OSWER
No.
9360.7­
16D
ECONOMIC
IMPACT
ANALYSIS
OF
PROPOSED
REPORTABLE
QUANTITY
ADJUSTMENTS
FOR
CARBAMATES
ADDED
AS
RCRA
HAZARDOUS
WASTES
AND
CERCLA
HAZARDOUS
SUBSTANCES
VOLUME
VII
Office
of
Emergency
and
Remedial
Response
U.
S.
Environmental
Protection
Agency
December
2002
OSWER
No.
9360.7­
16D
TABLE
OF
CONTENTS
Page
CHAPTER
1
­­
INTRODUCTION
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1­
1
1.1
STATUTORY
AUTHORITY
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1­
3
1.1.1
Relevant
CERCLA
Provisions
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1­
3
1.1.2
Relevant
EPCRA
Provisions
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1­
4
1.2
REPORTABLE
QUANTITY
ADJUSTMENT
METHODOLOGY
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1­
4
1.3
RCRA
HAZARDOUS
WASTES
AND
THEIR
CHARACTERISTICS
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1­
5
1.4
CARBAMATES
AND
THEIR
CHARACTERISTICS
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1­
5
1.5
PROPOSED
RQ
ADJUSTMENT
FOR
K178
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1­
6
1.6
ORGANIZATION
OF
THIS
EIA
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1­
7
CHAPTER
2
­­
UNIT
COSTS
TO
THE
REGULATED
COMMUNITY
AND
GOVERNMENT
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2­
1
2.1
METHODOLOGY
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2­
1
2.2
ACTIONS
ASSOCIATED
WITH
REPORTING
AND
PROCESSING
A
RELEASE
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2­
1
2.2.1
Actions
Performed
by
the
Regulated
Community
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2­
1
2.2.2
Actions
Performed
by
Government
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2­
2
2.3
UNIT
COSTS
OF
ACTIONS
PERFORMED
BY
THE
REGULATED
COMMUNITY
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2­
3
2.3.1
Notification
to
the
NRC
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2­
3
2.3.2
Notification
to
State
and
Local
Response
Authorities
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2­
4
2.3.3
Recordkeeping
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2­
5
2.3.4
Response
and
Litigation
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2­
6
2.4
UNIT
COSTS
OF
ACTIONS
PERFORMED
BY
THE
FEDERAL
GOVERNMENT
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2­
6
OSWER
No.
9360.7­
16D
TABLE
OF
CONTENTS
(
continued)

Page
2.4.1
Processing
Notifications
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.
2­
7
2.4.2
Other
Activities
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2­
8
2.5
UNIT
COSTS
OF
ACTIONS
PERFORMED
BY
STATE
AND
LOCAL
GOVERNMENT
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2­
8
CHAPTER
3
­­
COST
SAVINGS
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.
3­
1
3.1
ESTIMATED
NUMBER
OF
REPORTABLE
RELEASES
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3­
1
3.2
CALCULATION
OF
COST
SAVINGS
ESTIMATES
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.
3­
3
3.2.1
Cost
Savings
for
the
Regulated
Community
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3­
4
3.2.2
Cost
Savings
to
Government
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3­
4
3.3
TOTAL
COST
SAVINGS
ESTIMATES
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3­
5
CHAPTER
4
­­
INFORMATION
IMPACT
ANALYSIS
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4­
1
4.1
CALCULATION
OF
ANNUAL
REPORTING
BURDEN
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.
4­
2
4.1.1
Reports
to
the
National
Response
Center
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4­
2
4.1.2
Reports
to
SERCs
and
LEPCs
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4­
2
4.1.3
Reporting
Burden
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.
4­
2
4.2
CALCULATION
OF
ANNUAL
RECORDKEEPING
BURDEN
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.
4­
2
4.2.1
Recordkeeping
Related
to
NRC
Reports
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.
4­
2
4.2.2
Recordkeeping
Related
to
State
and
Local
Reports
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.
4­
3
4.2.3
Recordkeeping
Burden
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.
4­
3
4.3
TOTAL
ANNUAL
REPORTING/
RECORDKEEPING
BURDEN
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4­
3
CHAPTER
5
­­
PUBLIC
HEALTH
AND
WELFARE
AND
ENVIRONMENTAL
EFFECTS
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.
5­
1
OSWER
No.
9360.7­
16D
1
See
U.
S.
Environmental
Protection
Agency,
"
Regulatory
Analysis
of
Reportable
Quantity
Adjustments
Under
Sections
102
and
103
of
the
Comprehensive
Environmental
Response,
Compensation,
and
Liability
Act,"
Volume
I,
March
1985.

2
This
rulemaking
includes
proposed
RQ
adjustments
not
only
for
individual
carbamates,
but
also
for
thiocarbamates,
dithiocarbamates,
carbamoyl
oximes,
and
several
other
individual
substances
that
are
closely
related
to
carbamate
production
and/
or
waste
generation.
These
substances
were
designated
as
CERCLA
hazardous
substances
with
statutory
one­
pound
RQs
in
a
February
9,
1995
final
rule
(
60
FR
7824).
For
purposes
of
simplicity,
however,
the
remainder
of
this
EIA
refers
to
all
28
individual
substances
for
which
RQ
adjustments
are
being
proposed
as
"
carbamates,"
and
to
the
five
waste
streams
as
"
carbamate­
related"
waste
streams.
CHAPTER
1
INTRODUCTION
The
purpose
of
this
economic
impact
analysis
(
EIA)
is
to
estimate
the
cost
savings
associated
with
a
proposed
rule
to
adjust
reportable
quantities
(
RQs)
for
substances
listed
as
hazardous
substances
under
the
Comprehensive
Environmental
Response,
Compensation,
and
Liability
Act
of
1980
(
CERCLA),
and
as
hazardous
wastes
under
section
3001
of
the
Resource
Conservation
and
Recovery
Act
(
RCRA).
This
EIA
is
Volume
VII
in
a
series
of
EIAs
that
have
evaluated
the
economic
impact
of
adjusting
RQs
for
CERCLA
hazardous
substances;
the
first
volume
of
this
series
supported
the
initial
final
rule
(
50
FR
13456,
April
4,
1985)
to
adjust
RQs
for
CERCLA
hazardous
substances.
1
CERCLA
section
101(
14)
defines
the
term
"
hazardous
substance"
by
reference
to
lists
of
substances
under
various
environmental
statutes,
including
RCRA.
Thus,
all
RCRA
hazardous
wastes
are
automatically
CERCLA
hazardous
substances.
In
addition,
CERCLA
assigns
an
initial
or
"
statutory"
onepound
RQ
to
newly
listed
hazardous
substances.
The
Administrator
of
the
U.
S.
Environmental
Protection
Agency
(
EPA
or
"
the
Agency")
is
authorized
to
establish
an
RQ
for
each
CERCLA
hazardous
substance
which,
when
released
into
the
environment,
triggers
immediate
reporting
to
the
Federal
government.
The
process
of
adjusting
RQs
by
regulation
indicates
a
level
of
concern
about
a
given
substance
sufficient
to
require
a
report
to
the
National
Response
Center
(
NRC)
in
the
event
of
a
release
of
an
RQ
or
more.

A
February
9,
1995
(
60
FR
7824)
rule
finalized
the
listing
of
39
carbamate­
related
substances
as
RCRA
hazardous
wastes.
Thirty­
three
of
these
substances
(
28
individual
substances
and
five
hazardous
waste
streams)
were
not
already
CERCLA
hazardous
substances
and
thus
received
a
statutory
RQ
of
one
pound.
EPA
is
publishing
a
Notice
of
Proposed
Rulemaking
(
NPRM)
to
revise
the
regulatory
list
of
CERCLA
hazardous
substances
at
40
CFR
302.4
to
adjust
the
statutory
one­
pound
RQs
for
these
28
individual
carbamates
and
five
carbamate­
related
hazardous
waste
streams.
2
For
11
of
the
substances,
the
Agency
is
proposing
to
make
conforming
changes
to
the
Emergency
Planning
and
Community
Right­
to
Know
Act
(
EPCRA)
tables
of
extremely
hazardous
substances
(
EHSs)
at
40
CFR
part
355.

In
addition,
EPA
is
proposing
to
adjust
the
one­
pound
statutory
RQ
of
another
hazardous
waste
stream,
K178,
which
is
unrelated
to
the
carbamates
addressed
in
this
rule.

Background
OSWER
No.
9360.7­
16D
1­
2
On
November
8,
1984,
Congress
amended
RCRA
by
enacting
the
Hazardous
and
Solid
Waste
Amendments
of
1984
(
HSWA).
In
one
HSWA
provision
­­
a
newly
added
RCRA
section
3001(
e)(
2)
­­
Congress
directed
EPA
to
determine
whether
several
wastes,
including
wastes
generated
from
the
production
of
carbamates,
should
be
listed
as
RCRA
hazardous
wastes.
Carbamates
are
widely
used
as
active
ingredients
in
pesticides,
herbicides,
insecticides,
and
fungicides,
and
in
the
production
of
synthetic
rubber.
Before
Congress
enacted
HSWA
in
1984,
EPA
already
had
regulated
several
carbamate
substances
under
RCRA,
CERCLA,
and
other
statutes.

Based
on
EPA's
evaluation
of
the
carbamate
production
wastes,
the
Agency
developed
a
rule,
published
on
March
1,
1994
(
59
FR
9808),
proposing
to
list
80
carbamate­
related
substances
as
RCRA
hazardous
wastes.
These
80
substances
included:
(
1)
70
individual
carbamates;
(
2)
six
carbamate­
related
waste
streams;
and
(
3)
four
categories
of
carbamate
substances.
Subsequently,
in
a
February
9,
1995
rule
(
60
FR
7824),
the
Agency
finalized
the
listing
of
64
of
these
80
substances
as
RCRA
hazardous
wastes,
deferring
action
on
12
individual
substances
and
the
four
categories
of
carbamates
included
in
the
proposed
rule.
Thus,
EPA
listed
a
total
of
58
individual
carbamates
and
six
carbamate­
related
hazardous
waste
streams
as
RCRA
hazardous
wastes
in
the
February
9,
1995
final
rule.

On
November
1,
1996,
the
Court
of
Appeals
(
D.
C.
Circuit)
ruled
that
EPA
failed
to
follow
proper
rulemaking
procedures
in
making
some
of
the
carbamate
listing
determinations
in
the
February
9,
1995
rule.
Dithiocarbamate
Task
Force
v.
EPA,
98
F.
3d
1394
(
D.
C.
Cir.
1996).
The
court
vacated
the
RCRA
hazardous
waste
and
CERCLA
hazardous
substance
listings
for
24
of
the
58
individual
carbamates
and
one
of
the
six
carbamate­
related
waste
streams
(
K160)
included
in
that
rule.
In
addition,
the
court
vacated
three
other
carbamate­
related
waste
streams
(
K156,
K157,
and
K158)
only
to
the
extent
that
they
applied
to
the
chemical,
3­
iodo­
2­
propynyl
n­
butylcarbamate.
Under
the
court
decision,
the
vacated
carbamate
listings
are
to
be
treated
as
though
they
had
never
been
in
effect.

