RECURRING COSTS
                                      [D]
                                ONE-TIME COSTS
                                   [E=BxC]
                                RECURRING COSTS
                                   [F=BxD]

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

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

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

                                    Low end
                                   High end
SQG-to-LQG
                                      419
                                      837
VSQG-to-LQG
                                      264
                                      527
VSQG-to-SQG
                                      590
                                     1,180
TOTAL
                                     1,273
                                     2,544
Notes:
 Based on analysis of EPA's RCRAInfo database from 2000 to 2013.

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

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

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

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

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

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

EXHIBIT 3-16:  TOTAL ANNUALIZED COSTS OF THE FINAL RULE BY REQUIREMENT ($2015 ANNUALIZED OVER 20 YEARS)
                                  REQUIREMENT
                              LOW IMPACT SCENARIO
                             HIGH IMPACT SCENARIO

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

     EXHIBIT 3-17(A):  TOTAL COSTS OF THE FINAL RULE BY YEAR, MANDATORY PROVISIONS ONLY ($2015)
                                     YEAR
                              LOW IMPACT SCENARIO
                             HIGH IMPACT SCENARIO
                                 UNDISCOUNTED
                               3% DISCOUNT RATE
                               7% DISCOUNT RATE
                                 UNDISCOUNTED
                               3% DISCOUNT RATE
                               7% DISCOUNT RATE
                                                                         Year 1
                                                                    $12,100,000
                                                                    $12,100,000
                                                                    $12,100,000
                                                                    $18,900,000
                                                                    $18,000,000
                                                                    $17,400,000
                                                                         Year 2
                                                                     $2,790,000
                                                                     $2,710,000
                                                                     $2,610,000
                                                                     $8,830,000
                                                                     $7,730,000
                                                                     $6,870,000
                                                                         Year 3
                                                                     $2,810,000
                                                                     $2,650,000
                                                                     $2,450,000
                                                                     $8,980,000
                                                                     $7,640,000
                                                                     $6,550,000
                                                                         Year 4
                                                                     $2,790,000
                                                                     $2,550,000
                                                                     $2,280,000
                                                                     $8,830,000
                                                                     $7,290,000
                                                                     $6,000,000
                                                                         Year 5
                                                                     $4,650,000
                                                                     $4,130,000
                                                                     $3,540,000
                                                                    $11,400,000
                                                                     $9,320,000
                                                                     $7,530,000
                                                                         Year 6
                                                                     $2,790,000
                                                                     $2,410,000
                                                                     $1,990,000
                                                                     $8,830,000
                                                                     $6,870,000
                                                                     $5,240,000
                                                                         Year 7
                                                                     $2,810,000
                                                                     $2,350,000
                                                                     $1,870,000
                                                                     $8,980,000
                                                                     $6,790,000
                                                                     $4,990,000
                                                                         Year 8
                                                                     $2,790,000
                                                                     $2,270,000
                                                                     $1,740,000
                                                                     $8,830,000
                                                                     $6,470,000
                                                                     $4,580,000
                                                                         Year 9
                                                                     $4,650,000
                                                                     $3,670,000
                                                                     $2,700,000
                                                                    $11,400,000
                                                                     $8,280,000
                                                                     $5,750,000
                                                                        Year 10
                                                                     $2,790,000
                                                                     $2,140,000
                                                                     $1,520,000
                                                                     $8,830,000
                                                                     $6,100,000
                                                                     $4,000,000
                                                                        Year 11
                                                                     $2,810,000
                                                                     $2,090,000
                                                                     $1,430,000
                                                                     $8,980,000
                                                                     $6,030,000
                                                                     $3,810,000
                                                                        Year 12
                                                                     $2,790,000
                                                                     $2,020,000
                                                                     $1,330,000
                                                                     $8,830,000
                                                                     $5,750,000
                                                                     $3,490,000
                                                                        Year 13
                                                                     $4,650,000
                                                                     $3,260,000
                                                                     $2,060,000
                                                                    $11,400,000
                                                                     $7,350,000
                                                                     $4,380,000
                                                                        Year 14
                                                                     $2,790,000
                                                                     $1,900,000
                                                                     $1,160,000
                                                                     $8,830,000
                                                                     $5,420,000
                                                                     $3,050,000
                                                                        Year 15
                                                                     $2,810,000
                                                                     $1,860,000
                                                                     $1,090,000
