footprint of many properties in these areas.  To provide flexibility to LQGs, EPA is allowing LQGs to voluntarily apply for a facility-specific waiver from their local fire department if they are unable to meet the hazardous waste accumulation property line requirement.
The costs associated with this provision of the rule will include the cost of select LQGs applying for a waiver from the existing requirement.  The number of facilities that will apply for such a waiver is unknown.  As an indicator of the maximum number of LQGs that might apply, approximately 63 percent of all LQGs manage reactive or ignitable waste and are located in metropolitan areas (population of 50,000 or more), and 68 percent of LQGs manage this waste and are located in metropolitan or micropolitan areas (population of at least 10,000).  Based on the 20,771 LQGs in the universe, these values translate to a range of 13,086 to 14,125 LQGs that might apply for a waiver.  This range most likely represents an overestimate, however, because not all of these facilities necessarily have space constraints limiting their ability to keep ignitable or reactive waste at least 15 meters from the property line.
As an alternative to these values, the number of LQGs that report a change in physical address between BR reporting cycles may represent a better indicator of the number of LQGs that decide to submit a waiver application, as facilities experiencing problems complying with the 15-meter requirement may move to a different site to ensure compliance.  As shown in Exhibit 3-3, EPA's BR data suggest that approximately 0.05 percent of LQGs report a change in physical address on a biennial basis, which translates to 0.025 percent annually.  Applying this value to the 20,771 LQGs in the regulatory universe implies that approximately six LQGs change their location each year.  
Based on these data, this RIA assumes that between 6 and 14,125 LQGs apply for a waiver during the first year of the rule's implementation.  In subsequent years, a subset of all new LQGs is assumed to apply for a waiver.  As indicated in the methods discussion for the emergency response provisions of the rule, this RIA estimates that there are approximately 2,350 new LQGs each year.  Assuming that 68 percent of these facilities are in urban areas (consistent with the discussion above) and that the 0.025 percent value discussed in the previous paragraph represents a reasonable lower bound, this RIA estimates that between 1 and 1,601 facilities may apply for a waiver each year after the first year of the rule's implementation.
To estimate the cost of applying for an exemption, this RIA assumes that this cost is similar to that for a generator submitting an exemption from the RCRA manifest requirements.  These costs reflect 0.1 hours of managerial time, 0.17 hours of technical time, and 0.10 hours of clerical to develop the application, and 0.1 hours of managerial time and 0.4 hours of technical time to review the application.  This represents a cost of $43.56 per application per facility.
EXHIBIT 3-14 REPORTS THE ANNUALIZED UNIT AND AGGREGATE COSTS OF PREPARING AND SUBMITTING A WAIVER BY FACILITY TYPE.  FOR REPORTING PURPOSES, COSTS ARE BROKEN OUT BY ONE-TIME COSTS AND RECURRING COSTS OF THE RULEMAKING EVEN THOUGH ALL COSTS ARE INCURRED ONLY ONCE ON A PER-FACILITY BASIS.  THE ONE-TIME COSTS REFLECT THE FIRST-YEAR COSTS of the rule, which may be potentially incurred by all LQGs in urban environments.  The recurring costs of the rule only reflect applications by new LQGs in the affected universe.  Cost savings associated with this provision are discussed in the benefits chapter. 
EXHIBIT 3-15:  ANNUALIZED UNIT AND AGGREGATE COSTS FOR SPECIAL REQUIREMENTS FOR IGNITABLE AND REACTIVE WASTES ($2015 ANNUALIZED OVER 20 YEARS, USING A 7% DISCOUNT RATE)
                               GENERATOR STATUS
                                      [A]
                              LOW IMPACT ESTIMATE
NUMBER OF AFFECTED FACILITIES LIKELY TO INCUR COSTS
                                    [B][a]
                         ANNUALIZED COST PER FACILITY
                           AGGREGATE ANNUALIZED COST
                            TOTAL ANNUALIZED COSTS
                                    [G=E+F]
ONE-TIME COSTS
                                    [C][b]
                                RECURRING COSTS
                                    [D][c]
                                ONE-TIME COSTS
                                   [E=BxC]
                                RECURRING COSTS
                                   [F=BxD]

LQG
                                     6 (1)
                                     $3.84
                                    $39.72
                                      $23
                                      $40
                                      $63
SQG
                                       0
                                     $0.00
                                     $0.00
                                      $0
                                      $0
                                      $0
VSQG
                                       0
                                     $0.00
                                     $0.00
                                      $0
                                      $0
                                      $0
TOTAL
                                     6 (1)
                                      N/A
                                      N/A
                                      $23
                                      $40
                                      $63
                               GENERATOR STATUS
                                      [A]
                             HIGH IMPACT ESTIMATE
              NUMBER OF AFFECTED FACILITIES LIKELY TO INCUR COSTS
                                    [B][a]
                         ANNUALIZED COST PER FACILITY
                           AGGREGATE ANNUALIZED COST
                            TOTAL ANNUALIZED COSTS
                                    [G=E+F]
                                ONE-TIME COSTS
                                    [C][b]
                                RECURRING COSTS
                                    [D][c]
                                ONE-TIME COSTS
                                   [E=BxC]
                                RECURRING COSTS
                                   [F=BxD]

LQG
                                14,125 (1,601)
                                     $3.84
                                    $39.72
                                    $54,300
                                    $63,600
                                   $118,000
SQG
                                       0
                                     $0.00
                                     $0.00
                                      $0
                                      $0
                                      $0
VSQG
                                       0
                                     $0.00
                                     $0.00
                                      $0
                                      $0
                                      $0
TOTAL
                                14,125 (1,601)
                                      N/A
                                      N/A
                                    $54,300
                                    $63,600
                                   $118,000
Notes:
All aggregate cost estimates are rounded to three significant digits and may not sum due to rounding.
 The first value in Column B represents the number of facilities applying for waivers in the first year of rule implementation; the value in parentheses represents the number for all subsequent years.  This RIA estimates 6 LQGs will apply for waivers in the first year of the rule and 1 LQG each year thereafter in the low impact scenario. It assumes as many as 14,125 LQGs will apply for waivers in the first year of the rule and up to 1,601 LQGs each year thereafter in the high impact scenario. 
 The one-time costs of the rule represent the cost for all affected existing LQGs in the regulatory universe to apply for waivers. The cost of the application for a waiver is estimated to be $43.56 per facility (or $3.84 on an annualized basis).
 The recurring costs of the rule represent the cost for all affected new LQGs to apply for waivers. An average of 1,601 facilities will apply for waivers at a cost of $43.56 per facility each year after the first year of the rule, thus the average annualized cost over a 20-year period is $39.72 per facility. In other words, the $43.56 incurred in years 2 through 20 is discounted and expressed in present value terms; the resulting 19 present values are summed and then annualized.
3.4 RESULTS
Exhibit 3-15 reports the total annualized costs of the final rule by provision.  These costs are reported on an undiscounted basis as well as under discount rates of both three percent and seven percent.  As the exhibit shows, the most significant costs under the final rule are associated with labeling/marking.  In addition, three of the provisions -- intra-organizational transfers, episodic generation, and special requirements for ignitable and reactive wastes -- are optional and anticipated to result in cost savings, which are not included in Exhibit 3-15, but are included in the discussion of benefits in Chapter 4.
The costs presented in Exhibit 3-15 do not appear to be sensitive to the discount rate.  However, the various rule provisions differ with respect to the time horizon over which they affect generator activity.  Exhibits 3-16(a)-(c) therefore reports the total costs of the rule by year.  As shown in the exhibits, a significant percentage of the costs of the rule is composed of one-time notification costs incurred in the first year of the rule as opposed to recurring annual (or biennial) costs.  This RIA uses a 20-year time frame to assess these costs in present value and annualized terms.
Exhibit 3-17 presents the distribution of the total costs of the final rule across the three RCRA generator categories (i.e., LQGs, SQGs, and VSQGs).  As the exhibit shows, the aggregate costs of the rule are highest for LQGs and SQGs.  This reflects that the costs of the LQG requirements are generally the highest on a per facility basis, but there are a greater number of SQGs in the potentially affected universe.  The average annualized costs of the mandatory provisions of the rule, on a per facility basis, are negligible for VSQGs, between $56 and $88 for SQGs, and between $103 and $239 for LQGs (using a seven percent discount rate).  The average annualized per facility costs of the mandatory and voluntary provisions of the rule combined are between $2 and $3 for VSQGs, between $57 and $94 for SQGs, and between $119 and $268 for LQGs.
The annualized costs of the final rule appear to be low relative to many of the unit costs presented in this chapter, in part, because only a fraction of facilities are affected by each provision of the rule.  Spreading these costs over the full universe of LQGs, SQGs, and VSQGs reduces these costs on a per-facility basis.  Similarly, the actual costs of compliance for a single facility may be much higher than the average values reported above.  For example, closing as a landfill would cost a single LQG tens of thousands of dollars on an annualized basis; however, this RIA assumes that five or fewer such closures occur each year.
Finally, Exhibit 3-18 reports the total annualized costs of the final rule by one-time and recurring costs.  As the exhibit shows, approximately 20 percent of the costs of the final rule are incurred on a one-time basis in the low impact scenario and approximately 10 percent of the costs are incurred on a one-time basis in the high impact scenario.  As described above, these one-time costs are concentrated in the first year of the rule's implementation, after which time the costs associated with the rule decline significantly (see Exhibit 3-16).

EXHIBIT 3-16:  TOTAL ANNUALIZED COSTS OF THE FINAL RULE BY REQUIREMENT ($2015 ANNUALIZED OVER 20 YEARS)
                                  REQUIREMENT
                              LOW IMPACT SCENARIO
                             HIGH IMPACT SCENARIO
                                       
                        ANNUALIZED COSTS(UNDISCOUNTED)
                  ANNUALIZED COSTS(USING A 3% DISCOUNT RATE)
                  ANNUALIZED COSTS(USING A 7% DISCOUNT RATE)
                        ANNUALIZED COSTS(UNDISCOUNTED)
                  ANNUALIZED COSTS(USING A 3% DISCOUNT RATE)
                  ANNUALIZED COSTS(USING A 7% DISCOUNT RATE)
MANDATORY PROVISIONS OF THE FINAL RULE
Re-notification
                                                                       $459,000
                                                                       $480,000
                                                                       $507,000
                                                                       $594,000
                                                                       $621,000
                                                                       $656,000
Labeling
                                                                     $2,640,000
                                                                     $2,750,000
                                                                     $2,920,000
                                                                     $5,340,000
                                                                     $5,450,000
                                                                     $5,610,000
Closure
                                                                        $44,500
                                                                        $44,500
                                                                        $44,500
                                                                     $3,200,000
                                                                     $2,330,000
                                                                     $1,710,000
Emergency Response Preparedness
                                                                       $471,000
                                                                       $475,000
                                                                       $481,000
                                                                       $661,000
                                                                       $666,000
                                                                       $672,000
Transfer Facility
                                                                         $4,470
                                                                         $4,470
                                                                         $4,470
                                                                         $8,280
                                                                         $8,280
                                                                         $8,280
BR Requirements
                                                                         $7,000
                                                                         $7,100
                                                                         $7,240
                                                                        $68,800
                                                                        $69,800
                                                                        $71,100
Recycling
                                                                         $2,060
                                                                         $2,090
                                                                         $2,130
                                                                         $5,590
                                                                         $5,670
                                                                         $5,780
Prohibitions on Storage
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
Drip Pads and Containment Buildings
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
SUB-TOTAL: Mandatory Rule Provisions
                                                                     $3,630,000
                                                                     $3,760,000
                                                                     $3,960,000
                                                                     $9,870,000
                                                                     $9,150,000
                                                                     $8,740,000
VOLUNTARY PROVISIONS OF THE FINAL RULE
Intra-organizational Transfers
                                                                     $1,610,000
                                                                     $1,640,000
                                                                     $1,680,000
                                                                     $2,930,000
                                                                     $2,980,000
                                                                     $3,050,000
Episodic Generation
                                                                       $260,000
                                                                       $260,000
                                                                       $260,000
                                                                     $1,390,000
                                                                     $1,390,000
                                                                     $1,390,000
Ignitable and Reactive Waste
                                                                            $50
                                                                            $60
                                                                            $60
                                                                        $97,000
                                                                       $105,000
                                                                       $118,000
SUB-TOTAL: Voluntary Rule Provisions
                                                                     $1,870,000
                                                                     $1,900,000
                                                                     $1,940,000
                                                                     $4,420,000
                                                                     $4,480,000
                                                                     $4,560,000
MANDATORY AND VOLUNTARY PROVISIONS OF THE FINAL RULE COMBINED
TOTAL: Mandatory and Voluntary Provisions Combined
                                                                     $5,500,000
                                                                     $5,660,000
                                                                     $5,900,000
                                                                    $14,300,000
                                                                    $13,600,000
                                                                    $13,300,000
Notes:
All cost estimates are rounded to three significant digits and may not sum due to rounding.

     EXHIBIT 3-17(A):  TOTAL COSTS OF THE FINAL RULE BY YEAR, MANDATORY PROVISIONS ONLY ($2015)
                                     YEAR
                              LOW IMPACT SCENARIO
                             HIGH IMPACT SCENARIO
                                 UNDISCOUNTED
                               3% DISCOUNT RATE
                               7% DISCOUNT RATE
                                 UNDISCOUNTED
                               3% DISCOUNT RATE
                               7% DISCOUNT RATE
                                                                         Year 1
                                                                    $12,100,000
                                                                    $12,100,000
                                                                    $12,100,000
                                                                    $18,900,000
                                                                    $18,000,000
                                                                    $17,400,000
                                                                         Year 2
                                                                     $2,790,000
                                                                     $2,710,000
                                                                     $2,610,000
                                                                     $8,830,000
                                                                     $7,730,000
                                                                     $6,870,000
                                                                         Year 3
                                                                     $2,810,000
                                                                     $2,650,000
                                                                     $2,450,000
                                                                     $8,980,000
                                                                     $7,640,000
                                                                     $6,550,000
                                                                         Year 4
                                                                     $2,790,000
                                                                     $2,550,000
                                                                     $2,280,000
                                                                     $8,830,000
                                                                     $7,290,000
                                                                     $6,000,000
                                                                         Year 5
                                                                     $4,650,000
                                                                     $4,130,000
                                                                     $3,540,000
                                                                    $11,400,000
                                                                     $9,320,000
                                                                     $7,530,000
                                                                         Year 6
                                                                     $2,790,000
                                                                     $2,410,000
                                                                     $1,990,000
                                                                     $8,830,000
                                                                     $6,870,000
                                                                     $5,240,000
                                                                         Year 7
                                                                     $2,810,000
                                                                     $2,350,000
                                                                     $1,870,000
                                                                     $8,980,000
                                                                     $6,790,000
                                                                     $4,990,000
                                                                         Year 8
                                                                     $2,790,000
                                                                     $2,270,000
                                                                     $1,740,000
                                                                     $8,830,000
                                                                     $6,470,000
                                                                     $4,580,000
                                                                         Year 9
                                                                     $4,650,000
                                                                     $3,670,000
                                                                     $2,700,000
                                                                    $11,400,000
                                                                     $8,280,000
                                                                     $5,750,000
                                                                        Year 10
                                                                     $2,790,000
                                                                     $2,140,000
                                                                     $1,520,000
                                                                     $8,830,000
                                                                     $6,100,000
                                                                     $4,000,000
                                                                        Year 11
                                                                     $2,810,000
                                                                     $2,090,000
                                                                     $1,430,000
                                                                     $8,980,000
                                                                     $6,030,000
                                                                     $3,810,000
                                                                        Year 12
                                                                     $2,790,000
                                                                     $2,020,000
                                                                     $1,330,000
                                                                     $8,830,000
                                                                     $5,750,000
                                                                     $3,490,000
                                                                        Year 13
                                                                     $4,650,000
                                                                     $3,260,000
                                                                     $2,060,000
                                                                    $11,400,000
                                                                     $7,350,000
                                                                     $4,380,000
                                                                        Year 14
                                                                     $2,790,000
                                                                     $1,900,000
                                                                     $1,160,000
                                                                     $8,830,000
                                                                     $5,420,000
                                                                     $3,050,000
                                                                        Year 15
                                                                     $2,810,000
                                                                     $1,860,000
                                                                     $1,090,000
                                                                     $8,980,000
                                                                     $5,360,000
                                                                     $2,910,000
                                                                        Year 16
                                                                     $2,790,000
                                                                     $1,790,000
                                                                     $1,010,000
                                                                     $8,830,000
                                                                     $5,110,000
                                                                     $2,660,000
                                                                        Year 17
                                                                     $4,650,000
                                                                     $2,890,000
                                                                     $1,570,000
                                                                    $11,400,000
                                                                     $6,530,000
                                                                     $3,340,000
                                                                        Year 18
                                                                     $2,790,000
                                                                     $1,690,000
                                                                       $883,000
                                                                     $8,830,000
                                                                     $4,820,000
                                                                     $2,330,000
                                                                        Year 19
                                                                     $2,810,000
                                                                     $1,650,000
                                                                       $831,000
                                                                     $8,980,000
                                                                     $4,760,000
                                                                     $2,220,000
                                                                        Year 20
                                                                     $2,790,000
                                                                     $1,590,000
                                                                       $771,000
                                                                     $8,830,000
                                                                     $4,540,000
                                                                     $2,030,000
                                                    Total Costs (Over 20 Years)
                                                                    $72,600,000
                                                                    $57,700,000
                                                                    $44,900,000
                                                                   $197,000,000
                                                                   $140,000,000
                                                                    $99,100,000
                                                               Annualized Costs
                                                                     $3,630,000
                                                                     $3,760,000
                                                                     $3,960,000
                                                                     $9,870,000
                                                                     $9,150,000
                                                                     $8,740,000
Notes:
All cost estimates are rounded to three significant digits and may not sum due to rounding.
     EXHIBIT 3-17(B):  TOTAL COSTS OF THE FINAL RULE BY YEAR, VOLUNTARY PROVISIONS ONLY ($2015)
                                     YEAR
                              LOW IMPACT SCENARIO
                             HIGH IMPACT SCENARIO
                                 UNDISCOUNTED
                               3% DISCOUNT RATE
                               7% DISCOUNT RATE
                                 UNDISCOUNTED
                               3% DISCOUNT RATE
                               7% DISCOUNT RATE
                                                                         Year 1
                                                                     $3,890,000
                                                                     $3,890,000
                                                                     $3,890,000
                                                                     $8,380,000
                                                                     $8,380,000
                                                                     $8,380,000
                                                                         Year 2
                                                                       $737,000
                                                                       $716,000
                                                                       $689,000
                                                                     $2,310,000
                                                                     $2,240,000
                                                                     $2,160,000
                                                                         Year 3
                                                                     $2,900,000
                                                                     $2,730,000
                                                                     $2,530,000
                                                                     $6,310,000
                                                                     $5,950,000
                                                                     $5,520,000
                                                                         Year 4
                                                                       $737,000
                                                                       $675,000
                                                                       $602,000
                                                                     $2,310,000
                                                                     $2,120,000
                                                                     $1,890,000
                                                                         Year 5
                                                                     $2,900,000
                                                                     $2,580,000
                                                                     $2,210,000
                                                                     $6,310,000
                                                                     $5,610,000
                                                                     $4,820,000
                                                                         Year 6
                                                                       $737,000
                                                                       $636,000
                                                                       $526,000
                                                                     $2,310,000
                                                                     $1,990,000
                                                                     $1,650,000
                                                                         Year 7
                                                                     $2,900,000
                                                                     $2,430,000
                                                                     $1,930,000
                                                                     $6,310,000
                                                                     $5,290,000
                                                                     $4,210,000
                                                                         Year 8
                                                                       $737,000
                                                                       $599,000
                                                                       $459,000
                                                                     $2,310,000
                                                                     $1,880,000
                                                                     $1,440,000
                                                                         Year 9
                                                                     $2,900,000
                                                                     $2,290,000
                                                                     $1,690,000
                                                                     $6,310,000
                                                                     $4,990,000
                                                                     $3,680,000
                                                                        Year 10
                                                                       $737,000
                                                                       $565,000
                                                                       $401,000
                                                                     $2,310,000
                                                                     $1,770,000
                                                                     $1,260,000
                                                                        Year 11
                                                                     $2,900,000
                                                                     $2,160,000
                                                                     $1,470,000
                                                                     $6,310,000
                                                                     $4,700,000
                                                                     $3,210,000
                                                                        Year 12
                                                                       $737,000
                                                                       $533,000
                                                                       $350,000
                                                                     $2,310,000
                                                                     $1,670,000
                                                                     $1,100,000
                                                                        Year 13
                                                                     $2,900,000
                                                                     $2,030,000
                                                                     $1,290,000
                                                                     $6,310,000
                                                                     $4,430,000
                                                                     $2,800,000
                                                                        Year 14
                                                                       $737,000
                                                                       $502,000
                                                                       $306,000
                                                                     $2,310,000
                                                                     $1,570,000
                                                                       $959,000
                                                                        Year 15
                                                                     $2,900,000
                                                                     $1,920,000
                                                                     $1,120,000
                                                                     $6,310,000
                                                                     $4,170,000
                                                                     $2,450,000
                                                                        Year 16
                                                                       $737,000
                                                                       $473,000
                                                                       $267,000
                                                                     $2,310,000
                                                                     $1,480,000
                                                                       $838,000
                                                                        Year 17
                                                                     $2,900,000
                                                                     $1,810,000
                                                                       $982,000
                                                                     $6,310,000
                                                                     $3,940,000
                                                                     $2,140,000
                                                                        Year 18
                                                                       $737,000
                                                                       $446,000
                                                                       $233,000
                                                                     $2,310,000
                                                                     $1,400,000
                                                                       $732,000
                                                                        Year 19
                                                                     $2,900,000
                                                                     $1,700,000
                                                                       $858,000
                                                                     $6,310,000
                                                                     $3,710,000
                                                                     $1,870,000
                                                                        Year 20
                                                                       $737,000
                                                                       $420,000
                                                                       $204,000
                                                                     $2,310,000
                                                                     $1,320,000
                                                                       $639,000
                                                    Total Costs (Over 20 Years)
                                                                    $37,300,000
                                                                    $29,100,000
                                                                    $22,000,000
                                                                    $88,300,000
                                                                    $68,600,000
                                                                    $51,700,000
                                                               Annualized Costs
                                                                     $1,870,000
                                                                     $1,450,000
                                                                     $1,100,000
                                                                     $4,420,000
                                                                     $4,480,000
                                                                     $4,560,000
Notes:
All cost estimates are rounded to three significant digits and may not sum due to rounding.
     EXHIBIT 3-17(C):  TOTAL COSTS OF THE FINAL RULE BY YEAR, MANDATORY AND VOLUNTARY PROVISIONS ($2015)
                                     YEAR
                              LOW IMPACT SCENARIO
                             HIGH IMPACT SCENARIO
                                 UNDISCOUNTED
                               3% DISCOUNT RATE
                               7% DISCOUNT RATE
                                 UNDISCOUNTED
                               3% DISCOUNT RATE
                               7% DISCOUNT RATE
                                                                         Year 1
                                                                    $16,000,000
                                                                    $16,000,000
                                                                    $16,000,000
                                                                    $27,200,000
                                                                    $26,400,000
                                                                    $25,700,000
                                                                         Year 2
                                                                     $3,530,000
                                                                     $3,420,000
                                                                     $3,300,000
                                                                    $11,100,000
                                                                     $9,970,000
                                                                     $9,030,000
                                                                         Year 3
                                                                     $5,710,000
                                                                     $5,380,000
                                                                     $4,980,000
                                                                    $15,300,000
                                                                    $13,600,000
                                                                    $12,100,000
                                                                         Year 4
                                                                     $3,530,000
                                                                     $3,230,000
                                                                     $2,880,000
                                                                    $11,100,000
                                                                     $9,400,000
                                                                     $7,880,000
                                                                         Year 5
                                                                     $7,540,000
                                                                     $6,700,000
                                                                     $5,760,000
                                                                    $17,700,000
                                                                    $14,900,000
                                                                    $12,300,000
                                                                         Year 6
                                                                     $3,530,000
                                                                     $3,040,000
                                                                     $2,510,000
                                                                    $11,100,000
                                                                     $8,860,000
                                                                     $6,890,000
                                                                         Year 7
                                                                     $5,710,000
                                                                     $4,780,000
                                                                     $3,800,000
                                                                    $15,300,000
                                                                    $12,100,000
                                                                     $9,200,000
                                                                         Year 8
                                                                     $3,530,000
                                                                     $2,870,000
                                                                     $2,200,000
                                                                    $11,100,000
                                                                     $8,350,000
                                                                     $6,020,000
                                                                         Year 9
                                                                     $7,540,000
                                                                     $5,960,000
                                                                     $4,390,000
                                                                    $17,700,000
                                                                    $13,300,000
                                                                     $9,420,000
                                                                        Year 10
                                                                     $3,530,000
                                                                     $2,700,000
                                                                     $1,920,000
                                                                    $11,100,000
                                                                     $7,870,000
                                                                     $5,250,000
                                                                        Year 11
                                                                     $5,710,000
                                                                     $4,250,000
                                                                     $2,900,000
                                                                    $15,300,000
                                                                    $10,700,000
                                                                     $7,020,000
                                                                        Year 12
                                                                     $3,530,000
                                                                     $2,550,000
                                                                     $1,680,000
                                                                    $11,100,000
                                                                     $7,420,000
                                                                     $4,590,000
                                                                        Year 13
                                                                     $7,540,000
                                                                     $5,290,000
                                                                     $3,350,000
                                                                    $17,700,000
                                                                    $11,800,000
                                                                     $7,190,000
                                                                        Year 14
                                                                     $3,530,000
                                                                     $2,400,000
                                                                     $1,460,000
                                                                    $11,100,000
                                                                     $7,000,000
                                                                     $4,010,000
                                                                        Year 15
                                                                     $5,710,000
                                                                     $3,770,000
                                                                     $2,210,000
                                                                    $15,300,000
                                                                     $9,540,000
                                                                     $5,360,000
                                                                        Year 16
                                                                     $3,530,000
                                                                     $2,260,000
                                                                     $1,280,000
                                                                    $11,100,000
                                                                     $6,590,000
                                                                     $3,500,000
                                                                        Year 17
                                                                     $7,540,000
                                                                     $4,700,000
                                                                     $2,560,000
                                                                    $17,700,000
                                                                    $10,500,000
                                                                     $5,480,000
                                                                        Year 18
                                                                     $3,530,000
                                                                     $2,130,000
                                                                     $1,120,000
                                                                    $11,100,000
                                                                     $6,220,000
                                                                     $3,060,000
                                                                        Year 19
                                                                     $5,710,000
                                                                     $3,350,000
                                                                     $1,690,000
                                                                    $15,300,000
                                                                     $8,470,000
                                                                     $4,090,000
                                                                        Year 20
                                                                     $3,530,000
                                                                     $2,010,000
                                                                       $975,000
                                                                    $11,100,000
                                                                     $5,860,000
                                                                     $2,670,000
                                                    Total Costs (Over 20 Years)
                                                                   $110,000,000
                                                                    $86,800,000
                                                                    $66,900,000
                                                                   $286,000,000
                                                                   $209,000,000
                                                                   $151,000,000
                                                               Annualized Costs
                                                                     $5,500,000
                                                                     $5,660,000
                                                                     $5,900,000
                                                                    $14,300,000
                                                                    $13,600,000
                                                                    $13,300,000
Notes:
All cost estimates are rounded to three significant digits and may not sum due to rounding.
     EXHIBIT 3-18:  TOTAL ANNUALIZED COSTS OF THE FINAL RULE BY GENERATOR STATUS ($2015 ANNUALIZED OVER 20 YEARS)
                               GENERATOR STATUS
                              LOW IMPACT SCENARIO
                             HIGH IMPACT SCENARIO
                         NUMBER OF AFFECTED FACILITIES
                        ANNUALIZED COSTS(UNDISCOUNTED)
                  ANNUALIZED COSTS(USING A 3% DISCOUNT RATE)
                  ANNUALIZED COSTS(USING A 7% DISCOUNT RATE)
                         NUMBER OF AFFECTED FACILITIES
                        ANNUALIZED COSTS(UNDISCOUNTED)
                  ANNUALIZED COSTS(USING A 3% DISCOUNT RATE)
                  ANNUALIZED COSTS(USING A 7% DISCOUNT RATE)
MANDATORY PROVISIONS OF THE FINAL RULE
LQG
                                                                         20,771
                                                                       $872,000
                                                                       $983,000
                                                                     $1,150,000
                                                                         20,771
                                                                     $4,280,000
                                                                     $3,520,000
                                                                     $1,150,000
SQG
                                                                         49,887
                                                                     $2,760,000
                                                                     $2,780,000
                                                                     $2,810,000
                                                                         64,310
                                                                     $5,590,000
                                                                     $5,620,000
                                                                     $5,660,000
VSQG
                                                                        353,441
                                                                           $370
                                                                           $370
                                                                           $380
                                                                        591,809
                                                                         $2,540
                                                                         $2,580
                                                                         $2,630
Recycling Facility
                                                                             10
                                                                         $2,060
                                                                         $2,090
                                                                         $2,130
                                                                             20
                                                                         $5,590
                                                                         $5,670
                                                                         $5,780
SUB-TOTAL
                                                                        424,109
                                                                     $3,630,000
                                                                     $3,760,000
                                                                     $3,960,000
                                                                        676,910
                                                                     $9,870,000
                                                                     $9,150,000
                                                                     $8,740,000
VOLUNTARY PROVISIONS OF THE FINAL RULE
LQG
                                                                         20,771
                                                                     $1,250,000
                                                                     $1,280,000
                                                                     $1,320,000
                                                                         20,771
                                                                     $2,350,000
                                                                     $2,410,000
                                                                     $2,500,000
SQG
                                                                         49,887
                                                                        $36,100
                                                                        $36,100
                                                                        $36,100
                                                                         64,310
                                                                       $403,000
                                                                       $403,000
                                                                       $403,000
VSQG
                                                                        353,441
                                                                       $585,000
                                                                       $585,000
                                                                       $585,000
                                                                        591,809
                                                                     $1,660,000
                                                                     $1,660,000
                                                                     $1,660,000
Recycling Facility
                                                                             10
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             20
                                                                             $0
                                                                             $0
                                                                             $0
SUB-TOTAL
                                                                        424,109
                                                                     $1,870,000
                                                                     $1,900,000
                                                                     $1,940,000
                                                                        676,910
                                                                     $4,420,000
                                                                     $4,480,000
                                                                     $4,560,000
MANDATORY AND VOLUNTARY PROVISIONS OF THE FINAL RULE COMBINED
LQG
                                                                         20,771
                                                                     $2,120,000
                                                                     $2,260,000
                                                                     $2,470,000
                                                                         20,771
                                                                     $6,630,000
                                                                     $5,930,000
                                                                     $5,570,000
SQG
                                                                         49,887
                                                                     $2,790,000
                                                                     $2,820,000
                                                                     $2,850,000
                                                                         64,310
                                                                     $5,990,000
                                                                     $6,020,000
                                                                     $6,060,000
VSQG
                                                                        353,441
                                                                       $586,000
                                                                       $586,000
                                                                       $586,000
                                                                        591,809
                                                                     $1,660,000
                                                                     $1,660,000
                                                                     $1,660,000
Recycling Facility
                                                                             10
                                                                         $2,060
                                                                         $2,090
                                                                         $2,130
                                                                             20
                                                                         $5,590
                                                                         $5,670
                                                                         $5,780
TOTAL
                                                                        424,109
                                                                     $5,500,000
                                                                     $5,660,000
                                                                     $5,900,000
                                                                        676,910
                                                                    $14,300,000
                                                                    $13,600,000
                                                                    $13,300,000
Notes:
All annualized cost estimates are rounded to three significant digits and may not sum due to rounding.
EXHIBIT 3-19:  TOTAL ANNUALIZED COSTS OF THE FINAL RULE BY REQUIREMENT AND FREQUENCY USING A 7% DISCOUNT RATE ($2015)
                                  REQUIREMENT
                              LOW IMPACT SCENARIO
                             HIGH IMPACT SCENARIO
                                       
