12
                                      22
                                      72
Accommodation & Food Srvcs
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                      23
                                      81
Other Services
                                                                              0
                                                                              1
                                                                              0
                                                                            992
                                                                            993
                                      24
                                      92
Public Administration
                                                                              0
                                                                             49
                                                                              0
                                                                          1,376
                                                                          1,425
                                      25
                                      ??
NAICS code not reported
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                Column totals =
                                                                        427,104
                                                                         25,479
                                                                         40,532
                                                                        887,457
                                                                      1,380,571
                           Sub-total offsite tonnage excluded (Columns B+C+D) =
                                                                        953,468
                               90,800 shipments*
Impact for Exclusion 3 (NAICS code industry-by-industry impact for Exclusion 3 not estimated) =
                                                                        118,476
                    Combined impact (Exclusion 1 + Exclusion 2 + Exclusion 3) =
                                 1.499 million
Note: * Annual offsite shipments (i.e., RCRA manifests) affected estimated by dividing offsite tonnage by range of 10.5 tons average partial load.

                                  Exhibit 4G
Estimated Baseline Annual Cost Savings to Industry for the Three 2008 DSW Final Rule Exclusions
(Baseline Recycling Plus Baseline Disposal Switchover to Recycling* @100% Adoption Rate & 2011$)
                                     Item
                          Industry 2-digit NAICS code
                                       A
                                       B
                                       C
                                       D
                                  E (A+B+C+D)

                                 Exclusion 1A
                              (Generator onsite)
                                 Exclusion 1B
                              (Same co. offsite)
                                 Exclusion 1C
                               (offsite tolling)
                                  Exclusion 2
                               (Transfer-based)
                                   Combined
                                Exclusions 1+2
                                       1
                                      11
Ag, Forestry, Fishing, Hunting
                                                                            $0
                                                                            $0
                                                                            $0
                                                                        $7,696
                                                                        $7,696
                                       2
                                      21
Mining
                                                                            $0
                                                                            $0
                                                                            $0
                                                                      $400,495
                                                                      $400,495
                                       3
                                      22
Utilities
                                                                            $0
                                                                       $69,428
                                                                            $0
                                                                    $1,193,467
                                                                    $1,261,869
                                       4
                                      23
Construction
                                                                       $16,557
                                                                            $0
                                                                            $0
                                                                      $232,932
                                                                      $249,489
                                       5
                                      31
Manufacturing
                                                                            $0
                                                                            $0
                                                                            $0
                                                                      $577,597
                                                                      $577,597
                                       6
                                      32
Manufacturing
                                                                      $613,178
                                                                       $76,279
                                                                    $3,230,060
                                                                   $22,777,272
                                                                   $26,655,810
                                       7
                                      33
Manufacturing
                                                                    $1,450,981
                                                                      $269,383
                                                                            $0
                                                                   $44,803,949
                                                                   $46,524,314
                                       8
                                      42
Wholesale Trade
                                                                          $235
                                                                            $0
                                                                            $0
                                                                    $1,727,288
                                                                    $1,727,523
                                       9
                                      44
Retail Trade
                                                                            $0
                                                                            $0
                                                                            $0
                                                                      $184,892
                                                                      $184,892
                                      10
                                      45
Retail Trade
                                                                            $0
                                                                            $0
                                                                            $0
                                                                       $91,209
                                                                       $91,209