                                                                     $8,980,000
                                                                     $5,360,000
                                                                     $2,910,000
                                                                        Year 16
                                                                     $2,790,000
                                                                     $1,790,000
                                                                     $1,010,000
                                                                     $8,830,000
                                                                     $5,110,000
                                                                     $2,660,000
                                                                        Year 17
                                                                     $4,650,000
                                                                     $2,890,000
                                                                     $1,570,000
                                                                    $11,400,000
                                                                     $6,530,000
                                                                     $3,340,000
                                                                        Year 18
                                                                     $2,790,000
                                                                     $1,690,000
                                                                       $883,000
                                                                     $8,830,000
                                                                     $4,820,000
                                                                     $2,330,000
                                                                        Year 19
                                                                     $2,810,000
                                                                     $1,650,000
                                                                       $831,000
                                                                     $8,980,000
                                                                     $4,760,000
                                                                     $2,220,000
                                                                        Year 20
                                                                     $2,790,000
                                                                     $1,590,000
                                                                       $771,000
                                                                     $8,830,000
                                                                     $4,540,000
                                                                     $2,030,000
                                                    Total Costs (Over 20 Years)
                                                                    $72,600,000
                                                                    $57,700,000
                                                                    $44,900,000
                                                                   $197,000,000
                                                                   $140,000,000
                                                                    $99,100,000
                                                               Annualized Costs
                                                                     $3,630,000
                                                                     $3,760,000
                                                                     $3,960,000
                                                                     $9,870,000
                                                                     $9,150,000
                                                                     $8,740,000
Notes:
All cost estimates are rounded to three significant digits and may not sum due to rounding.
     EXHIBIT 3-17(B):  TOTAL COSTS OF THE FINAL RULE BY YEAR, VOLUNTARY PROVISIONS ONLY ($2015)
                                     YEAR
                              LOW IMPACT SCENARIO
                             HIGH IMPACT SCENARIO
                                 UNDISCOUNTED
                               3% DISCOUNT RATE
                               7% DISCOUNT RATE
                                 UNDISCOUNTED
                               3% DISCOUNT RATE
                               7% DISCOUNT RATE
                                                                         Year 1
                                                                     $3,890,000
                                                                     $3,890,000
                                                                     $3,890,000
                                                                     $8,380,000
                                                                     $8,380,000
                                                                     $8,380,000
                                                                         Year 2
                                                                       $737,000
                                                                       $716,000
                                                                       $689,000
                                                                     $2,310,000
                                                                     $2,240,000
                                                                     $2,160,000
                                                                         Year 3
                                                                     $2,900,000
                                                                     $2,730,000
                                                                     $2,530,000
                                                                     $6,310,000
                                                                     $5,950,000
                                                                     $5,520,000
                                                                         Year 4
                                                                       $737,000
                                                                       $675,000
                                                                       $602,000
                                                                     $2,310,000
                                                                     $2,120,000
                                                                     $1,890,000
                                                                         Year 5
                                                                     $2,900,000
                                                                     $2,580,000
                                                                     $2,210,000
                                                                     $6,310,000
                                                                     $5,610,000
                                                                     $4,820,000
                                                                         Year 6
                                                                       $737,000
                                                                       $636,000
                                                                       $526,000
                                                                     $2,310,000
                                                                     $1,990,000
                                                                     $1,650,000
                                                                         Year 7
                                                                     $2,900,000
                                                                     $2,430,000
                                                                     $1,930,000
                                                                     $6,310,000
                                                                     $5,290,000
                                                                     $4,210,000
                                                                         Year 8
                                                                       $737,000
                                                                       $599,000
                                                                       $459,000
                                                                     $2,310,000
                                                                     $1,880,000
                                                                     $1,440,000
                                                                         Year 9
                                                                     $2,900,000
                                                                     $2,290,000
                                                                     $1,690,000
                                                                     $6,310,000
                                                                     $4,990,000
                                                                     $3,680,000
                                                                        Year 10
                                                                       $737,000
                                                                       $565,000
                                                                       $401,000
                                                                     $2,310,000