To
clarify
the
legal
status
of
the
vacated
listings
for
the
regulated
community
and
the
public,
EPA,
in
a
June
17,
1997
final
rule
(
62
FR
32974),
amended
the
lists
of
RCRA
hazardous
wastes
and
CERCLA
hazardous
substances
(
in
40
CFR
parts
261
and
302
respectively)
to
remove
the
entries
for
the
24
individual
carbamates
and
one
carbamate­
related
waste
stream
(
K160)
that
were
vacated
by
the
court.
The
Agency
also
revised
the
entries
for
K156,
K157,
and
K158
to
indicate
that
they
do
not
apply
to
3­
iodo­
2­
propynyl
n­
butylcarbamate.

The
court's
ruling,
however,
did
not
change
the
February
9,
1995
listing
of
the
34
remaining
individual
carbamates
as
RCRA
hazardous
wastes;
that
listing
remains
in
effect.
Independently
from
the
February
9,
1995
rule,
EPA
already
has
added
six
of
these
34
individual
carbamates
to
the
CERCLA
list
of
hazardous
substances
in
Table
302.4
of
40
CFR
302.4,
and
developed
adjusted
RQs
for
these
substances.
These
six
substances
are:
carbaryl
(
Chemical
Abstracts
Service
Registry
Number
(
CASRN)
63­
25­
2);
carbofuran
(
CASRN
1563­
66­
2);
mercaptodimethur
(
CASRN
2032­
65­
7);
mexacarbate
(
CASRN
315­
18­
4);
triethylamine
(
CASRN
121­
44­
8);
and
propoxur
(
CASRN
114­
26­
1).

Upon
the
effective
date
of
the
February
9,
1995
final
rule,
the
28
remaining
individual
carbamates
and
five
carbamate­
related
hazardous
waste
streams
became
CERCLA
hazardous
substances
with
onepound
statutory
RQs.
The
Agency
is
proposing
in
this
rule
to
adjust
the
statutory
one­
pound
RQs
for
these
28
substances
and
five
waste
streams.
OSWER
No.
9360.7­
16D
1­
3
Eleven
of
the
individual
substances
with
proposed
RQ
adjustments
are
also
EPCRA
section
302
EHSs
(
for
the
names
of
these
11
substances,
see
proposed
revisions
to
Appendices
A
and
B
of
40
CFR
part
355,
included
at
the
end
of
the
proposed
rule).
In
an
August
30,
1989
proposal
(
54
FR
35988),
the
Agency
proposed
to
adjust
the
RQs
for
all
the
EPCRA
EHSs.
On
May
7,
1996
(
61
FR
20473),
EPA
finalized
adjustments
to
the
RQs
for
all
the
EHSs,
except
the
11
included
in
this
rule.
EPA
is
reproposing
adjusted
RQs
for
these
11
substances
today
for
reporting
both
under
CERCLA
and
EPCRA.

In
addition,
EPA
is
proposing
to
adjust
the
one­
pound
statutory
RQ
of
another
hazardous
waste
stream,
K178,
which
is
unrelated
to
the
carbamates
addressed
in
this
rule
(
see
Section
1.5
of
this
Chapter
for
information
regarding
K178).

The
proposed
RQ
adjustments
for
the
28
carbamates
and
five
carbamate­
related
hazardous
waste
streams
are
expected
to
result
in
a
decrease
in
costs
to
the
regulated
community
of
release­
reporting
and
recordkeeping,
and
a
decrease
in
costs
to
the
government
of
processing
notifications.
This
reduction
in
costs
(
i.
e.,
"
cost
savings")
occurs
because
all
but
two
of
the
carbamate
substances
are
proposed
to
have
their
RQs
adjusted
upward,
which
results
in
a
lower
reporting
and
recordkeeping
burden
for
the
regulated
community
and
government
officials.
The
overall
cost
savings
attributable
to
the
proposed
RQ
adjustments
for
the
carbamates
and
carbamate­
related
waste
streams
in
this
rule
is
estimated
to
be
approximately
$
90,640.
Although
additional
cost
savings
may
be
expected
to
result
from
the
Agency's
proposal
to
raise
the
RQ
for
K178,
EPA
has
not
included
an
estimate
of
the
cost
savings
related
to
K178
in
this
EIA
(
as
described
in
Section
1.5).

The
estimated
net
cost
savings
of
$
90,640
reflects
an
"
opportunity
cost"
savings,
because
industry
and
government
are
able
to
devote
existing
labor
resources
to
additional
tasks
that
they
no
longer
need
to
spend
on
the
reporting
and
recordkeeping
associated
with
releases
below
the
proposed
adjusted
RQ
levels.
This
EIA
recognizes
that
industry
and
government
entities
may
not
realize
an
accounting
cost
savings,
because
it
is
assumed
that
labor
resources
are
fixed
with
regard
to
this
rule.
Consequently,
the
term
"
cost
savings"
as
it
is
used
in
this
EIA
reflects
the
value
of
additional
labor
services
that
existing
work
force
personnel
can
perform.
Other
potential
cost
savings
associated
with
the
proposed
RQ
adjustments
(
e.
g.,
costs
to
the
regulated
community
of
response
and
litigation
and
costs
incurred
by
government
to
monitor
cleanup
activities,
conduct
removals,
or
undertake
legal
action
against
the
responsible
party)
are
not
quantified,
but
are
evaluated
and
discussed
qualitatively
in
Chapter
2.
Similarly,
the
potential
effects
of
the
proposed
RQ
adjustments
on
public
health
and
welfare
and
the
environment
are
discussed
qualitatively
in
Chapter
5.

The
remainder
of
this
chapter
contains:
(
1)
a
description
of
the
statutory
authority
for
adjusting
RQs
for
CERCLA
hazardous
substances;
(
2)
a
summary
of
the
methodology
used
to
adjust
RQs;
(
3)
a
brief
discussion
of
RCRA
hazardous
wastes
and
their
characteristics;
(
4)
a
brief
description
of
carbamates
and
their
characteristics;
(
5)
background
information
on
the
proposed
RQ
adjustment
for
hazardous
waste
stream
K178;
and
(
6)
an
overview
of
the
organization
of
this
EIA.

1.1
STATUTORY
AUTHORITY
1.1.1
Relevant
CERCLA
Provisions
The
statutory
provisions
that
are
relevant
to
EPA's
proposed
rule
to
adjust
RQs
are
described
below.
CERCLA
established
broad
Federal
authority
to
respond
to
releases
or
threats
of
releases
of
OSWER
No.
9360.7­
16D
1­
4
hazardous
substances
from
vessels
and
facilities.
CERCLA
section
101(
14)
defines
"
hazardous
substance"
as:


Any
hazardous
waste
having
the
characteristics
identified
under
or
listed
pursuant
to
section
3001
of
RCRA;


Any
substance
designated
pursuant
to
CERCLA
section
102(
a);


Any
substance
designated
pursuant
to
section
311
of
the
Clean
Water
Act
(
CWA);


Any
toxic
pollutant
listed
under
CWA
section
307(
a);


Any
hazardous
air
pollutant
listed
under
section
112
of
the
Clean
Air
Act;
and

Any
imminently
hazardous
chemical
or
mixture
for
which
EPA
has
taken
action
pursuant
to
section
7
of
the
Toxic
Substances
Control
Act.

Section
102(
a)
of
CERCLA
authorizes
the
EPA
Administrator
to
promulgate
regulations
establishing
the
quantity
of
a
hazardous
substance
that,
when
released
into
the
environment,
must
be
reported
to
the
NRC.
Under
CERCLA
section
102(
b),
the
RQ
remains
at
the
statutory
one­
pound
level
(
or
at
the
level
established
under
the
CWA)
unless
and
until
EPA
establishes
an
adjusted
RQ
through
regulation.
CERCLA
section
103(
a)
requires
the
"
person
in
charge"
of
a
vessel
or
facility
to
notify
the
NRC
immediately,
as
soon
as
the
person
has
knowledge
that
an
RQ
or
more
of
a
hazardous
substance
has
been
released
from
the
vessel
or
facility.
The
remaining
portion
of
this
EIA
uses
the
term
"
facility"
when
referring
to
emission
sources
of
carbamates
and
carbamate­
related
hazardous
waste
streams.
The
term
is
used
broadly
and
is
not
intended
to
exclude
reporting
and
responses
to
releases
of
hazardous
substances
from
vessels.

1.1.2
Relevant
EPCRA
Provisions
In
addition
to
the
Federal
reporting
requirements
established
by
CERCLA
section
103,
EPCRA
section
304
requires
reporting
to
State
emergency
response
commissions
(
SERCs)
and
local
emergency
planning
committees
(
LEPCs)
for
releases
of
CERCLA
hazardous
substances
and
EPCRA
EHSs.
Section
304
of
EPCRA
requires
that
owners
or
operators
of
certain
facilities
immediately
report
releases
of
CERCLA
hazardous
substances
and
EPCRA
EHSs
that
equal
or
exceed
their
RQs
to
the
SERC
of
any
State
likely
to
be
affected
by
the
release
and
to
the
community
emergency
coordinator
for
the
LEPC
of
any
area
likely
to
be
affected
by
the
release.
If
the
release
is
related
to
the
transportation
of
the
substance,
dialing
the
911
emergency
telephone
number
or,
in
its
absence,
calling
the
operator
is
acceptable.
As
soon
as
practicable
after
this
initial
notice,
a
written
follow­
up
emergency
notice
to
the
appropriate
SERC
and
LEPC
is
required
under
EPCRA
section
304(
c)
for
non­
transportation­
related
releases.

1.2
REPORTABLE
QUANTITY
ADJUSTMENT
METHODOLOGY
The
Agency
has
wide
discretion
in
adjusting
the
statutory
RQs
for
hazardous
substances
under
CERCLA.
The
methodology
for
adjusting
RQs
begins
with
an
evaluation
of
the
intrinsic
physical,
chemical,
and
toxicological
properties
of
each
hazardous
substance.
The
intrinsic
properties
­­
called
OSWER
No.
9360.7­
16D
3
The
RQ
levels
for
radionuclides
are
measured
in
units
of
curies,
from
0.001
curies
to
1,000
curies.

1­
5
"
primary
criteria"
­­
are
aquatic
toxicity,
mammalian
toxicity
(
i.
e.,
oral,
dermal,
and
inhalation),
ignitability,
reactivity,
chronic
toxicity,
and
potential
carcinogenicity.

The
Agency
ranks
hazardous
substances
for
each
intrinsic
property
on
a
scale
consisting
of
a
specific
range
of
values
associated
with
one
of
five
RQ
levels
(
1,
10,
100,
1,000,
and
5,000
pounds),
which
was
originally
established
under
CWA
section
311.3
For
hazardous
substances
evaluated
for
potential
carcinogenicity,
each
substance
is
assigned
a
hazard
ranking
of
"
high,"
"
medium,"
or
"
low"
based
on
its
weight­
of­
evidence
and
potency
assessments.
These
hazard
rankings
correspond
to
RQ
levels
of
1,
10,
and
100
pounds.
Each
hazardous
substance
evaluated
under
the
various
primary
criteria
is
assigned
several
tentative
RQ
values
based
on
its
particular
intrinsic
properties.
The
lowest
of
the
tentative
RQs
becomes
the
"
primary
criteria
RQ"
for
that
substance.

After
the
primary
criteria
RQs
are
assigned,
substances
are
further
evaluated
for
their
susceptibility
to
certain
degradative
processes
that
are
used
as
secondary
RQ
adjustment
criteria.
These
natural
degradative
processes
are
biodegradation,
hydrolysis,
and
photolysis
(
BHP).
If
a
hazardous
substance
degrades
relatively
rapidly
to
a
less
hazardous
form
by
one
or
more
of
the
BHP
processes,
its
primary
criteria
RQ
is
raised
one
level.
Conversely,
if
a
substance
degrades
to
a
more
hazardous
product
after
its
release,
the
original
substance
is
assigned
an
RQ
equal
to
the
RQ
for
the
more
hazardous
substance.