                                      11
                                      48
Transportation*
                                                                       ($1,135)
                                                                            $0
                                                                            $0
                                                                    $1,899,754
                                                                    $1,898,619
                                      12
                                      49
Postal, Messengers, Storage
                                                                            $0
                                                                       $33,342
                                                                            $0
                                                                      $545,613
                                                                      $578,956
                                      13
                                      51
Information
                                                                       $16,454
                                                                            $0
                                                                            $0
                                                                      $232,226
                                                                      $248,690
                                      14
                                      53
Real Estate, Rental & Leasing
                                                                            $0
                                                                       $28,371
                                                                            $0
                                                                      $107,310
                                                                      $135,681
                                      15
                                      54
Prof, Scientific & Tech Services
                                                                       $16,627
                                                                       $51,355
                                                                            $0
                                                                    $2,778,298
                                                                    $2,846,280
                                      16
                                      55
Mgt of Companies/Enterprises
                                                                            $0
                                                                            $0
                                                                            $0
                                                                       $86,042
                                                                       $86,042
                                      17
                                      56
Admin, Waste, & Remediation
                                                                      $150,908
                                                                      $700,732
                                                                            $0
                                                                    $1,713,242
                                                                    $2,564,882
                                      18
                                      61
Educational Services
                                                                       $31,431
                                                                       $67,548
                                                                            $0
                                                                    $3,460,750
                                                                    $3,559,728
                                      19
                                      62
Health Care, Social Assistance
                                                                       $14,295
                                                                       $64,925
                                                                            $0
                                                                    $1,391,195
                                                                    $1,470,415
                                      20
                                      71
Arts, Entertainment, Recreation
                                                                            $0
                                                                            $0
                                                                            $0
                                                                       $65,534
                                                                       $65,534
                                      21
                                      81
Other Services
                                                                            $0
                                                                       $34,201
                                                                            $0
                                                                    $1,119,441
                                                                    $1,153,643
                                      22
                                      92
Public Administration
                                                                            $0
                                                                       $33,980
                                                                            $0
                                                                    $4,027,347
                                                                    $4,061,328
                                                                Column totals =
                                                                    $2,268,550
                                                                    $1,428,521
                                                                    $3,230,061
                                                                   $89,423,563
                                                                   $96,350,694
                                   Average per affected facility ($/facility) =
                                                                       $22,461
                                                                       $17,006
                                                                       $35,109
                                                                       $19,206
                                                                       $19,532
                                Average per affected waste annual ton ($/ton) =
                                                                            $5
                                                                           $56
                                                                           $80
                                                                          $101
                                                                           $70
Impact for Exclusion 3 (NAICS code industry-by-industry impact for Exclusion 3 not estimated) =
                                                                    $1,311,182
                    Combined impact (Exclusion 1 + Exclusion 2 + Exclusion 3) =
                                                                 $97.7 million
* Reductions in state fees may influence generator waste management decisions (e.g., disposal vs. recycling) and are included in the micro-economic breakeven test. Distributive effects on state governments are not treated as social costs in this RIA for estimating the net economic impact.  Government fees often represent "transfer payments" not real resource costs.  State fees are taken out from the net economic impact.  As a result, cost savings may be negative in this table.