                                                                     $1,770,000
                                                                     $1,260,000
                                                                        Year 11
                                                                     $2,900,000
                                                                     $2,160,000
                                                                     $1,470,000
                                                                     $6,310,000
                                                                     $4,700,000
                                                                     $3,210,000
                                                                        Year 12
                                                                       $737,000
                                                                       $533,000
                                                                       $350,000
                                                                     $2,310,000
                                                                     $1,670,000
                                                                     $1,100,000
                                                                        Year 13
                                                                     $2,900,000
                                                                     $2,030,000
                                                                     $1,290,000
                                                                     $6,310,000
                                                                     $4,430,000
                                                                     $2,800,000
                                                                        Year 14
                                                                       $737,000
                                                                       $502,000
                                                                       $306,000
                                                                     $2,310,000
                                                                     $1,570,000
                                                                       $959,000
                                                                        Year 15
                                                                     $2,900,000
                                                                     $1,920,000
                                                                     $1,120,000
                                                                     $6,310,000
                                                                     $4,170,000
                                                                     $2,450,000
                                                                        Year 16
                                                                       $737,000
                                                                       $473,000
                                                                       $267,000
                                                                     $2,310,000
                                                                     $1,480,000
                                                                       $838,000
                                                                        Year 17
                                                                     $2,900,000
                                                                     $1,810,000
                                                                       $982,000
                                                                     $6,310,000
                                                                     $3,940,000
                                                                     $2,140,000
                                                                        Year 18
                                                                       $737,000
                                                                       $446,000
                                                                       $233,000
                                                                     $2,310,000
                                                                     $1,400,000
                                                                       $732,000
                                                                        Year 19
                                                                     $2,900,000
                                                                     $1,700,000
                                                                       $858,000
                                                                     $6,310,000
                                                                     $3,710,000
                                                                     $1,870,000
                                                                        Year 20
                                                                       $737,000
                                                                       $420,000
                                                                       $204,000
                                                                     $2,310,000
                                                                     $1,320,000
                                                                       $639,000
                                                    Total Costs (Over 20 Years)
                                                                    $37,300,000
                                                                    $29,100,000
                                                                    $22,000,000
                                                                    $88,300,000
                                                                    $68,600,000
                                                                    $51,700,000
                                                               Annualized Costs
                                                                     $1,870,000
                                                                     $1,450,000
                                                                     $1,100,000
                                                                     $4,420,000
                                                                     $4,480,000
                                                                     $4,560,000
Notes:
All cost estimates are rounded to three significant digits and may not sum due to rounding.
     EXHIBIT 3-17(C):  TOTAL COSTS OF THE FINAL RULE BY YEAR, MANDATORY AND VOLUNTARY PROVISIONS ($2015)
                                     YEAR
                              LOW IMPACT SCENARIO
                             HIGH IMPACT SCENARIO
                                 UNDISCOUNTED
                               3% DISCOUNT RATE
                               7% DISCOUNT RATE
                                 UNDISCOUNTED
                               3% DISCOUNT RATE
                               7% DISCOUNT RATE
                                                                         Year 1
                                                                    $16,000,000
                                                                    $16,000,000
                                                                    $16,000,000
                                                                    $27,200,000
                                                                    $26,400,000
                                                                    $25,700,000
                                                                         Year 2
                                                                     $3,530,000
                                                                     $3,420,000
                                                                     $3,300,000
                                                                    $11,100,000
                                                                     $9,970,000
                                                                     $9,030,000
                                                                         Year 3
                                                                     $5,710,000
                                                                     $5,380,000
                                                                     $4,980,000
                                                                    $15,300,000
                                                                    $13,600,000
                                                                    $12,100,000
                                                                         Year 4
                                                                     $3,530,000
                                                                     $3,230,000
                                                                     $2,880,000
                                                                    $11,100,000
                                                                     $9,400,000
                                                                     $7,880,000
                                                                         Year 5
                                                                     $7,540,000
                                                                     $6,700,000
                                                                     $5,760,000
                                                                    $17,700,000
                                                                    $14,900,000