                           ANNUALIZED ONE-TIME COSTS
                          ANNUALIZED RECURRING COSTS
                            TOTAL ANNUALIZED COSTS
                           ANNUALIZED ONE-TIME COSTS
                          ANNUALIZED RECURRING COSTS
                            TOTAL ANNUALIZED COSTS
MANDATORY PROVISIONS OF THE FINAL RULE
Re-notification
                                                                             $0
                                                                       $507,000
                                                                       $507,000
                                                                             $0
                                                                       $656,000
                                                                       $656,000
Labeling
                                                                       $636,000
                                                                     $2,280,000
                                                                     $2,920,000
                                                                       $636,000
                                                                     $4,980,000
                                                                     $5,610,000
Closure
                                                                             $0
                                                                        $44,500
                                                                        $44,500
                                                                             $0
                                                                     $1,710,000
                                                                     $1,710,000
Emergency Response Preparedness
                                                                        $21,200
                                                                       $459,000
                                                                       $481,000
                                                                        $25,500
                                                                       $647,000
                                                                       $672,000
Transfer Facility
                                                                             $0
                                                                         $4,470
                                                                         $4,470
                                                                             $0
                                                                         $8,280
                                                                         $8,280
BR Requirements
                                                                             $0
                                                                         $7,240
                                                                         $7,240
                                                                             $0
                                                                        $71,100
                                                                        $71,100
Recycling
                                                                             $0
                                                                         $2,130
                                                                         $2,130
                                                                             $0
                                                                         $5,780
                                                                         $5,780
Prohibitions on Storage
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
Drip Pads and Containment Buildings
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
SUB-TOTAL: Mandatory Rule Provisions
                                                                       $657,000
                                                                     $3,310,000
                                                                     $3,960,000
                                                                       $661,000
                                                                     $8,080,000
                                                                     $8,740,000
VOLUNTARY PROVISIONS OF THE FINAL RULE
Intra-organizational Transfers
                                                                        $87,100
                                                                     $1,590,000
                                                                     $1,680,000
                                                                       $134,000
                                                                     $2,920,000
                                                                     $3,050,000
Episodic Generation
                                                                             $0
                                                                       $260,000
                                                                       $260,000
                                                                             $0
                                                                     $1,390,000
                                                                     $1,390,000
Ignitable and Reactive Waste
                                                                            $20
                                                                            $40
                                                                            $60
                                                                        $54,300
                                                                        $63,600
                                                                       $118,000
SUB-TOTAL: Voluntary Rule Provisions
                                                                        $87,100
                                                                     $1,850,000
                                                                     $1,940,000
                                                                       $189,000
                                                                     $4,380,000
                                                                     $4,560,000
MANDATORY AND VOLUNTARY PROVISIONS OF THE FINAL RULE COMBINED
TOTAL: Mandatory and Voluntary Provisions Combined
                                                                       $744,000
                                                                     $5,160,000
                                                                     $5,900,000
                                                                       $850,000
                                                                    $12,500,000
                                                                    $13,300,000
Notes:
All annualized cost estimates are rounded to three significant digits and may not sum due to rounding.
     3.5 ANALYTIC LIMITATIONS
While the analysis presented in this chapter provides reasonable estimates of the costs associated with the final rule, the data and methods used in this analysis are subject to several uncertainties, the most significant of which are outlined below.
Facility-specific characteristics not accounted for.  In practice, hazardous waste management methods vary by industry and between individual facilities in the same industry.  Sufficient data were not available for this analysis to incorporate such considerations into the estimation of costs.  Therefore, while costs are estimated separately for LQGs, SQGs, and VSQGs, they do not account for facility-specific differences.  Thus, the average per facility cost estimates reported in this document may either overstate or understate costs for individual facilities.  
VSQG and SQG data are generally limited.  This RIA relies on limited data and information available in the BR and provided by the states to make assumptions regarding hazardous waste generation and management among SQGs and VSQGs.  In cases where data are unavailable, LQG (or SQG) data analysis and trends are applied to the VSQG universe, which may lead to overestimation or underestimation of actual costs.  
Ownership structure of entities is unknown.  The cost of the rule's VSQG consolidation provision is highly dependent on the uncertain ownership structure of the regulated universe.  Specifically, the estimated costs of consolidation depend on the number of VSQGs that could consolidate their waste and the number of LQGs that could manage this waste.  This RIA uses a facility name matching algorithm for a limited number of states as the basis for estimating these values.  Because this approach uses data from a limited number of states and applies them more broadly to the U.S. as a whole, it may overestimate or understate the number of facilities that could take advantage of this provision of the rule.  In addition, the number of eligible entities that may choose to consolidate waste is also highly uncertain.
Activity in SAAs.  As described above, the costs of the labeling/marking requirements of the rule are partially dependent on the number of containers in SAAs.  Because comprehensive data on SAAs were not readily available for this analysis, this RIA assumed that the number of containers in satellite areas is half the number in primary storage areas.  This assumption may lead to overestimation or underestimation of the rule's costs.
Information on the use of DOT labels is unknown.  The cost of the rule's labeling/marking requirements depend, in part, on the number of generators that will use DOT labels to comply with the final rule, rather than modify their current labels.  Because it cannot predict how all generators will choose to comply with the labeling/marking requirements, EPA estimates that approximately half of LQGs will use DOT labels and not modify their existing labeling systems and processes.  This assumption may lead to overestimation or underestimation of the rule's costs.
Number of LQGs closing as landfills is unknown.  No data are available on the number of LQGs that are required to close with contamination in place.  Absent such information, this RIA assumes that zero to one percent of the LQGs closing will close as a landfill.  This assumption likely overstates actual closure costs as anecdotal information from state enforcement personnel suggests that this is a rare occurrence.
Eligibility for episodic generation is uncertain.  Data on episodic generation are extremely limited.  Therefore, it is not possible to accurately estimate the percentage of facilities that experience one-time or short-term generation events that last for one calendar month or less.  To address this uncertainty, this RIA assumes that between 50 and 100 percent of episodic events occur within a 60 day period.  This RIA also assumes that between 25 and 50 percent of facilities that experience a planned episodic event will petition EPA to allow a second unplanned episodic event in the same calendar year.  It is not clear whether this assumption leads to overestimation or underestimation of costs.
Number of facilities applying for waivers under the rule provision for ignitable and reactive waste.  While the BR includes data identifying facilities that generate reactive and/or ignitable waste, no data are available that clearly indicate which of these facilities are located in areas where it is not possible to meet the 15-meter property line requirement.  This RIA estimates the potential costs of this provision based on assumptions spanning a wide range, the upper end of which likely leads to overestimation of this provision's costs.

CHAPTER 4  |  Assessment of Benefits
4.1 Introduction
This chapter provides an assessment of the benefits that may result from the final Hazardous Waste Generator Improvements Rule.  These benefits reflect the rule's focus on enhancing protection of human health and the environment and improving the efficiency of the RCRA hazardous waste generator standards.  For example, the rule will allow for more effective emergency response in the event of an accident due to the changes to the generator marking/labeling and contingency plan requirements.  The benefits of the rule also include cost savings likely to be realized by many generators due to the increased flexibility that the rule provides for VSQGs and for generators that will be elevated to a more stringent regulatory status because of episodic generation events.
This RIA would ideally quantify and monetize, wherever possible, each of these benefits.  Such an analysis is feasible for some categories of benefits.  For the majority of benefits, however, sufficient data are unavailable to support a detailed quantitative analysis.  For example, quantifying benefits associated with improved emergency response due to more detailed container labeling would require data on the annual number of emergencies at generator sites, the current risks associated with these incidents, the extent to which more detailed labeling would affect the procedures of emergency responders, and the reduction in risk associated with these changes.  Detailed data on these items are not readily available. 
The sections that follow characterize benefits for each individual provision of the rule. For those benefit categories with detailed data available, this RIA quantifies and monetizes benefits.  In instances where quantitative data are not available, this RIA provides a qualitative assessment of benefits.  
4.2 Monetized Benefits
The available data support the monetization of benefits associated with three major provisions of the final rule: (1) the accumulation of hazardous waste on drip pads or in containment buildings, (2) the intra-organization consolidation of VSQG waste at an LQG, and (3) the flexibility afforded SQGs and VSQGs that cross the threshold to a more stringent regulatory status due to episodic generation events.  Combined, these provisions are estimated to result in annualized benefits of $8.3 to $14.4 million using a 7 percent discount rate.  These values are not highly sensitive to the choice of discount rate.
4.2.1 Drip Pad and Containment Building Requirements for SQGs
As described in Chapter 3, the final rule will continue to require SQGs that accumulate hazardous waste in containment buildings without a permit or interim status to comply with the LQG 90-day accumulation limit (as opposed to the SQG 180-day accumulation limit) and SQGs that accumulate hazardous waste on drip pads without a permit or interim status to comply with the 180-day accumulation limit, but will otherwise allow these facilities to comply with the less stringent requirements for SQGs.  Therefore, SQGs that accumulate hazardous waste on drip pads or in containment buildings will experience a cost savings associated with no longer being subject to the requirements that apply to LQGs for personnel training, development of a full contingency plan, and biennial reporting.  Thus, the incremental cost savings for these generators is the difference between the LQG and SQG costs associated with these activities.  
EPA estimates that within the regulated universe there are 12 SQGs that accumulate hazardous waste in containment buildings and 295 SQGs that accumulate waste on drip pads currently subject to the LQG requirements.[,]  Furthermore, this RIA assumes that these facilities will not otherwise be subject to the LQG requirements for waste that is not accumulated on drips pads or in containment buildings.  EPA assumes that no VSQGs currently use drip pads or containment buildings.  Thus, there are 307 SQGs that may experience a cost savings as a result of this rule provision.  The following sections present the cost savings associated with the additional flexibility for SQGs to no longer comply with certain LQG requirements and estimate the total potential cost savings realized by SQGs that accumulate hazardous waste on drip pads or in containment buildings for 90 days or less.  All cost savings estimates presented below reflect the hourly labor costs reported in Chapter 3.
Training
LQGs and SQGs are required to conduct annual employee training related to hazardous waste management procedures to ensure that staff are able to perform their duties to maintain facility compliance with RCRA requirements and respond effectively to emergencies.  The requirements for LQGs in accordance with §262.17(a)(6)and §265.17 (a)(7), obligate LQGs to ensure that their training program is:
      "designed to ensure that facility personnel are able to respond effectively to emergencies by familiarizing them with emergency procedures, emergency equipment, and emergency systems, including, where applicable:(i) Procedures for using, inspecting, repairing, and replacing facility emergency and monitoring equipment..." 
In contrast, the less stringent SQG training requirements at §262.16(b)(9)(iii) state:
      "the generator must ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures, relevant to their responsibilities during normal facility operations and emergencies."  
Exhibit 4-1 presents the estimated cost to conduct annual training by generator status.  As shown in the exhibit, LQGs are assumed to train four technicians and two managers, while SQGs are assumed to train two technicians and one manager.  SQGs are expected to conduct informal training that requires approximately four hours of a manager's time to prepare (including pulling together EPA guidance, fact sheets, and relevant facility standard operating procedures).  Consistent with the more stringent training requirements for LQGs under §262.17 (a)(7), LQGs are expected to conduct more formal training using an online training course supplemented with facility-specific information.  The class fee is approximately $125 per trainee.  The total cost of training includes the cost of training materials and the cost of the staff time associated with the training.
EXHIBIT 4-1:  ANNUAL COST OF GENERATOR STAFF TRAINING PER FACILITY ($2015)
                               GENERATOR STATUS
                           STAFF REQUIRING TRAINING
                                   TRAINING/
                               INSTRUCTION TIME
                          TRAINING MATERIALS REQUIRED
                            TOTAL COST OF TRAINING
SQG 
2 technicians, 
1 manager
                                    4 hours
4 hours of manager's time to develop training
                                    $1,027
LQG
4 technicians, 
2 managers
                                    8 hours
$125 class fee per trainee, 0.6 hours for administrative requirements, and $3.20 in O&M costs for recordkeeping 
                                    $3,495

Based on the training costs presented in Exhibit 4-1, the flexibility afforded SQGs that accumulate hazardous waste on drip pads or in containment buildings for 90 days or less to avoid the more stringent LQG training requirements will result in a cost savings of $2,468 ($3,495 - $1,027) per facility.
Emergency Response Preparedness
Under the existing RCRA requirements for prevention, preparedness, and emergency response, LQGs must prepare a contingency plan, coordinate with local response agencies, and update the plan as needed.  Similarly, SQGs that accumulate hazardous waste in containment buildings for 90 days or less and SQGs that accumulate hazardous waste on drip pads for 180 days or less must meet the LQG requirements.  This RIA assumes that all SQGs that will avoid the more stringent LQG requirements under the final rule would have previously prepared a detailed, written contingency plan for handling emergencies (i.e., these are sunk costs).  Therefore, the cost savings for these facilities are limited to the annual cost to review, update, and distribute the contingency plan, which is assumed to require 1.5 hours of a technician's time and 2.1 hours of administrative time -- approximately $111 based on the hourly labor costs presented in Chapter 3.  Thus, the total cost savings associated with the flexibility afforded SQGs that accumulate hazardous waste on drip pads or in containment buildings to avoid the more stringent LQG requirements for contingency plan updating is $111 per facility per year.  Exhibit 4-2 reports the cost for an LQG to update its contingency plan.

EXHIBIT 4-2:  ANNUAL COST OF EMERGENCY RESPONSE PREPAREDNESS PER FACILITY ($2015)
                               GENERATOR STATUS
                                REQUIRED STAFF 
                        TIME TO UPDATE CONTINGENCY PLAN
                                  ACTIVITIES
                     TOTAL COST TO UPDATE CONTINGENCY PLAN
                                      LQG
                                  Technician
                                   1.5 hours
1.5 hours for data collection (e.g., list of emergency equipment at the facility) and amending/updating the existing contingency plan
                                    $110.90

                                Administrative
                                   2.1 hours
1.5 hours for information collection (e.g., emergency contact names and phone numbers), 0.5 hours to submit the plan to emergency management authorities, and 0.1 hours for administrative recordkeeping
                                       

Biennial Reports
Under existing RCRA regulations, SQGs that accumulate hazardous waste on drip pads or in containment buildings for 90 days or less must submit biennial reports of their hazardous waste generation activity to EPA or State authorities.  The fixed costs of preparing a biennial report include the time to read the instructions, complete the site ID form, submit the report to EPA or State authorities, and maintain a copy of the report for three years.  EPA estimates that the cost of these activities is approximately $286 per facility.  Additionally, the variable cost of completing each GM form for the BR submission is $21.02.  As described in Chapter 3, SQGs on average are estimated to complete between 6 and 7 GM forms per BR reporting year (one for each unique waste stream), which implies an additional $126 to $147 in reporting costs per BR cycle.  In total, these costs range from $412 to $433 every even-numbered year (or $213 to $224 on an annualized basis using a 7 percent discount rate).
Aggregate Benefits of Drip Pad and Containment Building Requirements for SQGs
As described above, EPA estimates that 307 SQGs could take advantage of the additional flexibility for facilities that accumulate hazardous waste on drip pads or in containment buildings for less than 90 days.  Exhibit 4-3 summarizes the cost savings associated with no longer being subject to the requirements that apply to LQGs for personnel training, emergency response preparedness, and biennial reporting.  These cost savings are reported on an annualized basis per facility and in aggregate.  In total, this RIA estimates that SQGs will experience annualized benefits of between $857,000 and $860,000 as a result of the drip pad and containment building requirements. 
EXHIBIT 4-3:  ANNUALIZED UNIT AND AGGREGATE COST SAVINGS FOR DRIP PAD AND CONTAINMENT BUILDING REQUIREMENTS ($2015 ANNUALIZED OVER 20 YEARS, USING A 7% DISCOUNT RATE)
                               GENERATOR STATUS
                                      [A]
                              LOW IMPACT ESTIMATE
NUMBER OF AFFECTED FACILITIES LIKELY TO INCUR COST SAVINGS
                                      [B]
                     ANNUALIZED COST SAVINGS PER FACILITY
                       AGGREGATE ANNUALIZED COST SAVINGS
                         TOTAL ANNUALIZED COST SAVINGS
                                    [G=E+F]
ONE-TIME COST SAVINGS
                                      [C]
                            RECURRING COST SAVINGS
                                      [D]
                             ONE-TIME COST SAVINGS
                                   [E=BxC]
                            RECURRING COST SAVINGS
                                   [F=BxD]

LQG
                                       0
                                     $0.00
                                     $0.00
                                      $0
                                      $0
                                      $0
SQG[a]
                                      307
                                     $0.00
                                   $2,790[b]
                                      $0
                                   $857,000
                                   $857,000
VSQG
                                       0
                                     $0.00
                                     $0.00
                                      $0
                                      $0
                                      $0
TOTAL
                                      307
                                      N/A
                                      N/A
                                      $0
                                   $857,000
                                   $857,000
                               GENERATOR STATUS
                                      [A]
                             HIGH IMPACT ESTIMATE
          NUMBER OF AFFECTED FACILITIES LIKELY TO INCUR COST SAVINGS
                                      [B]
                     ANNUALIZED COST SAVINGS PER FACILITY
                       AGGREGATE ANNUALIZED COST SAVINGS
                         TOTAL ANNUALIZED COST SAVINGS
                                    [G=E+F]
                             ONE-TIME COST SAVINGS
                                      [C]
                            RECURRING COST SAVINGS
                                      [D]
                             ONE-TIME COST SAVINGS
                                   [E=BxC]
                            RECURRING COST SAVINGS
                                   [F=BxD]

LQG
                                       0
                                     $0.00
                                     $0.00
                                      $0
                                      $0
                                      $0
SQG[a]
                                      307
                                     $0.00
                                   $2,800[c]
                                      $0
                                   $860,000
                                   $860,000
VSQG
                                       0
                                     $0.00
                                     $0.00
                                      $0
                                      $0
                                      $0
TOTAL
                                      307
                                      N/A
                                      N/A
                                      $0
                                   $860,000
                                   $860,000
Notes:
 EPA estimates that 12 SQGs accumulate hazardous waste in containment buildings and 295 SQGs accumulate hazardous waste on drip pads.
 The annualized costs savings include $2,468 for training, $111 for contingency plan updating, and $213 for biennial reporting in the low-impact scenario.
 The annualized costs savings include $2,468 for training, $111 for contingency plan updating, and $224 for biennial reporting in the high-impact scenario.
4.2.2 Intra-organizational Transfers of Hazardous Waste from VSQGs to LQGs
As outlined in Chapter 1, EPA is proposing to allow VSQGs to send their hazardous waste voluntarily to an LQG under the control of the same person, provided that both the VSQG(s) and LQG comply with certain conditions.  Under existing regulations, a VSQG may either treat or dispose of its hazardous waste on-site or ensure delivery to an off-site treatment, storage, or disposal facility, which can include permitted hazardous waste facilities, interim status hazardous waste facilities, municipal solid waste facilities, non-municipal non-hazardous waste facilities, and universal waste handlers. The existing VSQG regulations do not allow a generator to send its hazardous waste off-site to another generator, unless the receiving generator is also one of the types of facilities listed above.  In particular, existing RCRA regulations allow an LQG to accept waste from its VSQG affiliates only if the LQG has a RCRA storage permit and can demonstrate financial assurance for potential corrective action and closure/post-closure liabilities.  The final rule will eliminate the permit and financial assurance requirements for intra-organizational transfers of hazardous waste from VSQGs to LQGs in order to encourage improved VSQG waste management.  This section first describes the benefits of intra-organizational transfers for facilities that voluntarily begin to consolidate waste in response to the flexibility provided by the rule.  Then, this section describes the cost savings of this provision for facilities that already manage hazardous waste by means of intra-organizational transfers.  Information collected by EPA suggests that four LQGs are currently permitted to accept VSQG hazardous waste for consolidation.  
Voluntary Adoption of Intra-organizational Tranfsers
Allowing VSQGs to send their hazardous waste to an LQG under the control of the same person may result in a net cost savings from reduced management costs (1) at the establishment-level for individual VSQG facilities and (2) at the firm-level for organizations that manage multiple facilities that could potentially consolidate their hazardous waste.  At the establishment-level, VSQGs transport their waste to an LQG facility using the organizations' existing fleet of hazmat vehicles (or a hazardous waste transporter within their own delivery network) and pass on the costs of disposal to the LQG.  At the firm-level, organizations realize cost-savings associated with managing waste quantities in bulk.  Specifically, industry sources estimate that stand-alone VSQG facilities incur an average cost premium of approximately 10 percent to dispose of their hazardous waste relative to LQGs.  Organizations consolidating VSQG waste to LQGs may also realize a transportation cost savings due to the higher transport costs typically incurred by VSQGs on a per-ton basis compared to LQGs, as described below.
The net transportation cost savings associated with consolidating VSQG waste to LQGs owned by the same organization reflect two specific factors.  First, while VSQGs typically send their waste to a TSDF (or MSW landfill), LQGs manage more of their hazardous waste on-site (69.1 percent according to the 2013 BR data) and therefore, on average, incur lower transportation costs than VSQGs per ton of waste managed.  Second, the incremental cost for an LQG to ship additional waste off-site includes only the variable cost of transporting the additional waste (on a per drum basis), since the fixed costs of transportation (e.g., hiring a truck) are already incurred in the baseline, while the incremental cost for a VSQG to ship waste off-site includes both fixed and variable costs.
Considering both of these factors, this RIA estimates the net transportation cost savings per VSQG consolidated as the difference between the transportation costs associated with a VSQG's waste management in the baseline and the transportation costs associated with that waste once it is consolidated at an LQG.  VSQG costs to transport hazardous waste off-site include a fixed-cost of $46.93 for hiring a truck, plus variable costs of $34.00 per drum.  Based on the assumption stated in Chapter 3 that the average VSQG ships five to six 55-gallon drums per year, this translates to avoided transportation costs of $213 to $246 per VSQG.
Once the VSQG's waste is transferred to an LQG, the cost of transporting it to a TSDF includes the costs outlined above excluding the fixed cost of $46.93 to hire a truck, because the waste from the consolidated VSQG will likely be added to an existing shipment.  Thus, when an LQG ships the VSQG waste off-site, the variable transportation cost is approximately $166 to $199 per consolidated VSQG.  As noted above, however, 69.1 percent of LQG waste is managed on-site.  The expected transportation cost for a VSQG's waste once consolidated to an LQG is therefore approximately $51 to $62.  Subtracting this from the avoided VSQG transport cost yields a net transportation cost saving of $162 to $185 per consolidated VSQG.
As noted above, organizations consolidating their VSQG hazardous waste at LQGs will also realize a cost savings associated with a reduction in disposal costs due to the 10 percent disposal cost premium typically incurred by VSQGs relative to LQGs.  The cost savings associated with avoiding this cost premium depend on the method by which VSQG hazardous waste is managed, as the per ton cost of managing hazardous waste varies by management method.  This RIA assumes that hazardous waste managed by VSQGs will, if consolidated to an LQG, generally be managed using the same disposal methods as under the baseline, with the exception of hazardous waste managed for reclamation and recovery in the baseline.  Because the economic viability of reclamation and recovery may depend on a generator's proximity to reclamation facilities, this RIA assumes that waste undergoing reclamation in the baseline will not be consolidated.  To estimate the disposal costs of the other management methods used by VSQGs, this RIA applies the weighted average of the most common remaining off-site disposal methods.  As described in Chapter 2, the most typical off-site management methods among non-LQG facilities include: stabilization prior to land disposal at another site (36 percent over overall waste); landfill or surface impoundment without stabilization (10 percent); incineration (4 percent); and deepwell or underground injection (3 percent).  As shown in Exhibit 4-4, the weighted average disposal cost per VSQG across these management methods is approximately $168 to $175.  This value reflects annual hazardous waste generation of approximately 0.25 tons per VSQG (see Chapter 2), which is assumed to be split across five to six 55-gallon drums (see Chapter 3, Other Assumptions).  The exhibit also shows the cost of disposing of a VSQG's waste once it is consolidated to an LQG.  As presented in the exhibit, the estimated $15 to $16 in cost savings associated with consolidating to an LQG reflects the avoided cost premium paid by VSQGs in the baseline.