                                  Exhibit 4H
Estimated Baseline Annual Cost Savings for Baseline Recycling and Baseline Disposal
                 for the Three 2008 DSW Final Rule Exclusions
                        (@100% Adoption Rate and 2011$)
                                     Item
                          Industry 2-digit NAICS code
                                       A
                                       B
                                       C
                                       D
                                       E
                                       F

                         Impact on Baseline Recycling
                          Impact on Baseline Disposal
                           (Switchover to Recycling)

                                  Facilities
                                   Tons/year
                                  Net savings
                                  Facilities
                                   Tons/year
                                  Net savings
                                       1
                                      11
Ag, Forestry, Fishing, Hunting
                                                                              2
                                                                              9
                                                                         $6,382
                                                                              1
                                                                              3
                                                                         $1,314
                                       2
                                      21
Mining
                                                                             15
                                                                             64
                                                                       $313,596
                                                                              7
                                                                             57
                                                                        $86,899
                                       3
                                      22
Utilities
                                                                             82
                                                                          1,320
                                                                     $1,116,795
                                                                             19
                                                                             98
                                                                       $145,075
                                       4
                                      23
Construction
                                                                             13
                                                                            667
                                                                       $206,322
                                                                             10
                                                                            126
                                                                        $42,143
                                       5
                                      31
Manufacturing
                                                                             22
                                                                            251
                                                                       $468,541
                                                                             13
                                                                             49
                                                                       $109,058
                                       6
                                      32
Manufacturing
                                                                            899
                                                                        337,911
                                                                    $21,123,039
                                                                            655
                                                                          5,500
                                                                     $5,532,771
                                       7
                                      33
Manufacturing
                                                                          1,672
                                                                        933,113
                                                                    $39,166,879
                                                                            969
                                                                         14,337
                                                                     $7,357,435
                                       8
                                      42
Wholesale Trade
                                                                             64
                                                                         27,494
                                                                     $1,413,702
                                                                             49
                                                                            592
                                                                       $313,821
                                       9
                                      44
Retail Trade
                                                                             30
                                                                            229
                                                                       $184,892
                                                                              0
                                                                              0
                                                                             $0
                                      10
                                      45
Retail Trade
                                                                              4
                                                                             48
                                                                        $80,849
                                                                              1
                                                                              4
                                                                        $10,360
                                      11
                                      48
Transportation
                                                                             79
                                                                          1,282
                                                                     $1,619,366
                                                                             40
                                                                            295
                                                                       $279,253
                                      12
                                      49
Postal, Messengers, Storage
                                                                             13
                                                                          1,069
                                                                       $378,641
                                                                             16
                                                                            104
                                                                       $200,315
                                      13
                                      51
Information
                                                                             11
                                                                            239
                                                                       $233,582
                                                                              1
                                                                             20
                                                                        $15,107
                                      14
                                      53
Real Estate, Rental & Leasing
                                                                             11
                                                                          3,403
                                                                       $113,534
                                                                              4
                                                                              9
                                                                        $22,147
                                      15
                                      54
Prof, Scientific & Tech Services
                                                                            106
                                                                            638
                                                                     $2,311,577
                                                                             85
                                                                            386
                                                                       $534,703
                                      16
                                      55
Mgt of Companies/Enterprises
                                                                              4
                                                                             17
                                                                        $82,605
                                                                              1
                                                                              9
                                                                         $3,436
                                      17
                                      56
Admin, Waste, & Remediation
                                                                            133
                                                                         47,207
                                                                     $2,251,770
                                                                             38
                                                                            195
                                                                       $313,110
                                      18
                                      61
Educational Services
                                                                            120
                                                                            532
                                                                     $2,873,920
                                                                             92
                                                                            267
                                                                       $685,808
                                      19
                                      62
Health Care, Social Assistance
                                                                             61
                                                                            409
                                                                     $1,277,084
                                                                             35
                                                                            190
                                                                       $193,331
                                      20
                                      71
Arts, Entertainment, Recreation
                                                                              5
                                                                             12
                                                                        $58,884
                                                                              1
                                                                              0
                                                                         $6,650
                                      21
                                      81
Other Services
                                                                             70
                                                                            935
                                                                     $1,096,130
                                                                             11
                                                                             58
                                                                        $57,512
                                      22
                                      92
Public Administration
                                                                            111
                                                                            887
                                                                     $2,833,842
                                                                            146
                                                                            538
                                                                     $1,227,486
                                                                Column totals =
                                                                          3,528
                                                                      1,357,736
                                                                    $79,211,931
                                                                          2,192
                                    22,837
                                                                   $17,137,733

                                                                             74
                                                                        118,476
                                                                     $1,311,182
= Impact for Exclusion 3 (NAICS not estimated)
Baseline recycling + baseline disposal combined impact (Exclusion 1+Exclusion 2+Exclusion 3) =
                                     5,007
                                 1.499 million
                                $97.7 million

                                  Exhibit 4I
         Expected Change in Baseline RCRA Regulatory Generator Status
       for the Three 2008 DSW Final Rule Exclusions (100% Adoption Rate)
Note: impacts in this Exhibit based on annual tonnages from both baseline recycling + baseline disposal switchover to recycling
                               Generator Status*
                                       A
                                       B
                                       C
                                       D
                                       E
                                       F
                                       G
                                       H
                                    I (H-D)

                        Baseline Facility Status Counts
                       Post-Rule Facility Status Counts

                      Facilities Affected by Exclusion 1
                      Facilities Affected by Exclusion 2
                      Facilities Affected by Exclusion 3
                          Combined Exclusion (1+2+3)
                      Facilities Affected by Exclusion 1
                      Facilities Affected by Exclusion 2
                      Facilities Affected by Exclusion 3
                          Combined Exclusion (1+2+3)
  Incremental Change in Facility Status Counts because of 2008 DSW Final Rule