                                                                    $12,300,000
                                                                         Year 6
                                                                     $3,530,000
                                                                     $3,040,000
                                                                     $2,510,000
                                                                    $11,100,000
                                                                     $8,860,000
                                                                     $6,890,000
                                                                         Year 7
                                                                     $5,710,000
                                                                     $4,780,000
                                                                     $3,800,000
                                                                    $15,300,000
                                                                    $12,100,000
                                                                     $9,200,000
                                                                         Year 8
                                                                     $3,530,000
                                                                     $2,870,000
                                                                     $2,200,000
                                                                    $11,100,000
                                                                     $8,350,000
                                                                     $6,020,000
                                                                         Year 9
                                                                     $7,540,000
                                                                     $5,960,000
                                                                     $4,390,000
                                                                    $17,700,000
                                                                    $13,300,000
                                                                     $9,420,000
                                                                        Year 10
                                                                     $3,530,000
                                                                     $2,700,000
                                                                     $1,920,000
                                                                    $11,100,000
                                                                     $7,870,000
                                                                     $5,250,000
                                                                        Year 11
                                                                     $5,710,000
                                                                     $4,250,000
                                                                     $2,900,000
                                                                    $15,300,000
                                                                    $10,700,000
                                                                     $7,020,000
                                                                        Year 12
                                                                     $3,530,000
                                                                     $2,550,000
                                                                     $1,680,000
                                                                    $11,100,000
                                                                     $7,420,000
                                                                     $4,590,000
                                                                        Year 13
                                                                     $7,540,000
                                                                     $5,290,000
                                                                     $3,350,000
                                                                    $17,700,000
                                                                    $11,800,000
                                                                     $7,190,000
                                                                        Year 14
                                                                     $3,530,000
                                                                     $2,400,000
                                                                     $1,460,000
                                                                    $11,100,000
                                                                     $7,000,000
                                                                     $4,010,000
                                                                        Year 15
                                                                     $5,710,000
                                                                     $3,770,000
                                                                     $2,210,000
                                                                    $15,300,000
                                                                     $9,540,000
                                                                     $5,360,000
                                                                        Year 16
                                                                     $3,530,000
                                                                     $2,260,000
                                                                     $1,280,000
                                                                    $11,100,000
                                                                     $6,590,000
                                                                     $3,500,000
                                                                        Year 17
                                                                     $7,540,000
                                                                     $4,700,000
                                                                     $2,560,000
                                                                    $17,700,000
                                                                    $10,500,000
                                                                     $5,480,000
                                                                        Year 18
                                                                     $3,530,000
                                                                     $2,130,000
                                                                     $1,120,000
                                                                    $11,100,000
                                                                     $6,220,000
                                                                     $3,060,000
                                                                        Year 19
                                                                     $5,710,000
                                                                     $3,350,000
                                                                     $1,690,000
                                                                    $15,300,000
                                                                     $8,470,000
                                                                     $4,090,000
                                                                        Year 20
                                                                     $3,530,000
                                                                     $2,010,000
                                                                       $975,000
                                                                    $11,100,000
                                                                     $5,860,000
                                                                     $2,670,000
                                                    Total Costs (Over 20 Years)
                                                                   $110,000,000
                                                                    $86,800,000
                                                                    $66,900,000
                                                                   $286,000,000
                                                                   $209,000,000
                                                                   $151,000,000
                                                               Annualized Costs
                                                                     $5,500,000
                                                                     $5,660,000
                                                                     $5,900,000
                                                                    $14,300,000
                                                                    $13,600,000
                                                                    $13,300,000
Notes:
All cost estimates are rounded to three significant digits and may not sum due to rounding.
     EXHIBIT 3-18:  TOTAL ANNUALIZED COSTS OF THE FINAL RULE BY GENERATOR STATUS ($2015 ANNUALIZED OVER 20 YEARS)
                               GENERATOR STATUS
                              LOW IMPACT SCENARIO
                             HIGH IMPACT SCENARIO
                         NUMBER OF AFFECTED FACILITIES
                        ANNUALIZED COSTS(UNDISCOUNTED)
                  ANNUALIZED COSTS(USING A 3% DISCOUNT RATE)
                  ANNUALIZED COSTS(USING A 7% DISCOUNT RATE)