The
standard
RQ
adjustment
methodology
for
mixtures
of
hazardous
substances,
used
to
adjust
the
RQs
for
RCRA
hazardous
waste
streams,
differs
somewhat
from
the
methodology
applied
to
individual
hazardous
substances.
The
procedure
for
assigning
RQs
is
based
on
an
analysis
of
the
hazardous
constituents
of
the
wastes.
The
constituents
of
each
RCRA
hazardous
waste
are
identified
in
40
CFR
part
261,
Appendix
VII.
EPA
determines
an
RQ
for
each
constituent
within
the
waste
stream,
and
establishes
the
lowest
RQ
value
of
these
constituents
as
the
adjusted
RQ
for
the
waste
stream.

EPA
is
proposing
to
raise
the
statutory
one­
pound
RQs
for
27
of
the
28
individual
carbamates
and
four
of
the
five
carbamate­
related
hazardous
waste
streams.
In
addition,
EPA
is
proposing
to
raise
the
statutory
one­
pound
RQ
for
K178,
as
discussed
further
in
Section
1.5
of
this
EIA.
The
Agency
is
proposing
to
retain
one­
pound
RQs
for
the
remaining
individual
carbamate
and
carbamate­
related
hazardous
waste
stream.

1.3
RCRA
HAZARDOUS
WASTES
AND
THEIR
CHARACTERISTICS
The
term
"
hazardous
waste"
refers
to
industrial
byproducts
determined
to
be
hazardous
under
RCRA
section
3001.
These
wastes,
unless
properly
disposed,
can
contaminate
surrounding
land
and
water.
The
statute
defines
hazardous
waste
as
any
waste
or
combination
of
wastes
that
because
of
its
quantity,
concentration,
or
physical,
chemical,
or
infectious
characteristics
may
cause
or
significantly
contribute
to
an
increase
in
mortality
or
an
increase
in
serious
irreversible,
or
incapacitating
reversible,
illness;
or
pose
a
substantial
present
or
potential
hazard
to
human
health
or
the
environment
when
improperly
treated,
stored,
transported,
or
disposed
of,
or
otherwise
managed.
In
the
RCRA
regulations
at
40
CFR
part
261,
subpart
D,
EPA
specifically
lists
over
400
hazardous
waste
constituents
of
concern.
OSWER
No.
9360.7­
16D
4
See
U.
S.
Environmental
Protection
Agency,
"
Engineering
Analysis
of
the
Production
of
Carbamates,
Non­
CBI
Version,"
January
6,
1995.

1­
6
If
a
waste
is
identified
as
hazardous,
it
is
assigned
a
RCRA
Hazardous
Waste
Number.
This
number
must
be
used
in
complying
with
the
notification
requirements
of
section
3010
of
RCRA.
K­
wastes
are
waste
streams
from
specific
sources;
P­
wastes
are
acute
hazardous
wastes
from
commercial
chemical
products,
manufacturing
chemical
intermediates,
or
off­
specification
commercial
chemical
products;
and
U­
wastes
are
toxic
wastes
from
commercial
chemical
products,
manufacturing
chemical
intermediates,
or
off­
specification
commercial
chemical
products.
The
28
individual
substances
whose
RQs
are
proposed
to
be
adjusted
are
P­
and
U­
wastes,
and
the
six
hazardous
waste
streams
(
including
K178)
are
K­
wastes.

1.4
CARBAMATES
AND
THEIR
CHARACTERISTICS
The
domestic
carbamate
manufacturing
industry
produces
64
chemical
products
consisting
of
four
major
segments:
(
1)
carbamates;
(
2)
carbamoyl
oximes;
(
3)
thiocarbamates;
and
(
4)
dithiocarbamates.
Carbamate
products
are
widely
used
as
active
ingredients
in
pesticides,
herbicides,
insecticides,
and
fungicides.
Dithiocarbamates
also
are
manufactured
for
use
as
rubber
accelerators
in
the
rubber
processing
industry.
Carbamate
products
are
also
used
in
the
wood
preserving
and
textiles
industries.
The
carbamate
industry
in
the
United
States
is
composed
of
20
manufacturers
at
24
facilities.
The
majority
of
the
carbamate
product
manufacturers
are
located
in
the
eastern
half
of
the
United
States;
with
only
four
facilities
located
west
of
the
Mississippi
River.
The
total
domestic
production
of
carbamates
in
1990
was
approximately
112,000
metric
tons.
Approximately
841,000
metric
tons
of
waste
are
generated
as
part
of
the
manufacturing
process.
4
1.5
PROPOSED
RQ
ADJUSTMENT
FOR
K178
As
noted
in
Section
1.2
above,
the
Agency's
standard
methodology
for
adjusting
the
RQs
for
RCRA
waste
streams
is
based
on
an
analysis
of
the
hazardous
constituents
of
each
waste,
as
identified
in
40
CFR
Part
261,
Appendix
VII.
We
determine
an
RQ
for
each
constituent
and
establish
the
lowest
RQ
value
of
these
constituents
as
the
adjusted
RQ
for
the
waste
stream.
When
there
are
hazardous
constituents
identified
for
a
waste
stream
that
are
not
individual
CERCLA
hazardous
substances,
EPA
develops
an
RQ
for
these
constituents
in
order
to
assign
an
appropriate
RQ
to
the
waste
stream
(
see
48
FR
23565,
May
25,
1983).
In
other
words,
we
derive
the
RQ
for
a
RCRA
waste
stream
based
on
the
lowest
RQ
of
all
of
the
hazardous
constituents
identified
for
that
waste
in
Appendix
VII
of
40
CFR
Part
261,
regardless
of
whether
the
constituents
are
CERCLA
hazardous
substances.

On
September
14,
2000,
EPA
published
a
proposed
rule
to
list
three
waste
streams
from
inorganic
chemical
manufacturing
processes
as
RCRA
hazardous
wastes
in
40
CFR
261.32
and
as
CERCLA
hazardous
substances
in
40
CFR
302.4
(
65
FR
55684).
In
that
rule,
we
proposed
to
adjust
the
one­
pound
statutory
RQs
for
two
of
the
three
waste
streams,
K176
and
K177.
EPA
identified
two
hazardous
constituents
for
the
third
waste
stream,
K178
(
nonwastewaters
from
the
production
of
titanium
dioxide
by
the
chloride­
ilmenite
process).
The
two
hazardous
constituents
identified
in
the
rule
for
K178
were:
thallium,
which
is
a
CERCLA
hazardous
substance
with
a
1,000­
pound
RQ;
and
manganese,
which
does
not
appear
on
the
CERCLA
hazardous
substance
list
in
40
CFR
302.4
and,
therefore,
has
not
been
assigned
an
RQ.
Because
EPA
had
not
yet
developed
an
RQ
for
manganese
at
that
time,
we
did
not
propose
to
adjust
the
RQ
for
K178
in
the
September
14,
2000
proposed
rule.
OSWER
No.
9360.7­
16D
1­
7
Numerous
commenters
to
the
proposed
rule
objected
to
using
manganese
as
a
basis
for
listing
K178
wastes,
citing
potential
adverse
impacts
to
many
industries.
Although
EPA
continues
to
believe
that
manganese
poses
significant
issues
that
ultimately
should
be
resolved,
the
court­
ordered
schedule
for
the
hazardous
waste
listings
provided
no
flexibility
to
address
those
issues
fully
before
finalizing
the
listings.
For
that
reason,
in
the
final
rule,
EPA
deferred
final
action
on
adding
manganese
to
Appendix
VII
of
40
CFR
Part
261
as
a
basis
for
listing
K178
wastes
(
66
FR
58258;
November
20,
2001).
The
final
hazardous
waste
listing
for
K178
is
based
solely
on
thallium.
As
a
result,
we
are
proposing
an
RQ
of
1,000
pounds
for
the
K178
waste
stream,
based
on
the
constituent
RQ
for
thallium,
the
sole
hazardous
constituent
identified
for
the
waste
stream.

As
noted
in
Section
1.2
above,
the
proposed
RQ
adjustment
for
K178
is
expected
to
result
in
a
decrease
in
costs
to
the
regulated
community
and
the
government.
This
cost
savings
occurs
because
EPA
is
proposing
to
raise
the
one­
pound
statutory
RQ
for
K178
to
1000
pounds,
which
results
in
lower
reporting
and
recordkeeping
burdens
for
the
regulated
community
and
government
officials.
Please
note,
however,
that
EPA
has
not
included
an
estimate
of
the
cost
savings
associated
with
the
K178
RQ
adjustment
in
today's
EIA.
Thus,
the
estimated
net
cost
savings
of
$
90,640
for
the
RQ
adjustments
included
in
today's
rule
may
be
conservative.
In
other
words,
the
cost
savings
is
expected
to
be
higher
than
$
90,640
because
this
value
does
not
include
the
additional
cost
savings
expected
from
the
K178
RQ
adjustment.
The
remainder
of
this
document
focuses
only
on
the
net
cost
savings
associated
with
the
RQ
adjustments
for
the
28
individual
carbamates
and
the
five
carbamate­
related
waste
streams.

1.6
ORGANIZATION
OF
THIS
EIA
The
remainder
of
this
EIA
is
organized
as
follows:


Chapter
2
provides
estimates
of
the
unit
costs
to
the
regulated
community
and
the
government
resulting
from
CERCLA
and
EPCRA
notification­
related
effects.


Chapter
3
provides
estimates
of
the
potential
cost
savings
to
the
regulated
community
and
the
government
of
the
RQ
adjustments
for
the
33
CERCLA
hazardous
substances.


Chapter
4
presents
an
estimate
of
the
effects
of
the
RQ
adjustments
on
the
reporting
and
recordkeeping
burden.


Chapter
5
provides
a
qualitative
summary
of
the
potential
effects
of
the
RQ
adjustments
on
public
health
and
welfare
and
the
environment.
OSWER
No.
9360.7­
16D
CHAPTER
2
UNIT
COSTS
TO
THE
REGULATED
COMMUNITY
AND
GOVERNMENT
This
chapter
provides
the
estimated
unit
costs
associated
with
EPA's
proposed
rule
to
adjust
the
statutory
one­
pound
RQs
for
28
carbamates
and
five
carbamate­
related
hazardous
waste
streams.
This
chapter
identifies
the
categories
of
actions
performed
by
the
regulated
community
and
government
officials
for
each
reportable
release
of
a
CERCLA
hazardous
substance.
For
the
regulated
community,
these
actions
include
notification,
recordkeeping,
response,
and
litigation.
For
government
officials,
such
actions
include
notification
processing
and
initial
evaluation,
cleanup
monitoring
activities,
field
response
actions,
and
enforcement/
cost
recovery
actions.
The
unit
costs
of
these
actions
are
based
on
the
amount
of
resources
that
are
used
in
performing
"
one
unit"
of
the
action.
This
chapter
calculates,
where
possible,
the
unit
costs
associated
with
each
category
of
action.
These
unit
costs
are
then
used
in
Chapter
3
to
estimate
the
total
cost
savings
attributable
to
this
rule.