                               Option 1 Selected
                             Option 1 NOT Selected

                               Option 1 Selected
                             Option 1 NOT Selected
                               Option 1 Selected
                             Option 1 NOT Selected
                                      LQG
                                      255
                                     3,752
                                 Not estimated
                                     4,007
                                      201
                                     3,752
                                     2,811
                                 Not estimated
                                     3,953
                                     3,013
                                      -54
                                     -995
                                      SQG
                                      17
                                      829
                                 Not estimated
                                      846
                                      59
                                      829
                                     1,185
                                 Not estimated
                                      888
                                     1,244
                                      42
                                      398
                                     CESQG
                                       4
                                      75
                                 Not estimated
                                      79
                                      16
                                      75
                                      660
                                 Not estimated
                                      91
                                      676
                                      12
                                      597
                                 Column totals
                                      277
                                     4,656
                                      74
                                     5,007
                                      277
                                     4,656
                                     4,656
                                      74
                                     5,007
                                     5,007
                                       0
                                       0
Explanatory Notes:
* RCRA generator status is determined by the monthly hazardous waste generation tonnages reported by each facility in the RCRA Biennial Report:
LQGs = >13.2 tons/year
SQGs = Between 1.3 and 13.2 tons/year
CESQG = <1.3 tons per year (note: this RIA counts facilities post-rule as CESQGs even if they are expected to become non-generators post rule).
"Acute hazardous" wastes determinations of generator status are not taken into consideration in this RIA.

   * Update Results Based on "Base Case" 13% Facilities Adopting (662) With Future Annual Discounting

For a future annual adoption rate scenario for the 2011 proposed DSW recycling exclusion revisions (if promulgated), this scenario is formulated relative to the actual count of 49 industrial facilities which submitted DSW exclusion notifications under the 2008 DSW final rule as of April 26, 2011.  These 49 notifications were submitted to EPA over an approximate two-year, four-month period (i.e., between December 28, 2008 and April 26, 2011), which represents an annual average of 21 facilities per-year adopting the 2008 DSW recycling exclusions (i.e., (49 facilities) / (2.33 years) = 21 facilities per year).  This actual adoption rate is applied in this RIA as a "base case" adoption scenario over the 50-year future period of analysis (i.e., 2015 to 2064) applied in this RIA.

Using 21 facilities as an average annual adoption rate, over the future 50 year period, the cumulative average annual count of facilities adopting the 2008 DSW final rule under this scenario is 662 or 13% of all facilities potentially eligible for the 2008 DSW exclusions 1,2, and 3 (662/5,007 x 100 = 13%).  Previously in EPA's RIA for the 2008 DSW exclusions final rule, industry implementation cost estimates were presented for a scenario in which 100% (i.e., 4,933 for exclusions 1 and 2 or 5,007 including exclusion 3 as of 2007 data year) of eligible industrial facilities submitted notifications for the 2008 DSW exclusions.  This 13% "base case" adoption rate is applied in this RIA as a future scenario to estimate the baseline cost savings estimate associated with the 2008 DSW final rule exclusions.

Three alternative discount rates (i.e., 0%, 3%, and 7%) are applied to the baseline costs.  Two of these discount rates (3% and 7%) are prescribed in OMB's 2003 "Circular A4" regulatory analysis guidance for Federal regulatory agencies.

Note: The higher 7% discount rate is used as the "base case" rate for this RIA, because the costs and cost savings associated with the pre-2008 and 2008 DSW recycling exclusions, as well as the 2011 proposed revisions to the DSW exclusions, almost exclusively impact industry rather than government.  The higher discount rate (7%) may represent industry opportunity costs relative to investment opportunities by affected industries.

The 13% "base case" baseline cost savings for the 2008 DSW final rule recycling exclusions are:

   * 0% discount rate:	$15.1 million per year (see Exhibit 4J below).
   * 3% discount rate:	$10.8 million per year (see Exhibit 4K below).
   * 7% discount rate:	$7.4 million per year (see Exhibit 4L below).

                                  Exhibit 4J
Estimated Baseline Annual Cost Savings to Industry for the Three 2008 DSW Final Rule Exclusions
(Baseline Recycling Plus Disposal Switchover to Recycling @13% State Adoption Rate, 2011$, 0% Discount Rate)
                                     Item
                          Industry 2-digit NAICS code
                                       A
                                       B
                                       C
                                       D
                                  E (A+B+C+D)