                         NUMBER OF AFFECTED FACILITIES
                        ANNUALIZED COSTS(UNDISCOUNTED)
                  ANNUALIZED COSTS(USING A 3% DISCOUNT RATE)
                  ANNUALIZED COSTS(USING A 7% DISCOUNT RATE)
MANDATORY PROVISIONS OF THE FINAL RULE
LQG
                                                                         20,771
                                                                       $872,000
                                                                       $983,000
                                                                     $1,150,000
                                                                         20,771
                                                                     $4,280,000
                                                                     $3,520,000
                                                                     $1,150,000
SQG
                                                                         49,887
                                                                     $2,760,000
                                                                     $2,780,000
                                                                     $2,810,000
                                                                         64,310
                                                                     $5,590,000
                                                                     $5,620,000
                                                                     $5,660,000
VSQG
                                                                        353,441
                                                                           $370
                                                                           $370
                                                                           $380
                                                                        591,809
                                                                         $2,540
                                                                         $2,580
                                                                         $2,630
Recycling Facility
                                                                             10
                                                                         $2,060
                                                                         $2,090
                                                                         $2,130
                                                                             20
                                                                         $5,590
                                                                         $5,670
                                                                         $5,780
SUB-TOTAL
                                                                        424,109
                                                                     $3,630,000
                                                                     $3,760,000
                                                                     $3,960,000
                                                                        676,910
                                                                     $9,870,000
                                                                     $9,150,000
                                                                     $8,740,000
VOLUNTARY PROVISIONS OF THE FINAL RULE
LQG
                                                                         20,771
                                                                     $1,250,000
                                                                     $1,280,000
                                                                     $1,320,000
                                                                         20,771
                                                                     $2,350,000
                                                                     $2,410,000
                                                                     $2,500,000
SQG
                                                                         49,887
                                                                        $36,100
                                                                        $36,100
                                                                        $36,100
                                                                         64,310
                                                                       $403,000
                                                                       $403,000
                                                                       $403,000
VSQG
                                                                        353,441
                                                                       $585,000
                                                                       $585,000
                                                                       $585,000
                                                                        591,809
                                                                     $1,660,000
                                                                     $1,660,000
                                                                     $1,660,000
Recycling Facility
                                                                             10
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             20
                                                                             $0
                                                                             $0
                                                                             $0
SUB-TOTAL
                                                                        424,109
                                                                     $1,870,000
                                                                     $1,900,000
                                                                     $1,940,000
                                                                        676,910
                                                                     $4,420,000
                                                                     $4,480,000
                                                                     $4,560,000
MANDATORY AND VOLUNTARY PROVISIONS OF THE FINAL RULE COMBINED
LQG
                                                                         20,771
                                                                     $2,120,000
                                                                     $2,260,000
                                                                     $2,470,000
                                                                         20,771
                                                                     $6,630,000
                                                                     $5,930,000
                                                                     $5,570,000
SQG
                                                                         49,887
                                                                     $2,790,000
                                                                     $2,820,000
                                                                     $2,850,000
                                                                         64,310
                                                                     $5,990,000
                                                                     $6,020,000
                                                                     $6,060,000
VSQG
                                                                        353,441
                                                                       $586,000
                                                                       $586,000
                                                                       $586,000
                                                                        591,809
                                                                     $1,660,000
                                                                     $1,660,000
                                                                     $1,660,000
Recycling Facility
                                                                             10
                                                                         $2,060
                                                                         $2,090
                                                                         $2,130
                                                                             20
                                                                         $5,590
                                                                         $5,670
                                                                         $5,780
TOTAL
                                                                        424,109
                                                                     $5,500,000
                                                                     $5,660,000
                                                                     $5,900,000
                                                                        676,910
                                                                    $14,300,000
                                                                    $13,600,000
                                                                    $13,300,000
Notes:
All annualized cost estimates are rounded to three significant digits and may not sum due to rounding.
EXHIBIT 3-19:  TOTAL ANNUALIZED COSTS OF THE FINAL RULE BY REQUIREMENT AND FREQUENCY USING A 7% DISCOUNT RATE ($2015)
                                  REQUIREMENT
                              LOW IMPACT SCENARIO
                             HIGH IMPACT SCENARIO