2.1
METHODOLOGY
Regulations
produce
economic
effects
only
if
they
induce
actions.
The
decreased
actions
produced
as
a
result
of
upward
RQ
adjustments
extend
beyond
the
reductions
in
the
required
telephone
notification
of
releases
to
include
reduced
government
and
industry
time
spent
on
recordkeeping.
The
effects
of
all
these
actions
taken
together
can
be
categorized
as
the
"
cost
savings"
of
the
proposed
RQ
adjustment
rule.
Conversely,
downward
RQ
adjustments
would
produce
increases
in
these
same
actions
and
therefore
result
in
additional
costs.

To
estimate
the
cost
savings
of
this
proposed
rulemaking,
this
analysis
examines
the
"
cost
savings"
resulting
from
the
upward
RQ
adjustments
for
the
carbamates
and
carbamate­
related
hazardous
waste
streams.
This
evaluation
identifies
the
categories
of
actions
that
might
occur
for
each
reportable
release;
then,
where
possible,
estimates
the
unit
costs
associated
with
each
category
of
action;
and
finally,
computes
the
number
of
times
each
category
of
action
is
reduced
as
a
result
of
RQ
adjustments.
The
cost
savings
equals
the
difference
between
the
total
costs
of
reporting
releases
at
the
statutory
RQ
and
the
cost
of
reporting
releases
at
the
proposed
adjusted
RQ.

2.2
ACTIONS
ASSOCIATED
WITH
REPORTING
AND
PROCESSING
A
RELEASE
This
section
describes
actions
taken
by
the
regulated
community
and
government
to
respond
to
a
release.
Not
all
of
these
actions
will
be
performed
for
every
release.
Although
notification
of
releases
of
CERCLA
hazardous
substances
in
quantities
equal
to
or
greater
than
their
RQ
is
required
by
regulation,
several
actions
such
as
litigation,
monitoring
field
response
activities,
and
conducting
government
field
response
actions
may
not
always
be
necessary.

2.2.1
Actions
Performed
by
the
Regulated
Community
Actions
that
may
be
taken
by
the
regulated
community
when
a
release
occurs
are
divided
into
four
categories:
(
1)
notification;
(
2)
recordkeeping;
(
3)
response;
and
(
4)
possible
litigation
to
contest
enforcement
actions.
Notification
is
caused
directly
by
CERCLA
section
103
and
EPCRA
section
304
OSWER
No.
9360.7­
16D
2­
2
requirements
to
report
a
release.
Recordkeeping,
response,
and
possible
litigation
are
caused
only
indirectly
by
the
requirements
to
report
a
release.

Notification
by
a
responsible
party
of
a
reportable
release
includes
reporting
to
the
NRC,
as
required
by
CERCLA
section
103,
and
to
the
relevant
SERCs
and
LEPCs,
as
required
by
EPCRA
section
304.
Notification
involves
more
than
just
the
time
spent
by
a
facility
employee
in
a
telephone
conversation
with
the
response
authorities.
Notification
also
includes
the
time
spent
by
anyone
at
the
facility
who
might
become
involved
in
communicating
with
the
government
at
the
time
of,
or
subsequent
to,
the
release.
Depending
on
the
size
of
the
organization
responsible
for
the
release,
the
amount
released,
and
the
substance
released,
the
following
personnel
might
spend
time
communicating
with
the
NRC,
SERC,
and
LEPC:
foreman,
plant
manager,
plant
environmental
control
specialist,
plant
safety
specialist,
and
attorneys.

Recordkeeping
may
be
associated
with
notification.
Although
neither
CERCLA
nor
EPCRA
requires
that
records
of
releases
be
kept,
regulated
parties
often
keep
a
log
of
calls
made
to
government
authorities.
Such
a
log
would
be
useful
for
managers
in
establishing
that
the
notification
requirements
of
CERCLA
section
103
and
EPCRA
section
304
have
been
met
and
in
preparing
the
follow­
up
written
report
to
SERCs
and
LEPCs,
as
required
by
EPCRA
section
304.

Response
includes
any
action
taken
by
the
responsible
party
to
mitigate
the
effects
of
a
release.
Response
actions
may
include:
sampling
the
air,
water,
soil,
and/
or
substance
released;
evaluating
the
necessity
for
evacuation
and
relocation;
containing
the
release;
and
neutralizing
the
hazardous
material
through
techniques
such
as
pumping
out
the
material,
activated
carbon
treatment,
aeration,
or
chemical
treatment.

Litigation
may
be
undertaken
by
a
responsible
party
to
contest
enforcement
attempts
by
the
Federal
government
to
recover
the
costs
of
removal
actions
and/
or
natural
resource
damages
resulting
from
a
release.

2.2.2
Actions
Performed
by
Government
Government
responses
to
a
release
are
divided
into
four
categories.
Each
category
may
be
caused
by
the
occurrence
of
a
reportable
release.

Notification
processing
and
initial
evaluation
includes
communication
with
the
person
who
calls
the
NRC,
SERC,
and
LEPC.
It
also
includes
evaluating
information
provided
by
a
person
about
a
reportable
release,
determining
an
initial
government
response,
and
necessary
recordkeeping.

Monitoring
cleanup
activities
is
comprised
of
two
parts:
off­
scene
monitoring
and
on­
scene
monitoring.

Off­
scene
monitoring
includes
supervising
the
responsible
party's
actions
through
telephone
and
data
monitoring.
In
conducting
off­
scene
monitoring
activities,
the
Agency
may
monitor
the
efforts
of
the
responsible
party
to
neutralize,
clean
up,
or
contain
the
released
substance;
inquire
about
the
results
of
sampling
activities
of
the
air,
water,
soil,
or
other
contaminated
media,
or
the
substance
released;
and
track
the
status
of
evacuation
or
relocation
efforts,
if
applicable.
OSWER
No.
9360.7­
16D
5
These
wage
estimates
are
consistent
with
those
cited
in
the
information
collection
request
analysis
that
addresses
CERCLA
release
reporting,
entitled
Renewal
of
Information
Collection
Request
for
Notification
of
Episodic
Releases
of
Oil
and
Hazardous
Substances
(
ICR
#
1049.09),
February
23,
2001,
pages
11­
12.

2­
3
On­
scene
monitoring
is
conducted
in
person
by
a
government
official.
It
includes
providing
advice
and
assistance
to
the
cleanup
team,
coordinating
communications
among
response
organizations,
providing
information
to
the
public,
and
ensuring
that
the
Agency's
concerns
are
represented
in
determining
the
appropriate
response.

Conducting
field
response
actions
takes
place
when
the
responsible
party
cannot,
or
will
not,
adequately
clean
up
the
hazardous
substance
release,
and
the
release
represents
a
hazard
to
public
health
or
welfare
or
the
environment.
The
government
response
agency
generally
uses
private
contractors
to
clean
up
a
release,
although
most
State
and
local
government
response
teams
have
some
sampling,
monitoring,
containment,
and
safety
equipment
to
address
the
initial
emergency
and
to
oversee
and
assist
the
contractors
in
the
cleanup.

Enforcement/
cost
recovery
actions
take
place
when
the
Federal
government
has
conducted
a
removal
and
litigates
to
recover
the
costs
of
the
removal,
and/
or
natural
resource
damages
from
responsible
parties.

The
next
steps
in
the
analysis
are
to
determine
the
value
and
frequency
of
each
of
these
possible
actions.

2.3
UNIT
COSTS
OF
ACTIONS
PERFORMED
BY
THE
REGULATED
COMMUNITY
This
section
presents
estimates
of
the
unit
costs
associated
with
the
possible
actions
of
the
regulated
community
presented
in
Section
2.2.1.
The
unit
costs
of
the
actions
are
estimated
based
on
the
amount
of
resources
that
are
expended
in
performing
"
one
unit"
of
the
action.
For
example,
the
unit
costs
associated
with
reporting
one
release
are
equivalent
to
the
value
of
the
resources
that
are
consumed
by
performing
that
action.

The
estimated
unit
costs
are
based
on
three
categories
of
industry
labor
and
wage
rates.
These
hourly
wage
rates
are
based
on
salaries
of
employees
in
private
manufacturing
industries
who
have
the
experience
and
skills
necessary
to
perform
these
actions:
5
Managerial:
$
55.34
Technical:
$
40.05
Clerical:
$
26.02
These
rates
reflect
employer
cost
for
employee
compensation
in
the
United
States
as
of
March
2000
and
include
both
employer
costs
for
legally
required
benefits
(
e.
g.,
social
security,
workers'
compensation,
and
unemployment
insurance),
other
important
fringe
benefit
categories
(
e.
g.,
insurance,
paid
leave,
and
retirement
and
savings),
and
overhead
and
general
and
administrative
costs.

The
remainder
of
this
section
presents
the
unit
costs
of
the
actions
performed
by
the
regulated
community.
OSWER
No.
9360.7­
16D
6
For
further
information,
see:
U.
S.
Environmental
Protection
Agency,
Renewal
of
Information
Collection
Request
for
Notification
of
Episodic
Releases
of
Oil
and
Hazardous
Substances
(
ICR
#
1049.09),
February
23,
2001,
pages
10.

2­
4
2.3.1
Notification
to
the
NRC
CERCLA
section
103(
a)
requires
the
person
in
charge
of
a
facility
or
vessel
to
notify
the
NRC
immediately
when
any
hazardous
substance
is
released
in
an
amount
that
equals
or
exceeds
its
RQ.
The
information
that
must
be
provided
to
the
NRC
watchstander
in
the
notification
includes
general
background
information,
such
as
the
location
of
the
incident
and
the
name
and
address
of
the
discharger,
as
well
as
more
detailed
information
about
the
circumstances
surrounding
the
release,
including
the
type
of
material
released,
environmental
media
affected,
and
the
cause
and
source
of
the
release.
Notification
under
CERCLA
section
103(
a)
is
intended
to
ensure
that
Federal
authorities
receive
prompt
notification
of
hazardous
substance
releases
for
which
a
timely
response
may
be
necessary
to
protect
public
health
or
welfare
or
the
environment.

Although
it
is
not
feasible
to
measure
notification
costs
directly,
available
evidence
does
allow
such
costs
to
be
estimated.
Based
on
telephone
conversations
with
facilities
that
reported
releases
of
hazardous
substances
to
the
NRC,
EPA
has
estimated
that
notification
requires
2.0
person­
hours,
including
1.0
hour
of
technical
time
and
1.0
hour
of
managerial
time.
6
This
estimate
includes
the
time
required
to
evaluate
a
release
in
determining
the
appropriateness
of
notifying
the
NRC,
in
addition
to
the
required
time
to
report
the
release.
Because
the
NRC
has
a
toll
free
telephone
number,
there
are
no
other
costs
associated
with
making
the
telephone
call.
Therefore,
unit
costs
associated
with
notification
of
a
release
would
be
approximately
$
95
[($
55.34
x
1.0
hour)
+
($
40.05
x
1.0
hour)].

2.3.2
Notification
to
State
and
Local
Response
Authorities
Upon
release
of
an
RQ
of
a
hazardous
substance,
a
facility
must
immediately
notify
both
the
LEPC
of
any
area
likely
to
be
affected
by
the
release
and
the
SERC
of
any
State
likely
to
be
affected
by
the
release.
Because
the
information
to
be
reported
to
both
organizations
is
similar,
the
cost
elements
and
costing
issues
associated
with
them
will
be
discussed
together.