                                 Exclusion 1A
                              (Generator onsite)
                                 Exclusion 1B
                              (Same co. offsite)
                                 Exclusion 1C
                               (offsite tolling)
                                  Exclusion 2
                               (Transfer-based)
                                   Combined
                                Exclusions 1+2
                                       1
                                      11
Ag, Forestry, Fishing, Hunting
                                                                            $0
                                                                            $0
                                                                            $0
                                                                        $1,032
                                                                        $1,032
                                       2
                                      21
Mining
                                                                            $0
                                                                            $0
                                                                            $0
                                                                       $53,705
                                                                       $53,705
                                       3
                                      22
Utilities
                                                                            $0
                                                                        $9,310
                                                                            $0
                                                                      $160,040
                                                                      $169,350
                                       4
                                      23
Construction
                                                                        $2,220
                                                                            $0
                                                                            $0
                                                                       $31,235
                                                                       $33,456
                                       5
                                      31
Manufacturing
                                                                            $0
                                                                            $0
                                                                            $0
                                                                       $77,454
                                                                       $77,454
                                       6
                                      32
Manufacturing
                                                                       $82,225
                                                                       $10,229
                                                                      $433,141
                                                                    $3,054,362
                                                                    $3,579,957
                                       7
                                      33
Manufacturing
                                                                      $194,572
                                                                       $36,123
                                                                            $0
                                                                    $6,008,071
                                                                    $6,238,766
                                       8
                                      42
Wholesale Trade
                                                                           $31
                                                                            $0
                                                                            $0
                                                                      $231,624
                                                                      $231,655
                                       9
                                      44
Retail Trade
                                                                            $0
                                                                            $0
                                                                            $0
                                                                       $24,793
                                                                       $24,793
                                      10
                                      45
Retail Trade
                                                                            $0
                                                                            $0
                                                                            $0
                                                                       $12,231
                                                                       $12,231
                                      11
                                      48
Transportation*
                                                                         ($152)
                                                                            $0
                                                                            $0
                                                                      $254,751
                                                                      $254,599
                                      12
                                      49
Postal, Messengers, Storage
                                                                            $0
                                                                        $4,471
                                                                            $0
                                                                       $73,165
                                                                       $77,636
                                      13
                                      51
Information
                                                                        $2,206
                                                                            $0
                                                                            $0
                                                                       $31,141
                                                                       $33,347
                                      15
                                      53
Real Estate, Rental & Leasing
                                                                            $0
                                                                        $3,804
                                                                            $0
                                                                       $14,390
                                                                       $18,194
                                      16
                                      54
Prof, Scientific & Tech Services
                                                                        $2,230
                                                                        $6,887
                                                                            $0
                                                                      $372,561
                                                                      $381,677
                                      17
                                      55
Mgt of Companies/Enterprises
                                                                            $0
                                                                            $0
                                                                            $0
                                                                       $11,538
                                                                       $11,538
                                      18
                                      56
Admin, Waste, & Remediation
                                                                       $20,236
                                                                       $93,966
                                                                            $0
                                                                      $229,740
                                                                      $343,943
                                      19
                                      61
Educational Services
                                                                        $4,215
                                                                        $9,058
                                                                            $0
                                                                      $464,076
                                                                      $477,349
                                      20
                                      62
Health Care, Social Assistance
                                                                        $1,917
                                                                        $8,706
                                                                            $0
                                                                      $186,555
                                                                      $197,178
                                      21
                                      71
Arts, Entertainment, Recreation
                                                                            $0
                                                                            $0
                                                                            $0
                                                                        $8,788
                                                                        $8,788
                                      23
                                      81
Other Services
                                                                            $0
                                                                        $4,586
                                                                            $0
                                                                      $150,114
                                                                      $154,700
                                      24
                                      92
Public Administration
                                                                            $0
                                                                        $4,557
                                                                            $0
                                                                      $540,055
                                                                      $544,611
                                                                Column totals =
                                                                      $309,701
                                                                      $191,698
                                                                      $433,141
                                                                   $11,991,421
                                                                   $12,925,960
                                   Average per affected facility ($/facility) =
                                                                       $23,278
                                                                       $17,101
                                                                       $36,249
                                                                       $19,741
                                                                       $20,075
                                Average per affected waste annual ton ($/ton) =
                                                                            $6
                                                                           $56
                                                                           $82
                                                                          $104
                                                                           $72
Impact for Exclusion 3 (NAICS code industry-by-industry impact for Exclusion 3 not estimated) =
                                                                     $2,128,086
                    Combined impact (Exclusion 1 + Exclusion 2 + Exclusion 3) =
                                                                   $15,054,046
* Reductions in state fees may influence generator waste management decisions (e.g., disposal vs. recycling) and are included in the micro-economic breakeven test.  Distributive effects on state governments are not treated as social costs in this RIA for estimating the net economic impact.  Government fees often represent "transfer payments" not real resource costs.  State fees are taken out from the net economic impact.  As a result, cost savings may be negative in this table.