EXHIBIT 4-4:  PER FACILITY COST SAVINGS FOR DISPOSAL OF HAZARDOUS WASTE GENERATED BY A VSQG ($2015)MANAGEMENT METHOD
            PERCENTAGE OF NON-LQG WASTE MANAGEDLOW IMPACT ESTIMATE
                             HIGH IMPACT ESTIMATE
AVERAGE COST TO DISPOSE OF VSQG HAZARDOUS WASTE (PER FACILITY)SAVINGS IF MANAGED AT AN LQG INSTEAD OF A VSQGAVERAGE COST TO DISPOSE OF VSQG HAZARDOUS WASTE (PER FACILITY)SAVINGS IF MANAGED AT AN LQG INSTEAD OF A VSQGWASTE MANAGED BY VSQG
                             WASTE MANAGED BY LQG
                             WASTE MANAGED BY VSQG
                             WASTE MANAGED BY LQG
                                 INCINERATION
                                     4.0%
                                    $1,021
                                     $928
                                      $93
                                    $1,028
                                     $935
                                      $93
Deepwell or Underground Injection
                                     3.4%
                                     $106
                                      $96
                                      $10
                                     $113
                                     $103
                                      $10
HW Landfill
(with stabilization)
                                     36.4%
                                     $108
                                      $98
                                      $10
                                     $116
                                     $105
                                      $11
HW landfill
(without stabilization)
                                     10.3%
                                      $76
                                      $69
                                      $7
                                      $83
                                      $76
                                      $8
Weighted-Average Cost of Disposal
                                       -
                                     $168
                                     $153
                                      $15
                                     $175
                                     $159
                                      $16
Notes:
 The values in this exhibit assume that VSQGs generate, on average, between 5 containers (low-end estimate) and 6 containers (high-end estimate) worth of hazardous waste each year.
 This RIA assumes that waste managed using the most common off-site disposal methods could potentially be consolidated at an LQG facility. These methods account for approximately 54 percent of total hazardous waste management. It is assumed that the remaining 46 percent -- which may be managed on-site (e.g., sewering), transferred off-site with no treatment or recovery, or treated using another method -- will not be consolidated at another facility.
 Average disposal costs are estimated for a VSQG facility generating approximately 0.25 tons of hazardous waste per year based on the average quantity reported in the 2013 BR data and data provided from the States of Maine, New Jersey, and Washington. A facility generating this amount of hazardous waste will likely accumulate five to six partially-filled 55-gallon drums per year, assuming an accumulation storage limit of one year and an average container capacity of approximately 157 to 313 pounds per drum. The unit costs for the management methods presented here are assumed to be the following (without the VSQG cost premium): $1.78 per pound for hazardous waste incineration, $247 per ton for landfilling with stabilization, $140 per ton for landfilling without stabilization, and $257 per ton for deepwell or underground injection.  These values are based on U.S. EPA Office Resource Conservation and Recovery, Unit Cost Compendium, September 26, 2011. The costs in this exhibit for each management method also reflect a loading cost of approximately $6.80 per drum, as derived from RACER 2010.
 Values may not equal difference between preceding two columns due to rounding.
Facilities that Already Consolidate Hazardous Waste
The intra-organization transfer provision of the final rule may also lead to cost savings for organizations that already consolidate VSQG hazardous waste at an LQG.  As noted above, information collected by EPA suggests that four LQGs currently accept VSQG waste for consolidation.  These LQGs will experience two types of cost-savings: (1) the avoided cost to renew their RCRA storage permit and (2) the avoided cost to secure financial assurance to address corrective action and post-closure liabilities.  The cost to obtain a RCRA storage permit is very high, which may explain why most LQGs do not elect to obtain one.  However, for the four permitted facilities assumed to accept VSQG waste in the baseline, this is a sunk cost and does not represent a cost savings under the rule.  The permit-related cost savings for these facilities are limited to the avoided renewal costs for the Part B permit, which expires every ten years.  The cost to review the regulations and submit the Part B renewal application is an estimated $5,500 per facility, or approximately $732 on an annualized basis (using a 7 percent discount rate). 
In addition, financial assurance costs for potential corrective action and closure/post-closure liabilities represent a significant cost for facilities with RCRA storage permits.  Avoiding these costs represents a benefit to LQGs that already accept hazardous waste from VSQGs operated by the same owners.  This RIA uses the costs of securing a third-party financial instrument (a letter of credit) as a proxy for the burden of obtaining financial assurance.  Industry sources provided a range of cost estimates for annual premiums for securing a letter of credit, ranging from 1 percent to 3 percent of corrective action and closure/post-closure liabilities.  For the purposes of this analysis, EPA uses the midpoint of this range (2 percent).  The corrective action and closure/post-closure liabilities covered by a letter of credit or other financial instrument can vary widely.  Based on the results of a survey of corrective action liabilities reported in EPA's 2002 Regulatory Impact Analysis for the corrective action program, EPA estimates that the median cost of corrective action remediation is approximately $5 million (in 2002 dollars), which is equivalent to approximately $6.5 million (in 2015 dollars).  For closure/post-closure care, this RIA applies the closure/post-closure costs reported in Chapter 3 for LQGs that will be required to close as a landfill (approximately $631,000).  Companies that secure a letter of credit also typically incur an annual administrative processing cost of approximately $1,010.  Combining these items, the total annual cost of securing financial assurance for corrective action and closure/post-closure activities is approximately $142,700 per facility.
The intra-organization transfer provision will result in no additional costs (or benefits) for VSQGs that currently consolidate their hazardous waste, as these facilities will experience no change in their operations relative to baseline. 
Similar to the cost assessment for the intra-organization transfer provision presented in Chapter 3, this assessment of benefits assumes that VSQG consolidation will be limited to VSQGs in those states that prohibit or severely restrict the disposal of hazardous waste in MSW landfills and the estimated 10 percent of VSQGs in other states that send their hazardous waste to a TSDF.[,]
Cost Savings Across Waste Management Activities
Drawing from the cost information summarized in the previous sections, Exhibit 4-5 reports the per facility cost savings associated with intra-organizational transfers from VSQGs to LQGs.
EXHIBIT 4-5:  COST SAVINGS ASSOCIATED WITH INTRA-ORGANIZATIONAL TRANSFERS PER ORGANIZATION ($2015)
                               RCRA REQUIREMENT
               COST OF WASTE MANAGEMENTCOST SAVINGS PER SHIPMENT
                          ANNUALIZED NET COST SAVINGS
                     (USING A 7 PERCENT DISCOUNT RATE)VSQG
                                      LQG
                                TRANSPORTATION
                                       
                                       
                                       
                                       
Low-end
                                     $213
                                      $51
                                     $162
                                     $940
High-end
                                     $246
                                      $62
                                     $185
                                    $1,657
Disposal
                                       
                                       
                                       
                                       
Low-end
                                     $168
                                     $152
                                      $15
                                      $89
High-end
                                     $175
                                     $159
                                      $16
                                     $143
RCRA Part B Permit Renewal[3,4]
                                       
                                    $5,500
                                       
                                     $732
Financial Assurance (post-closure) 3,5
                                       
                                   $142,708
                                       
                                   $142,708
Total Cost Savings (excluding RCRA Part B Permit)
                               $1,029 to $1,800
Total Cost Savings (including RCRA Part B Permit)[3]
                             $144,469 to $145,239
Notes:
 The costs of waste management activities reflect transportation and disposal costs for between 5 and 6 drums as managed by a VSQG and LQG, respectively. 
 EPA estimates that LQGs will consolidate waste for an average of 5.8 VSQGs per LQG in the low-impact scenario and 9.0 VSQGs per LQG in the high-impact scenario.
 EPA estimates that only 4 permitted LQGs that currently consolidate VSQG waste will experience cost savings associated with the RCRA Part B permit requirements.
 Facilities must renew their RCRA Part B Permit every 10 years. Thus, costs are annualized over a 10-year period.
 The cost of posting financial assurance includes $1,010 in administrative costs and $141,697 for obtaining a letter of credit. The average cost of obtaining a letter of credit is estimated to be 2 percent of post-closure liabilities, which include approximately $6.5 million for corrective action remediation and $631,000 for closure as a landfill.

Aggregate Benefits of Intra-organizational Tranfsers
As described in Chapter 3, between 20,569 and 31,738 VSQGs in the potentially affected universe could take advantage of the flexibility provided by this provision and an estimated 3,541 LQGs will receive this waste (in addition to the four LQGs that already accept VSQG waste for consolidation).  Exhibit 4-6 shows the derivation of the net transportation and disposal cost savings associated with intra-organization transfers allowed under the rule as well as the cost savings for avoided RCRA storage permit renewal and financial assurance costs for LQGs that already consolidate VSQG waste.  The costs (for LQGs) and cost savings (for VSQGs) are presented as annualized impacts per facility and in aggregate.  From the perspective of the organizations that own these LQGs and VSQGs, the net impact is a cost savings.  The waste management activity is simply transferred from VSQGs to LQGs.  This RIA presents this change in the location of where management costs are realized as a cost increase for LQGs and a cost savings for VSQGs for illustrative purposes.  The cost savings realized by VSQGs, however, exceed the increase in costs realized by LQGs, leading to a net cost savings.  All of the benefits associated with intra-organizational transfers are realized on a recurring annual basis, with the exception of avoided RCRA storage permit renewal costs.
As the exhibit illustrates, the intra-organizational transfer provision of the final rule yields a total cost savings of between approximately $4.2 and $6.9 million.
EXHIBIT 4-6:  ANNUALIZED UNIT AND AGGREGATE COST SAVINGS FOR INTRA-ORGANIZATION TRANSFERS ($2015 ANNUALIZED OVER 20 YEARS, USING A 7% DISCOUNT RATE)
                               GENERATOR STATUS
                                      [A]
                              LOW IMPACT ESTIMATE
NUMBER OF AFFECTED FACILITIES LIKELY TO INCUR COST SAVINGS
                                      [B]
                     ANNUALIZED COST SAVINGS PER FACILITY
                       AGGREGATE ANNUALIZED COST SAVINGS
                         TOTAL ANNUALIZED COST SAVINGS
                                    [G=E+F]
ONE-TIME COST SAVINGS
                                      [C]
                            RECURRING COST SAVINGS
                                      [D]
                             ONE-TIME COST SAVINGS
                                   [E=BxC]
                            RECURRING COST SAVINGS
                                   [F=BxD]

LQG[a]
                                 3,541 (4)[b]
                                     $0.00
                                  ($1,022)[c]
                                      $0
                                 ($3,620,000)
                                 ($3,620,000)
SQG
                                       0
                                     $0.00
                                     $0.00
                                      $0
                                      $0
                                      $0
VSQG
                                    20,569
                                     $0.00
                                    $381[d]
                                      $0
                                  $7,830,000
                                  $7,830,000
TOTAL
                                 24,110 (4)[b]
                                      N/A
                                      N/A
                                      $0
                                  $4,210,000
                                  $4,210,000
                               GENERATOR STATUS
                                      [A]
                             HIGH IMPACT ESTIMATE
          NUMBER OF AFFECTED FACILITIES LIKELY TO INCUR COST SAVINGS
                                      [B]
                     ANNUALIZED COST SAVINGS PER FACILITY
                       AGGREGATE ANNUALIZED COST SAVINGS
                         TOTAL ANNUALIZED COST SAVINGS
                                    [G=E+F]
                             ONE-TIME COST SAVINGS
                                      [C]
                            RECURRING COST SAVINGS
                                      [D]
                             ONE-TIME COST SAVINGS
                                   [E=BxC]
                            RECURRING COST SAVINGS
                                   [F=BxD]

LQG[e]
                                 3,541 (4)[b]
                                     $0.00
                                  ($1,818)[f]
                                      $0
                                 ($6,440,000)
                                 ($6,440,000)
SQG
                                       0
                                     $0.00
                                     $0.00
                                      $0
                                      $0
                                      $0
VSQG
                                    31,738
                                     $0.00
                                    $421[d]
                                      $0
                                  $13,400,000
                                  $13,400,000
TOTAL
                                 35,279 (4)[b]
                                      N/A
                                      N/A
                                      $0
                                  $6,940,000
                                  $6,940,000
Notes:
Positive values are a cost savings, whereas negative values in parentheses are a cost increase. All aggregate cost savings are rounded to three significant digits and may not sum due to rounding.
 LQGs that can consolidate hazardous waste are assumed to manage waste for an average of 5.8 VSQGs in the low impact scenario.
 In addition to facilities that may take advantage of the flexibility provided by this provision, information collected by EPA indicates that 4 LQG facilities already accept VSQG waste for consolidation. These facilities may incur cost savings as detailed below.
 This is a weighted average of the following: For LQGs that do not already consolidate waste: facilities will incur an average annual disposal cost of $152 plus transportation costs of $51 for VSQG waste that is managed by an LQG. This reflects a net transport costs savings of $162 per VSQG and a net disposal cost savings of $15 per VSQG (for a total cost savings of $177 per consolidated VSQG) for the organization as a whole. These costs are multiplied by 5.8 VSQGs per LQG in the low impact scenario. For LQGs that already consolidate waste: facilities experience the cost savings of (1) avoided RCRA Part B permit renewal costs every 10 years (a cost savings of $5,500, or $732 on an annualized basis, per facility) and (2) avoided costs of securing financial assurance for corrective action and closure/post-closure activities (a total annual cost savings of $142,700 per facility). Combined, these represent $143,400 in cost savings.
 This cost savings represents an average annual hazardous waste disposal cost savings of $168 in the low impact scenario ($175 in the high impact scenario) plus an average annual transportation cost savings of $213 in the low impact scenario ($246 in the high impact scenario) for VSQG waste that is managed by an LQG voluntarily under the rule.
 LQGs that can consolidate hazardous waste are assumed to manage waste for an average of 9.0 VSQGs in the high impact scenario.
 See costs in footnote b. For LQGS that do not already consolidate waste, costs are multiplied by 9.0 VSQGs per LQG in the high impact scenario.

4.2.3 Generators that Temporarily Change Generator Status Due to an Episodic Event
Under the final rule, EPA will allow a VSQG or SQG to retain its existing regulatory status in the event of no more than one planned and one unplanned episodic event per calendar year that would otherwise elevate the facility to a more stringent regulatory status.  This provision will result in a cost savings for VSQGs and SQGs that avoid the cost increase associated with such a change in generator status.  These costs are associated with the RCRA generator requirements for training, inspections, manifests, contingency plan updating, and biennial reporting.  The following sections present the costs associated with these waste management activities, and also estimate the potential cost savings realized by facilities that experience temporary episodic events.  All cost and cost savings estimates presented below reflect the hourly labor costs reported in Chapter 3.  These costs are summarized in Exhibit 4-7 and reported in aggregate on an annualized basis in Exhibit 4-8 below.
As noted above, this provision is limited to only those generators that experience one planned and one unplanned episodic event per year (with a petition submitted for the second event).  Therefore, the assessment of benefits presented in this chapter would ideally limit the quantification of benefits to those SQGs and VSQGs that experience no more than two episodic events per year.  The data applied in Chapter 3 to estimate the number of episodic generators, however, lack sufficient detail to distinguish between episodic generators with no more than two episodic events and those with more than two episodic events.  Instead, the analysis presented in this RIA is based on the total number of episodic generators, regardless of the annual number of episodic events per year.  The benefits estimates presented here therefore represent a high end estimate of benefits, as they may reflect estimated cost savings for episodic generators with more than two episodic events.  
Training
The RCRA training requirements for LQGs and SQGs are described earlier in this chapter in the section on drip pad and containment building requirements.  No training requirements exist for VSQGs.  Based on the training costs presented in Exhibit 4-1, the flexibility afforded episodic generators will result in savings of $1,027 per VSQG avoiding SQG status, $2,468 ($3,495 minus $1,027) for SQGs that avoid LQG status, and $3,495 for VSQGs that avoid becoming LQGs.
Inspections
LQGs and SQGs are required to conduct weekly inspections of hazardous waste storage areas.  This RIA assumes that a technician takes one hour to inspect all storage areas for an LQG or SQG, which implies a weekly inspection cost of $42.21 per LQG or SQG.  In the baseline, if an episodic generator crosses the threshold from VSQG to LQG or SQG in a given month, the facility will need to conduct inspections until the waste is removed from the site.  Based on the manifest requirement that all hazardous waste generated during an episodic event must be shipped off-site within 60 days of the event, this RIA estimates that, on average, episodic generators that cross the SQG or LQG threshold will be able to ship waste off-site within 45 days of the episodic event and will have to conduct weekly inspections for seven weeks after the event (facilities will have up to nine weeks to ship waste off-site).  Therefore, VSQGs that would otherwise become SQGs or LQGs avoid an additional $295 in inspections costs by complying with the episodic generation requirements.  SQGs that would become LQGs due to an episodic event realize no cost savings because SQGs are required to conduct inspections in the baseline.
Manifest Training
Based on the RCRA training regulations, this RIA assumes that LQGs and SQGs provide training to employees every three years on the preparation of hazardous waste manifests.  This RIA assumes each facility trains one manager and one technician to complete manifests.  Employees are expected to receive a four-hour manifest training session once every three years.  As part of this training, this RIA assumes facilities will use EPA's free online hazardous waste manifest video.  The cost of manifest training also includes one hour of a manager's time to compile EPA's hazardous waste manifest instructions and other training materials.  Approximately 0.3 hours of administrative time will likely be incurred to schedule the training every three years.  Based on these estimates, the cost of manifest training is approximately $606 per facility once every three years (an annualized cost of $216, using a 7 percent discount rate).  VSQGs that avoid SQG or LQG status due to this provision will avoid this cost altogether.
Manifests
Under RCRA, LQGs and SQGs are required to prepare a manifest that, among other information, includes the RCRA waste codes for each hazardous waste shipment.  No such requirements exist for VSQGs.  This RIA estimates that the cost to complete a manifest is $10.30 per shipment for SQGs.  This value is also assumed to apply to VSQGs and SQGs that become LQGs due to an episodic generation event.  With respect to the frequency of manifesting, this RIA assumes that an episodic generation event occurring in the baseline may lead a generator that is otherwise a VSQG to submit one manifest for the shipment of its non-episodic waste.  Under the final rule, the facility will not need to prepare a manifest for this waste and will realize a cost savings.
Emergency Response Preparedness
As described earlier in the section on drip pad and containment building requirements, under existing regulations LQGs must prepare a contingency plan, coordinate with local response agencies, and update the plan as needed.  This RIA assumes that all facilities that avoid LQG status under the rule have previously prepared a detailed, written contingency plan for handling emergencies (when they surpassed the LQG threshold during previous episodic generation events), because such a plan is required of all LQGs.  Therefore, the cost savings for these facilities is the annual cost to review, update, and distribute the contingency plan, which is assumed to take approximately 1.5 of a technician's time and 2.1 hours of administrative time, or approximately $111.  Thus, the total cost savings associated with avoiding LQG status and the associated contingency plan updating is approximately $111 per facility per year.
Biennial Reports
Under existing RCRA regulations, LQGs must submit biennial reports of their hazardous waste generation activity to EPA or State authorities.  As described above, EPA estimates the fixed costs of preparing a biennial report to be approximately $286 per facility.  Additionally, the variable cost of completing each GM form for the BR submission is $21.02.  As described in Chapter 3, LQGs on average are estimated to complete between 6 and 13 unique GM forms per BR reporting year.  LQGs incur these costs every even-numbered year.  In total, these costs range from $412 to $559 (or $213 to $289 on an annualized basis using a 7 percent discount rate).
Cost Savings Across Waste Management Activities
Drawing from the cost information summarized in the previous sections, Exhibit 4-7 reports the per facility cost savings associated with the changes in generator status that are avoided under the final rule.
EXHIBIT 4-7:  PER-FACILITY COST SAVINGS ASSOCIATED WITH AVOIDING A CHANGE FROM A LESS STRINGENT TO A MORE STRINGENT GENERATOR STATUS ($2015)
                               RCRA REQUIREMENT
                      CHANGE IN GENERATOR STATUS AVOIDED
                                   FREQUENCY
                                  VSQG-TO-SQG
                                  VSQG-TO-LQG
                                  SQG-TO-LQG
                                   TRAINING
                                    $1,027
                                    $3,495
                                    $2,468
                                    Annual
Inspections[1]
                                      $42
                                      $42
                                      $0
                                    Weekly
Manifest Training[2]
                                     $606
                                     $606
                                      $0
                                 Every 3 Years
Manifests
                                      $10
                                      $10
                                      $0
                                    Annual
Emergency Response
                                      $0
                                     $111
                                     $111
                                    Annual
Biennial Reports[3]
                                      $0
                                 $412 to $559
                                 $412 to $559
                                 Every 2 Years
Total (annualized)
                                    $1,550
                               $4,350 to $4,420
                               $2,790 to $2,870
                                       
Notes:
 EPA estimates that facilities have to conduct inspections due to a change in generator status for an average of seven weeks following the episodic event until all episodic hazardous waste can be shipped off-site at an average cost of $295 per facility for all VSQGs.
 This represents an annualized cost of $216 per facility.
 This represents an annualized cost of $213 to $289 per facility.

Aggregate Benefits of Episodic Generation Provisions
To estimate the total cost savings associated with this rule provision, this RIA applies the per facility savings in Exhibit 4-7 to the estimated number of eligible generators.  As described in Chapter 3, this RIA estimates that 2,544 facilities (including both VSQGs and SQGs) move into a more stringent generator status each year.  This value represents less than 1 percent of the potentially affected universe.  The number of these facilities that will be elevated to a higher generator status due to an episodic generation event that meets the rule conditions (e.g., the episodic event must occur within a single calendar month) is uncertain.  Due to this uncertainty, this RIA estimates the number of facilities qualifying for this rule provision as a range.  The low end of the range assumes that 50 percent of facilities experiencing a change in generator status meet the rule conditions (one or two episodic events per year lasting no more than a month) and take advantage of this provision.  The high end of the range assumes that 100 percent of affected facilities are able to take advantage of this provision.  As reported in Exhibit 4-8, based on these assumptions, EPA estimates an aggregate annual cost savings of between $3.2 million and $6.6 million (using a seven percent discount rate) for VSQGs and SQGs that could maintain their existing regulatory status in the event of an episodic generation event.  This range is similar when applying a 3 percent discount rate.  The flexibility afforded episodic generators under the final rule will yield annualized cost savings on a per-facility basis ranging from $1,550 per VSQG avoiding SQG status to $4,350 to $4,420 per VSQG avoiding LQG status.  This flexibility will also yield annualized cost savings of approximately $2,790 to $2,870 per SQG avoiding LQG status.
EXHIBIT 4-8:  ANNUALIZED UNIT AND AGGREGATE COST SAVINGS FOR THE EPISODIC GENERATION PROVISION ($2015 ANNUALIZED OVER 20 YEARS, USING A 7% DISCOUNT RATE)[a]
                               GENERATOR STATUS
                                      [A]
                              LOW IMPACT ESTIMATE
NUMBER OF AFFECTED FACILITIES LIKELY TO INCUR COST SAVINGS
                                      [B]
                     ANNUALIZED COST SAVINGS PER FACILITY
                       AGGREGATE ANNUALIZED COST SAVINGS
                         TOTAL ANNUALIZED COST SAVINGS
                                    [G=E+F]
ONE-TIME COST SAVINGS
                                      [C]
                            RECURRING COST SAVINGS
                                      [D]
                             ONE-TIME COST SAVINGS
                                   [E=BxC]
                            RECURRING COST SAVINGS
                                   [F=BxD]

LQG
                                       0
                                     $0.00
                                     $0.00
                                      $0
                                      $0
                                      $0
SQG
                                      419
                                     $0.00
                                   $2,790[c]
                                      $0
                                  $1,170,000
                                  $1,170,000
VSQG[b]
                                      854
                                     $0.00
                                   $2,420[d]
                                      $0
                                  $2,060,000
                                  $2,060,000
TOTAL
                                     1,273
                                      N/A
                                      N/A
                                      $0
                                  $3,230,000
                                  $3,230,000
                               GENERATOR STATUS
                                      [A]
                             HIGH IMPACT ESTIMATE
          NUMBER OF AFFECTED FACILITIES LIKELY TO INCUR COST SAVINGS
                                      [B]
                     ANNUALIZED COST SAVINGS PER FACILITY
                       AGGREGATE ANNUALIZED COST SAVINGS
                         TOTAL ANNUALIZED COST SAVINGS
                                    [G=E+F]
                             ONE-TIME COST SAVINGS
                                      [C]
                            RECURRING COST SAVINGS
                                      [D]
                             ONE-TIME COST SAVINGS
                                   [E=BxC]
                            RECURRING COST SAVINGS
                                   [F=BxD]

LQG
                                       0
                                     $0.00
                                     $0.00
                                      $0
                                      $0
                                      $0
SQG
                                      837
                                     $0.00
                                   $2,870[c]
                                      $0
                                  $2,400,000
                                  $2,400,000
VSQG[b]
                                     1,707
                                     $0.00
                                   $2,440[e]
                                      $0
                                  $4,160,000
                                  $4,160,000
TOTAL
                                     2,544
                                      N/A
                                      N/A
                                      $0
                                  $6,560,000
                                  $6,560,000
Notes:
 See Exhibit 4-7 for unit cost details by waste management activity.
 This RIA assumes that the following changes in generator status will occur but for the regulatory flexibility provided by the final rule: 264 VSQG-to-LQG and 590 VSQG-to-SQG changes in the low impact scenario and 527 VSQG-to-LQG and 1,180 VSQG-to-SQG changes in the high impact scenario.
 The SQG values reflect per facility costs presented above in Exhibit 4-7.
 This figure is a weighted average that reflects a cost savings of $1,550 per VSQG that would otherwise be elevated to SQG status and $4,350 per VSQG that would otherwise be elevated to LQG status in the low impact scenario.  As indicated in Chapter 3, an estimated 590 VSQGs will avoid SQG status under the low-impact scenario and 264 VSQGs will avoid LQG status.
 This figure is a weighted average that reflects a cost savings of $1,550 for VSQGs that would otherwise be elevated to SQG status and $4,420 for VSQGs that would otherwise be elevated to LQG status in the high impact scenario.  As indicated in Chapter 3, an estimated 1,180 VSQGs will avoid SQG status under the high-impact scenario and 527 will avoid LQG status.