The
actual
notifications
would
take
the
form
of
telephone
calls
to
the
appropriate
local
committees
and
State
commissions.
For
purposes
of
calculating
notification
costs
to
State
and
local
response
authorities,
the
costs
of
determining
whether
a
release
is
reportable
are
included
in
the
costs
of
notifying
the
NRC
and,
therefore,
are
not
being
included
in
the
calculation
of
State
and
local
notification
costs
to
avoid
double­
counting.
It
is
assumed
that
for
a
member
of
the
managerial
staff
to
contact
the
LEPC,
a
30­
minute
local
call
will
be
required
with
an
associated
labor
cost
of
approximately
$
28
($
55.34
x
0.50
hour).
The
telephone
call
could
last
much
longer
than
30
minutes,
but
it
is
assumed
that
this
additional
time
corresponds
to
the
management
of
the
release
as
opposed
to
the
notification
of
the
release.
Another
30­
minute
telephone
call
(
involving
an
additional
labor
cost
of
$
28)
must
then
be
made
to
the
SERC.
Because
this
call
could
be
a
long­
distance
call,
an
additional
cost
of
$
7
is
estimated
to
be
incurred
for
a
30­
minute
in­
State
call
at
average
long­
distance
business
rates.
Therefore,
the
unit
cost
associated
with
initial
telephone
notification
of
a
release
to
State
and
local
governments
would
be
approximately
$
63
($
28
+
$
28
+
$
7).
OSWER
No.
9360.7­
16D
7
The
estimate
of
a
physician's
wage
rate
was
obtained
from
the
Bureau
of
the
Census,
U.
S.
Department
of
Commerce,
Economic
and
Statistics
Administration,
Statistical
Abstracts
of
the
United
States
­
The
National
Data
Book
­
1996,.
This
wage
rate
also
factored
in
the
Employment
Cost
Index,
Employer
Costs
for
Employee
Compensation,
(
Bureau
of
Labor
Statistics,
U.
S.
Department
of
Labor).

8
For
a
discussion
of
how
the
proportion
of
releases
considered
small
or
large
was
derived,
including
the
effort
of
individual
actions
required
by
notification
to
SERCs
and
LEPCs,
see
U.
S.
Environmental
Protection
Agency,
"
Regulatory
Impact
Analysis
in
Support
of
Rulemaking
Under
Sections
302,
303,
and
304
of
Title
III
of
the
Superfund
Amendments
and
Reauthorization
Act
of
1986,"
April
10,
1987,
pages
H­
9
­
H­
16.

2­
5
It
is
also
necessary
to
estimate
costs
for
the
follow­
up
written
notification
report
by
the
regulated
community
to
the
SERCs
and
LEPCs.
Section
304
of
EPCRA
requires
the
owner
or
operator
of
a
facility
reporting
a
release
to
provide
a
written
follow­
up
emergency
notice
that
updates
the
information
provided
in
the
initial
telephone
notification
and
includes
additional
information
with
respect
to:


Actions
taken
to
respond
to
and
contain
the
release;


Any
known
or
anticipated
acute
or
chronic
health
risks
associated
with
the
release;
and

Advice
regarding
medical
attention
necessary
for
exposed
individuals.

In
estimating
the
cost
of
follow­
up
written
notification,
releases
have
been
divided
into
three
categories:
small
releases,
large
releases,
and
large
releases
resulting
in
injuries
requiring
hospitalization.
For
small
releases,
0.50
hour
of
managerial
time,
2.2
hours
of
technical
time,
and
1.0
hour
of
clerical
time
are
estimated
for
preparing
the
written
notification
for
a
total
cost
of
approximately
$
147
per
release,
which
includes
a
cost
of
$
5
for
certified
postage
to
send
a
copy
of
the
report
to
both
the
SERC
and
LEPC.
For
large
releases,
follow­
up
written
notification
is
estimated
to
require
3.0
hours
of
managerial
time,
3.0
hours
of
technical
time,
and
2.0
hours
of
clerical
time
for
a
total
cost
of
approximately
$
343
per
release,
including
$
5
for
postage.
Large
releases
resulting
in
hospitalization
require
the
same
labor
effort
as
large
releases
without
hospitalization
with
the
addition
of
one
hour
of
physician
effort
regarding
medical
advice
for
exposed
individuals
at
a
cost
of
approximately
$
137.7
The
total
cost
of
written
notification,
including
postage,
for
large
releases
resulting
in
hospitalization
is
approximately
$
480.
A
weighted
average
cost
per
notification
of
approximately
$
160
was
calculated
based
on
the
fraction
of
small
releases
(
94
percent
of
all
releases),
large
releases
without
hospitalization
(
five
percent),
and
large
releases
resulting
in
injuries
requiring
hospitalization
(
one
percent)
[($
147
x
0.94)
+
($
343
x
0.05)
+
($
480
x
0.01)].
8
Burden
hours
for
the
managerial,
technical,
and
clerical
positions,
as
well
as
other
costs,
were
also
estimated
based
on
the
fraction
of
small
releases,
large
releases
without
hospitalization,
and
large
releases
resulting
in
hospitalization.
For
example,
the
weighted
average
managerial
burden
per
notification
is
approximately
0.65
hour
[(
0.50
x
0.94)
+
(
3.0
x
0.05)
+
(
3.0
x
0.01)].

2.3.3
Recordkeeping
Although
CERCLA
and
EPCRA
do
not
require
that
records
of
releases
be
kept,
a
facility
would
probably
maintain
a
log
of
any
calls
made
to
government
organizations.
Such
a
log
would
be
useful
for
managers
in
establishing
that
the
notification
requirements
of
CERCLA
section
103(
a)
and
EPCRA
section
304
have
been
met.
The
log
might
include
a
description
of
the
incident
and
its
cause,
the
NRC
report
number,
a
brief
account
of
any
conversations
with
Federal,
State,
and
local
officials,
and
a
description
of
the
outcome
of
the
incident,
including
any
cleanup
action
taken.
The
burden
associated
with
internal
OSWER
No.
9360.7­
16D
9
Economic
Impact
Analysis
of
Reportable
Quantity
Adjustments
for
the
Hazardous
Air
Pollutants
and
RCRA
Hazardous
Wastes
Added
as
CERCLA
Hazardous
Substances,
Volume
VI,
Office
of
Emergency
and
Remedial
Response,
U.
S.
EPA,
April
1995.

2­
6
recordkeeping
is
estimated
at
1.0
technical
hour
and
1.0
clerical
hour
per
release;
a
ratio
of
0.10
managerial
hour
to
each
hour
of
clerical
time
is
also
assumed.
Therefore,
recordkeeping
is
estimated
to
cost
approximately
$
72
[($
40.05
x
1.0
hour)
+
($
26.02
x
1.0
hour)
+
($
55.34
x
0.10
hour)]
per
release.
To
avoid
double­
counting,
this
analysis
assumes
that
one
record
will
be
kept
of
the
telephone
notification
to
the
NRC,
SERCs,
and
LEPCs.

2.3.4
Response
and
Litigation
To
avoid
overestimating
cost
savings,
this
EIA
does
not
attempt
to
quantify
the
decrease
in
industry
response
costs
or
litigation
costs
as
a
result
of
the
RQ
adjustments.
For
a
discussion
of
unit
costs
of
industry
response
and
litigation,
see
Chapter
2
of
the
analysis
for
hazardous
air
pollutants.
9
Exhibit
2­
1
presents
a
summary
of
the
quantified
unit
costs
incurred
by
the
regulated
community
for
each
carbamate­
related
release.
This
summary
includes
the
costs
to
determine
whether
a
release
is
reportable,
to
notify
the
NRC,
to
notify
SERCs
and
LEPCs,
and
to
record
these
actions.
These
unit
costs
are
used
later
in
the
analysis
to
estimate
the
total
cost
savings
that
the
regulated
community
is
expected
to
experience
as
a
result
of
adjusting
the
RQs
for
the
carbamates
and
carbamate­
related
hazardous
waste
streams.

EXHIBIT
2­
1
ESTIMATED
UNIT
COSTS
OF
ACTIONS
PERFORMED
BY
THE
REGULATED
COMMUNITY
Action
Burden
Hours
Other
Costs1
Unit
Cost2
Manageria
l
$
45.96/
hr
Technical
$
32.70/
hr
Clerical
$
19.89/
hr
NRC
Notification
1.0
1.0
n/
a
n/
a
$
95
LEPC
Notification
0.50
n/
a
n/
a
n/
a
$
28
SERC
Notification
0.50
n/
a
n/
a
$
7
$
35
SERC
and
LEPC
Follow­
up
Notification
0.65
2.2
1.1
$
5
$
160
Recordkeeping
0.10
1.0
1.0
n/
a
$
72
n/
a
=
not
applicable.
1
Includes
overhead
and
medical
costs,
where
applicable.
2
Costs
are
rounded
to
nearest
whole
number.

2.4
UNIT
COSTS
OF
ACTIONS
PERFORMED
BY
THE
FEDERAL
GOVERNMENT
OSWER
No.
9360.7­
16D
10
The
pay
rates
for
the
General
Schedule
(
GS)
for
2001
were
published
by
the
Office
of
Personnel
Management
(
http://
www3.
opm.
gov/
oca/
01tables/
GShrly/
html/
washingt.
htm).
The
GS
levels
used
in
this
analysis
are
for
the
Washington­
Baltimore
locality
pay
area.

11
See
"
Instructions
for
Preparing
Information
Collection
Requests,"
U.
S.
EPA
Office
of
Policy,
Planning
and
Evaluation,
Information
Policy
Branch,
June
1,
1992,
page
30.

2­
7
This
section
estimates
the
burden
to
the
Federal
government
associated
with
the
CERCLA
reporting
requirements.
Federal
government
authorities
are
expected
to
perform
the
following
activities:


Process
notifications;


Monitor
cleanup
activities;


Conduct
field
response
actions;
and

Conduct
enforcement/
cost
recovery
actions.

The
estimated
burden
to
the
Federal
government
of
completing
these
activities
is
based
on
historical
estimates
and
expenditures
by
EPA.
The
compensation
rate
assumed
for
government
employees
is
based
on
the
GS­
12
step
1
hourly
wage
rate
of
$
25.47.10
This
rate
is
adjusted
to
include
the
cost
of
personal
fringe
benefits,
assumed
to
be
60
percent
of
direct
wages.
11
The
compensation
rate
for
a
Federal
government
employee,
therefore,
is
assumed
to
equal
an
hourly
wage
rate
of
$
40.75.

2.4.1
Processing
Notifications
NRC
personnel
are
responsible
for
entering
the
release
information
provided
by
facilities
into
their
data
base,
the
Incident
Reporting
Information
System
(
IRIS).
As
mentioned
previously,
the
information
that
must
be
provided
to
the
NRC
watchstander
in
the
notification
includes
general
background
information,
such
as
the
location
of
the
incident
and
the
name
and
address
of
the
discharger,
as
well
as
more
detailed
information
about
the
circumstances
surrounding
the
release,
including
the
type
of
material
released,
environmental
media
affected,
and
the
cause
and
source
of
the
release.
The
NRC
watchstander,
in
turn,
enters
the
information
into
IRIS
(
the
NRC
application
used
to
store
and
disseminate
incident
data),
which
is
browsed
by
the
NRC
duty
officer
and
then
transmitted
to
the
ERNS
application.
The
data
are
then
loaded
into
the
Emergency
Response
Notification
System
(
ERNS),
a
national
data
base
that
stores
release
information.
These
data
are
available
within
twenty
minutes.
This
allows
ERNS
users
to
begin
the
process
of
working
the
incident
and
updating
the
data
in
a
timely
fashion.