                                  Exhibit 4K
Estimated Baseline Annual Cost Savings to Industry for the Three 2008 DSW Final Rule Exclusions
(Baseline Recycling Plus Disposal Switchover to Recycling @ 13% Adoption Rate, 2011$, 3% Discount Rate)
                                     Item
                          Industry 2-digit NAICS code
                                       A
                                       B
                                       C
                                       D
                                  E (A+B+C+D)

                                 Exclusion 1A
                              (Generator onsite)
                                 Exclusion 1B
                              (Same co. offsite)
                                 Exclusion 1C
                               (offsite tolling)
                                  Exclusion 2
                               (Transfer-based)
                                   Combined
                                Exclusions 1+2
                                       1
                                      11
Ag, Forestry, Fishing, Hunting
                                                                            $0
                                                                            $0
                                                                            $0
                                                                          $744
                                                                          $744
                                       2
                                      21
Mining
                                                                            $0
                                                                            $0
                                                                            $0
                                                                       $38,719
                                                                       $38,719
                                       3
                                      22
Utilities
                                                                            $0
                                                                        $6,712
                                                                            $0
                                                                      $115,382
                                                                      $122,094
                                       4
                                      23
Construction
                                                                        $1,601
                                                                            $0
                                                                            $0
                                                                       $22,519
                                                                       $24,120
                                       5
                                      31
Manufacturing
                                                                            $0
                                                                            $0
                                                                            $0
                                                                       $55,841
                                                                       $55,841
                                       6
                                      32
Manufacturing
                                                                       $59,281
                                                                        $7,375
                                                                      $312,276
                                                                    $2,202,064
                                                                    $2,580,995
                                       7
                                      33
Manufacturing
                                                                      $140,278
                                                                       $26,043
                                                                            $0
                                                                    $4,331,561
                                                                    $4,497,883
                                       8
                                      42
Wholesale Trade
                                                                           $23
                                                                            $0
                                                                            $0
                                                                      $166,991
                                                                      $167,014
                                       9
                                      44
Retail Trade
                                                                            $0
                                                                            $0
                                                                            $0
                                                                       $17,875
                                                                       $17,875
                                      10
                                      45
Retail Trade
                                                                            $0
                                                                            $0
                                                                            $0
                                                                        $8,818
                                                                        $8,818
                                      11
                                      48
Transportation*
                                                                         ($110)
                                                                            $0
                                                                            $0
                                                                      $183,665
                                                                      $183,555
                                      12
                                      49
Postal, Messengers, Storage
                                                                            $0
                                                                        $3,223
                                                                            $0
                                                                       $52,749
                                                                       $55,972
                                      13
                                      51
Information
                                                                        $1,591
                                                                            $0
                                                                            $0
                                                                       $22,451
                                                                       $24,042
                                      15
                                      53
Real Estate, Rental & Leasing
                                                                            $0
                                                                        $2,743
                                                                            $0
                                                                       $10,375
                                                                       $13,117
                                      16
                                      54
Prof, Scientific & Tech Services
                                                                        $1,607
                                                                        $4,965
                                                                            $0
                                                                      $268,601
                                                                      $275,173
                                      17
                                      55
Mgt of Companies/Enterprises
                                                                            $0
                                                                            $0
                                                                            $0
                                                                        $8,318
                                                                        $8,318
                                      18
                                      56
Admin, Waste, & Remediation
                                                                       $14,590
                                                                       $67,745
                                                                            $0
                                                                      $165,633
                                                                      $247,968
                                      19
                                      61
Educational Services
                                                                        $3,039
                                                                        $6,530
                                                                            $0
                                                                      $334,579
                                                                      $344,148
                                      20
                                      62
Health Care, Social Assistance
                                                                        $1,382
                                                                        $6,277
                                                                            $0
                                                                      $134,498
                                                                      $142,157
                                      21
                                      71
Arts, Entertainment, Recreation
                                                                            $0
                                                                            $0
                                                                            $0
                                                                        $6,336
                                                                        $6,336
                                      23
                                      81
Other Services
                                                                            $0
                                                                        $3,306
                                                                            $0
                                                                      $108,225
                                                                      $111,532
                                      24
                                      92
Public Administration
                                                                            $0
                                                                        $3,285
                                                                            $0
                                                                      $389,356
                                                                      $392,641
                                                                Column totals =
                                                                      $223,281
                                                                      $138,206
                                                                      $312,276
                                                                    $8,645,300
                                                                    $9,319,063
                                   Average per affected facility ($/facility) =
                                                                       $16,783
                                                                       $12,329
                                                                       $26,134
                                                                       $14,232
                                                                       $14,473
                                Average per affected waste annual ton ($/ton) =
                                                                            $4
                                                                           $41
                                                                           $59
                                                                           $75
                                                                           $52
Impact for Exclusion 3 (NAICS code industry-by-industry impact for Exclusion 3 not estimated) =
                                                                     $1,453,803
                    Combined impact (Exclusion 1 + Exclusion 2 + Exclusion 3) =
                                                                   $10,772,866
* Reductions in state fees may influence generator waste management decisions (e.g., disposal vs. recycling) and are included in the micro-economic breakeven test. Distributive effects on state governments are not treated as social costs in this RIA for estimating the net economic impact.  Government fees often represent "transfer payments" not real resource costs.  State fees are taken out from the net economic impact.  As a result, cost savings may be negative in this table.