4.3 Non-Quantified Benefits
In addition to the monetized benefits presented in the previous section, the final rule may yield a variety of other non-quantifiable benefits.  These benefits are summarized below for each major rule provision outlined in Chapter 1.
4.3.1 SQG Re-notification
EPA's proposal that SQGs re-notify EPA of their hazardous waste generation activities every four years will improve the ability of EPA and the states to perform compliance monitoring of regulated facilities.  The data available to EPA will become more accurate and up-to-date, allowing the Agency to observe the changes in facilities' operations over time and therefore conduct more precise and meaningful reviews of their waste generation activity.  Similarly, the information collected through re-notification will help EPA and the states target their outreach, enforcement, and compliance assistance efforts.  For example, the information collected from re-notifications may help determine which facilities warrant greater oversight by providing information on which facilities are still operating and which facilities manage hazardous waste considered to be higher risk.  This more targeted enforcement approach may reduce the risk of environmental damage from the mismanagement of hazardous waste.
Re-notification may also result in time savings associated with assembling data for analyses performed by the Agency and the states on a periodic basis.  For example, information collected from re-notifications may inform analyses of regulatory burdens to the regulated community and the benefits of RCRA regulations, or serve as data inputs in public reports on hazardous waste generation and management. 
4.3.2 Marking and Labeling of Containers for SQGs and LQGs
As described in Chapter 1, EPA is proposing that SQGs and LQGs mark containers with (1) the words "Hazardous Waste" and (2) an indication of the hazards of a container's contents (e.g., the applicable hazardous waste characteristics).
This change will help increase awareness of a container's contents among the various individuals in the waste management chain, which may in turn prevent improper treatment, transportation, and disposal of hazardous waste.  In addition, due to the increased awareness associated with enhanced labeling, generator employees may handle hazardous waste with greater care, potentially leading to a reduction in the number of accidental spills and other incidents that might jeopardize the health and safety of site employees and the nearby population. 
The more detailed information that EPA requires for container labels will also enhance the ability of emergency responders to limit adverse impacts from exposure to hazardous materials.  Emergency medical technicians will be able to treat those exposed to the hazardous waste in a manner specific to the waste's hazards, limiting exposure time, preventing lethal outcomes, and improving the time and chances of recovery.  
4.3.3 LQG Closure Conditions
With respect to facility closure, EPA is proposing that LQGs accumulating hazardous wastes in containers meet the landfill closure requirements if they cannot demonstrate that contaminated soils can be removed or decontaminated.  This provision of the rule will ensure that facilities are closed in a manner that reflects the additional risk associated with leaving hazardous waste (or materials containing hazardous constituents) in place at closure.  Under current regulation, LQGs that accumulate hazardous waste in containers may close accumulation areas with contamination in place without implementing measures to contain the waste.  Relative to these baseline closure requirements, the closure requirements for landfills are much more stringent and designed to contain any contaminants left in place at closure, thereby preventing potential releases to the environment. 
The Agency is also requiring that LQGs document their intention to close waste accumulation unit(s) at least 30 days prior to closure as well as when the units have been closed.  These requirements will a) provide regulatory authorities with knowledge of the location and specifics of hazardous waste sites planned for closure; b) allow the authorities to confirm that the unit is properly closed in compliance with the applicable closure regulations; and c) allow the authorities to monitor the unit during the post-closure period, alerting regulators in cases where generators may have abandoned the site or closed it improperly, or where other complications may have developed at the site.  This, in turn, will prevent releases of harmful substances to the environment and adverse impacts to human health and the environment.
4.3.4 Strengthening of the Preparedness, Prevention, and Emergency Response Conditions for LQGs
Building on the current preparedness requirements for LQGs, EPA is requiring that all new LQGs and LQGs that modify their plans submit a quick reference guide to their contingency plans to local emergency management authorities.  While LQGs are already required to provide a copy of their contingency plans to local emergency response agencies, the length of these documents may make it difficult for first responders to identify key information in the limited time available when an emergency occurs.
The contingency plan quick reference guide required under the final rule will allow first responders to more easily discern the layout of a facility, the location of hazardous wastes, the specific hazards associated with those wastes, and what chemicals to use (or not use) near those wastes.  To the extent that first responders are able to respond more quickly and effectively based on this information, this requirement may prevent lethal outcomes and injuries among fire fighters, other first responders, and facility employees, and may also reduce exposure risk for local populations and ecosystems. 
4.3.5 Transfer Facility Requirements
EPA is changing the marking and labeling requirements for transporters storing hazardous waste at a transfer facility.  Including this information on the container will alert facility workers of the container's contents and its potential hazards, which may help prevent the improper treatment of this material.  Displaying this information on the containers may also help first responders limit exposure to local populations and ecosystems in the event of a fire or other emergency. 
4.3.6 Biennial Reporting Requirements
As described in Chapter 1, EPA is proposing a clarifying change to the biennial reporting requirements for LQGs under the rule.  The Agency is proposing that LQGs report all of the hazardous waste that they generate for the entire reporting year, not just waste for the month(s) during which they were LQGs.  In addition, the Agency is requiring that certain classes of recycling facilities subject to CFR 261.6 submit BR reports.  These changes will make the BR more complete and consistent, allowing the Agency and the states to base their policy, programmatic, and enforcement decisions on more reliable hazardous waste generation and management data. 
4.3.7 Prohibitions on Storage of Restricted Waste for TSDFs
EPA is also requiring that TSDFs mark containers holding hazardous waste with (1) the words "Hazardous Waste" and (2) an indication of the hazards of a container's contents.  Under existing regulations, TSDFs must already marking containers holding hazardous waste with a description of the contents of the container.  As described above, including this information on containers may help prevent the improper treatment or transportation of hazardous waste, and may also help first responders limit exposures to hazardous waste in the unlikely event of a fire or other emergency.
4.3.8 Intra-organization Transfers of Hazardous Waste from VSQGs to LQGs (Voluntary)
As outlined above, the final rule will allow VSQGs to send their hazardous waste to an LQG under the control of the same person, provided that both the VSQG(s) and LQG comply with certain conditions.  In addition to the reduced transportation and disposal costs estimated above, allowing VSQGs to send their hazardous waste to an LQG under the ownership of the same organization will contribute to more environmentally sound management of hazardous waste and reduce environmental risks associated with long-term storage of hazardous wastes on site.  These potential benefits are outlined in more detail below.
 Improved Oversight. The rule will require that LQGs receiving waste from VSQGs within the same organization manage the VSQG-generated waste in accordance with RCRA LQG requirements.  Under these requirements, LQGs are subject to more rigorous management conditions (labeling, emergency planning, and containment standards) that are more protective of human health and the environment than VSQG requirements.  As a result, this change will improve oversight and management of hazardous waste by subjecting hazardous wastes generated by VSQGs to more rigorous management and disposal requirements. Related to these differences in requirements, the consolidation of VSQG waste at LQGs owned by the same company may lead to more protective management of hazardous waste, as LQGs typically have a better understanding of safe management practices and implement these practices on a more consistent basis.
 Reduce the Amount of Hazardous Waste Deposited in Subtitle D Landfills. Under the final rule, VSQGs that dispose of their hazardous waste in Subtitle D units (e.g., MSW landfills) in the baseline may send their waste to LQGs instead.  Because LQGs receiving VSQG hazardous waste must manage this waste in a permitted Subtitle C facility, the consolidation of VSQG waste to LQGs may, in effect, lead to the diversion of VSQG hazardous waste from Subtitle D disposal to Subtitle C disposal.  Such a change in the management of VSQG hazardous waste will reduce the overall quantity of hazardous waste disposed of in Subtitle D units, resulting in improved environmental quality and outcomes, particularly associated with landfill leaching. 
 Reduce Risks Associated with Longer Storage Times of Hazardous Wastes at VSQG Facilities. Whereas LQGs have up to 90 days to accumulate hazardous waste without having to obtain a RCRA storage permit or comply with interim status standards, VSQGs may accumulate up to 1,000 kilograms of hazardous waste (or up to 1 kilogram of acute hazardous waste or up to 100 kilograms of residues from the cleanup of a spill of acute hazardous waste) without any time constraint. The longer storage time of the hazardous waste on site presents a greater risk of adverse impacts to human health and the environment. Allowing VSQGs to send their hazardous waste to an LQG under the control of the same person may reduce the overall time that VSQG hazardous waste is accumulated on site, further reducing the potential risk to human health and the environment.
 Reduced Liability Risk. Organizations that opt to transfer their VSQG hazardous waste to LQGs within the organization will likely realize a reduction in liability risk.  Because the transferred waste will be managed at facilities with more protective safeguards than under the baseline, the likelihood of an environmental accident will be lower, which will reduce the organization's expected liabilities.  This reduction in liabilities could lead to cost savings associated with lower legal costs and lower insurance costs.    
4.3.9 Generators that Temporarily Change Generator Status Due to an Episodic Event (Voluntary)
As described above, EPA is proposing to allow a VSQG or an SQG to maintain its existing regulatory status in the event of up to two planned or unplanned episodic events per calendar year in which the facility generates a quantity of hazardous waste in a single month that would otherwise elevate the facility to a more stringent regulatory status.  In addition to the cost savings associated with avoided SQG- or LQG-specific activities (as estimated above), this provision of the rule may result in additional cost savings associated with facilities maintaining a more consistent RCRA generator status over time.  Changing status from one month to the next may impose an administrative burden on facilities as they re-visit the requirements for different generator status categories and implement measures to ensure compliance.  If facilities are able to maintain a more consistent generator status over time, they will not need to re-visit the generator requirements as frequently or make as many changes to their internal controls to ensure compliance with RCRA.
4.3.10 Special Requirements for Ignitable and Reactive Wastes (Voluntary)
The final rule will also include flexibility for LQGs to apply for a waiver from the hazardous waste accumulation property line requirement.  Under this requirement, containers holding ignitable or reactive waste must be located at least 15 meters (50 feet) from a facility's property line.  In some settings, however, particularly in urban environments, LQGs may experience difficulty in meeting this requirement.  For example, meeting this requirement may not be possible if the width of a facility is 100 feet or less or if a facility's operations have expanded such that it no longer has the ability to accumulate ignitable or reactive waste at least 15 meters (50 feet) from the facility's property line.
With a waiver from this requirement, LQGs will avoid a variety of costs associated with the 50-foot limit.  For example, some LQGs will avoid the costs of relocation or purchasing additional property to meet the 50-foot requirement.  In addition, facilities that otherwise reconfigure their layout to meet the 50-foot requirement may be able to structure their operations to streamline the process flow at the facility, rather than structure their operations based on the required location of ignitable or reactive waste.  This more optimal facility structure will likely result in operational cost savings for affected facilities and provide greater flexibility for meeting other requirements (e.g., Occupational Safety and Health Administration regulations).  The option of obtaining a waiver may also allow some businesses to operate in geographic areas where they are unable to operate under current regulation.




CHAPTER 5  |  Summary of Regulatory Benefits and Costs
This chapter compares the costs and benefits of the final Hazardous Waste Generator Improvements Rule as estimated in Chapters 3 and 4 of this RIA.  Specifically, this chapter calculates the net benefits of the final rule (i.e., benefits minus costs).  From an economic perspective, the rule will enhance economic efficiency if benefits (cost savings) exceed costs.  Focusing solely on these or other benefit-cost metrics provides an incomplete view of the effects of the rule, however, because many positive impacts of the rule cannot feasibly be monetized, such as improvements in emergency response preparedness associated with the rule's enhanced marking and labeling requirements.
Exhibits 5-1 and 5-2 report the net benefits of the final rule using discount rates of 3 percent and 7 percent, respectively.  The exhibits present net benefits separately for the mandatory and voluntary provisions of the rule and also net benefits combined for both mandatory and voluntary provisions.  As indicated in both exhibits, benefits were not monetized for many of the rule's provisions because sufficient data were not available.  Net benefits for these provisions (both mandatory and voluntary) are therefore presented as negative.  These negative values, however, do not reflect the benefits presented in Chapter 4 that EPA was unable to monetize.  In excluding these benefits, the negative values in the exhibits underestimate the net benefits associated with the rule's mandatory provisions.
For the voluntary provisions of the rule, this RIA estimates positive net benefits (cost savings) ranging from $5.5 to $8.9 million per year using a discount rate of 7 percent.  For both the low impact and high impact scenarios, the positive net benefits for these provisions reflect, in part, the net benefits associated with additional flexibility provided during episodic generation events.  As discussed in Chapter 4, organizations that opt into the episodic generation requirements are expected to experience cost savings associated with reduced hazardous waste management costs.  The net benefits of this provision are also expected to be higher under the high impact scenario than the low impact scenario.  This difference reflects the assumption in this RIA (stated in Chapter 4) that 50 percent of episodic generators will meet the rule conditions for taking advantage of this provision (i.e., no more than two episodic event per year lasting no more than two calendar months per event) under the low impact scenario while all episodic generators are assumed to meet these conditions under the high impact scenario.

EXHIBIT 5-1:  NET BENEFITS OF THE FINAL RULE ($2015 ANNUALIZED OVER 20 YEARS, USING A 3% DISCOUNT RATE)
                                  REQUIREMENT
                               LOW-END SCENARIO
                               HIGH-END SCENARIO
                               ANNUALIZED COSTS
                              ANNUALIZED BENEFITS
                                 NET BENEFITS
                               ANNUALIZED COSTS
                              ANNUALIZED BENEFITS
                                 NET BENEFITS
MANDATORY PROVISIONS OF THE FINAL RULE
Re-notification
                                                                      $480,000 
                                 Not monetized
                                      --
                                                                      $621,000 
                                 Not monetized
                                      --
Labeling
                                                                    $2,750,000 
                                                                               
                                                                               
                                                                    $5,450,000 
                                                                               
                                                                               
Closure
                                                                       $44,500 
                                                                               
                                                                               
                                                                    $2,330,000 
                                                                               
                                                                               
Emergency Response Preparedness
                                                                      $475,000 
                                                                               
                                                                               
                                                                      $666,000 
                                                                               
                                                                               
Transfer Facility
                                                                        $4,470 
                                                                               
                                                                               
                                                                        $8,280 
                                                                               
                                                                               
BR Requirements
                                                                        $7,100 
                                                                               
                                                                               
                                                                       $69,800 
                                                                               
                                                                               
Recycling
                                                                         $2,090
                                                                               
                                                                               
                                                                         $5,670
                                                                               
                                                                               
Prohibitions on Storage
                                                                            $0 
                                                                               
                                                                               
                                                                            $0 
                                                                               
                                                                               
Drip Pads and Containment Buildings
                                                                            $0 
                                                                      $856,000 
                                                                       $856,000
                                                                            $0 
                                                                       $859,000
                                                                       $859,000
SUB-TOTAL: Mandatory Rule Provisions
                                                                    $3,760,000 
                                                                      $856,000 
                                                                   ($2,910,000)
                                                                     $9,150,000
                                                                       $859,000
                                                                   ($8,290,000)
VOLUNTARY PROVISIONS OF THE FINAL RULE
Intra-organizational Transfers
                                                                    $1,640,000 
                                                                    $4,210,000 
                                                                    $2,570,000 
                                                                    $2,980,000 
                                                                    $6,940,000 
                                                                    $3,960,000 
Episodic Generation
                                                                      $260,000 
                                                                     $3,230,000
                                                                     $2,970,000
                                                                    $1,390,000 
                                                                     $6,550,000
                                                                     $5,150,000
Ignitable and Reactive Waste
                                                                           $60 
                                                                  Not monetized
                                                                          ($60)
                                                                      $105,000 
                                                                  Not monetized
                                                                     ($105,000)
SUB-TOTAL: Voluntary Rule Provisions
                                                                    $1,900,000 
                                                                     $7,440,000
                                                                     $5,540,000
                                                                    $4,480,000 
                                                                    $13,500,000
                                                                     $9,010,000
MANDATORY AND VOLUNTARY PROVISIONS OF THE FINAL RULE COMBINED
TOTAL: Mandatory and Voluntary Provisions Combined
                                                                    $5,660,000 
                                                                     $8,300,000
                                                                     $2,630,000
                                                                   $13,600,000 
                                                                   $14,300,000 
                                                                       $722,000
Notes:
All estimates are rounded to three significant digits and may not sum due to rounding.

EXHIBIT 5-2:  NET BENEFITS OF THE FINAL RULE ($2015 ANNUALIZED OVER 20 YEARS, USING A 7% DISCOUNT RATE)
                                  REQUIREMENT
                               LOW-END SCENARIO
                               HIGH-END SCENARIO
                               ANNUALIZED COSTS
                              ANNUALIZED BENEFITS
                                 NET BENEFITS
                               ANNUALIZED COSTS
                              ANNUALIZED BENEFITS
                                 NET BENEFITS
MANDATORY PROVISIONS OF THE FINAL RULE
Re-notification
                                                                       $507,000
                                 Not monetized
                                      --
                                                                       $656,000
                                 Not monetized
                                      --
Labeling
                                                                     $2,920,000
                                                                               
                                                                               
                                                                     $5,610,000
                                                                               
                                                                               
Closure
                                                                        $44,500
                                                                               
                                                                               
                                                                     $1,710,000
                                                                               
                                                                               
Emergency Response Preparedness
                                                                       $481,000
                                                                               
                                                                               
                                                                       $672,000
                                                                               
                                                                               
Transfer Facility
                                                                         $4,470
                                                                               
                                                                               
                                                                         $8,280
                                                                               
                                                                               
BR Requirements
                                                                         $7,240
                                                                               
                                                                               
                                                                        $71,100
                                                                               
                                                                               
Recycling
                                                                         $2,130
                                                                               
                                                                               
                                                                         $5,780
                                                                               
                                                                               
Prohibitions on Storage
                                                                             $0
                                                                               
                                                                               
                                                                             $0
                                                                               
                                                                               
Drip Pads and Containment Buildings
                                                                             $0
                                                                       $857,000
                                                                       $857,000
                                                                             $0
                                                                       $860,000
                                                                       $860,000
SUB-TOTAL: Mandatory Rule Provisions
                                                                     $3,960,000
                                                                       $857,000
                                                                   ($3,110,000)
                                                                     $8,740,000
                                                                       $860,000
                                                                   ($7,880,000)
VOLUNTARY PROVISIONS OF THE FINAL RULE
Intra-organizational Transfers
                                                                     $1,680,000
                                                                     $4,210,000
                                                                    $2,530,000 
                                                                     $3,050,000
                                                                     $6,940,000
                                                                    $3,890,000 
Episodic Generation
                                                                       $260,000
                                                                     $3,230,000
                                                                     $2,970,000
                                                                     $1,390,000
                                                                     $6,560,000
                                                                     $5,170,000
Ignitable and Reactive Waste
                                                                           $60 
                                                                  Not monetized
                                                                          ($60)
                                                                      $118,000 
                                                                  Not monetized
                                                                     ($118,000)
SUB-TOTAL: Voluntary Rule Provisions
                                                                     $1,940,000
                                                                     $7,450,000
                                                                     $5,510,000
                                                                     $4,560,000
                                                                    $13,500,000
                                                                     $8,940,000
MANDATORY AND VOLUNTARY PROVISIONS OF THE FINAL RULE COMBINED
TOTAL: Mandatory and Voluntary Provisions Combined
                                                                    $5,900,000 
                                                                     $8,300,000
                                                                     $2,400,000
                                                                   $13,300,000 
                                                                    $14,400,000
                                                                     $1,060,000
Notes:
All estimates are rounded to three significant digits and may not sum due to rounding.



In addition, the values in Exhibits 5-1 and 5-2 show that the estimated net benefits of the voluntary intra-organizational transfer provision are positive.  While there is a transfer of costs from VSQGs to LQGs, the net benefits of the provision are positive for the organization as a whole.  Furthermore, because not all benefits associated with VSQG consolidation can be monetized in this RIA, EPA estimates that the actual benefits are even larger.  Therefore, EPA expects that eligible organizations are likely to take advantage of this provision.  As described in Chapter 4, these qualitative benefits include reduced liability risk for organizations that opt to consolidate waste because the transferred waste will be managed at facilities with more protective safeguards.  In addition, this voluntary provision will provide the following social welfare benefits:  
 Improved oversight by subjecting hazardous wastes generated by VSQGs to more rigorous management and disposal requirements in accordance with RCRA LQG requirements; 
 Reducing the amount of hazardous waste deposited in Subtitle D landfills; and
 Reduced risks associated with longer storage times of hazardous waste at VSQG facilities in accordance with the 90 day storage limit for LQGs, lowering the potential risk to human health and the environment.

CHAPTER 6  |  Equity Considerations and Other Impacts
As required by applicable statutes and executive orders, this chapter summarizes EPA's analysis of equity considerations and other regulatory concerns associated with the final rule.  This chapter assesses potential impacts with respect to the following issues: 
Regulatory planning and review: requires examination and quantification of costs and benefits of regulating with and without the final rule;
Regulatory flexibility: focuses on the potential effects of the final rule on small entities; 
Employment impacts: assesses the potential impact of the final rule on employment; 
Unfunded mandates: examines the implications of the final rule with respect to unfunded mandates; 
Federalism: considers potential issues related to state sovereignty; 
Tribal governments: extends the discussion of federal unfunded mandates to include impacts on Native American tribal governments and their communities; 
Environmental justice: considers potential issues for minority and low-income populations; 
Children's health protection: examines the potential impact of the final rule on the health of children; and
Energy Impacts: examines the impacts of the final rule on energy use, supply, and distribution.
6.1 Regulatory Planning and Review 
Under Executive Order (EO) 12866 [58 FR 51735 (October 4, 1993)], as amended by Executive Order 13563, the Agency, in conjunction with the Office of Management and Budget's (OMB's) Office of Information and Regulatory Affairs (OIRA), must determine whether a regulatory action is "significant" and therefore subject to the Office of Management and Budget (OMB) review and the full requirements of the Executive Order.  EO 12866 defines "significant regulatory action" as one that is likely to result in a rule that may: 
   (1)	Have an annual effect on the economy of $100 million or more or adversely affect in a material way the economy, a sector of the economy, productivity, competition, jobs, the environment, public health or safety, or State, local, or tribal governments or communities; 
   (2)	Create a serious inconsistency or otherwise interfere with an action taken or planned by another agency; 
   (3)	Materially alter the budgetary impact of entitlements, grants, user fees, or loan programs or the rights and obligations of recipients thereof; or 
   (4)	Raise novel legal or policy issues arising out of legal mandates, the President's priorities, or the principles set forth in the Executive Order. 
This action is a "significant regulatory action" in that it may raise novel legal or policy issues arising out of legal mandates, the President's priorities, or the principles set forth in the Executive Order.  Therefore, it was submitted to OMB for review.  
Findings for this RIA indicate that the final rule is projected to result in aggregate annualized costs of approximately $5.0 to $10.6 million for the mandatory provisions of the rule, and $7.3 to $15.8 million when factoring in the voluntary provisions, using a discount rate of 7 percent.  This full range is below the $100 million threshold established under part 3(f)(1) of the Order.  The final rule is therefore not considered to be an economically significant action.  
In addition to calling for assessment of regulatory costs, the Executive Order also requires Federal agencies to assess benefits and, "recognizing that some costs and benefits are difficult to quantify, propose or adopt a regulation only upon a reasoned determination that the benefits of the intended regulation justify its costs."  As described in Chapter 4, monetization of all the rule's benefits was not possible given limitations in the available data.  This RIA, however, estimates that the final rule will lead to $9.1 to $15.7 million in quantifiable benefits per year under three provisions combined: (1) the accumulation of hazardous waste on drip pads or in containment buildings, (2) the intra-organization consolidation of VSQG waste at an LQG, and (3) the flexibility afforded SQGs and VSQGs that cross the threshold to a more stringent regulatory status due to episodic generation events.  In addition, requirements related to labeling/marking, LQG closure, and other rule provisions will help ensure that hazardous waste is managed in such a way as to minimize risks to human health and the environment.
6.2 Regulatory Flexibility
The Regulatory Flexibility Act (RFA) as amended by the Small Business Regulatory Enforcement Fairness Act of 1996 (SBREFA), 5 USC 601 et seq., generally requires an agency to prepare a regulatory flexibility analysis of any rule subject to notice and comment rulemaking requirements under the Administrative Procedure Act or any other statute.  This analysis must be completed 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 organizations, and small governmental jurisdictions.  Based on EPA's RFA/SBREFA analytic guidance, a rule is not expected to result in a significant economic impact for a substantial number of small entities if the costs of the regulation for a facility are less than 1 percent of annual revenues.  
Ideally, assessment of the rule's small entity impacts would identify specific entities affected by the rule as small and assess impacts for these entities.  As described in previous chapters of this Assessment, however, detailed data necessary for the assessment of regulatory impacts for individual facilities are not readily available.  In the absence of such information, this Assessment uses the average cost impacts by generator status in conjunction with revenue and employment data from the 2007 Economic Census and the 2007 Census of Agriculture for industries affected by the rule to gauge potential small entity impacts.  The steps in this process are as follows:
 Identify most heavily represented industries among small entities.  To identify the most common industries among small entities affected by the rule, EPA consulted data from two surveys conducted in 1985, a National Small Quantity Hazardous Waste Survey and a Screening Survey of Industrial Subtitle D Establishments, in addition to several state and local studies of VSQGs.  Although some of these data are more than 25 years old, they represent the most comprehensive data available on SQGs and VSQGs.  EPA used this information to identify industries with the largest number of hazardous waste generators in the SQG and VSQG universe.  This list broadly includes the following industry groups: (a) pesticide end-users and application services; (b) industrial chemical manufacturers; (c) wood preservation; (d) pharmaceutical and other chemical and chemical product manufacturers; (e) dry cleaners and industrial launderers; (f) funeral services and crematories; (g) photography; (h) textile manufacturing; (i) vehicle maintenance; (j) metal manufacturing; (k) construction; (l) printing; (m) professional cleaning services; (n) hospitals; and (o) wholesale paints and chemicals.  For this analysis, EPA assumes that LQGs are not owned by small entities.
 Estimate percentage of facilities that are small, by industry.  To assess the prevalence of small entities within the industries identified in Step 1, EPA relied on NAICS-level data from the 2007 Economic Census and the 2007 Census of Agriculture and calculated the percentage of facilities, by NAICS code, owned by facilities below the Small Business Administration (SBA) small size standard threshold (see Exhibit 6-1).  SBA's small size standards vary by industry and may be based on either a firm's annual revenues or number of employees.  The 2007 Economic Census reports the number of firms and number of establishments by revenue-based or employee-based categories (e.g., establishments with 50 to 99 employees).  In those cases where one of the categories is below the SBA threshold, all entities within that category are considered small.  Similarly, entities in categories above the SBA threshold are not considered small.  For some NAICS codes, the SBA small size threshold is between the category boundaries used by the Economic Census.  In these cases, entities within each category are assumed to be evenly distributed between small firms and large firms.  
      Ideally, this analysis would apply the industry-specific percentages estimated in this step to the SQGs and VSQGs in the affected universe to derive estimates of the number of small entities in the universe.  Performing this calculation, however, is not possible because the SQGs and VSQGs in the regulated universe are not broken out by industry.  Therefore, Exhibit 6-1 reports the percentage of facilities in the industries identified in Step 1 that are small according to the SBA thresholds.  For the majority of industries, more than 80 percent of facilities in each NAICS code are considered to be small. 
 Estimate average annual revenues of affected small entities.  EPA also used the Economic Census and Census of Agriculture data to calculate the average annual revenue per small entity in the industries identified in Step 1 by dividing the total revenues of entities meeting the SBA definition by the total number of establishments owned by those entities within each industry.  Exhibit 6-1 reports the small business size standard for each NAICS code, the percentage of facilities that are considered to be small, and the average annual revenues per small facility.
 Estimate regulatory costs per small entity.  The average incremental costs of the rule per small entity are estimated based on the cost analysis presented in Chapter 3.  As an upper bound, this regulatory flexibility analysis reports the total per facility costs for SQGs and VSQGs, excluding the voluntary provisions of the rule, for a hypothetical small facility that incurs costs under every provision of the rule.  Based on this approach, EPA estimates an upper bound annualized cost of $112 to $209 per facility (excluding the rule's voluntary provisions) using a 7 percent discount rate for small facilities (SQGs and VSQGs) that will incur compliance costs associated with each of the mandatory provisions of the rule.  In practice, however, many small entities will incur costs associated with only a subset of the rule provisions.
      For small facilities not affected by every provision of the rule, these estimates may overstate the potential cost impacts.  In addition, many SQGs and VSQGs that take advantage of the voluntary provisions of the rule are anticipated to experience a net cost savings relative to the baseline.  These provisions are excluded from this regulatory flexibility analysis. 
EXHIBIT 6-1:  CHARACTERIZATION OF INDUSTRIES REPRESENTED AMONG SMALL ENTITIES AFFECTED BY THE FINAL RULE 
                                     NAICS
                          NAICS INDUSTRY DESCRIPTION
SBA SMALL SIZE STANDARDPERCENTAGE OF FACILITIES THAT ARE SMALLAVERAGE REVENUE PER SMALL FACILITY($2015, MILLIONS) 