Each
of
the
hazardous
substance
releases
reported
to
the
NRC
must
be
evaluated
by
Federal
authorities.
The
first
step
in
the
evaluation
is
for
the
NRC
to
notify
the
appropriate
Federal
On­
Scene
Coordinator
(
OSC)
by
telephone
that
a
release
has
occurred
and
to
communicate
all
relevant
information
about
the
release,
including
whether
the
release
is
to
air,
soil,
water,
etc.,
the
source
of
the
release,
and
the
type
of
substance
released;
this
communication
must
occur
within
15
minutes
of
the
original
notification.
The
OSC
is
responsible
for
evaluating
the
circumstances
surrounding
the
release
to
determine
whether
government
monitoring
and/
or
a
Federal
response
action
may
be
necessary.
OSWER
No.
9360.7­
16D
12
Economic
Impact
Analysis
of
Reportable
Quantity
Adjustments
for
the
Hazardous
Air
Pollutants
and
RCRA
Hazardous
Wastes
Added
as
CERCLA
Hazardous
Substances,
Volume
VI,
OERR,
U.
S.
EPA,
April
1995.

13
Burden
hours
for
processing
notifications
by
the
SERCs
and
LEPCs
were
obtained
from
U.
S.
Environmental
Protection
Agency,
"
Regulatory
Impact
Analysis
in
Support
of
Rulemaking
Under
Sections
302,
303,
and
304
of
Title
III
of
the
Superfund
Amendments
and
Reauthorization
Act
of
1986,"
April
10,
1987.
This
RIA
did
not
include
any
estimate
of
clerical
hours
for
SERC
burden
hours,
only
for
LEPCs.
For
purposes
of
this
analysis,
it
is
assumed
that
notification
processing
by
SERCs
entails
the
use
of
clerical
hours
and
that
the
time
required
is
equivalent
to
the
time
estimated
for
LEPC
clerical
hours.

2­
8
Federal
government
processing
of
the
telephone
call
consists
of
the
time
necessary
for
the
NRC
to
communicate
with
the
reporting
party,
to
record
the
information
provided
in
the
IRIS
data
base
(
approximately
15
minutes),
and
to
contact
the
predesignated
Federal
OSC
or
other
parties
by
telephone
(
a
maximum
of
30
minutes).
The
release
data
stored
in
IRIS
are
transmitted
electronically
from
the
NRC
to
the
ERNS
application
(
ERNS
data
base).
This
final
activity
may
require
another
15
minutes.
The
unit
cost
associated
with
processing
the
initial
telephone
call
is
estimated
to
be
approximately
$
41
(
1.0
hour
x
$
40.75).

2.4.2
Other
Activities
This
EIA
does
not
attempt
to
quantify
the
decrease
in
costs
for
other
government
activities
(
i.
e.,
monitoring
cleanup
activities,
conducting
field
response
actions,
or
conducting
enforcement/
cost
recovery
actions)
as
a
result
of
the
RQ
adjustments,
because
the
level
of
activity
associated
with
each
reported
release
is
subject
to
great
variability
dependent
on
the
unique
characteristics
of
each
release.
Excluding
these
activities
from
the
remainder
of
this
analysis
will
tend
to
avoid
overestimating
cost
savings
realized
by
the
Federal
government
as
a
result
of
this
rulemaking.
For
a
discussion
of
the
previous
assumptions
used
concerning
the
unit
costs
of
monitoring
activities,
response
actions,
and
enforcement/
cost
recovery
actions,
see
Chapter
2
of
the
analysis
for
hazardous
air
pollutants.
12
2.5
UNIT
COSTS
OF
ACTIONS
PERFORMED
BY
STATE
AND
LOCAL
GOVERNMENT
This
section
estimates
the
burden
to
State
and
local
governments
associated
with
the
EPCRA
section
304
requirement
for
owners
and
operators
of
facilities
to
report
releases
of
CERCLA
hazardous
substances
to
the
SERC
and
LEPC.
Activities
performed
by
State
and
local
government
authorities
include
the
collection
and
storage
of
information
received
from
the
immediate
release
notification.
Such
information
includes
the
affected
area,
the
chemical
name,
the
quantity
released,
the
time
and
duration
of
the
release,
the
medium
or
media
into
which
the
release
occurred,
any
known
health
risks
and
advice
concerning
medical
treatment
for
exposed
individuals,
proper
precautions
to
take,
and
the
name
and
telephone
number
of
a
contact
person.

In
addition
to
the
initial
telephone
notification,
State
and
local
authorities
must
receive
and
store
information
from
the
follow­
up
written
notification.
Such
information
includes
updates
of
information
from
the
initial
telephone
notification,
actions
taken
to
respond
to
and
contain
the
release,
any
known
or
anticipated
acute
or
chronic
health
risks,
and
where
appropriate,
advice
regarding
medical
attention
for
exposed
individuals.
Processing
the
initial
telephone
call
and
the
follow­
up
written
notification
is
estimated
to
require
1.0
technical
person­
hour
and
0.080
clerical
person­
hour
for
State
governments.
A
similar
burden
estimate
is
assumed
for
local
governments.
13
OSWER
No.
9360.7­
16D
14
Based
on
the
pay
rates
for
the
General
Schedule
(
GS)
for
2001
published
by
the
Office
of
Personnel
Management
(
http://
www3.
opm.
gov/
oca/
01tables/
GShrly/
html/
washingt.
htm).
The
GS
levels
used
in
this
analysis
are
for
the
Washington­
Baltimore
locality
pay
area.

2­
9
It
is
assumed,
for
purposes
of
this
analysis,
that
the
labor
rate
for
a
State
or
local
technical
government
worker
is
equivalent
to
the
rate
for
a
Federal
government
worker
at
the
GS­
12,
step
1
level.
The
hourly
rate
for
a
clerical
worker
is
assumed
to
be
comparable
to
the
Federal
government's
clerical
category
(
GS­
4,
step
1)
at
a
rate
of
$
16.58
an
hour.
This
rate
includes
the
costs
of
personal
fringe
benefits,
assumed
to
be
60
percent
of
direct
wages.
14
Thus,
the
total
unit
cost
of
actions
performed
by
both
State
and
local
authorities
is
approximately
$
84
[
2
x
(
1.0
hour
x
$
40.75
+
0.080
hour
x
$
16.58)]
per
reportable
release.

Exhibit
2­
2
presents
a
summary
of
Federal,
State,
and
local
unit
costs
of
action.

EXHIBIT
2­
2
ESTIMATED
UNIT
COSTS
OF
ACTIONS
PERFORMED
BY
FEDERAL,
STATE,
AND
LOCAL
GOVERNMENTS
Action
Burden
Hours
Unit
Costs
1
Technical
$
40.75/
hr
Clerical
$
16.58/
hr
Federal
Government
Processing
Initial
Telephone
Notification
1.0
n/
a
$
41
State
and
Local
Government
Processing
Initial
Telephone
Notification
1.0
n/
a
$
41
Processing
Follow­
up
Written
Notification
1.0
0.16
$
43
n/
a
=
not
applicable.
1
Costs
are
rounded
to
nearest
whole
number.
OSWER
No.
9360.7­
16D
15
Economic
Impact
Analysis
of
Reportable
Quantity
Adjustments
for
the
Hazardous
Air
Pollutants
and
RCRA
Hazardous
Wastes
Added
as
CERCLA
Hazardous
Substances,
Volume
VI,
Office
of
Emergency
and
Remedial
Response,
U.
S.
EPA,
April
1995.
CHAPTER
3
COST
SAVINGS
This
chapter
provides
the
estimated
cost
savings
associated
with
EPA's
proposal
to
adjust
the
statutory
one­
pound
RQs
for
the
28
individual
carbamates
and
five
carbamate­
related
hazardous
waste
streams
that
were
listed
as
RCRA
hazardous
wastes
and
as
CERCLA
hazardous
substances.
The
regulated
community
and
government
are
expected
to
benefit
from
the
decreased
number
of
release
notifications
associated
with
the
proposed
upward
RQ
adjustments
for
these
33
carbamates.
In
particular,
cost
savings
to
the
regulated
community
are
estimated
to
result
from
reduced
reporting
and
recordkeeping,
while
the
government
is
estimated
to
benefit
from
the
decreased
costs
of
receiving
and
processing
notifications.

This
analysis
uses
three
components
to
determine
cost
savings:
(
1)
the
actions
performed
by
the
regulated
community
and
government
for
each
reportable
release;
(
2)
the
value,
or
unit
cost,
associated
with
each
of
these
actions;
and
(
3)
the
estimated
number
of
reportable
releases.
In
examining
the
effects
of
adjusting
RQs,
this
analysis
considers
only
episodic
releases,
or
those
releases
that
are
non­
routine,
unanticipated,
or
accidental.
Consequently,
this
analysis
is
conservative
in
that
any
cost
savings
associated
with
continuous
releases
are
not
quantified.

3.1
ESTIMATED
NUMBER
OF
REPORTABLE
RELEASES
This
section
discusses
the
method
used
to
predict
future
reportable
releases
for
substances
having
their
statutory
RQs
adjusted
from
one
pound
to
an
equivalent
or
higher
RQ.
In
the
EIA
for
the
final
RQ
adjustments
of
hazardous
air
pollutants
(
HAPs),
the
method
used
to
predict
future
reportable
releases
for
substances
having
an
upward
RQ
adjustment
relied
on
actual
reports
of
HAP
releases
equal
to
or
exceeding
each
substance's
adjusted
RQ.
15
This
EIA
uses
a
similar
approach
for
carbamates,
but
it
uses
release
reports
of
commonly
used
pesticide
substances
to
estimate
the
number
of
reports
per
substance
for
each
adjusted
RQ
category.
The
analysis
assumes
that
a
carbamate
with
an
adjusted
RQ
will
have
the
same
annual
number
of
reports
as
other
pesticides
with
the
same
adjusted
RQ.
This
assumption
was
made
because
of
the
general
lack
of
data
on
carbamate
releases
for
the
33
substances
listed
in
1995
and
because
of
the
widespread
use
of
carbamates
as
pesticides.

The
first
step
in
this
analysis
was
to
collect
release­
reporting
data
for
pesticides
identified
as
CERCLA
hazardous
substances.
Data
from
the
Emergency
Response
Notification
(
ERNS)
database
for
reports
made
in
1998
were
analyzed
for
each
CERCLA
substance
that
appears
on
the
list
of
the
25
most
OSWER
No.
9360.7­
16D
16
Pesticides
Industry
Sales
and
Usage:
1996
and
1997
Market
Estimates,
Office
of
Pesticide
Programs,
USEPA,
Washington,
D.
C.

17
Pesticide
Use
Report
­­
Fiscal
Year
1999,
U.
S.
Department
of
Agriculture,
Washington,
D.
C.

18
Because
none
of
the
commonly
used
pesticides
studied
in
this
analysis
had
a
5,000­
pound
RQ,
this
analysis
assumes
that
the
average
annual
number
of
reports
for
individual
substances
with
5,000­
pound
RQs
is
the
same
as
that
of
a
1,000­
pound
RQ
substance.