                           ANNUALIZED ONE-TIME COSTS
                          ANNUALIZED RECURRING COSTS
                            TOTAL ANNUALIZED COSTS
                           ANNUALIZED ONE-TIME COSTS
                          ANNUALIZED RECURRING COSTS
                            TOTAL ANNUALIZED COSTS
MANDATORY PROVISIONS OF THE FINAL RULE
Re-notification
                                                                             $0
                                                                       $507,000
                                                                       $507,000
                                                                             $0
                                                                       $656,000
                                                                       $656,000
Labeling
                                                                       $636,000
                                                                     $2,280,000
                                                                     $2,920,000
                                                                       $636,000
                                                                     $4,980,000
                                                                     $5,610,000
Closure
                                                                             $0
                                                                        $44,500
                                                                        $44,500
                                                                             $0
                                                                     $1,710,000
                                                                     $1,710,000
Emergency Response Preparedness
                                                                        $21,200
                                                                       $459,000
                                                                       $481,000
                                                                        $25,500
                                                                       $647,000
                                                                       $672,000
Transfer Facility
                                                                             $0
                                                                         $4,470
                                                                         $4,470
                                                                             $0
                                                                         $8,280
                                                                         $8,280
BR Requirements
                                                                             $0
                                                                         $7,240
                                                                         $7,240
                                                                             $0
                                                                        $71,100
                                                                        $71,100
Recycling
                                                                             $0
                                                                         $2,130
                                                                         $2,130
                                                                             $0
                                                                         $5,780
                                                                         $5,780
Prohibitions on Storage
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
Drip Pads and Containment Buildings
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
                                                                             $0
SUB-TOTAL: Mandatory Rule Provisions
                                                                       $657,000
                                                                     $3,310,000
                                                                     $3,960,000
                                                                       $661,000
                                                                     $8,080,000
                                                                     $8,740,000
VOLUNTARY PROVISIONS OF THE FINAL RULE
Intra-organizational Transfers
                                                                        $87,100
                                                                     $1,590,000
                                                                     $1,680,000
                                                                       $134,000
                                                                     $2,920,000
                                                                     $3,050,000
Episodic Generation
                                                                             $0
                                                                       $260,000
                                                                       $260,000
                                                                             $0
                                                                     $1,390,000
                                                                     $1,390,000
Ignitable and Reactive Waste
                                                                            $20
                                                                            $40
                                                                            $60
                                                                        $54,300
                                                                        $63,600