                         REVENUE(MILLIONS OF DOLLARS)
                              NUMBER OF EMPLOYEES


                                                                         115112
Soil Preparation, Planting, and Cultivating
                                     $7.5
                                       
                                     99.9%
                                     $0.14
                                                                         211112
Natural Gas Liquid Extraction
                                       
                                      750
                                    100.0%
                                    $161.25
                                                                            236
Construction of Buildings
                                     $36.5
                                       
                                     97.4%
                                     $2.62
                                                                            237
Heavy and Civil Engineering Construction
                                     $36.5
                                       
                                     93.8%
                                     $4.86
                                                                         313110
Fiber, Yarn, and Thread Mills
                                       
                                     1,250
                                    100.0%
                                    $23.59
                                                                         313210
Broadwoven Fabric Mills
                                       
                                     1,000
                                     99.6%
                                    $14.31
                                                                         313220
Narrow Fabric Mills and Schiffli Machine Embroidery
                                       
                                      500
                                    100.0%
                                     $3.46
                                                                         313230
Nonwoven Fabric Mills
                                       
                                      750
                                     97.9%
                                    $20.77
                                                                         313240
Knit Fabric Mills
                                       
                                      500
                                     99.2%
                                     $6.61
                                                                         313310
Textile and Fabric Finishing Mills
                                       
                                     1,000
                                    100.0%
                                     $5.84
                                                                         313320
Fabric Coating Mills
                                       
                                     1,000
                                    100.0%
                                    $13.81
                                                                         314110
Carpet and Rug Mills
                                       
                                     1,500
                                     99.1%
                                    $39.70
                                                                         314120
Curtain and Linen Mills
                                       
                                      750
                                     99.8%
                                     $2.35
                                                                         314910
Textile Bag and Canvas Mills
                                       
                                      500
                                     99.9%
                                     $1.73
                                                                         314994
Rope, Cordage, Twine, Tire Cord, and Tire Fabric Mills
                                       
                                     1,000
                                    100.0%
                                    $24.75
                                                                         314999
All Other Miscellaneous Textile Product Mills
                                       
                                      500
                                     99.8%
                                     $1.88
                                                                         321114
Wood Preservation
                                       
                                      500
                                    100.0%
                                    $12.83
                                                                         322110
Pulp Mills
                                       
                                      750
                                     86.0%
                                    $126.42
                                                                         322121
Paper (except Newsprint) Mills
                                       
                                     1,250
                                     89.5%
                                    $189.91
                                                                         322122
Newsprint Mills
                                       
                                      750
                                    100.0%
                                    $71.76
                                                                         322130
Paperboard Mills
                                       
                                     1,250
                                     85.6%
                                    $129.45
                                                                         323111
Commercial Printing (except Screen and Books)
                                       
                                      500
                                     96.4%
                                     $9.10
                                                                         323113
Commercial Screen Printing
                                       
                                      500
                                     99.9%
                                     $1.83
                                                                         323117
Books Printing
                                       
                                     1,250
                                     99.5%
                                     $8.66
                                                                         325110
Petrochemical Manufacturing
                                       
                                     1,000
                                    100.0%
                                   $1,566.49
                                                                         325120
Industrial Gas Manufacturing
                                       
                                     1,000
                                    100.0%
                                    $16.03
                                                                         325130
Synthetic Dye and Pigment Manufacturing
                                       
                                     1,000
                                    100.0%
                                    $32.31
                                                                          32518
Other Basic Inorganic Chemical Manufacturing
                                       
                                     1,000
                                     99.4%
                                    $36.09
                                                                         325193
Ethyl Alcohol Manufacturing
                                       
                                     1,000
                                    100.0%
                                    $78.07
                                                                         325199
All Other Basic Organic Chemical Manufacturing
                                       
                                     1,250
                                     98.8%
                                    $107.11
                                                                         325320
Pesticide and Other Agricultural Chemical Manufacturing
                                       
                                     1,000
                                    100.0%
                                    $39.35
                                                                         325412
Pharmaceutical Preparation Manufacturing
                                       
                                     1,250
                                     97.1%
                                    $112.53
                                                                         325910
Printing Ink Manufacturing
                                       
                                      500
                                     99.6%
                                    $10.92
                                                                         326211
Tire Manufacturing (except Retreading)
                                       
                                     1,500
                                     80.4%
                                    $83.24
                                                                         326212
Tire Retreading
                                       
                                      500
                                    100.0%
                                     $3.52
                                                                         326220
Rubber and Plastics Hoses and Belting Manufacturing
                                       
                                      750
                                     97.4%
                                    $15.01
                                                                         326291
Rubber Product Manufacturing for Mechanical Use
                                       
                                      750
                                     98.6%
                                    $14.74
                                                                         326299
All Other Rubber Product Manufacturing
                                       
                                      500
                                     99.5%
                                     $9.79
                                                                         327110
Pottery, Ceramics, and Plumbing Fixture Manufacturing
                                       
                                     1,000
                                     99.6%
                                     $1.86
                                                                         327120
Clay Building Material and Refractories Manufacturing
                                       
                                      750
                                     99.6%
                                     $9.93
                                                                         327211
Flat Glass Manufacturing
                                       
                                     1,000
                                    100.0%
                                    $71.37
                                                                         327212
Other Pressed and Blown Glass and Glassware Manufacturing
                                       
                                     1,250
                                     99.2%
                                     $8.73
                                                                         327213
Glass Container Manufacturing
                                       
                                     1,250
                                    100.0%
                                    $81.83
                                                                         327215
Glass Product Manufacturing Made of Purchased Glass
                                       
                                     1,000
                                     99.9%
                                     $7.22
                                                                         327310
Cement Manufacturing
                                       
                                     1,000
                                    100.0%
                                    $39.92
                                                                         327320
Ready-Mix Concrete Manufacturing
                                       
                                      500
                                     99.9%
                                     $6.33
                                                                         327331
Concrete Block and Brick Manufacturing
                                       
                                      500
                                     99.9%
                                     $7.54
                                                                         327332
Concrete Pipe Manufacturing
                                       
                                      750
                                    100.0%
                                     $9.38
                                                                         327390
Other Concrete Product Manufacturing
                                       
                                      500
                                     99.9%
                                     $5.70
                                                                         327410
Lime Manufacturing
                                       
                                      750
                                     98.2%
                                    $22.78
                                                                         327420
Gypsum Product Manufacturing
                                       
                                     1,500
                                    100.0%
                                    $21.47
                                                                         327910
Abrasive Product Manufacturing
                                       
                                      750
                                     98.7%
                                    $13.74
                                                                         327991
Cut Stone and Stone Product Manufacturing
                                       
                                      500
                                    100.0%
                                     $2.06
                                                                         327992
Ground or Treated Mineral and Earth Manufacturing
                                       
                                      500
                                     99.6%
                                    $10.15
                                                                         327993
Mineral Wool Manufacturing
                                       
                                     1,500
                                    100.0%
                                    $20.29
                                                                         327999
All Other Miscellaneous Nonmetallic Mineral Product Manufacturing
                                       
                                      500
                                    100.0%
                                     $7.52
                                                                         331110
Iron and Steel Mills and Ferroalloy Manufacturing
                                       
                                     1,500
                                     90.4%
                                    $225.73
                                                                         424950
Paint, Varnish, and Supplies Merchant Wholesalers
                                       
                                      150
                                     62.7%
                                     $6.05
                                                                         483211
Inland Water Freight Transportation
                                       
                                      750
                                     90.5%
                                    $13.40
                                                                         484110
General Freight Trucking, Local
                                     $27.5
                                       
                                     99.5%
                                     $1.00
                                                                         484121
General Freight Trucking, Long-Distance, Truckload  
                                     $27.5
                                       
                                     89.6%
                                     $1.93
                                                                         484122
General Freight Trucking, Long-Distance, Less Than Truckload
                                     $27.5
                                       
                                     39.6%
                                     $1.72
                                                                         484210
Used Household and Office Goods Moving
                                     $27.5
                                       
                                     95.7%
                                     $1.02
                                                                         484220
Specialized Freight (except Used Goods) Trucking, Local
                                     $27.5
                                       
                                     98.1%
                                     $1.14
                                                                         484230
Specialized Freight (except Used Goods) Trucking, Long-Distance
                                     $27.5
                                       
                                     77.6%
                                     $2.08
                                                                         532111
Passenger Car Rental
                                     $38.5
                                       
                                     35.4%
                                     $0.69
                                                                         532112
Passenger Car Leasing
                                     $38.5
                                       
                                     94.8%
                                     $1.41
                                                                         532120
Truck, Utility Trailer, and RV (Recreational Vehicle) Rental and Leasing
                                     $38.5
                                       
                                     35.2%
                                     $1.70
                                                                         541921
Photography Studios, Portrait
                                     $7.5
                                       
                                     61.5%
                                     $0.32
                                                                         541922
Commercial Photography
                                     $7.5
                                       
                                     98.7%
                                     $0.48
                                                                         561710
Exterminating and Pest Control Services
                                     $11.0
                                       
                                     84.7%
                                     $0.55
                                                                         561720
Janitorial Services
                                     $18.0
                                       
                                     95.6%
                                     $0.52
                                                                         561730
Landscaping Services
                                     $7.5
                                       
                                     96.9%
                                     $0.61
                                                                         561740
Carpet and Upholstery Cleaning Services
                                     $5.5
                                       
                                     97.6%
                                     $0.37
                                                                         562211
Hazardous Waste Treatment and Disposal
                                     $38.5
                                       
                                     57.4%
                                     $3.98
                                                                            622
Hospitals
                                     $38.5
                                       
                                     24.9%
                                    $16.86
                                                                         712130
Zoos and Botanical Gardens
                                     $27.5
                                       
                                     99.3%
                                     $0.72
                                                                         713910
Golf Courses and Country Clubs
                                     $15.0
                                       
                                     90.1%
                                     $1.36
                                                                         811111
General Automotive Repair
                                     $7.5
                                       
                                     97.2%
                                     $0.53
                                                                         811112
Automotive Exhaust System Repair
                                     $7.5
                                       
                                     97.6%
                                     $0.37
                                                                         811113
Automotive Transmission Repair
                                     $7.5
                                       
                                     99.4%
                                     $0.51
                                                                         811118
Other Automotive Mechanical and Electrical Repair and Maintenance
                                     $7.5
                                       
                                     93.0%
                                     $0.49
                                                                         811121
Automotive Body, Paint and Interior Repair and Maintenance
                                     $7.5
                                       
                                     96.6%
                                     $0.81
                                                                         811191
Automotive Oil Change and Lubrication Shops  
                                     $7.5
                                       
                                     66.5%
                                     $0.59
                                                                         811198
All Other Automotive Repair and Maintenance
                                     $7.5
                                       
                                     88.7%
                                     $0.43
                                                                         812210
Funeral Homes and Funeral Services
                                     $7.5
                                       
                                     84.6%
                                     $0.82
                                                                         812220
Cemeteries and Crematories
                                     $20.5
                                       
                                     81.1%
                                     $0.44
                                                                         812310
Coin-Operated Laundries and Drycleaners
                                     $7.5
                                       
                                     96.1%
                                     $0.25
                                                                         812320
Dry-cleaning and Laundry Services (except Coin-Operated)
                                     $5.5
                                       
                                     94.5%
                                     $0.36
                                                                         812331
Linen Supply
                                     $32.5
                                       
                                     62.8%
                                     $2.99
                                                                         812332
Industrial Launderers
                                     $38.5
                                       
                                     37.5%
                                     $2.63
                                                                         812921
Photofinishing Laboratories (except One-Hour)
                                     $20.5
                                       
                                     94.2%
                                     $0.48
                                                                         812922
One-Hour Photofinishing
                                     $15.0
                                       
                                    100.0%
                                     $0.15
Notes:
 U. S. Small Business Administration, Table of Small Business Size Standards Matched to North American Industry Classification System Codes, effective February 26, 2016, accessed at https://www.sba.gov/content/small-business-size-standards.
 Based on analysis of data compiled from the U.S. Census Bureau's 2007 Economic Census (accessed at http://www.census.gov/econ/census07) and the U.S. Department of Agriculture's Census of Agriculture (accessed at http://www.agcensus.usda.gov/index.php). 

As Exhibit 6-1 shows, the average annual revenues of small entities in the affected universe range from approximately $135,000 (for NAICS 115112 - soil preparation, planting, and cultivating) to over $1.5 billion (for NAICS 325110 - petrochemical manufacturing).  As described in Step 4, above, the average annualized costs of the rule are estimated to be between $112 and $209 on a per facility basis for SQGs and VSQGs (using a 7 percent discount rate).  Therefore, at most, the costs of the final rule represent between 0.08 and 0.15 percent of annual revenues for VSQGs and SQGs.  Since the incremental impact to the smallest facilities in terms of revenue is less than 1 percent of average annual revenues, the final rule is not expected to have a significant impact to a substantial number of small entities.
As shown in the presentation of year-by-year costs in Chapter 3, the costs of the final rule are estimated to be higher in the first year than in later years.  These relatively high costs in the first year reflect the one-time costs associated with the rule's marking/ labeling requirements.  To assess whether these higher costs for the first year represent a significant impact to a substantial number of small entities that year, upper bound costs similar to those presented above for annualized costs were developed for costs incurred in the first year of the rule.  For a hypothetical small entity (SQG or VSQG) that incurs the first-year costs of all of the rule's mandatory provisions, the costs of the rule range from $196 to $354.  This range represents 0.15 to 0.26 percent of annual revenues per facility for the industry with the lowest per-facility revenues in Exhibit 6-1, further suggesting that the rule will not lead to a significant economic impact for a substantial number of small entities.  
6.3 Employment Impact Analysis
Executive Order 13563 "Improving Regulation and Regulatory Review" (76 FR 3821; January 18, 2011) requires Federal agencies to consider the employment impacts of regulatory policy.  Specifically, Executive Order 13563 states, "Our regulatory system must protect public health, welfare, safety, and our environment while promoting economic growth, innovation, competitiveness, and job creation." Consistent with the requirements of the Executive Order, this RIA considers the employment impacts of the final rule.  Ideally, this RIA would include a quantitative assessment of these impacts, but insufficient data are available to quantify changes in employment associated with the rule.  This RIA therefore presents a qualitative assessment of the rule's potential employment impacts.
In general, an environmental regulation can be understood as an increase in demand for a particular output: environmental quality.  Meeting this new demand can result in increased demand for the various factors of production (including labor) available to the economy.  However, the regulated sector generally relies on revenues generated by their other market outputs to cover the costs of supplying increased environmental quality. This can lead to reduced demand for labor and other factors of production used to produce the market output.  As noted by Berman and Bui (2001), although it is often assumed that regulation increases marginal cost, and thereby reduces output and labor demand, it need not be the case. Some components of the final rule improve flexibility and reduce costs and thus may improve production efficiency. Regarding the final rule, because the costs of this rule are relatively low, both in aggregate and on a per-facility basis, EPA believes it is unlikely that it will result in significant employment impacts.
6.4 Unfunded Mandates Analysis
Among its other purposes and federal agency rulemaking requirements, the Unfunded Mandates Reform Act (UMRA) requires federal agencies, unless otherwise prohibited by law, to assess the effects of their regulatory actions on state, local, and tribal governments and on the private sector, to determine whether any rulemaking may result in "any Federal mandate that may result in the expenditure by State, local, and tribal governments, in the aggregate, or by the private sector, of $100 million or more in any one year."
Section 202 of UMRA requires federal agencies that propose rules that are likely to exceed this expenditure threshold to prepare a "Written Statement" containing the following five components, supply the statement to OMB, and summarize it in the Federal Register: 
 Identification of the applicable authorizing federal law;
 Qualitative and quantitative assessment of the anticipated costs and benefits of the rule including the costs and benefits to state, local, and tribal governments or the private sector, and an analysis of whether federal resources may be available to pay these costs;
 Estimates of future compliance costs and any disproportionate budgetary effects;
 Estimates of effects on the national economy such as productivity, economic growth, employment, job creation, international competitiveness; and
 Description and summary of agency's prior consultation with elected representatives of the affected state, local and tribal governments.
The total annualized cost of the final rule, including the voluntary provisions, is estimated to be $5.9 to $13.3 million (using a 7 percent discount rate), but declines to $4.0 to $8.7 million when excluding the voluntary provisions.  Determining the private sector and state/local/tribal government shares of these costs requires information on the extent to which regulated facilities are owned by these two groups.  Based on EPA's 2013 BR database, approximately 5.0 percent of LQGs are owned by state/local/tribal governments and the private sector accounts for approximately 92.4 percent of LQGs.  Facility-level data are not widely available for SQGs and VSQGs.  However, using limited SQG and VSQG data from the BR, EPA estimates that 1.8 percent of SQGs and VSQGs are owned by state/local/tribal governments and 96.6 percent are privately-owned.  Applying these percentages to the estimated costs of the final rule, including the voluntary provisions of the rule, suggests that the annualized cost to state/local/tribal governments is between $0.2 and $0.4 million and the annualized cost to the private sector is between $5.6 and $12.6 million (using a 7 percent discount rate).  Excluding the voluntary provisions of the rule, the annualized cost to state/local/tribal governments is between $0.1 and $0.3 million and the annualized cost to the private sector is between $3.8 and $8.3 million (using a 7 percent discount rate).  Therefore, based on the magnitude of the rule's estimated cost impacts, EPA expects that the rule will not result in annual expenditures exceeding $100 million for the private sector or state, local, and tribal governments, separately or in aggregate.
6.5 Federalism Analysis
The 1999 Federalism Executive Order 13132 furthers the policies of UMRA by establishing federalism principles, federalism policymaking criteria, and a state and local government consultation process for the development of federal regulations with implications for federalism.  These include regulations and other federal policies and actions that have substantial direct effects on states, on the relationship between the federal government and the states, or on the distribution of power and responsibilities among the various levels of government. 
Pursuant to the consultation process of Executive Order 13132, this section evaluates whether the final rule may "impose substantial direct compliance costs" on state and local governments.  EPA's 2008 guidance for compliance with Executive Order 13132 describes two numerical methods for evaluating whether an EPA rule may have federalism implications with respect to "substantial direct compliance costs":
 The $25 million test. Annualized direct compliance cost expenditures to state and local governments in aggregate of $25 million or more.
 The 1 percent test. Annualized direct compliance costs faced by state and local governments are likely to equal or exceed 1percent of their annual revenues.
The annualized cost of the final rule to state and local governments is estimated to be between $0.2 and $0.4 million, including the voluntary provisions of the rule, and between $0.1 and $0.3 million, excluding the voluntary provisions (using a 7 percent discount rate).  Thus, the estimated costs incurred by facilities owned by state and local governments are not expected to exceed the $25 million threshold.  This suggests that the final rule will not result in substantial direct compliance costs, as defined in the EPA guidance, for facilities owned by state and local governments.  
EPA does not expect that the final rule will affect the relationship between the federal government and the states or on the distribution of power and responsibilities among the various levels of government.  
6.6 Tribal Governments Analysis
EO 13175, entitled "Consultation and Coordination with Indian Tribal Governments" (65 FR 67249, November 9, 2000), requires EPA to develop an accountable process to ensure "meaningful and timely input by tribal officials in the development of regulatory policies that have tribal implications."
To assess the potential tribal implications of the rule, EPA compiled data on the number of tribally-owned establishments in the U.S. and estimated the costs of the rule for these facilities.  Based on the 2013 BR data, 12 facilities (or less than 0.1 percent of LQGs) are tribally-owned.  Similarly, less than 0.1 percent of SQGs and VSQGs, or between 112 and 182 facilities, are tribally-owned.  To estimate the potential costs of the rule for these facilities, the aggregate costs described above were applied to the estimated percentage of tribally-owned establishments.  This suggests that the annualized cost to tribal entities is between $2,000 and $5,000, including the voluntary provisions of the rule, and between $1,300 and $3,100, excluding the voluntary provisions (using a 7 percent discount rate).  Based on these values, the final rule is not expected to impose a substantial burden on tribal governments.
6.7 Energy Impact Analysis
EO 13211, "Actions Concerning Regulations that Affect Energy Supply, Distribution, or Use" (May 18, 2001), addresses the need for regulators to more fully consider the potential energy impacts of regulatory action.  Under this executive order, agencies are required to prepare a Statement of Energy Effects when a regulatory action may have significant adverse effects on energy supply, distribution, or use, including impacts on price and foreign supplies.  Additionally, the requirements obligate agencies to consider reasonable alternatives to regulatory actions with adverse effects and the impacts that such alternatives might have on energy supply, distribution, or use.
The final rule will not directly regulate energy production or consumption. In addition, with annualized costs of approximately $4.0 to $8.7 million for the mandatory provisions of the rule and $5.9 to $13.3 million when adding the voluntary provisions (based on a discount rate of 7 percent), this rule is not considered an economically significant action under EO 12866.  
Changes in the management of hazardous waste resulting from the final rule are not expected to significantly impact energy production or distribution.  The rule, however, may lead to a small increase in energy production.  As described in Chapter 1, voluntary provisions of the rule will allow for intra-organization transfers of hazardous waste from VSQGs to LQGs under certain conditions.  Under the baseline, the hazardous waste generated by VSQGs may be managed as municipal solid waste, as the RCRA regulations do not require VSQGs to manage their hazardous waste at a permitted TSDF.  In contrast, any hazardous waste sent from a VSQG to an LQG within the same organization must be managed at a TSDF under the provisions of the rule, consistent with the requirement for all waste generated by LQGs.  Such TSDFs include hazardous waste burning cement kilns, which use the energy value of the wastes they burn as a source of heat for the production of cement.  Thus, to the extent that the rule diverts hazardous waste generated by VSQGs from disposal as municipal solid waste to combustion for energy recovery, the rule may lead to an increase in energy production.  The magnitude of this effect is uncertain.
Aside from the potential increase in energy production described above, the requirements of the rule will have minimal impact on energy consumption; therefore, the rule is not expected to have a significant adverse effect on energy supply, distribution, or use. In addition, no measurable adverse impacts are expected on energy prices or foreign supplies.
6.8 Environmental Justice Analysis
EO 12898 (59 FR 7629, Feb. 16, 1994) directs federal agencies, to the greatest extent practicable and permitted by law, to make environmental justice part of their mission by identifying and addressing, as appropriate, disproportionately high and adverse human health or environmental effects of their programs, policies, and activities on minority populations and low-income populations in the United States.  Among other actions, the Order directs agencies to improve research and data collection regarding health and environmental effects in minority and low-income communities.
EPA does not expect that the final rule will result in disproportionately high or adverse impacts for minority or low-income populations.  Overall, the Agency anticipates that the rule will reduce any adverse effects associated with the management of hazardous waste, thus benefiting minority and low-income populations.  For example, the rule will expand the marking and labeling requirements for hazardous waste containers used by SQGs and LQGs, reducing the likelihood that SQG and LQG staff mismanage the contents these containers.  Improved labeling will also help emergency responders minimize local populations' exposure to hazardous waste in the unlikely event of an accident.  Similarly, the requirement that new LQGs submit a quick reference guide for their contingency plans to emergency management authorities will help these authorities respond more quickly should an accident occur.  Low income and minority populations may also experience a reduction in risk associated with the intra-organization transfers of hazardous waste from VSQGs to LQGs under the rule.  Because the storage, inspection, employee training, and other requirements for LQGs are more stringent than those for VSQGs, transferring hazardous waste from VSQGs to LQGs will reduce the risks associated with the management of hazardous waste generated by VSQGs.
While the voluntary provisions of the rule related to episodic generation may reduce the stringency of requirements for some SQGs and VSQGs, EPA does not expect that these changes will lead to increased risk for low-income or minority populations.  This portion of the rule will still require that hazardous waste generated on an episodic basis is managed in a permitted unit on-site or at a permitted offsite TSDF, minimizing exposure risk for low-income and minority populations in the area.   
6.9 Children's Health Protection Analysis
EO 13045, entitled "Protection of Children from Environmental Health Risks and Safety Risks" (62 FR. 19885, April 23, 1997) applies to any rule that: (1) is determined to be "economically significant" as defined under EO 12866, or (2) concerns an environmental health or safety risk that EPA has reason to believe may have a disproportionate effect on children. If the regulatory action meets both criteria, the Agency must evaluate the environmental health or safety effects of the planned rule on children, and explain why the planned regulation is preferable to other potentially effective and reasonably feasible alternatives considered by the Agency. 
EPA does not anticipate that the final rule will lead to a disproportionate negative impact on children.  As described in the environmental justice discussion above, the final rule includes several provisions that will reduce risks for populations in close proximity to generator facilities.  These reductions in risk represent a benefit for all segments of the population, including children.