3­
2
commonly
used
conventional
pesticides
in
U.
S.
agricultural
crop
production,
16
and
each
CERCLA
substance
that
appears
in
the
Pesticide
Use
Report.
17
Next,
the
pesticide
release
reports
were
grouped
by
substances
having
the
same
RQ
to
estimate
an
overall
average
annual
number
of
reports
per
substance
within
each
RQ
category.
This
EIA
assumes
that
each
of
the
33
carbamates,
once
their
RQs
are
adjusted,
will
have
a
similar
average
annual
number
of
reported
releases
as
commonly
used
CERCLA­
listed
pesticides
having
a
similarly
adjusted
RQ.
18
Exhibit
3­
1
shows:
(
1)
the
average
annual
number
of
reports
per
commonly
used
CERCLA­
listed
pesticide;
(
2)
the
number
of
carbamates
(
including
the
carbamate­
related
K­
waste
streams)
that
appear
in
this
proposed
rule,
divided
into
their
proposed
adjusted
RQ
categories;
and
(
3)
the
expected
number
of
carbamate
reported
releases
in
each
RQ
category.

EXHIBIT
3­
1
EXPECTED
NUMBER
OF
REPORTS
OF
CARBAMATES
AFTER
RQ
ADJUSTMENT
Adjusted
RQ
(
lbs)
Average
Annual
Reported
Releases
per
CERCLA­
Listed
Pesticide
Number
of
Carbamates*
in
This
Proposed
Rule
Expected
Total
Number
of
Reports
After
RQ
Adjustment
1
4.3
2
8.6
10
2.5
12
30.0
100
6.1
11
67.1
1,000
0.33
5
1.6
5,000
0.33**
3
1.0
*
Includes
the
five
carbamate­
related
hazardous
K­
waste
streams
**
Analysis
assumes
same
average
as
1,000­
pound
RQ
because
of
insufficient
data
To
predict
the
baseline
number
of
reported
releases
for
the
carbamates
at
their
statutory
one­
pound
RQ
level,
this
analysis
relies
on
reports
of
releases
of
unspecified
pesticides,
because
reports
in
ERNS
rarely
identify
a
specific
carbamate
substance.
For
the
period
1995
through
1999,
ERNS
contains
88
reports
of
unspecified
pesticide
releases
where
the
quantity
released
is
known.
Of
the
88
reported
releases,
some
would
still
have
been
reported
if
the
RQ
had
been
adjusted
to
a
higher
category.
If
the
RQ
were
raised
10,
100,
1,000,
or
5,000
pounds,
the
number
of
reports
would
decrease
to
57,
30,
14,
or
4,
respectively.
OSWER
No.
9360.7­
16D
3­
3
The
relationship
between
the
number
of
releases
at
or
above
one
pound
and
the
number
of
releases
at
or
above
the
adjusted
RQ
was
expressed
as
a
ratio
and
used
in
this
EIA
to
estimate
the
baseline
number
of
reported
releases
of
carbamate­
related
substances
with
a
one­
pound
RQ.
In
other
words,
the
ratio
shows
the
relationship
of
the
expected
number
of
reports
before
and
after
RQ
adjustment.

For
each
RQ
level,
Exhibit
3­
2
shows
the
number
of
reports
after
RQ
adjustment
from
Exhibit
3­
1,
the
ratio
derived
from
the
ERNS
pesticide
data,
and
the
estimated
baseline
(
i.
e.,
before
RQ
adjustment)
number
of
reports.
For
example,
data
collected
for
the
pesticide
releases
show
that
for
substances
whose
RQs
are
adjusted
from
one
pound
to
10
pounds,
the
number
of
reports
decreases
by
a
factor
of
1.54
to
1.
Consequently,
this
EIA
assumes
that
for
a
carbamate­
related
substance,
the
number
of
reported
releases
at
a
one­
pound
RQ
level
is
approximately
1.54
times
the
estimated
number
of
reported
releases
at
a
10­
pound
RQ
level.

Exhibit
3­
2
also
shows
that
a
total
of
284
reported
releases
of
the
listed
carbamates
is
expected
annually
at
the
current
statutory
one­
pound
RQ
level.
The
total
number
of
reported
releases
is
expected
to
decline
to
108
after
the
RQ
adjustments
are
finalized.
As
discussed
in
Chapter
4,
the
approximate
decrease
of
176
in
the
estimated
number
of
reports
is
the
expected
effect
of
this
proposed
rulemaking.
The
remainder
of
this
analysis
refers
to
the
decrease
in
the
number
of
reportable
releases
resulting
from
the
proposed
RQ
adjustments
as
decremental
reportable
releases
(
DRRs).

EXHIBIT
3­
2
ESTIMATED
REPORTED
RELEASES
OF
CARBAMATES
INCLUDED
IN
THIS
PROPOSED
RULE
Adjusted
RQ
(
lbs)
Expected
Reports
After
RQ
Adjustment
(
A)
Release
Report
Ratio
(
B)
Expected
Reports
Before
Adjustment
(
C)
=
(
A)
x
(
B)
DRRs1,2
(
C)­(
A)

1
8.6
1.0
to
1
8.6
0
10
30.0
1.54
to
1
46.2
16
100
67.1
2.93
to
1
197
130
1,000
1.6
6.29
to
1
10.1
9
5,000
1.0
22.0
to
1
22.0
21
Total1
108
n/
a
284
176
1
Rounded
to
the
nearest
whole
number.
2
Decremental
Reportable
Releases.

3.2
CALCULATION
OF
COST
SAVINGS
ESTIMATES
The
effect
of
the
proposed
RQ
adjustments
for
the
33
substances
in
this
rule
would
be
to
decrease
the
expected
number
of
releases
that
are
required
to
be
reported.
Accordingly,
this
reduction,
which
is
shown
in
Exhibit
3­
2,
is
multiplied
by
the
unit
costs
associated
with
a
reportable
release,
as
explained
in
OSWER
No.
9360.7­
16D
19
Although
not
all
hazardous
substance
releases
reportable
to
the
NRC
are
required
to
be
reported
to
the
SERC
and
LEPC,
for
simplicity
this
analysis
assumes
that
the
number
of
reportable
releases
is
the
same
for
the
NRC,
SERC,
and
LEPC.

3­
4
Sections
2.3
and
2.4.
For
purposes
of
this
analysis,
unit
costs
are
multiplied
by
the
decrease
in
the
number
of
reports
to
estimate
the
total
cost
savings
associated
with
this
rule.
The
formulas
used
to
estimate
total
cost
savings
for
the
regulated
community
and
the
government
are
presented
below.

3.2.1
Cost
Savings
for
the
Regulated
Community
Notification
effects.
Notification
cost
savings
of
reporting
to
the
NRC,
SERCs,
and
LEPCs
equal
the
unit
cost
of
notification
multiplied
by
the
number
of
DRRs.
19
Because
of
the
different
unit
costs
associated
with
reporting
to
the
NRC,
SERCs,
and
LEPCs,
three
different
formulas
are
used
to
estimate
the
total
cost
savings
of
notification:

(
Total
DRRs)
x
$
95
=
cost
savings
from
notifying
NRC
Using
data
from
Exhibit
2­
1
and
Exhibit
3­
2:
176
x
$
95
=
$
16,720.

(
Total
DRRs)
x
$
63
=
cost
savings
from
initial
notification
of
SERCs
and
LEPCs
Using
data
from
Exhibit
2­
1
and
Exhibit
3­
2:
176
x
$
63
=
$
11,088.

(
Total
DRRs)
x
$
160
=
cost
savings
from
follow­
up
notification
of
SERCs
and
LEPCs
Using
data
from
Exhibit
2­
1
and
Exhibit
3­
2:
176
x
$
160
=
$
28,160.

The
total
cost
savings
of
notification
equal
the
sum
of
these
three
cost
savings
estimates.

Recordkeeping
effects.
Recordkeeping
cost
savings
equal
the
unit
cost
of
recordkeeping
multiplied
by
the
number
of
DRRs.

(
Total
DRRs)
x
$
72
=
cost
savings
of
recordkeeping
Using
data
from
Exhibit
2­
1
and
Exhibit
3­
2:
176
x
$
72
=
$
12,672.

The
total
cost
savings
to
the
regulated
community
is
estimated
at
about
$
68,640.

3.2.2
Cost
Savings
to
Government
Notification
Processing.
Notification
processing
cost
savings
equal
the
number
of
DRRs
multiplied
by
the
unit
cost
of
notification
processing
to
the
NRC,
SERCs,
and
LEPCs.

(
Total
DRRs)
x
$
41
=
cost
savings
for
NRC
Using
data
from
Exhibit
2­
2
and
Exhibit
3­
2:
176
x
$
41
=
$
7,216.

(
Total
DRRs)
x
$
84
=
cost
savings
for
SERCs
and
LEPCs
Using
data
from
Exhibit
2­
2
and
Exhibit
3­
2:
176
x
$
84
=
$
14,784.

The
total
cost
savings
to
government
is
estimated
at
about
$
22,000.
OSWER
No.
9360.7­
16D
3­
5
3.3
TOTAL
COST
SAVINGS
ESTIMATES
As
shown
in
Exhibit
3­
3,
for
the
28
carbamates
and
five
carbamate­
related
hazardous
waste
streams,
the
proposed
rule
would
result
in
estimated
cost
savings
of
approximately
$
90,640
annually,
of
which
about
$
68,640
is
attributable
to
savings
to
the
regulated
community.
These
estimated
cost
savings
reflect
decreased
notifications
to
the
NRC
under
CERCLA
section
103,
as
well
as
reduced
reporting
to
SERCs
and
LEPCs
under
section
304
of
EPCRA.

EXHIBIT
3­
3
COST
SAVINGS
ASSOCIATED
WITH
PROPOSED
CARBAMATE
RQ
ADJUSTMENTS
Action
Regulated
Community
Government
Total
Cost
Savings**
$/
release
Cost
Savings**
$/
release
Cost
Savings**

Initial
Notification
NRC
$
95
$
16,720
$
41
$
7,216
$
23,936
SERC
LEPC
$
63
$
11,088
$
41
$
7,216
$
18,304
Follow­
up
Notification
SERC
LEPC
$
160
$
28,160
$
43
$
7,568
$
35,728
Recordkeeping
$
72
$
12,672
0*
0*
$
12,672
Total
$
390
$
68,640
$
125
$
22,000
$
90,640
*
Any
cost
savings
associated
with
recordkeeping
for
Federal,
State,
and
local
governments
are
included
in
the
unit
costs
for
initial
telephone
notification
and
follow­
up
notification.

**
Rounded
to
the
nearest
whole
number.
Computed
as
$/
release
times
176
DRRs.
OSWER
No.
9360.7­
16D
CHAPTER
4
INFORMATION
IMPACT
ANALYSIS
This
chapter
presents
the
methodology
for,
and
results
of,
estimating
the
annual
reporting
and
recordkeeping
burden
associated
with
EPA's
proposed
rule
to
adjust
the
RQs
for
28
carbamates
and
five
carbamate­
related
hazardous
waste
streams.
Those
members
of
the
regulated
community
potentially
affected
by
the
reporting
requirements
for
these
hazardous
substances
include
entities
that
use,
generate,
transport,
handle,
or
dispose
of
hazardous
substances.
Numerous
industries,
as
well
as
various
private
organizations
and
governmental
jurisdictions,
may,
at
some
time,
be
responsible
for
a
hazardous
substance
release.

The
Paperwork
Reduction
Act
requires
an
agency
to
obtain
OMB
clearance
if
its
regulatory
action
imposes
any
requirements
on
the
regulated
community
to
keep
records,
to
report,
or
to
monitor
or
generate
data.
If
the
regulation
results
in
an
increase
in
reporting
or
recordkeeping
burden,
the
Agency
must
also
submit
to
OMB
an
Information
Collection
Request
(
ICR).
The
purpose
of
this
chapter
is
to
demonstrate
that
this
rulemaking
results
in
a
decrease
of
burden
to
the
regulated
community
and
therefore
does
not
require
an
ICR.