                                                                       $118,000
SUB-TOTAL: Voluntary Rule Provisions
                                                                        $87,100
                                                                     $1,850,000
                                                                     $1,940,000
                                                                       $189,000
                                                                     $4,380,000
                                                                     $4,560,000
MANDATORY AND VOLUNTARY PROVISIONS OF THE FINAL RULE COMBINED
TOTAL: Mandatory and Voluntary Provisions Combined
                                                                       $744,000
                                                                     $5,160,000
                                                                     $5,900,000
                                                                       $850,000
                                                                    $12,500,000
                                                                    $13,300,000
Notes:
All annualized cost estimates are rounded to three significant digits and may not sum due to rounding.
     3.5 ANALYTIC LIMITATIONS
While the analysis presented in this chapter provides reasonable estimates of the costs associated with the final rule, the data and methods used in this analysis are subject to several uncertainties, the most significant of which are outlined below.
Facility-specific characteristics not accounted for.  In practice, hazardous waste management methods vary by industry and between individual facilities in the same industry.  Sufficient data were not available for this analysis to incorporate such considerations into the estimation of costs.  Therefore, while costs are estimated separately for LQGs, SQGs, and VSQGs, they do not account for facility-specific differences.  Thus, the average per facility cost estimates reported in this document may either overstate or understate costs for individual facilities.
VSQG and SQG data are generally limited.  This RIA relies on limited data and information available in the BR and provided by the states to make assumptions regarding hazardous waste generation and management among SQGs and VSQGs.  In cases where data are unavailable, LQG (or SQG) data analysis and trends are applied to the VSQG universe, which may lead to overestimation or underestimation of actual costs.
Ownership structure of entities is unknown.  The cost of the rule's VSQG consolidation provision is highly dependent on the uncertain ownership structure of the regulated universe.  Specifically, the estimated costs of consolidation depend on the number of VSQGs that could consolidate their waste and the number of LQGs that could manage this waste.  This RIA uses a facility name matching algorithm for a limited number of states as the basis for estimating these values.  Because this approach uses data from a limited number of states and applies them more broadly to the U.S. as a whole, it may overestimate or understate the number of facilities that could take advantage of this provision of the rule.  In addition, the number of eligible entities that may choose to consolidate waste is also highly uncertain.
Activity in SAAs.  As described above, the costs of the labeling/marking requirements of the rule are partially dependent on the number of containers in SAAs.  Because comprehensive data on SAAs were not readily available for this analysis, this RIA assumed that the number of containers in satellite areas is half the number in primary storage areas.  This assumption may lead to overestimation or underestimation of the rule's costs.
Information on the use of DOT labels is unknown.  The cost of the rule's labeling/marking requirements depend, in part, on the number of generators that will use DOT labels to comply with the final rule, rather than modify their current labels.  Because it cannot predict how all generators will choose to comply with the labeling/marking requirements, EPA estimates that approximately half of LQGs will use DOT labels and not modify their existing labeling systems and processes.  This assumption may lead to overestimation or underestimation of the rule's costs.
Number of LQGs closing as landfills is unknown.  No data are available on the number of LQGs that are required to close with contamination in place.  Absent such information, this RIA assumes that zero to one percent of the LQGs closing will close as a landfill.  This assumption likely overstates actual closure costs as anecdotal information from state enforcement personnel suggests that this is a rare occurrence.
Eligibility for episodic generation is uncertain.  Data on episodic generation are extremely limited.  Therefore, it is not possible to accurately estimate the percentage of facilities that experience one-time or short-term generation events that last for one calendar month or less.  To address this uncertainty, this RIA assumes that between 50 and 100 percent of episodic events occur within a 60 day period.  This RIA also assumes that between 25 and 50 percent of facilities that experience a planned episodic event will petition EPA to allow a second unplanned episodic event in the same calendar year.  It is not clear whether this assumption leads to overestimation or underestimation of costs.
Number of facilities applying for waivers under the rule provision for ignitable and reactive waste.  While the BR includes data identifying facilities that generate reactive and/or ignitable waste, no data are available that clearly indicate which of these facilities are located in areas where it is not possible to meet the 15-meter property line requirement.  This RIA estimates the potential costs of this provision based on assumptions spanning a wide range, the upper end of which likely leads to overestimation of this provision's costs.