Appendix A  |  Detailed Cost and Benefit Impacts by yEar
This appendix provides a more detailed reporting of the costs and benefits of the final Hazardous Waste Generator Improvements Rule. For each hazardous waste generator category, it reports the low-end and high-end costs and benefits estimates of the rule by regulatory provision and year.  These exhibits represent the stream of costs over time and may help inform the public of the burden of the final rule.
EXHIBIT A-1:  COSTS OF THE FINAL RULE BY PROVISION AND YEAR FOR LQGs (LOW-END)
                                     Year
                             Mandatory Provisions
                             Voluntary Provisions
SUBTOTAL: Mandatory Provisions of the Final Rule
SUBTOTAL: Voluntary Provisions of the Final Rule
TOTAL: Mandatory and Voluntary Provisions Combined

Re-notification
Labeling/ Marking
Closure
Emergency Response Preparedness
Transfer Facility Requirements
BR Requirements
Prohibitions on Storage of Restricted Waste
Drip Pad and Container Building Requirements
Intra-organizational Transfers
Episodic Generation
Special Requirements for Ignitable and Reactive Wastes



                                                                         Year 1
                                                                             $0
                                                                     $7,205,624
                                                                        $44,529
                                                                       $524,132
                                                                         $4,472
                                                                        $11,793
                                                                             $0
                                                                             $0
                                                                     $3,264,490
                                                                             $0
                                                                           $261
                                                                     $7,790,549
                                                                     $3,264,752
                                                                    $11,055,301
                                                                         Year 2
                                                                             $0
                                                                             $0
                                                                        $44,529
                                                                       $453,536
                                                                         $4,472
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $115,771
                                                                             $0
                                                                            $44
                                                                       $502,537
                                                                       $115,814
                                                                       $618,351
                                                                         Year 3
                                                                             $0
                                                                             $0
                                                                        $44,529
                                                                       $453,536
                                                                         $4,472
                                                                        $11,793
                                                                             $0
                                                                             $0
                                                                     $2,277,509
                                                                             $0
                                                                            $44
                                                                       $514,330
                                                                     $2,277,552
                                                                     $2,791,882
                                                                         Year 4
                                                                             $0
                                                                             $0
                                                                        $44,529
                                                                       $453,536
                                                                         $4,472
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $115,771
                                                                             $0
                                                                            $44
                                                                       $502,537
                                                                       $115,814
                                                                       $618,351
                                                                         Year 5
                                                                             $0
                                                                             $0
                                                                        $44,529
                                                                       $453,536
                                                                         $4,472
                                                                        $11,793
                                                                             $0
                                                                             $0
                                                                     $2,277,509
                                                                             $0
                                                                            $44
                                                                       $514,330
                                                                     $2,277,552
                                                                     $2,791,882
                                                                         Year 6
                                                                             $0
                                                                             $0
                                                                        $44,529
                                                                       $453,536
                                                                         $4,472
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $115,771
                                                                             $0
                                                                            $44
                                                                       $502,537
                                                                       $115,814
                                                                       $618,351
                                                                         Year 7
                                                                             $0
                                                                             $0
                                                                        $44,529
                                                                       $453,536
                                                                         $4,472
                                                                        $11,793
                                                                             $0
                                                                             $0
                                                                     $2,277,509
                                                                             $0
                                                                            $44
                                                                       $514,330
                                                                     $2,277,552
                                                                     $2,791,882
                                                                         Year 8
                                                                             $0
                                                                             $0
                                                                        $44,529
                                                                       $453,536
                                                                         $4,472
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $115,771
                                                                             $0
                                                                            $44
                                                                       $502,537
                                                                       $115,814
                                                                       $618,351
                                                                         Year 9
                                                                             $0
                                                                             $0
                                                                        $44,529
                                                                       $453,536
                                                                         $4,472
                                                                        $11,793
                                                                             $0
                                                                             $0
                                                                     $2,277,509
                                                                             $0
                                                                            $44
                                                                       $514,330
                                                                     $2,277,552
                                                                     $2,791,882
                                                                        Year 10
                                                                             $0
                                                                             $0
                                                                        $44,529
                                                                       $453,536
                                                                         $4,472
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $115,771
                                                                             $0
                                                                            $44
                                                                       $502,537
                                                                       $115,814
                                                                       $618,351
                                                                        Year 11
                                                                             $0
                                                                             $0
                                                                        $44,529
                                                                       $453,536
                                                                         $4,472
                                                                        $11,793
                                                                             $0
                                                                             $0
                                                                     $2,277,509
                                                                             $0
                                                                            $44
                                                                       $514,330
                                                                     $2,277,552
                                                                     $2,791,882
                                                                        Year 12
                                                                             $0
                                                                             $0
                                                                        $44,529
                                                                       $453,536
                                                                         $4,472
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $115,771
                                                                             $0
                                                                            $44
                                                                       $502,537
                                                                       $115,814
                                                                       $618,351
                                                                        Year 13
                                                                             $0
                                                                             $0
                                                                        $44,529
                                                                       $453,536
                                                                         $4,472
                                                                        $11,793
                                                                             $0
                                                                             $0
                                                                     $2,277,509
                                                                             $0
                                                                            $44
                                                                       $514,330
                                                                     $2,277,552
                                                                     $2,791,882
                                                                        Year 14
                                                                             $0
                                                                             $0
                                                                        $44,529
                                                                       $453,536
                                                                         $4,472
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $115,771
                                                                             $0
                                                                            $44
                                                                       $502,537
                                                                       $115,814
                                                                       $618,351
                                                                        Year 15
                                                                             $0
                                                                             $0
                                                                        $44,529
                                                                       $453,536
                                                                         $4,472
                                                                        $11,793
                                                                             $0
                                                                             $0
                                                                     $2,277,509
                                                                             $0
                                                                            $44
                                                                       $514,330
                                                                     $2,277,552
                                                                     $2,791,882
                                                                        Year 16
                                                                             $0
                                                                             $0
                                                                        $44,529
                                                                       $453,536
                                                                         $4,472
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $115,771
                                                                             $0
                                                                            $44
                                                                       $502,537
                                                                       $115,814
                                                                       $618,351
                                                                        Year 17
                                                                             $0
                                                                             $0
                                                                        $44,529
                                                                       $453,536
                                                                         $4,472
                                                                        $11,793
                                                                             $0
                                                                             $0
                                                                     $2,277,509
                                                                             $0
                                                                            $44
                                                                       $514,330
                                                                     $2,277,552
                                                                     $2,791,882
                                                                        Year 18
                                                                             $0
                                                                             $0
                                                                        $44,529
                                                                       $453,536
                                                                         $4,472
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $115,771
                                                                             $0
                                                                            $44
                                                                       $502,537
                                                                       $115,814
                                                                       $618,351
                                                                        Year 19
                                                                             $0
                                                                             $0
                                                                        $44,529
                                                                       $453,536
                                                                         $4,472
                                                                        $11,793
                                                                             $0
                                                                             $0
                                                                     $2,277,509
                                                                             $0
                                                                            $44
                                                                       $514,330
                                                                     $2,277,552
                                                                     $2,791,882
                                                                        Year 20
                                                                             $0
                                                                             $0
                                                                        $44,529
                                                                       $453,536
                                                                         $4,472
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $115,771
                                                                             $0
                                                                            $44
                                                                       $502,537
                                                                       $115,814
                                                                       $618,351
Total 
(Undiscounted)
                                                                             $0
                                                                     $7,205,624
                                                                       $890,582
                                                                     $9,141,315
                                                                        $89,439
                                                                       $117,928
                                                                             $0
                                                                             $0
                                                                    $24,919,775
                                                                             $0
                                                                         $1,089
                                                                    $17,444,888
                                                                    $24,920,864
                                                                    $42,365,752
PV Total
(3% discount rate)
                                                                             $0
                                                                     $7,205,624
                                                                       $682,355
                                                                     $7,020,490
                                                                        $68,527
                                                                        $91,691
                                                                             $0
                                                                             $0
                                                                    $19,568,821
                                                                             $0
                                                                           $885
                                                                    $15,068,687
                                                                    $19,569,707
                                                                    $34,638,393
PV Total 
(7% discount rate)
                                                                             $0
                                                                     $7,205,624
                                                                       $504,764
                                                                     $5,211,696
                                                                        $50,692
                                                                        $69,100
                                                                             $0
                                                                             $0
                                                                    $14,965,933
                                                                             $0
                                                                           $712
                                                                    $13,041,875
                                                                    $14,966,645
                                                                    $28,008,520
Annualized 
(3% discount rate)
                                                                             $0
                                                                       $470,224
                                                                        $44,529
                                                                       $458,143
                                                                         $4,472
                                                                         $5,984
                                                                             $0
                                                                             $0
                                                                     $1,277,022
                                                                             $0
                                                                            $58
                                                                       $983,352
                                                                     $1,277,079
                                                                     $2,260,431
Annualized 
(7% discount rate)
                                                                             $0
                                                                       $635,663
                                                                        $44,529
                                                                       $459,764
                                                                         $4,472
                                                                         $6,096
                                                                             $0
                                                                             $0
                                                                     $1,320,260
                                                                             $0
                                                                            $63
                                                                     $1,150,524
                                                                     $1,320,323
                                                                     $2,470,847

EXHIBIT A-2:  COSTS OF THE FINAL RULE BY PROVISION AND YEAR FOR SQGs (LOW-END)
                                     Year
                             Mandatory Provisions
                             Voluntary Provisions
SUBTOTAL: Mandatory Provisions of the Final Rule
SUBTOTAL: Voluntary Provisions of the Final Rule
TOTAL: Mandatory and Voluntary Provisions Combined

Re-notification
Labeling/Marking
Closure
Emergency Response Preparedness
Transfer Facility Requirements
BR Requirements
Prohibitions on Storage of Restricted Waste
Drip Pad and Container Building Requirements
Intra-organizational Transfers
Episodic Generation
Special Requirements for Ignitable and Reactive Wastes
                                       
                                       
                                       
                                                                         Year 1
                                                                     $1,837,235
                                                                     $2,281,373
                                                                             $0
                                                                       $175,468
                                                                             $0
                                                                         $1,471
                                                                             $0
                                                                             $0
                                                                             $0
                                                                        $36,140
                                                                             $0
                                                                     $4,295,546
                                                                        $36,140
                                                                     $4,331,687
                                                                         Year 2
                                                                             $0
                                                                     $2,281,373
                                                                             $0
                                                                         $5,914
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                        $36,140
                                                                             $0
                                                                     $2,287,287
                                                                        $36,140
                                                                     $2,323,427
                                                                         Year 3
                                                                             $0
                                                                     $2,281,373
                                                                             $0
                                                                         $5,914
                                                                             $0
                                                                         $1,471
                                                                             $0
                                                                             $0
                                                                             $0
                                                                        $36,140
                                                                             $0
                                                                     $2,288,758
                                                                        $36,140
                                                                     $2,324,898
                                                                         Year 4
                                                                             $0
                                                                     $2,281,373
                                                                             $0
                                                                         $5,914
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                        $36,140
                                                                             $0
                                                                     $2,287,287
                                                                        $36,140
                                                                     $2,323,427
                                                                         Year 5
                                                                     $1,837,235
                                                                     $2,281,373
                                                                             $0
                                                                         $5,914
                                                                             $0
                                                                         $1,471
                                                                             $0
                                                                             $0
                                                                             $0
                                                                        $36,140
                                                                             $0
                                                                     $4,125,992
                                                                        $36,140
                                                                     $4,162,133
                                                                         Year 6
                                                                             $0
                                                                     $2,281,373
                                                                             $0
                                                                         $5,914
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                        $36,140
                                                                             $0
                                                                     $2,287,287
                                                                        $36,140
                                                                     $2,323,427
                                                                         Year 7
                                                                             $0
                                                                     $2,281,373
                                                                             $0
                                                                         $5,914
                                                                             $0
                                                                         $1,471
                                                                             $0
                                                                             $0
                                                                             $0
                                                                        $36,140
                                                                             $0
                                                                     $2,288,758
                                                                        $36,140
                                                                     $2,324,898
                                                                         Year 8
                                                                             $0
                                                                     $2,281,373
                                                                             $0
                                                                         $5,914
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                        $36,140
                                                                             $0
                                                                     $2,287,287
                                                                        $36,140
                                                                     $2,323,427
                                                                         Year 9
                                                                     $1,837,235
                                                                     $2,281,373
                                                                             $0
                                                                         $5,914
                                                                             $0
                                                                         $1,471
                                                                             $0
                                                                             $0
                                                                             $0
                                                                        $36,140
                                                                             $0
                                                                     $4,125,992
                                                                        $36,140
                                                                     $4,162,133
                                                                        Year 10
                                                                             $0
                                                                     $2,281,373
                                                                             $0
                                                                         $5,914
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                        $36,140
                                                                             $0
                                                                     $2,287,287
                                                                        $36,140
                                                                     $2,323,427
                                                                        Year 11
                                                                             $0
                                                                     $2,281,373
                                                                             $0
                                                                         $5,914
                                                                             $0
                                                                         $1,471
                                                                             $0
                                                                             $0
                                                                             $0
                                                                        $36,140
                                                                             $0
                                                                     $2,288,758
                                                                        $36,140
                                                                     $2,324,898
                                                                        Year 12
                                                                             $0
                                                                     $2,281,373
                                                                             $0
                                                                         $5,914
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                        $36,140
                                                                             $0
                                                                     $2,287,287
                                                                        $36,140
                                                                     $2,323,427
                                                                        Year 13
                                                                     $1,837,235
                                                                     $2,281,373
                                                                             $0
                                                                         $5,914
                                                                             $0
                                                                         $1,471
                                                                             $0
                                                                             $0
                                                                             $0
                                                                        $36,140
                                                                             $0
                                                                     $4,125,992
                                                                        $36,140
                                                                     $4,162,133
                                                                        Year 14
                                                                             $0
                                                                     $2,281,373
                                                                             $0
                                                                         $5,914
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                        $36,140
                                                                             $0
                                                                     $2,287,287
                                                                        $36,140
                                                                     $2,323,427
                                                                        Year 15
                                                                             $0
                                                                     $2,281,373
                                                                             $0
                                                                         $5,914
                                                                             $0
                                                                         $1,471
                                                                             $0
                                                                             $0
                                                                             $0
                                                                        $36,140
                                                                             $0
                                                                     $2,288,758
                                                                        $36,140
                                                                     $2,324,898
                                                                        Year 16
                                                                             $0
                                                                     $2,281,373
                                                                             $0
                                                                         $5,914
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                        $36,140
                                                                             $0
                                                                     $2,287,287
                                                                        $36,140
                                                                     $2,323,427
                                                                        Year 17
                                                                     $1,837,235
                                                                     $2,281,373
                                                                             $0
                                                                         $5,914
                                                                             $0
                                                                         $1,471
                                                                             $0
                                                                             $0
                                                                             $0
                                                                        $36,140
                                                                             $0
                                                                     $4,125,992
                                                                        $36,140
                                                                     $4,162,133
                                                                        Year 18
                                                                             $0
                                                                     $2,281,373
                                                                             $0
                                                                         $5,914
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                        $36,140
                                                                             $0
                                                                     $2,287,287
                                                                        $36,140
                                                                     $2,323,427
                                                                        Year 19
                                                                             $0
                                                                     $2,281,373
                                                                             $0
                                                                         $5,914
                                                                             $0
                                                                         $1,471
                                                                             $0
                                                                             $0
                                                                             $0
                                                                        $36,140
                                                                             $0
                                                                     $2,288,758
                                                                        $36,140
                                                                     $2,324,898
                                                                        Year 20
                                                                             $0
                                                                     $2,281,373
                                                                             $0
                                                                         $5,914
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                        $36,140
                                                                             $0
                                                                     $2,287,287
                                                                        $36,140
                                                                     $2,323,427
Total 
(Undiscounted)
                                                                     $9,186,173
                                                                    $45,627,455
                                                                             $0
                                                                       $287,830
                                                                             $0
                                                                        $14,714
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $722,810
                                                                             $0
                                                                    $55,116,171
                                                                       $722,810
                                                                    $55,838,981
PV Total
(3% discount rate)
                                                                     $7,353,427
                                                                    $34,959,297
                                                                             $0
                                                                       $260,176
                                                                             $0
                                                                        $11,440
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $553,810
                                                                             $0
                                                                    $42,584,340
                                                                       $553,810
                                                                    $43,138,150
PV Total 
(7% discount rate)
                                                                     $5,746,228
                                                                    $25,860,718
                                                                             $0
                                                                       $236,590
                                                                             $0
                                                                         $8,621
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $409,674
                                                                             $0
                                                                    $31,852,158
                                                                       $409,674
                                                                    $32,261,832
Annualized 
(3% discount rate)
                                                                       $479,870
                                                                     $2,281,373
                                                                             $0
                                                                        $16,979
                                                                             $0
                                                                           $747
                                                                             $0
                                                                             $0
                                                                             $0
                                                                        $36,140
                                                                             $0
                                                                     $2,778,968
                                                                        $36,140
                                                                     $2,815,108
Annualized 
(7% discount rate)
                                                                       $506,919
                                                                     $2,281,373
                                                                             $0
                                                                        $20,871
                                                                             $0
                                                                           $761
                                                                             $0
                                                                             $0
                                                                             $0
                                                                        $36,140
                                                                             $0
                                                                     $2,809,924
                                                                        $36,140
                                                                     $2,846,064
EXHIBIT A-3:  COSTS OF THE FINAL RULE BY PROVISION AND YEAR FOR VSQGs (LOW-END)
                                     Year
                             Mandatory Provisions
                             Voluntary Provisions
SUBTOTAL: Mandatory Provisions of the Final Rule
SUBTOTAL: Voluntary Provisions of the Final Rule
TOTAL: Mandatory and Voluntary Provisions Combined

Re-notification
Labeling/Marking
Closure
Emergency Response Preparedness
Transfer Facility Requirements
BR Requirements
Prohibitions on Storage of Restricted Waste
Drip Pad and Container Building Requirements
Intra-organizational Transfers
Episodic Generation
Special Requirements for Ignitable and Reactive Wastes



                                                                         Year 1
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                           $736
                                                                             $0
                                                                             $0
                                                                       $361,783
                                                                       $223,385
                                                                             $0
                                                                           $736
                                                                       $585,169
                                                                       $585,904
                                                                         Year 2
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $361,783
                                                                       $223,385
                                                                             $0
                                                                             $0
                                                                       $585,169
                                                                       $585,169
                                                                         Year 3
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                           $736
                                                                             $0
                                                                             $0
                                                                       $361,783
                                                                       $223,385
                                                                             $0
                                                                           $736
                                                                       $585,169
                                                                       $585,904
                                                                         Year 4
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $361,783
                                                                       $223,385
                                                                             $0
                                                                             $0
                                                                       $585,169
                                                                       $585,169
                                                                         Year 5
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                           $736
                                                                             $0
                                                                             $0
                                                                       $361,783
                                                                       $223,385
                                                                             $0
                                                                           $736
                                                                       $585,169
                                                                       $585,904
                                                                         Year 6
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $361,783
                                                                       $223,385
                                                                             $0
                                                                             $0
                                                                       $585,169
                                                                       $585,169
                                                                         Year 7
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                           $736
                                                                             $0
                                                                             $0
                                                                       $361,783
                                                                       $223,385
                                                                             $0
                                                                           $736
                                                                       $585,169
                                                                       $585,904
                                                                         Year 8
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $361,783
                                                                       $223,385
                                                                             $0
                                                                             $0
                                                                       $585,169
                                                                       $585,169
                                                                         Year 9
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                           $736
                                                                             $0
                                                                             $0
                                                                       $361,783
                                                                       $223,385
                                                                             $0
                                                                           $736
                                                                       $585,169
                                                                       $585,904
                                                                        Year 10
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $361,783
                                                                       $223,385
                                                                             $0
                                                                             $0
                                                                       $585,169
                                                                       $585,169
                                                                        Year 11
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                           $736
                                                                             $0
                                                                             $0
                                                                       $361,783
                                                                       $223,385
                                                                             $0
                                                                           $736
                                                                       $585,169
                                                                       $585,904
                                                                        Year 12
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $361,783
                                                                       $223,385
                                                                             $0
                                                                             $0
                                                                       $585,169
                                                                       $585,169
                                                                        Year 13
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                           $736
                                                                             $0
                                                                             $0
                                                                       $361,783
                                                                       $223,385
                                                                             $0
                                                                           $736
                                                                       $585,169
                                                                       $585,904
                                                                        Year 14
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $361,783
                                                                       $223,385
                                                                             $0
                                                                             $0
                                                                       $585,169
                                                                       $585,169
                                                                        Year 15
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                           $736
                                                                             $0
                                                                             $0
                                                                       $361,783
                                                                       $223,385
                                                                             $0
                                                                           $736
                                                                       $585,169
                                                                       $585,904
                                                                        Year 16
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $361,783
                                                                       $223,385
                                                                             $0
                                                                             $0
                                                                       $585,169
                                                                       $585,169
                                                                        Year 17
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                           $736
                                                                             $0
                                                                             $0
                                                                       $361,783
                                                                       $223,385
                                                                             $0
                                                                           $736
                                                                       $585,169
                                                                       $585,904
                                                                        Year 18
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $361,783
                                                                       $223,385
                                                                             $0
                                                                             $0
                                                                       $585,169
                                                                       $585,169
                                                                        Year 19
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                           $736
                                                                             $0
                                                                             $0
                                                                       $361,783
                                                                       $223,385
                                                                             $0
                                                                           $736
                                                                       $585,169
                                                                       $585,904
                                                                        Year 20
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $361,783
                                                                       $223,385
                                                                             $0
                                                                             $0
                                                                       $585,169
                                                                       $585,169
Total 
(Undiscounted)
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                         $7,357
                                                                             $0
                                                                             $0
                                                                     $7,235,669
                                                                     $4,467,703
                                                                             $0
                                                                         $7,357
                                                                    $11,703,372
                                                                    $11,710,729
PV Total
(3% discount rate)
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                         $5,720
                                                                             $0
                                                                             $0
                                                                     $5,543,897
                                                                     $3,423,109
                                                                             $0
                                                                         $5,720
                                                                     $8,967,006
                                                                     $8,972,726
PV Total 
(7% discount rate)
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                         $4,311
                                                                             $0
                                                                             $0
                                                                     $4,101,031
                                                                     $2,532,204
                                                                             $0
                                                                         $4,311
                                                                     $6,633,234
                                                                     $6,637,545
Annualized 
(3% discount rate)
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                           $373
                                                                             $0
                                                                             $0
                                                                       $361,783
                                                                       $223,385
                                                                             $0
                                                                           $373
                                                                       $585,169
                                                                       $585,542
Annualized 
(7% discount rate)
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                           $380
                                                                             $0
                                                                             $0
                                                                       $361,783
                                                                       $223,385
                                                                             $0
                                                                           $380
                                                                       $585,169
                                                                       $585,549

EXHIBIT A-4:  COSTS OF THE FINAL RULE BY PROVISION AND YEAR FOR RECYCLING FACILITIES (LOW-END)
                                     Year
                             Mandatory Provisions
                             Voluntary Provisions
SUBTOTAL: Mandatory Provisions of the Final Rule
SUBTOTAL: Voluntary Provisions of the Final Rule
TOTAL: Mandatory and Voluntary Provisions Combined

BR Reporting Requirements
                                       



                                                                         Year 1
                                                                         $4,117
                                                                             $0
                                                                         $4,117
                                                                             $0
                                                                         $4,117
                                                                         Year 2
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                         Year 3
                                                                         $4,117
                                                                             $0
                                                                         $4,117
                                                                             $0
                                                                         $4,117
                                                                         Year 4
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                         Year 5
                                                                         $4,117
                                                                             $0
                                                                         $4,117
                                                                             $0
                                                                         $4,117
                                                                         Year 6
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                         Year 7
                                                                         $4,117
                                                                             $0
                                                                         $4,117
                                                                             $0
                                                                         $4,117
                                                                         Year 8
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                         Year 9
                                                                         $4,117
                                                                             $0
                                                                         $4,117
                                                                             $0
                                                                         $4,117
                                                                        Year 10
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                        Year 11
                                                                         $4,117
                                                                             $0
                                                                         $4,117
                                                                             $0
                                                                         $4,117
                                                                        Year 12
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                        Year 13
                                                                         $4,117
                                                                             $0
                                                                         $4,117
                                                                             $0
                                                                         $4,117
                                                                        Year 14
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                        Year 15
                                                                         $4,117
                                                                             $0
                                                                         $4,117
                                                                             $0
                                                                         $4,117
                                                                        Year 16
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                        Year 17
                                                                         $4,117
                                                                             $0
                                                                         $4,117
                                                                             $0
                                                                         $4,117
                                                                        Year 18
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                        Year 19
                                                                         $4,117
                                                                             $0
                                                                         $4,117
                                                                             $0
                                                                         $4,117
                                                                        Year 20
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
Total 
(Undiscounted)
                                                                        $41,174
                                                                             $0
                                                                        $41,174
                                                                             $0
                                                                        $41,174
PV Total
(3% discount rate)
                                                                        $32,013
                                                                             $0
                                                                        $32,013
                                                                             $0
                                                                        $32,013
PV Total 
(7% discount rate)
                                                                        $24,126
                                                                             $0
                                                                        $24,126
                                                                             $0
                                                                        $24,126
Annualized 
(3% discount rate)
                                                                         $2,089
                                                                             $0
                                                                         $2,089
                                                                             $0
                                                                         $2,089
Annualized 
(7% discount rate)
                                                                         $2,128
                                                                             $0
                                                                         $2,128
                                                                             $0
                                                                         $2,128

EXHIBIT A-5:  COSTS OF THE FINAL RULE BY PROVISION AND YEAR FOR LQGs (HIGH-END)
                                     Year
                             Mandatory Provisions
                             Voluntary Provisions
SUBTOTAL: Mandatory Provisions of the Final Rule
SUBTOTAL: Voluntary Provisions of the Final Rule
TOTAL: Mandatory and Voluntary Provisions Combined

Re-notification
Labeling/Marking
Closure
Emergency Response Preparedness
Transfer Facility Requirements
BR Requirements
Prohibitions on Storage of Restricted Waste
Drip Pad and Container Building Requirements
Intra-organizational Transfers
Episodic Generation
Special Requirements for Ignitable and Reactive Wastes



                                                                         Year 1
                                                                             $0
                                                                     $7,205,624
                                                                     $3,199,258
                                                                       $711,610
                                                                         $8,280
                                                                       $128,030
                                                                             $0
                                                                             $0
                                                                     $5,704,227
                                                                             $0
                                                                       $615,257
                                                                    $11,252,802
                                                                     $6,319,484
                                                                    $17,572,286
                                                                         Year 2
                                                                             $0
                                                                             $0
                                                                     $3,199,258
                                                                       $641,014
                                                                         $8,280
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $178,634
                                                                             $0
                                                                        $69,736
                                                                     $3,848,553
                                                                       $248,371
                                                                     $4,096,924
                                                                         Year 3
                                                                             $0
                                                                             $0
                                                                     $3,199,258
                                                                       $641,014
                                                                         $8,280
                                                                       $128,030
                                                                             $0
                                                                             $0
                                                                     $4,181,313
                                                                             $0
                                                                        $69,736
                                                                     $3,976,583
                                                                     $4,251,049
                                                                     $8,227,632
                                                                         Year 4
                                                                             $0
                                                                             $0
                                                                     $3,199,258
                                                                       $641,014
                                                                         $8,280
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $178,634
                                                                             $0
                                                                        $69,736
                                                                     $3,848,553
                                                                       $248,371
                                                                     $4,096,924
                                                                         Year 5
                                                                             $0
                                                                             $0
                                                                     $3,199,258
                                                                       $641,014
                                                                         $8,280
                                                                       $128,030
                                                                             $0
                                                                             $0
                                                                     $4,181,313
                                                                             $0
                                                                        $69,736
                                                                     $3,976,583
                                                                     $4,251,049
                                                                     $8,227,632
                                                                         Year 6
                                                                             $0
                                                                             $0
                                                                     $3,199,258
                                                                       $641,014
                                                                         $8,280
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $178,634
                                                                             $0
                                                                        $69,736
                                                                     $3,848,553
                                                                       $248,371
                                                                     $4,096,924
                                                                         Year 7
                                                                             $0
                                                                             $0
                                                                     $3,199,258
                                                                       $641,014
                                                                         $8,280
                                                                       $128,030
                                                                             $0
                                                                             $0
                                                                     $4,181,313
                                                                             $0
                                                                        $69,736
                                                                     $3,976,583
                                                                     $4,251,049
                                                                     $8,227,632
                                                                         Year 8
                                                                             $0
                                                                             $0
                                                                     $3,199,258
                                                                       $641,014
                                                                         $8,280
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $178,634
                                                                             $0
                                                                        $69,736
                                                                     $3,848,553
                                                                       $248,371
                                                                     $4,096,924
                                                                         Year 9
                                                                             $0
                                                                             $0
                                                                     $3,199,258
                                                                       $641,014
                                                                         $8,280
                                                                       $128,030
                                                                             $0
                                                                             $0
                                                                     $4,181,313
                                                                             $0
                                                                        $69,736
                                                                     $3,976,583
                                                                     $4,251,049
                                                                     $8,227,632
                                                                        Year 10
                                                                             $0
                                                                             $0
                                                                     $3,199,258
                                                                       $641,014
                                                                         $8,280
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $178,634
                                                                             $0
                                                                        $69,736
                                                                     $3,848,553
                                                                       $248,371
                                                                     $4,096,924
                                                                        Year 11
                                                                             $0
                                                                             $0
                                                                     $3,199,258
                                                                       $641,014
                                                                         $8,280
                                                                       $128,030
                                                                             $0
                                                                             $0
                                                                     $4,181,313
                                                                             $0
                                                                        $69,736
                                                                     $3,976,583
                                                                     $4,251,049
                                                                     $8,227,632
                                                                        Year 12
                                                                             $0
                                                                             $0
                                                                     $3,199,258
                                                                       $641,014
                                                                         $8,280
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $178,634
                                                                             $0
                                                                        $69,736
                                                                     $3,848,553
                                                                       $248,371
                                                                     $4,096,924
                                                                        Year 13
                                                                             $0
                                                                             $0
                                                                     $3,199,258
                                                                       $641,014
                                                                         $8,280
                                                                       $128,030
                                                                             $0
                                                                             $0
                                                                     $4,181,313
                                                                             $0
                                                                        $69,736
                                                                     $3,976,583
                                                                     $4,251,049
                                                                     $8,227,632
                                                                        Year 14
                                                                             $0
                                                                             $0
                                                                     $3,199,258
                                                                       $641,014
                                                                         $8,280
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $178,634
                                                                             $0
                                                                        $69,736
                                                                     $3,848,553
                                                                       $248,371
                                                                     $4,096,924
                                                                        Year 15
                                                                             $0
                                                                             $0
                                                                     $3,199,258
                                                                       $641,014
                                                                         $8,280
                                                                       $128,030
                                                                             $0
                                                                             $0
                                                                     $4,181,313
                                                                             $0
                                                                        $69,736
                                                                     $3,976,583
                                                                     $4,251,049
                                                                     $8,227,632
                                                                        Year 16
                                                                             $0
                                                                             $0
                                                                     $3,199,258
                                                                       $641,014
                                                                         $8,280
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $178,634
                                                                             $0
                                                                        $69,736
                                                                     $3,848,553
                                                                       $248,371
                                                                     $4,096,924
                                                                        Year 17
                                                                             $0
                                                                             $0
                                                                     $3,199,258
                                                                       $641,014
                                                                         $8,280
                                                                       $128,030
                                                                             $0
                                                                             $0
                                                                     $4,181,313
                                                                             $0
                                                                        $69,736
                                                                     $3,976,583
                                                                     $4,251,049
                                                                     $8,227,632
                                                                        Year 18
                                                                             $0
                                                                             $0
                                                                     $3,199,258
                                                                       $641,014
                                                                         $8,280
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $178,634
                                                                             $0
                                                                        $69,736
                                                                     $3,848,553
                                                                       $248,371
                                                                     $4,096,924
                                                                        Year 19
                                                                             $0
                                                                             $0
                                                                     $3,199,258
                                                                       $641,014
                                                                         $8,280
                                                                       $128,030
                                                                             $0
                                                                             $0
                                                                     $4,181,313
                                                                             $0
                                                                        $69,736
                                                                     $3,976,583
                                                                     $4,251,049
                                                                     $8,227,632
                                                                        Year 20
                                                                             $0
                                                                             $0
                                                                     $3,199,258
                                                                       $641,014
                                                                         $8,280
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $178,634
                                                                             $0
                                                                        $69,736
                                                                     $3,848,553
                                                                       $248,371
                                                                     $4,096,924
Total 
(Undiscounted)
                                                                             $0
                                                                     $7,205,624
                                                                    $63,985,162
                                                                    $12,890,883
                                                                       $165,606
                                                                     $1,280,300
                                                                             $0
                                                                             $0
                                                                    $45,122,383
                                                                             $0
                                                                     $1,940,249
                                                                    $85,527,575
                                                                    $47,062,632
                                                                   $132,590,207
PV Total
(3% discount rate)
                                                                             $0
                                                                     $7,205,624
                                                                    $35,679,630
                                                                     $9,893,371
                                                                       $126,886
                                                                       $995,450
                                                                             $0
                                                                             $0
                                                                    $35,381,613
                                                                             $0
                                                                     $1,614,147
                                                                    $53,900,961
                                                                    $36,995,760
                                                                    $90,896,721
PV Total 
(7% discount rate)
                                                                             $0
                                                                     $7,205,624
                                                                    $19,440,270
                                                                     $7,336,875
                                                                        $93,862
                                                                       $750,187
                                                                             $0
                                                                             $0
                                                                    $27,001,383
                                                                             $0
                                                                     $1,336,024
                                                                    $34,826,818
                                                                    $28,337,407
                                                                    $63,164,226
Annualized 
(3% discount rate)
                                                                             $0
                                                                       $470,224
                                                                     $2,328,380
                                                                       $645,621
                                                                         $8,280
                                                                        $64,961
                                                                             $0
                                                                             $0
                                                                     $2,308,932
                                                                             $0
                                                                       $105,336
                                                                     $3,517,467
                                                                     $2,414,268
                                                                     $5,931,735
Annualized 
(7% discount rate)
                                                                             $0
                                                                       $635,663
                                                                     $1,714,976
                                                                       $647,242
                                                                         $8,280
                                                                        $66,180
                                                                             $0
                                                                             $0
                                                                     $2,382,000
                                                                             $0
                                                                       $117,861
                                                                     $3,072,341
                                                                     $2,499,861
                                                                     $5,572,202