The
CERCLA
and
EPCRA
emergency
release
notification
requirements
ensure
that
the
government
can
respond
appropriately
to
a
release.
Information
received
by
the
NRC
is
referred
to
the
appropriate
EPA
Regional
office
or
U.
S.
Coast
Guard
District
office.
These
authorities
can
then
evaluate
the
release
and
provide
relevant
information
and
assistance
to
the
appropriate
State
and
local
response
officials.
In
addition,
the
Agency
can
determine
the
need
for
other
actions,
including
on­
and
off­
site
monitoring.

Compliance
with
CERCLA
section
103
requires
a
telephone
call
to
the
NRC,
and
compliance
with
EPCRA
section
304
requires
a
telephone
call
and
written
follow­
up
report
to
the
appropriate
SERC
and
LEPC.
Although
recordkeeping
is
not
required
under
CERCLA
or
EPCRA,
this
analysis
assumes
that
releasers
will
keep
records
of
any
interaction
with
government
officials.
The
amount
of
time
the
regulated
community
will
spend
on
(
1)
NRC
reporting
and
recordkeeping
activities
and
(
2)
State/
local
reporting
and
recordkeeping
activities
is
estimated
separately.
The
burden
on
the
public
associated
with
reporting
and
recordkeeping
depends
on
the
number
and
size
of
reportable
releases
encompassed
by
the
proposed
rulemaking,
as
well
as
on
the
amount
of
time
necessary
to
report
and
record
releases.

Under
this
rule,
the
Agency
has
proposed
to
assign
one­
pound
adjusted
RQs
to
one
individual
carbamate
substance
and
one
waste
stream;
therefore,
the
number
of
reported
releases
for
these
substances
would
not
change.
The
RQs
for
the
27
remaining
individual
substances
and
four
hazardous
waste
streams
are
proposed
to
be
adjusted
upward
from
the
statutory
one­
pound
level
to
10,
100,
1,000,
or
5,000
pounds.
Promulgation
of
these
proposed
RQ
adjustments
in
a
final
rule
would
result
in
fewer
reportable
releases
to
the
NRC
under
CERCLA
section
103,
and
to
SERCs
and
LEPCs
under
EPCRA
section
304.

As
shown
in
Exhibit
3­
2
of
this
report,
the
estimated
number
of
reportable
releases
is
expected
to
decline
by
176.
The
reduction
in
the
number
of
reportable
releases
will
reduce
the
overall
reporting
and
recordkeeping
burden
associated
with
releases
at
or
above
the
current
statutory
one­
pound
RQ
level.
A
OSWER
No.
9360.7­
16D
20
This
estimate
is
taken
from
the
U.
S.
Environmental
Protection
Agency
report,
"
Regulatory
Impact
Analysis
in
Support
of
Rulemaking
Under
Sections
302,
303,
and
304
of
Title
III
of
the
Superfund
Amendments
and
Reauthorization
Act
of
1986,"
April
10,
1987.

4­
2
calculation
of
the
new
reporting
and
recordkeeping
burden
was
presented
in
Section
3.1
and
is
summarized
below.

4.1
CALCULATION
OF
ANNUAL
REPORTING
BURDEN
4.1.1
Reports
to
the
National
Response
Center
Reporting
a
release
to
the
NRC
is
estimated
to
require,
on
average,
2.0
hours
(
1.0
hour
of
managerial
time
and
1.0
hour
of
technical
time)
to
gather
and
transmit
information
on
releases.
(
See
Chapter
2
for
additional
information
on
these
estimates.)
To
compute
the
reduction
in
the
annual
NRCrelated
reporting
burden
associated
with
the
proposed
RQ
adjustments,
the
number
of
decreased
reportable
releases
is
multiplied
by
the
amount
of
time
estimated
to
report
a
release.
For
the
proposed
RQ
adjustments
of
the
hazardous
substances,
there
is
an
estimated
decrease
of
176
reportable
releases
(
as
shown
in
Exhibit
3­
2).
The
annual
NRC­
related
reporting
burden,
therefore,
is
estimated
to
decrease
by
about
352
hours.

4.1.2
Reports
to
SERCs
and
LEPCs
Reporting
a
release
to
SERCs
and
LEPCs
is
estimated
to
require,
on
average,
1.0
hour
to
gather
and
transmit
information
on
releases
of
all
sizes.
20
An
additional
amount
of
time
is
required
to
submit
follow­
up
reports.
On
average,
this
is
expected
to
require
about
4.0
hours.
Total
SERC
and
LEPC
time
required
to
report
a
release
is
estimated
to
be
approximately
5.0
hours.
To
compute
the
reduction
in
the
State
and
local
reporting
burden,
the
number
of
decreased
reportable
releases
for
carbamate
substances
(
176)
is
multiplied
by
5.0
hours,
for
an
annual
reduction
of
approximately
880
hours.

4.1.3
Reporting
Burden
The
reduction
in
NRC,
SERC,
and
LEPC
reporting
burdens
attributed
to
this
rule
yields
an
estimated
decrease
in
the
annual
reporting
burden
for
the
carbamate
substances
of
1,232
hours
(
352
hours
+
880
hours).

4.2
CALCULATION
OF
ANNUAL
RECORDKEEPING
BURDEN
4.2.1
Recordkeeping
Related
to
NRC
Reports
Voluntary
recordkeeping
is
estimated
to
require
1.0
technical
hour,
1.0
clerical
hour,
and
0.10
managerial
hour
per
release
(
as
described
in
Section
2.3.3
of
this
EIA).
For
this
proposed
rulemaking,
there
is
a
decrease
of
176
reportable
releases
for
the
28
carbamates
and
five
carbamate­
related
hazardous
waste
streams
(
as
shown
in
Exhibit
3­
2).
Therefore,
the
annual
recordkeeping
burden
associated
with
reports
to
the
NRC
is
estimated
to
decrease
by
about
370
hours
(
2.1
hours
x
176
reportable
releases)
as
a
result
of
this
proposed
rule.
OSWER
No.
9360.7­
16D
4­
3
4.2.2
Recordkeeping
Related
to
State
and
Local
Reports
The
recordkeeping
burden
associated
with
notifying
the
NRC
of
a
release
is
assumed
to
also
capture
any
voluntary
recordkeeping
associated
with
notifying
SERCs
and
LEPCs
of
the
same
release.
Therefore,
no
additional
annual
recordkeeping
burden
is
associated
with
release
reports
to
SERCs
and
LEPCs.

4.2.3
Recordkeeping
Burden
The
combined
recordkeeping
burden
associated
with
releases
required
to
be
reported
to
the
NRC,
SERCs,
and
LEPCs
is
equivalent
to
the
recordkeeping
burden
associated
with
reports
to
the
NRC.
It
is
estimated
that
as
a
result
of
the
proposed
rule
the
recordkeeping
burden
will
decrease
by
about
370
hours.

4.3
TOTAL
ANNUAL
REPORTING/
RECORDKEEPING
BURDEN
The
estimated
annual
total
reduction
in
reporting
and
recordkeeping
burdens
associated
with
this
proposed
rule
is
approximately
1,602
hours.
This
estimate
is
comprised
of
1,232
hours
associated
with
reduced
reporting
burdens
and
370
hours
associated
with
reduced
recordkeeping
burdens
to
the
regulated
community.
OSWER
No.
9360.7­
16D
CHAPTER
5
PUBLIC
HEALTH
AND
WELFARE
AND
ENVIRONMENTAL
EFFECTS
Releases
of
carbamate
substances
have
the
potential
to
cause
damages
to
public
health
or
welfare
or
the
environment.
Releases
can
occur
whenever
hazardous
substances
are
handled
or
stored
during
manufacture,
transportation,
use,
or
disposal;
in
general,
releases
occur
either
in­
plant
or
in­
transit.
Causes
of
releases
include
human
error
(
e.
g.,
improper
reaction
conditions,
overfilling
tanks
during
transfer
operations,
and
driver
errors),
equipment
failure
(
e.
g.,
deteriorated
seals
and
ruptured
pipes
or
tanks),
and
improper
storage
or
abandonment.
When
releases
occur,
they
may
result
in
increased
risks
to
public
health
or
welfare
or
the
environment,
such
as:


Mortality
and
acute
or
chronic
morbidity.
These
risks
include
increased
human
exposures
(
by
ingestion,
inhalation,
or
dermal
contact)
to
carcinogens,
mutagens,
teratogens,
and
nontoxic
but
irritating
substances.


General
environmental
damages.
These
risks
include
the
adverse
impacts
of
released
substances
on
crop
yields,
non­
crop
vegetation,
fish,
wildlife,
and
farm
and
commercial
animal
production.


Public
welfare
damages.
These
risks
include
increased
property
damages,
aesthetic
damages,
recreational
damages,
and
productivity
losses.

However,
this
EIA
assumes
that
the
proposed
adjustment
of
RQs
for
these
hazardous
substances
will
have
minimal
effects
on
the
above
risks
for
several
reasons.
First,
RQs
are
considered
by
the
Agency
to
function
primarily
as
reporting
triggers.
The
RQs
cannot
prevent
a
release
from
occurring,
but
serve
only
to
notify
Federal
officials
of
potential
threats
after
a
release
has
occurred
so
that
government
personnel
can
decide
whether
a
government
response
is
warranted.
Consequently,
adjustment
of
a
hazardous
substance's
RQ
either
upward
or
downward
should
not
have
any
significant
influence
on
the
number
of
releases
of
that
substance.

Second,
the
Agency
considers
inherent
substance­
specific
risks
to
public
health
and
welfare
and
the
environment
as
part
of
the
RQ
adjustment
methodology.
The
methodology
for
adjusting
RQs
begins
with
an
evaluation
of
the
intrinsic
physical,
chemical,
and
toxicological
properties
of
each
hazardous
substance.
The
intrinsic
properties
examined
are
aquatic
toxicity,
mammalian
toxicity
(
oral,
dermal,
and
inhalation),
ignitability,
reactivity,
chronic
toxicity,
and
potential
carcinogenicity.
Because
the
Agency
considers
these
properties
as
part
of
its
RQ
adjustment
methodology,
it
is
assumed
that
releases
of
hazardous
substances
below
an
adjusted
RQ,
under
most
release
circumstances,
would
not
pose
a
sufficient
risk
to
public
health
or
welfare
or
the
environment
to
warrant
a
government
response.
Consequently,
this
proposed
rule
is
not
expected
to
result
in
any
increased
damages,
so
long
as
the
regulated
community
remains
in
compliance
with
the
release­
reporting
requirements
and
continues
to
respond
to
releases
less
than
an
RQ
without
government
assistance.

The
public
health
and
welfare
and
environmental
benefits
of
the
RQ
adjustments
in
the
proposed
rule
result
primarily
from
allowing
private
parties
and
government
to
focus
their
resources
on
responding
to
OSWER
No.
9360.7­
16D
5­
2
those
releases
that
pose
a
more
serious
threat
to
public
health
and
welfare
and
the
environment,
rather
than
on
responding
to
all
releases
above
one
pound,
the
statutory
reporting
threshold
for
the
hazardous
substances.
By
concentrating
resources
on
those
releases
that
pose
the
most
serious
threats,
both
private
parties
and
the
government
will
be
able
to
identify
more
effectively
and
respond
more
rapidly
to
these
releases
and
thus
reduce
any
damages
that
may
result.