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

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

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

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

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

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

LQG
                                       0
                                     $0.00
                                     $0.00
                                      $0
                                      $0
                                      $0
SQG[a]
                                      307
                                     $0.00
                                   $2,800[c]
                                      $0
                                   $860,000
                                   $860,000
VSQG
                                       0
                                     $0.00
                                     $0.00
                                      $0
                                      $0
                                      $0
TOTAL
                                      307
                                      N/A
                                      N/A
                                      $0
                                   $860,000
                                   $860,000
Notes:
 EPA estimates that 12 SQGs accumulate hazardous waste in containment buildings and 295 SQGs accumulate hazardous waste on drip pads.
 The annualized costs savings include $2,468 for training, $111 for contingency plan updating, and $213 for biennial reporting in the low-impact scenario.
 The annualized costs savings include $2,468 for training, $111 for contingency plan updating, and $224 for biennial reporting in the high-impact scenario.
4.2.2 Intra-organizational Transfers of Hazardous Waste from VSQGs to LQGs
As outlined in Chapter 1, EPA is proposing to allow VSQGs to send their hazardous waste voluntarily to an LQG under the control of the same person, provided that both the VSQG(s) and LQG comply with certain conditions.  Under existing regulations, a VSQG may either treat or dispose of its hazardous waste on-site or ensure delivery to an off-site treatment, storage, or disposal facility, which can include permitted hazardous waste facilities, interim status hazardous waste facilities, municipal solid waste facilities, non-municipal non-hazardous waste facilities, and universal waste handlers. The existing VSQG regulations do not allow a generator to send its hazardous waste off-site to another generator, unless the receiving generator is also one of the types of facilities listed above.  In particular, existing RCRA regulations allow an LQG to accept waste from its VSQG affiliates only if the LQG has a RCRA storage permit and can demonstrate financial assurance for potential corrective action and closure/post-closure liabilities.  The final rule will eliminate the permit and financial assurance requirements for intra-organizational transfers of hazardous waste from VSQGs to LQGs in order to encourage improved VSQG waste management.  This section first describes the benefits of intra-organizational transfers for facilities that voluntarily begin to consolidate waste in response to the flexibility provided by the rule.  Then, this section describes the cost savings of this provision for facilities that already manage hazardous waste by means of intra-organizational transfers.  Information collected by EPA suggests that four LQGs are currently permitted to accept VSQG hazardous waste for consolidation.
Voluntary Adoption of Intra-organizational Tranfsers
Allowing VSQGs to send their hazardous waste to an LQG under the control of the same person may result in a net cost savings from reduced management costs (1) at the establishment-level for individual VSQG facilities and (2) at the firm-level for organizations that manage multiple facilities that could potentially consolidate their hazardous waste.  At the establishment-level, VSQGs transport their waste to an LQG facility using the organizations' existing fleet of hazmat vehicles (or a hazardous waste transporter within their own delivery network) and pass on the costs of disposal to the LQG.  At the firm-level, organizations realize cost-savings associated with managing waste quantities in bulk.  Specifically, industry sources estimate that stand-alone VSQG facilities incur an average cost premium of approximately 10 percent to dispose of their hazardous waste relative to LQGs.  Organizations consolidating VSQG waste to LQGs may also realize a transportation cost savings due to the higher transport costs typically incurred by VSQGs on a per-ton basis compared to LQGs, as described below.