EXHIBIT A-6:  COSTS OF THE FINAL RULE BY PROVISION AND YEAR FOR SQGs (HIGH-END)
                                     Year
                             Mandatory Provisions
                             Voluntary Provisions
SUBTOTAL: Mandatory Provisions of the Final Rule
SUBTOTAL: Voluntary Provisions of the Final Rule
TOTAL: Mandatory and Voluntary Provisions Combined

                                Re-notification
                               Labeling/Marking
Closure
Emergency Response Preparedness
Transfer Facility Requirements
BR Requirements
Prohibitions on Storage of Restricted Waste
Drip Pad and Container Building Requirements
Intra-organizational Transfers
Episodic Generation
Special Requirements for Ignitable and Reactive Wastes



                                                                         Year 1
                                                                     $2,375,967
                                                                     $4,976,989
                                                                             $0
                                                                       $224,488
                                                                             $0
                                                                         $4,393
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $403,312
                                                                             $0
                                                                     $7,581,837
                                                                       $403,312
                                                                     $7,985,148
                                                                         Year 2
                                                                             $0
                                                                     $4,976,989
                                                                             $0
                                                                         $5,914
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $403,312
                                                                             $0
                                                                     $4,982,903
                                                                       $403,312
                                                                     $5,386,215
                                                                         Year 3
                                                                             $0
                                                                     $4,976,989
                                                                             $0
                                                                         $5,914
                                                                             $0
                                                                         $4,393
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $403,312
                                                                             $0
                                                                     $4,987,296
                                                                       $403,312
                                                                     $5,390,608
                                                                         Year 4
                                                                             $0
                                                                     $4,976,989
                                                                             $0
                                                                         $5,914
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $403,312
                                                                             $0
                                                                     $4,982,903
                                                                       $403,312
                                                                     $5,386,215
                                                                         Year 5
                                                                     $2,375,967
                                                                     $4,976,989
                                                                             $0
                                                                         $5,914
                                                                             $0
                                                                         $4,393
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $403,312
                                                                             $0
                                                                     $7,363,263
                                                                       $403,312
                                                                     $7,766,574
                                                                         Year 6
                                                                             $0
                                                                     $4,976,989
                                                                             $0
                                                                         $5,914
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $403,312
                                                                             $0
                                                                     $4,982,903
                                                                       $403,312
                                                                     $5,386,215
                                                                         Year 7
                                                                             $0
                                                                     $4,976,989
                                                                             $0
                                                                         $5,914
                                                                             $0
                                                                         $4,393
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $403,312
                                                                             $0
                                                                     $4,987,296
                                                                       $403,312
                                                                     $5,390,608
                                                                         Year 8
                                                                             $0
                                                                     $4,976,989
                                                                             $0
                                                                         $5,914
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $403,312
                                                                             $0
                                                                     $4,982,903
                                                                       $403,312
                                                                     $5,386,215
                                                                         Year 9
                                                                     $2,375,967
                                                                     $4,976,989
                                                                             $0
                                                                         $5,914
                                                                             $0
                                                                         $4,393
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $403,312
                                                                             $0
                                                                     $7,363,263
                                                                       $403,312
                                                                     $7,766,574
                                                                        Year 10
                                                                             $0
                                                                     $4,976,989
                                                                             $0
                                                                         $5,914
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $403,312
                                                                             $0
                                                                     $4,982,903
                                                                       $403,312
                                                                     $5,386,215
                                                                        Year 11
                                                                             $0
                                                                     $4,976,989
                                                                             $0
                                                                         $5,914
                                                                             $0
                                                                         $4,393
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $403,312
                                                                             $0
                                                                     $4,987,296
                                                                       $403,312
                                                                     $5,390,608
                                                                        Year 12
                                                                             $0
                                                                     $4,976,989
                                                                             $0
                                                                         $5,914
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $403,312
                                                                             $0
                                                                     $4,982,903
                                                                       $403,312
                                                                     $5,386,215
                                                                        Year 13
                                                                     $2,375,967
                                                                     $4,976,989
                                                                             $0
                                                                         $5,914
                                                                             $0
                                                                         $4,393
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $403,312
                                                                             $0
                                                                     $7,363,263
                                                                       $403,312
                                                                     $7,766,574
                                                                        Year 14
                                                                             $0
                                                                     $4,976,989
                                                                             $0
                                                                         $5,914
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $403,312
                                                                             $0
                                                                     $4,982,903
                                                                       $403,312
                                                                     $5,386,215
                                                                        Year 15
                                                                             $0
                                                                     $4,976,989
                                                                             $0
                                                                         $5,914
                                                                             $0
                                                                         $4,393
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $403,312
                                                                             $0
                                                                     $4,987,296
                                                                       $403,312
                                                                     $5,390,608
                                                                        Year 16
                                                                             $0
                                                                     $4,976,989
                                                                             $0
                                                                         $5,914
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $403,312
                                                                             $0
                                                                     $4,982,903
                                                                       $403,312
                                                                     $5,386,215
                                                                        Year 17
                                                                     $2,375,967
                                                                     $4,976,989
                                                                             $0
                                                                         $5,914
                                                                             $0
                                                                         $4,393
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $403,312
                                                                             $0
                                                                     $7,363,263
                                                                       $403,312
                                                                     $7,766,574
                                                                        Year 18
                                                                             $0
                                                                     $4,976,989
                                                                             $0
                                                                         $5,914
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $403,312
                                                                             $0
                                                                     $4,982,903
                                                                       $403,312
                                                                     $5,386,215
                                                                        Year 19
                                                                             $0
                                                                     $4,976,989
                                                                             $0
                                                                         $5,914
                                                                             $0
                                                                         $4,393
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $403,312
                                                                             $0
                                                                     $4,987,296
                                                                       $403,312
                                                                     $5,390,608
                                                                        Year 20
                                                                             $0
                                                                     $4,976,989
                                                                             $0
                                                                         $5,914
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $403,312
                                                                             $0
                                                                     $4,982,903
                                                                       $403,312
                                                                     $5,386,215
Total 
(Undiscounted)
                                                                    $11,879,834
                                                                    $99,539,783
                                                                             $0
                                                                       $336,851
                                                                             $0
                                                                        $43,931
                                                                             $0
                                                                             $0
                                                                             $0
                                                                     $8,066,232
                                                                             $0
                                                                   $111,800,399
                                                                     $8,066,232
                                                                   $119,866,631
PV Total
(3% discount rate)
                                                                     $9,509,672
                                                                    $76,266,382
                                                                             $0
                                                                       $309,196
                                                                             $0
                                                                        $34,157
                                                                             $0
                                                                             $0
                                                                             $0
                                                                     $6,180,266
                                                                             $0
                                                                    $86,119,407
                                                                     $6,180,266
                                                                    $92,299,673
PV Total 
(7% discount rate)
                                                                     $7,431,195
                                                                    $56,417,135
                                                                             $0
                                                                       $285,611
                                                                             $0
                                                                        $25,741
                                                                             $0
                                                                             $0
                                                                             $0
                                                                     $4,571,777
                                                                             $0
                                                                    $64,159,681
                                                                     $4,571,777
                                                                    $68,731,458
Annualized 
(3% discount rate)
                                                                       $620,582
                                                                     $4,976,989
                                                                             $0
                                                                        $20,178
                                                                             $0
                                                                         $2,229
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $403,312
                                                                             $0
                                                                     $5,619,978
                                                                       $403,312
                                                                     $6,023,289
Annualized 
(7% discount rate)
                                                                       $655,563
                                                                     $4,976,989
                                                                             $0
                                                                        $25,196
                                                                             $0
                                                                         $2,271
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $403,312
                                                                             $0
                                                                     $5,660,019
                                                                       $403,312
                                                                     $6,063,330

EXHIBIT A-7:  COSTS OF THE FINAL RULE BY PROVISION AND YEAR FOR VSQGs (HIGH-END)
                                     Year
                             Mandatory Provisions
                             Voluntary Provisions
SUBTOTAL: Mandatory Provisions of the Final Rule
SUBTOTAL: Voluntary Provisions of the Final Rule
TOTAL: Mandatory and Voluntary Provisions Combined

Re-notification
Labeling/Marking
Closure
Emergency Response Preparedness
Transfer Facility Requirements
BR Requirements
Prohibitions on Storage of Restricted Waste
Drip Pad and Container Building Requirements
Intra-organizational Transfers
Episodic Generation
Special Requirements for Ignitable and Reactive Wastes



                                                                         Year 1
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                         $5,087
                                                                             $0
                                                                             $0
                                                                       $669,879
                                                                       $990,627
                                                                             $0
                                                                         $5,087
                                                                     $1,660,506
                                                                     $1,665,593
                                                                         Year 2
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $669,879
                                                                       $990,627
                                                                             $0
                                                                             $0
                                                                     $1,660,506
                                                                     $1,660,506
                                                                         Year 3
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                         $5,087
                                                                             $0
                                                                             $0
                                                                       $669,879
                                                                       $990,627
                                                                             $0
                                                                         $5,087
                                                                     $1,660,506
                                                                     $1,665,593
                                                                         Year 4
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $669,879
                                                                       $990,627
                                                                             $0
                                                                             $0
                                                                     $1,660,506
                                                                     $1,660,506
                                                                         Year 5
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                         $5,087
                                                                             $0
                                                                             $0
                                                                       $669,879
                                                                       $990,627
                                                                             $0
                                                                         $5,087
                                                                     $1,660,506
                                                                     $1,665,593
                                                                         Year 6
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $669,879
                                                                       $990,627
                                                                             $0
                                                                             $0
                                                                     $1,660,506
                                                                     $1,660,506
                                                                         Year 7
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                         $5,087
                                                                             $0
                                                                             $0
                                                                       $669,879
                                                                       $990,627
                                                                             $0
                                                                         $5,087
                                                                     $1,660,506
                                                                     $1,665,593
                                                                         Year 8
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $669,879
                                                                       $990,627
                                                                             $0
                                                                             $0
                                                                     $1,660,506
                                                                     $1,660,506
                                                                         Year 9
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                         $5,087
                                                                             $0
                                                                             $0
                                                                       $669,879
                                                                       $990,627
                                                                             $0
                                                                         $5,087
                                                                     $1,660,506
                                                                     $1,665,593
                                                                        Year 10
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $669,879
                                                                       $990,627
                                                                             $0
                                                                             $0
                                                                     $1,660,506
                                                                     $1,660,506
                                                                        Year 11
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                         $5,087
                                                                             $0
                                                                             $0
                                                                       $669,879
                                                                       $990,627
                                                                             $0
                                                                         $5,087
                                                                     $1,660,506
                                                                     $1,665,593
                                                                        Year 12
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $669,879
                                                                       $990,627
                                                                             $0
                                                                             $0
                                                                     $1,660,506
                                                                     $1,660,506
                                                                        Year 13
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                         $5,087
                                                                             $0
                                                                             $0
                                                                       $669,879
                                                                       $990,627
                                                                             $0
                                                                         $5,087
                                                                     $1,660,506
                                                                     $1,665,593
                                                                        Year 14
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $669,879
                                                                       $990,627
                                                                             $0
                                                                             $0
                                                                     $1,660,506
                                                                     $1,660,506
                                                                        Year 15
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                         $5,087
                                                                             $0
                                                                             $0
                                                                       $669,879
                                                                       $990,627
                                                                             $0
                                                                         $5,087
                                                                     $1,660,506
                                                                     $1,665,593
                                                                        Year 16
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $669,879
                                                                       $990,627
                                                                             $0
                                                                             $0
                                                                     $1,660,506
                                                                     $1,660,506
                                                                        Year 17
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                         $5,087
                                                                             $0
                                                                             $0
                                                                       $669,879
                                                                       $990,627
                                                                             $0
                                                                         $5,087
                                                                     $1,660,506
                                                                     $1,665,593
                                                                        Year 18
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $669,879
                                                                       $990,627
                                                                             $0
                                                                             $0
                                                                     $1,660,506
                                                                     $1,660,506
                                                                        Year 19
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                         $5,087
                                                                             $0
                                                                             $0
                                                                       $669,879
                                                                       $990,627
                                                                             $0
                                                                         $5,087
                                                                     $1,660,506
                                                                     $1,665,593
                                                                        Year 20
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                       $669,879
                                                                       $990,627
                                                                             $0
                                                                             $0
                                                                     $1,660,506
                                                                     $1,660,506
Total 
(Undiscounted)
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                        $50,867
                                                                             $0
                                                                             $0
                                                                    $13,397,578
                                                                    $19,812,543
                                                                             $0
                                                                        $50,867
                                                                    $33,210,121
                                                                    $33,260,988
PV Total
(3% discount rate)
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                        $39,550
                                                                             $0
                                                                             $0
                                                                    $10,265,090
                                                                    $15,180,171
                                                                             $0
                                                                        $39,550
                                                                    $25,445,261
                                                                    $25,484,811
PV Total 
(7% discount rate)
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                        $29,805
                                                                             $0
                                                                             $0
                                                                     $7,593,476
                                                                    $11,229,348
                                                                             $0
                                                                        $29,805
                                                                    $18,822,825
                                                                    $18,852,630
Annualized 
(3% discount rate)
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                         $2,581
                                                                             $0
                                                                             $0
                                                                       $669,879
                                                                       $990,627
                                                                             $0
                                                                         $2,581
                                                                     $1,660,506
                                                                     $1,663,087
Annualized 
(7% discount rate)
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                         $2,629
                                                                             $0
                                                                             $0
                                                                       $669,879
                                                                       $990,627
                                                                             $0
                                                                         $2,629
                                                                     $1,660,506
                                                                     $1,663,135



EXHIBIT A-8:  COSTS OF THE FINAL RULE BY PROVISION AND YEAR FOR RECYCLING FACILITIES (HIGH-END)
                                     Year
                             Mandatory Provisions
                             Voluntary Provisions
SUBTOTAL: Mandatory Provisions of the Final Rule
SUBTOTAL: Voluntary Provisions of the Final Rule
TOTAL: Mandatory and Voluntary Provisions Combined

BR Reporting Requirements
                                       



                                                                         Year 1
                                                                        $11,178
                                                                             $0
                                                                        $11,178
                                                                             $0
                                                                        $11,178
                                                                         Year 2
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                         Year 3
                                                                        $11,178
                                                                             $0
                                                                        $11,178
                                                                             $0
                                                                        $11,178
                                                                         Year 4
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                         Year 5
                                                                        $11,178
                                                                             $0
                                                                        $11,178
                                                                             $0
                                                                        $11,178
                                                                         Year 6
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                         Year 7
                                                                        $11,178
                                                                             $0
                                                                        $11,178
                                                                             $0
                                                                        $11,178
                                                                         Year 8
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                         Year 9
                                                                        $11,178
                                                                             $0
                                                                        $11,178
                                                                             $0
                                                                        $11,178
                                                                        Year 10
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                        Year 11
                                                                        $11,178
                                                                             $0
                                                                        $11,178
                                                                             $0
                                                                        $11,178
                                                                        Year 12
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                        Year 13
                                                                        $11,178
                                                                             $0
                                                                        $11,178
                                                                             $0
                                                                        $11,178
                                                                        Year 14
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                        Year 15
                                                                        $11,178
                                                                             $0
                                                                        $11,178
                                                                             $0
                                                                        $11,178
                                                                        Year 16
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                        Year 17
                                                                        $11,178
                                                                             $0
                                                                        $11,178
                                                                             $0
                                                                        $11,178
                                                                        Year 18
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                        Year 19
                                                                        $11,178
                                                                             $0
                                                                        $11,178
                                                                             $0
                                                                        $11,178
                                                                        Year 20
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
Total 
(Undiscounted)
                                                                       $111,775
                                                                             $0
                                                                       $111,775
                                                                             $0
                                                                       $111,775
PV Total
(3% discount rate)
                                                                        $86,907
                                                                             $0
                                                                        $86,907
                                                                             $0
                                                                        $86,907
PV Total 
(7% discount rate)
                                                                        $65,494
                                                                             $0
                                                                        $65,494
                                                                             $0
                                                                        $65,494
Annualized 
(3% discount rate)
                                                                         $5,671
                                                                             $0
                                                                         $5,671
                                                                             $0
                                                                         $5,671
Annualized 
(7% discount rate)
                                                                         $5,778
                                                                             $0
                                                                         $5,778
                                                                             $0
                                                                         $5,778

EXHIBIT A-9:  BENEFITS OF THE FINAL RULE BY PROVISION AND YEAR FOR LQGs (LOW-END)
                                     Year
                                   Benefits
TOTAL

Intra-organizational Transfers
Episodic Generation Flexibility
Drip Pad and Container Building Requirements

                                                                         Year 1
                                                                    -$3,600,053
                                                                             $0
                                                                             $0
                                                                    -$3,600,053
                                                                         Year 2
                                                                    -$3,622,052
                                                                             $0
                                                                             $0
                                                                    -$3,622,052
                                                                         Year 3
                                                                    -$3,622,052
                                                                             $0
                                                                             $0
                                                                    -$3,622,052
                                                                         Year 4
                                                                    -$3,622,052
                                                                             $0
                                                                             $0
                                                                    -$3,622,052
                                                                         Year 5
                                                                    -$3,622,052
                                                                             $0
                                                                             $0
                                                                    -$3,622,052
                                                                         Year 6
                                                                    -$3,622,052
                                                                             $0
                                                                             $0
                                                                    -$3,622,052
                                                                         Year 7
                                                                    -$3,622,052
                                                                             $0
                                                                             $0
                                                                    -$3,622,052
                                                                         Year 8
                                                                    -$3,622,052
                                                                             $0
                                                                             $0
                                                                    -$3,622,052
                                                                         Year 9
                                                                    -$3,622,052
                                                                             $0
                                                                             $0
                                                                    -$3,622,052
                                                                        Year 10
                                                                    -$3,622,052
                                                                             $0
                                                                             $0
                                                                    -$3,622,052
                                                                        Year 11
                                                                    -$3,600,053
                                                                             $0
                                                                             $0
                                                                    -$3,600,053
                                                                        Year 12
                                                                    -$3,622,052
                                                                             $0
                                                                             $0
                                                                    -$3,622,052
                                                                        Year 13
                                                                    -$3,622,052
                                                                             $0
                                                                             $0
                                                                    -$3,622,052
                                                                        Year 14
                                                                    -$3,622,052
                                                                             $0
                                                                             $0
                                                                    -$3,622,052
                                                                        Year 15
                                                                    -$3,622,052
                                                                             $0
                                                                             $0
                                                                    -$3,622,052
                                                                        Year 16
                                                                    -$3,622,052
                                                                             $0
                                                                             $0
                                                                    -$3,622,052
                                                                        Year 17
                                                                    -$3,622,052
                                                                             $0
                                                                             $0
                                                                    -$3,622,052
                                                                        Year 18
                                                                    -$3,622,052
                                                                             $0
                                                                             $0
                                                                    -$3,622,052
                                                                        Year 19
                                                                    -$3,622,052
                                                                             $0
                                                                             $0
                                                                    -$3,622,052
                                                                        Year 20
                                                                    -$3,622,052
                                                                             $0
                                                                             $0
                                                                    -$3,622,052
Total 
(Undiscounted)
                                                                   -$72,397,048
                                                                             $0
                                                                             $0
                                                                   -$72,397,048
PV Total
(3% discount rate)
                                                                   -$55,465,233
                                                                             $0
                                                                             $0
                                                                   -$55,465,233
PV Total 
(7% discount rate)
                                                                   -$41,024,937
                                                                             $0
                                                                             $0
                                                                   -$41,024,937
Annualized 
(3% discount rate)
                                                                    -$3,619,548
                                                                             $0
                                                                             $0
                                                                    -$3,619,548
Annualized 
(7% discount rate)
                                                                    -$3,619,125
                                                                             $0
                                                                             $0
                                                                    -$3,619,125
Note: Intra-organizational transfers of hazardous waste will result in a transfer of costs from VSQGs to LQGs; therefore, the benefits for LQGs are reported as a net cost, rather than a net benefit. The cost savings for VSQGs are reported below.
EXHIBIT A-10:  BENEFITS OF THE FINAL RULE BY PROVISION AND YEAR FOR SQGs (LOW-END)
                                     Year
                                   Benefits
TOTAL

Intra-organizational Transfers
Episodic Generation Flexibility
Drip Pad and Container Building Requirements

                                                                         Year 1
                                                                             $0
                                                                     $1,253,004
                                                                       $918,072
                                                                     $2,171,076
                                                                         Year 2
                                                                             $0
                                                                     $1,080,484
                                                                       $791,667
                                                                     $1,872,151
                                                                         Year 3
                                                                             $0
                                                                     $1,253,004
                                                                       $918,072
                                                                     $2,171,076
                                                                         Year 4
                                                                             $0
                                                                     $1,080,484
                                                                       $791,667
                                                                     $1,872,151
                                                                         Year 5
                                                                             $0
                                                                     $1,253,004
                                                                       $918,072
                                                                     $2,171,076
                                                                         Year 6
                                                                             $0
                                                                     $1,080,484
                                                                       $791,667
                                                                     $1,872,151
                                                                         Year 7
                                                                             $0
                                                                     $1,253,004
                                                                       $918,072
                                                                     $2,171,076
                                                                         Year 8
                                                                             $0
                                                                     $1,080,484
                                                                       $791,667
                                                                     $1,872,151
                                                                         Year 9
                                                                             $0
                                                                     $1,253,004
                                                                       $918,072
                                                                     $2,171,076
                                                                        Year 10
                                                                             $0
                                                                     $1,080,484
                                                                       $791,667
                                                                     $1,872,151
                                                                        Year 11
                                                                             $0
                                                                     $1,253,004
                                                                       $918,072
                                                                     $2,171,076
                                                                        Year 12
                                                                             $0
                                                                     $1,080,484
                                                                       $791,667
                                                                     $1,872,151
                                                                        Year 13
                                                                             $0
                                                                     $1,253,004
                                                                       $918,072
                                                                     $2,171,076
                                                                        Year 14
                                                                             $0
                                                                     $1,080,484
                                                                       $791,667
                                                                     $1,872,151
                                                                        Year 15
                                                                             $0
                                                                     $1,253,004
                                                                       $918,072
                                                                     $2,171,076
                                                                        Year 16
                                                                             $0
                                                                     $1,080,484
                                                                       $791,667
                                                                     $1,872,151
                                                                        Year 17
                                                                             $0
                                                                     $1,253,004
                                                                       $918,072
                                                                     $2,171,076
                                                                        Year 18
                                                                             $0
                                                                     $1,080,484
                                                                       $791,667
                                                                     $1,872,151
                                                                        Year 19
                                                                             $0
                                                                     $1,253,004
                                                                       $918,072
                                                                     $2,171,076
                                                                        Year 20
                                                                             $0
                                                                     $1,080,484
                                                                       $791,667
                                                                     $1,872,151
Total 
(Undiscounted)
                                                                             $0
                                                                    $23,334,876
                                                                    $17,097,391
                                                                    $40,432,267
PV Total
(3% discount rate)
                                                                             $0
                                                                    $17,898,482
                                                                    $13,114,162
                                                                    $31,012,644
PV Total 
(7% discount rate)
                                                                             $0
                                                                    $13,258,801
                                                                     $9,714,683
                                                                    $22,973,484
Annualized 
(3% discount rate)
                                                                             $0
                                                                     $1,168,019
                                                                       $855,804
                                                                     $2,023,822
Annualized 
(7% discount rate)
                                                                             $0
                                                                     $1,169,661
                                                                       $857,007
                                                                     $2,026,668
EXHIBIT A-11:  BENEFITS OF THE FINAL RULE BY PROVISION AND YEAR FOR VSQGs (LOW-END)
                                     Year
                                   Benefits
TOTAL

Intra-organizational Transfers
Episodic Generation Flexibility
Drip Pad and Container Building Requirements

