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