                                                                         Year 1
                                                                     $7,832,494
                                                                     $2,445,512
                                                                             $0
                                                                    $10,278,006
                                                                         Year 2
                                                                     $7,832,494
                                                                     $1,818,931
                                                                             $0
                                                                     $9,651,425
                                                                         Year 3
                                                                     $7,832,494
                                                                     $1,927,631
                                                                             $0
                                                                     $9,760,125
                                                                         Year 4
                                                                     $7,832,494
                                                                     $2,336,813
                                                                             $0
                                                                    $10,169,306
                                                                         Year 5
                                                                     $7,832,494
                                                                     $1,927,631
                                                                             $0
                                                                     $9,760,125
                                                                         Year 6
                                                                     $7,832,494
                                                                     $1,818,931
                                                                             $0
                                                                     $9,651,425
                                                                         Year 7
                                                                     $7,832,494
                                                                     $2,445,512
                                                                             $0
                                                                    $10,278,006
                                                                         Year 8
                                                                     $7,832,494
                                                                     $1,818,931
                                                                             $0
                                                                     $9,651,425
                                                                         Year 9
                                                                     $7,832,494
                                                                     $1,927,631
                                                                             $0
                                                                     $9,760,125
                                                                        Year 10
                                                                     $7,832,494
                                                                     $2,336,813
                                                                             $0
                                                                    $10,169,306
                                                                        Year 11
                                                                     $7,832,494
                                                                     $1,927,631
                                                                             $0
                                                                     $9,760,125
                                                                        Year 12
                                                                     $7,832,494
                                                                     $1,818,931
                                                                             $0
                                                                     $9,651,425
                                                                        Year 13
                                                                     $7,832,494
                                                                     $2,445,512
                                                                             $0
                                                                    $10,278,006
                                                                        Year 14
                                                                     $7,832,494
                                                                     $1,818,931
                                                                             $0
                                                                     $9,651,425
                                                                        Year 15
                                                                     $7,832,494
                                                                     $1,927,631
                                                                             $0
                                                                     $9,760,125
                                                                        Year 16
                                                                     $7,832,494
                                                                     $2,336,813
                                                                             $0
                                                                    $10,169,306
                                                                        Year 17
                                                                     $7,832,494
                                                                     $1,927,631
                                                                             $0
                                                                     $9,760,125
                                                                        Year 18
                                                                     $7,832,494
                                                                     $1,818,931
                                                                             $0
                                                                     $9,651,425
                                                                        Year 19
                                                                     $7,832,494
                                                                     $2,445,512
                                                                             $0
                                                                    $10,278,006
                                                                        Year 20
                                                                     $7,832,494
                                                                     $1,818,931
                                                                             $0
                                                                     $9,651,425
Total 
(Undiscounted)
                                                                   $156,649,875
                                                                    $41,090,792
                                                                             $0
                                                                   $197,740,667
PV Total
(3% discount rate)
                                                                   $120,023,560
                                                                    $31,540,379
                                                                             $0
                                                                   $151,563,940
PV Total 
(7% discount rate)
                                                                    $88,785,979
                                                                    $23,393,869
                                                                             $0
                                                                   $112,179,847
Annualized 
(3% discount rate)
                                                                     $7,832,494
                                                                     $2,058,261
                                                                             $0
                                                                     $9,890,755
Annualized 
(7% discount rate)
                                                                     $7,832,494
                                                                     $2,063,753
                                                                             $0
                                                                     $9,896,247

EXHIBIT A-12:  BENEFITS OF THE FINAL RULE BY PROVISION AND YEAR FOR LQGs (HIGH-END)
                                     Year
                                   Benefits
TOTAL

Intra-organizational Transfers
Episodic Generation Flexibility
Drip Pad and Container Building Requirements

                                                                         Year 1
                                                                    -$6,418,363
                                                                             $0
                                                                             $0
                                                                    -$6,418,363
                                                                         Year 2
                                                                    -$6,440,362
                                                                             $0
                                                                             $0
                                                                    -$6,440,362
                                                                         Year 3
                                                                    -$6,440,362
                                                                             $0
                                                                             $0
                                                                    -$6,440,362
                                                                         Year 4
                                                                    -$6,440,362
                                                                             $0
                                                                             $0
                                                                    -$6,440,362
                                                                         Year 5
                                                                    -$6,440,362
                                                                             $0
                                                                             $0
                                                                    -$6,440,362
                                                                         Year 6
                                                                    -$6,440,362
                                                                             $0
                                                                             $0
                                                                    -$6,440,362
                                                                         Year 7
                                                                    -$6,418,363
                                                                             $0
                                                                             $0
                                                                    -$6,418,363
                                                                         Year 8
                                                                    -$6,440,362
                                                                             $0
                                                                             $0
                                                                    -$6,440,362
                                                                         Year 9
                                                                    -$6,440,362
                                                                             $0
                                                                             $0
                                                                    -$6,440,362
                                                                        Year 10
                                                                    -$6,440,362
                                                                             $0
                                                                             $0
                                                                    -$6,440,362
                                                                        Year 11
                                                                    -$6,440,362
                                                                             $0
                                                                             $0
                                                                    -$6,440,362
                                                                        Year 12
                                                                    -$6,440,362
                                                                             $0
                                                                             $0
                                                                    -$6,440,362
                                                                        Year 13
                                                                    -$6,440,362
                                                                             $0
                                                                             $0
                                                                    -$6,440,362
                                                                        Year 14
                                                                    -$6,440,362
                                                                             $0
                                                                             $0
                                                                    -$6,440,362
                                                                        Year 15
                                                                    -$6,440,362
                                                                             $0
                                                                             $0
                                                                    -$6,440,362
                                                                        Year 16
                                                                    -$6,440,362
                                                                             $0
                                                                             $0
                                                                    -$6,440,362
                                                                        Year 17
                                                                    -$6,440,362
                                                                             $0
                                                                             $0
                                                                    -$6,440,362
                                                                        Year 18
                                                                    -$6,440,362
                                                                             $0
                                                                             $0
                                                                    -$6,440,362
                                                                        Year 19
                                                                    -$6,440,362
                                                                             $0
                                                                             $0
                                                                    -$6,440,362
                                                                        Year 20
                                                                    -$6,440,362
                                                                             $0
                                                                             $0
                                                                    -$6,440,362
Total 
(Undiscounted)
                                                                  -$128,763,238
                                                                             $0
                                                                             $0
                                                                  -$128,763,238
PV Total
(3% discount rate)
                                                                   -$98,650,388
                                                                             $0
                                                                             $0
                                                                   -$98,650,388
PV Total 
(7% discount rate)
                                                                   -$72,968,677
                                                                             $0
                                                                             $0
                                                                   -$72,968,677
Annualized 
(3% discount rate)
                                                                    -$6,437,724
                                                                             $0
                                                                             $0
                                                                    -$6,437,724
Annualized 
(7% discount rate)
                                                                    -$6,437,128
                                                                             $0
                                                                             $0
                                                                    -$6,437,128
Note: Intra-organizational transfers of hazardous waste will result in a transfer of costs from VSQGs to LQGs; therefore, the benefits for LQGs are reported as a net cost, rather than a net benefit. The cost savings for VSQGs are reported below.

EXHIBIT A-13:  BENEFITS OF THE FINAL RULE BY PROVISION AND YEAR FOR SQGs (HIGH-END)
                                     Year
                                   Benefits
TOTAL

Intra-organizational Transfers
Episodic Generation Flexibility
Drip Pad and Container Building Requirements

                                                                         Year 1
                                                                             $0
                                                                     $2,626,169
                                                                       $924,525
                                                                     $3,550,694
                                                                         Year 2
                                                                             $0
                                                                     $2,158,389
                                                                       $791,667
                                                                     $2,950,056
                                                                         Year 3
                                                                             $0
                                                                     $2,626,169
                                                                       $924,525
                                                                     $3,550,694
                                                                         Year 4
                                                                             $0
                                                                     $2,158,389
                                                                       $791,667
                                                                     $2,950,056
                                                                         Year 5
                                                                             $0
                                                                     $2,626,169
                                                                       $924,525
                                                                     $3,550,694
                                                                         Year 6
                                                                             $0
                                                                     $2,158,389
                                                                       $791,667
                                                                     $2,950,056
                                                                         Year 7
                                                                             $0
                                                                     $2,626,169
                                                                       $924,525
                                                                     $3,550,694
                                                                         Year 8
                                                                             $0
                                                                     $2,158,389
                                                                       $791,667
                                                                     $2,950,056
                                                                         Year 9
                                                                             $0
                                                                     $2,626,169
                                                                       $924,525
                                                                     $3,550,694
                                                                        Year 10
                                                                             $0
                                                                     $2,158,389
                                                                       $791,667
                                                                     $2,950,056
                                                                        Year 11
                                                                             $0
                                                                     $2,626,169
                                                                       $924,525
                                                                     $3,550,694
                                                                        Year 12
                                                                             $0
                                                                     $2,158,389
                                                                       $791,667
                                                                     $2,950,056
                                                                        Year 13
                                                                             $0
                                                                     $2,626,169
                                                                       $924,525
                                                                     $3,550,694
                                                                        Year 14
                                                                             $0
                                                                     $2,158,389
                                                                       $791,667
                                                                     $2,950,056
                                                                        Year 15
                                                                             $0
                                                                     $2,626,169
                                                                       $924,525
                                                                     $3,550,694
                                                                        Year 16
                                                                             $0
                                                                     $2,158,389
                                                                       $791,667
                                                                     $2,950,056
                                                                        Year 17
                                                                             $0
                                                                     $2,626,169
                                                                       $924,525
                                                                     $3,550,694
                                                                        Year 18
                                                                             $0
                                                                     $2,158,389
                                                                       $791,667
                                                                     $2,950,056
                                                                        Year 19
                                                                             $0
                                                                     $2,626,169
                                                                       $924,525
                                                                     $3,550,694
                                                                        Year 20
                                                                             $0
                                                                     $2,158,389
                                                                       $791,667
                                                                     $2,950,056
Total 
(Undiscounted)
                                                                             $0
                                                                    $47,845,585
                                                                    $17,161,921
                                                                    $65,007,506
PV Total
(3% discount rate)
                                                                             $0
                                                                    $36,711,773
                                                                    $13,164,335
                                                                    $49,876,108
PV Total 
(7% discount rate)
                                                                             $0
                                                                    $27,207,566
                                                                     $9,752,493
                                                                    $36,960,060
Annualized 
(3% discount rate)
                                                                             $0
                                                                     $2,395,736
                                                                       $859,078
                                                                     $3,254,813
Annualized 
(7% discount rate)
                                                                             $0
                                                                     $2,400,189
                                                                       $860,342
                                                                     $3,260,531

EXHIBIT A-14:  BENEFITS OF THE FINAL RULE BY PROVISION AND YEAR FOR VSQGs (HIGH-END)
                                     Year
                                   Benefits
TOTAL

Intra-organizational Transfers
Episodic Generation Flexibility
Drip Pad and Container Building Requirements

                                                                         Year 1
                                                                    $13,377,196
                                                                     $4,963,636
                                                                             $0
                                                                    $18,340,832
                                                                         Year 2
                                                                    $13,377,196
                                                                     $3,633,951
                                                                             $0
                                                                    $17,011,147
                                                                         Year 3
                                                                    $13,377,196
                                                                     $3,928,479
                                                                             $0
                                                                    $17,305,676
                                                                         Year 4
                                                                    $13,377,196
                                                                     $4,669,107
                                                                             $0
                                                                    $18,046,304
                                                                         Year 5
                                                                    $13,377,196
                                                                     $3,928,479
                                                                             $0
                                                                    $17,305,676
                                                                         Year 6
                                                                    $13,377,196
                                                                     $3,633,951
                                                                             $0
                                                                    $17,011,147
                                                                         Year 7
                                                                    $13,377,196
                                                                     $4,963,636
                                                                             $0
                                                                    $18,340,832
                                                                         Year 8
                                                                    $13,377,196
                                                                     $3,633,951
                                                                             $0
                                                                    $17,011,147
                                                                         Year 9
                                                                    $13,377,196
                                                                     $3,928,479
                                                                             $0
                                                                    $17,305,676
                                                                        Year 10
                                                                    $13,377,196
                                                                     $4,669,107
                                                                             $0
                                                                    $18,046,304
                                                                        Year 11
                                                                    $13,377,196
                                                                     $3,928,479
                                                                             $0
                                                                    $17,305,676
                                                                        Year 12
                                                                    $13,377,196
                                                                     $3,633,951
                                                                             $0
                                                                    $17,011,147
                                                                        Year 13
                                                                    $13,377,196
                                                                     $4,963,636
                                                                             $0
                                                                    $18,340,832
                                                                        Year 14
                                                                    $13,377,196
                                                                     $3,633,951
                                                                             $0
                                                                    $17,011,147
                                                                        Year 15
                                                                    $13,377,196
                                                                     $3,928,479
                                                                             $0
                                                                    $17,305,676
                                                                        Year 16
                                                                    $13,377,196
                                                                     $4,669,107
                                                                             $0
                                                                    $18,046,304
                                                                        Year 17
                                                                    $13,377,196
                                                                     $3,928,479
                                                                             $0
                                                                    $17,305,676
                                                                        Year 18
                                                                    $13,377,196
                                                                     $3,633,951
                                                                             $0
                                                                    $17,011,147
                                                                        Year 19
                                                                    $13,377,196
                                                                     $4,963,636
                                                                             $0
                                                                    $18,340,832
                                                                        Year 20
                                                                    $13,377,196
                                                                     $3,633,951
                                                                             $0
                                                                    $17,011,147
Total 
(Undiscounted)
                                                                   $267,543,926
                                                                    $82,870,398
                                                                             $0
                                                                   $350,414,324
PV Total
(3% discount rate)
                                                                   $204,989,469
                                                                    $63,617,201
                                                                             $0
                                                                   $268,606,670
PV Total 
(7% discount rate)
                                                                   $151,638,483
                                                                    $47,192,828
                                                                             $0
                                                                   $198,831,311
Annualized 
(3% discount rate)
                                                                    $13,377,196
                                                                     $4,151,529
                                                                             $0
                                                                    $17,528,726
Annualized 
(7% discount rate)
                                                                    $13,377,196
                                                                     $4,163,242
                                                                             $0
                                                                    $17,540,438

Appendix B  |  Summary of 2013 BR Data

This appendix provides a summary of the 2013 Biennial Report database used throughout this RIA to inform estimates about the size of the regulatory universe, the amount of hazardous waste, and number of waste streams generated.  Exhibit B-1 reports the total quantity of hazardous waste and the number of waste streams generated by generator status. Exhibit B-2 reports the number of facilities by NAICS code and generator status.
EXHIBIT B-1:  SUMMARY OF 2013 BR DATA (AS OF DECEMBER 2015)
                               GENERATOR STATUS
                             NUMBER OF FACILITIES
                  TOTAL QUANTITY OF HAZARDOUS WASTE GENERATED
                                    (TONS)
            MEAN QUANTITY OF HAZARDOUS WASTE GENERATED PER FACILITY
                                    (TONS)
           MEDIAN QUANTITY OF HAZARDOUS WASTE GENERATED PER FACILITY
                                    (TONS)
                   MEAN NUMBER OF WASTE STREAMS PER FACILITY
                  MEDIAN NUMBER OF WASTE STREAMS PER FACILITY
LQG
                                    20,771
                                  35,151,466
                                     1,692
                                      7.6
                                      13
                                       6
SQG
                                     1,921
                                    30,108
                                      16
                                      1.6
                                       8
                                       8
VSQG
                                     2,091
                                    15,436
                                       7
                                      0.1
                                       7
                                       7
Unknown
                                      487
                                    25,401
                                      52
                                      4.5
                                       4
                                       1
TOTAL
                                    25,270
                                  35,222,411
                                     1,394
                                      4.2
                                      12
                                       6


EXHIBIT B-2:  SUMMARY OF 2013 BR BY NAICS CODE AND GENERATOR STATUS (AS OF DECEMBER 2015)
                                     NAICS
                                      LQG
                                      SQG
                                     VSQG
                                    UNKNOWN
                                     TOTAL
                                       
                             NUMBER OF FACILITIES
                         QUANTITY OF HAZ. WASTE (TONS)
                             NUMBER OF FACILITIES
                         QUANTITY OF HAZ. WASTE (TONS)
                             NUMBER OF FACILITIES
                         QUANTITY OF HAZ. WASTE (TONS)
                             NUMBER OF FACILITIES
                         QUANTITY OF HAZ. WASTE (TONS)
                             NUMBER OF FACILITIES
                         QUANTITY OF HAZ. WASTE (TONS)
111
                                      25
                                      457
                                       4
                                      73
                                       3
                                       2
                                       7
                                      57
                                      39
                                      589
112
                                       2
                                      13
                                       0
                                       
                                       0
                                       
                                       1
                                      48
                                       3
                                      61
115
                                      10
                                      336
                                       2
                                       2
                                       2
                                      49
                                       0
                                       
                                      14
                                      387
211
                                      69
                                    12,074
                                       4
                                      19
                                       8
                                      35
                                       2
                                       4
                                      83
                                    12,132
212
                                      40
                                   1,261,538
                                       8
                                      57
                                       4
                                      44
                                       0
                                       
                                      52
                                   1,261,639
213
                                      47
                                     4,871
                                       8
                                      163
                                       8
                                      52
                                       2
                                      19
                                      65
                                     5,105
221
                                     1,825
                                    52,270
                                      56
                                     1,674
                                      36
                                     1,139
                                      24
                                     2,220
                                     1,941
                                    57,303
236
                                      31
                                    13,870
                                       1
                                       3
                                       0
                                       
                                       6
                                      123
                                      38
                                    13,996
237
                                      159
                                    25,920
                                       2
                                      18
                                       3
                                       9
                                      42
                                     2,365
                                      206
                                    28,312
238
                                      59
                                     3,332
                                       3
                                      11
                                       1
                                       2
                                      24
                                      122
                                      87
                                     3,468
311
                                      78
                                     9,239
                                      10
                                      92
                                       6
                                      26
                                       1
                                      66
                                      95
                                     9,422
312
                                      17
                                      941
                                       2
                                      11
                                       2
                                       4
                                       1
                                      56
                                      22
                                     1,011
313
                                      47
                                     4,790
                                       5
                                      26
                                       1
                                      24
                                       2
                                       8
                                      55
                                     4,848
314
                                       9
                                      81
                                       2
                                       9
                                       0
                                       
                                       0
                                       
                                      11
                                      90
315
                                       2
                                      96
                                       1
                                      12
                                       0
                                       
                                       1
                                       1
                                       4
                                      109
316
                                       4
                                      161
                                       0
                                       
                                       0
                                       
                                       0
                                       
                                       4
                                      161
321
                                      156
                                     8,612
                                      13
                                      97
                                       5
                                      11
                                       3
                                      14
                                      177
                                     8,735
322
                                      138
                                    11,332
                                       7
                                     5,948
                                      11
                                      108
                                       2
                                      173
                                      158
                                    17,561
323
                                      242
                                    21,182
                                       8
                                      101
                                       1
                                      10
                                       4
                                      89
                                      255
                                    21,381
324
                                      192
                                   5,848,566
                                       9
                                      67
                                       4
                                      62
                                       1
                                      23
                                      206
                                   5,848,718
325
                                     2,239
                                  18,590,532
                                      68
                                     1,394
                                      50
                                      406
                                      25
                                     1,402
                                     2,382
                                  18,593,734
326
                                      383
                                    56,468
                                      23
                                      200
                                       3
                                      30
                                       3
                                      91
                                      412
                                    56,789
327
                                      148
                                    46,374
                                      13
                                      451
                                      11
                                      145
                                       8
                                      725
                                      180
                                    47,694
331
                                      585
                                   2,805,538
                                      17
                                      306
                                       4
                                      316
                                       4
                                      506
                                      610
                                   2,806,667
332
                                     1,779
                                    349,226
                                      65
                                     1,006
                                      27
                                     1,060
                                      27
                                     2,581
                                     1,898
                                    353,874
333
                                      371
                                    127,663
                                      25
                                      643
                                      14
                                      139
                                       5
                                      28
                                      415
                                    128,472
334
                                      561
                                    97,012
                                      19
                                      680
                                       2
                                      339
                                      10
                                      248
                                      592
                                    98,279
335
                                      212
                                    130,662
                                      17
                                      542
                                       1
                                       2
                                       6
                                      244
                                      236
                                    131,450
336
                                      867
                                    147,618
                                      24
                                      231
                                       6
                                      97
                                       4
                                      162
                                      901
                                    148,107
337
                                      152
                                     9,992
                                       6
                                      121
                                       0
                                       
                                       3
                                      19
                                      161
                                    10,133
339
                                      261
                                    28,299
                                      14
                                      114
                                       6
                                      361
                                       5
                                      52
                                      286
                                    28,825
423
                                      84
                                    42,764
                                       5
                                      549
                                       4
                                     1,429
                                       7
                                     6,364
                                      100
                                    51,105
424
                                      378
                                    33,519
                                      29
                                      827
                                      19
                                      228
                                      17
                                      849
                                      443
                                    35,423
425
                                       4
                                     6,085
                                       1
                                       3
                                       0
                                       
                                       0
                                       
                                       5
                                     6,089
441
                                       8
                                      76
                                       2
                                       7
                                       0
                                       
                                       1
                                      60
                                      11
                                      143
442
                                      12
                                       2
                                       0
                                       
                                       0
                                       
                                       0
                                       
                                      12
                                       2
444
                                      27
                                      235
                                       8
                                      67
                                       1
                                       5
                                       1
                                       4
                                      37
                                      311
445
                                      101
                                      36
                                       0
                                       
                                      213
                                      52
                                       2
                                      12
                                      316
                                      100
446
                                     4,448
                                     2,245
                                      371
                                      370
                                     1,023
                                      232
                                      23
                                      10
                                     5,865
                                     2,857
447
                                      67
                                      317
                                       9
                                      277
                                       5
                                      16
                                      18
                                      226
                                      99
                                      836
448
                                       1
                                       5
                                       1
                                      14
                                       0
                                       
                                       0
                                       
                                       2
                                      19
451
                                       2
                                       2
                                       3
                                      36
                                       0
                                       
                                       0
                                       
                                       5
                                      38
452
                                      868
                                      866
                                      739
                                     1,118
                                      263
                                      44
                                      13
                                       3
                                     1,883
                                     2,030
453
                                      19
                                      35
                                       0
                                       
                                      13
                                       1
                                       0
                                       
                                      32
                                      36
454
                                      10
                                      496
                                       0
                                       
                                       0
                                       
                                       0
                                       
                                      10
                                      496
481
                                      33
                                     2,823
                                       1
                                       1
                                       0
                                       
                                       0
                                       
                                      34
                                     2,824
482
                                      36
                                     8,301
                                       6
                                      18
                                       5
                                      472
                                       4
                                      22
                                      51
                                     8,813
483
                                      36
                                     3,355
                                       9
                                      18
                                       0
                                       
                                       0
                                       
                                      45
                                     3,373
484
                                      49
                                     1,155
                                      14
                                      54
                                       3
                                      27
                                       9
                                      232
                                      75
                                     1,467
485
                                      71
                                     1,974
                                       5
                                      66
                                       1
                                       2
                                       2
                                      45
                                      79
                                     2,087
486
                                      177
                                     7,569
                                      23
                                      419
                                      13
                                      320
                                       7
                                      59
                                      220
                                     8,367
488
                                      268
                                    79,648
                                       8
                                      83
                                       9
                                      181
                                       8
                                     1,329
                                      293
                                    81,241
491
                                       2
                                       3
                                       0
                                       
                                       0
                                       
                                       0
                                       
                                       2
                                       3
492
                                      22
                                      200
                                       5
                                      31
                                       0
                                       
                                       0
                                       
                                      27
                                      231
493
                                      301
                                    222,186
                                      30
                                      564
                                       7
                                      105
                                      17
                                      562
                                      355
                                    223,416
511
                                       6
                                      45
                                       0
                                       
                                       0
                                       
                                      11
                                      47
                                      17
                                      91
512
                                       6
                                      132
                                       0
                                       
                                       0
                                       
                                       0
                                       
                                       6
                                      132
517
                                      10
                                      71
                                       2
                                       2
                                       1
                                      19
                                       1
                                       1
                                      14
                                      94
519
                                       0
                                       
                                       0
                                       
                                       0
                                       
                                       1
                                       1
                                       1
                                       1
522
                                       1
                                       5
                                       0
                                       
                                       0
                                       
                                       1
                                       2
                                       2
                                       7
524
                                       1
                                       1
                                       0
                                       
                                       0
                                       
                                       0
                                       
                                       1
                                       1
525
                                       5
                                      34
                                       0
                                       
                                       2
                                       9
                                       1
                                       4
                                       8
                                      48
531
                                      42
                                    16,309
                                       1
                                       2
                                       4
                                      17
                                      10
                                      297
                                      57
                                    16,625
532
                                      16
                                     4,569
                                       1
                                       5
                                       0
                                       
                                       0
                                       
                                      17
                                     4,574
541
                                      539
                                    21,171
                                      29
                                      208
                                      13
                                      74
                                       9
                                      127
                                      590
                                    21,580
551
                                       6
                                      83
                                       0
                                       
                                       1
                                       0
                                       1
                                       3
                                       8
                                      86
561
                                      29
                                    47,033
                                       0
                                       
                                       2
                                      37
                                       3
                                      126
                                      34
                                    47,196
562
                                      620
                                   4,811,348
                                      20
                                     9,833
                                      16
                                     7,470
                                      21
                                     2,128
                                      677
                                   4,830,778
611
                                      377
                                    13,263
                                      17
                                      99
                                       7
                                      10
                                       5
                                      40
                                      406
                                    13,413
621
                                      184
                                     5,372
                                       5
                                      33
                                       2
                                       0
                                       0
                                       
                                      191
                                     5,405
622
                                      470
                                     6,347
                                      24
                                      145
                                      10
                                      19
                                       4
                                       4
                                      508
                                     6,514
623
                                       2
                                       5
                                       0
                                       
                                       1
                                       3
                                       0
                                       
                                       3
                                       8
624
                                       0
                                       
                                       1
                                       1
                                       0
                                       
                                       0
                                       
                                       1
                                       1
711
                                       5
                                     1,429
                                       1
                                       5
                                       0
                                       
                                       1
                                      69
                                       7
                                     1,503
712
                                      11
                                    23,072
                                       0
                                       
                                       0
                                       
                                       0
                                       
                                      11
                                    23,072
713
                                      17
                                     2,066
                                       0
                                       
                                       0
                                       
                                       1
                                       4
                                      18
                                     2,070
721
                                       3
                                      98
                                       0
                                       
                                       2
                                      50
                                       1
                                      141
                                       6
                                      289
722
                                       1
                                      15
                                       0
                                       
                                       0
                                       
                                       0
                                       
                                       1
                                      15
811
                                      101
                                    43,222
                                       6
                                      40
                                       4
                                      43
                                       8
                                      242
                                      119
                                    43,546
812
                                      228
                                     4,205
                                      92
                                      198
                                      215
                                      20
                                       5
                                      111
                                      540
                                     4,534
813
                                       6
                                      31
                                       2
                                      739
                                       0
                                       
                                       2
                                       7
                                      10
                                      777
921
                                      30
                                     2,140
                                       3
                                      81
                                       3
                                      51
                                       4
                                      68
                                      40
                                     2,340
922
                                      19
                                     4,921
                                       1
                                       2
                                       1
                                      13
                                       1
                                      20
                                      22
                                     4,957
923
                                       5
                                      51
                                       0
                                       
                                       1
                                       1
                                       0
                                       
                                       6
                                      51
924
                                      19
                                    10,746
                                       2
                                      12
                                       1
                                       2
                                       5
                                      350
                                      27
                                    11,110
925
                                       3
                                      11
                                       0
                                       
                                       0
                                       
                                       0
                                       
                                       3
                                      11
926
                                      51
                                      804
                                       0
                                       
                                       2
                                       6
                                      36
                                      380
                                      89
                                     1,190
927
                                      12
                                     1,340
                                       0
                                       
                                       0
                                       
                                       0
                                       
                                      12
                                     1,340
928
                                      212
                                    48,564
                                       9
                                      113
                                       5
                                       4
                                       3
                                       8
                                      229
                                    48,689
TOTAL
                                    20,771
                                  35,151,466
                                     1,921
                                    30,108
                                     2,091
                                    15,436
                                      487
                                    25,401
                                    25,270
                                  35,222,411

