                                  Exhibit 4L
Estimated Baseline Annual Cost Savings to Industry for the Three 2008 DSW Final Rule Exclusions
(Baseline Recycling Plus Disposal Switchover to Recycling, 13% Adoption Rate, 2011$, 7% Discount Rate)
                                     Item
                          Industry 2-digit NAICS code
                                       A
                                       B
                                       C
                                       D
                                  E (A+B+C+D)

                                 Exclusion 1A
                              (Generator onsite)
                                 Exclusion 1B
                              (Same co. offsite)
                                 Exclusion 1C
                               (offsite tolling)
                                  Exclusion 2
                               (Transfer-based)
                                   Combined
                                Exclusions 1+2
                                       1
                                      11
Ag, Forestry, Fishing, Hunting
                                                                            $0
                                                                            $0
                                                                            $0
                                                                          $488
                                                                          $488
                                       2
                                      21
Mining
                                                                            $0
                                                                            $0
                                                                            $0
                                                                       $25,401
                                                                       $25,401
                                       3
                                      22
Utilities
                                                                            $0
                                                                        $4,403
                                                                            $0
                                                                       $75,693
                                                                       $80,097
                                       4
                                      23
Construction
                                                                        $1,050
                                                                            $0
                                                                            $0
                                                                       $14,773
                                                                       $15,823
                                       5
                                      31
Manufacturing
                                                                            $0
                                                                            $0
                                                                            $0
                                                                       $36,633
                                                                       $36,633
                                       6
                                      32
Manufacturing
                                                                       $38,890
                                                                        $4,838
                                                                      $204,860
                                                                    $1,444,603
                                                                    $1,693,191
                                       7
                                      33
Manufacturing
                                                                       $92,026
                                                                       $17,085
                                                                            $0
                                                                    $2,841,601
                                                                    $2,950,712
                                       8
                                      42
Wholesale Trade
                                                                           $15
                                                                            $0
                                                                            $0
                                                                      $109,550
                                                                      $109,565
                                       9
                                      44
Retail Trade
                                                                            $0
                                                                            $0
                                                                            $0
                                                                       $11,726
                                                                       $11,726
                                      10
                                      45
Retail Trade
                                                                            $0
                                                                            $0
                                                                            $0
                                                                        $5,785
                                                                        $5,785
                                      11
                                      48
Transportation*
                                                                          ($72)
                                                                            $0
                                                                            $0
                                                                      $120,488
                                                                      $120,416
                                      12
                                      49
Postal, Messengers, Storage
                                                                            $0
                                                                        $2,115
                                                                            $0
                                                                       $34,604
                                                                       $36,719
                                      13
                                      51
Information
                                                                        $1,044
                                                                            $0
                                                                            $0
                                                                       $14,728
                                                                       $15,772

                                      53
Real Estate, Rental & Leasing
                                                                            $0
                                                                        $1,799
                                                                            $0
                                                                        $6,806
                                                                        $8,605

                                      54
Prof, Scientific & Tech Services
                                                                        $1,055
                                                                        $3,257
                                                                            $0
                                                                      $176,208
                                                                      $180,520

                                      55
Mgt of Companies/Enterprises
                                                                            $0
                                                                            $0
                                                                            $0
                                                                        $5,457
                                                                        $5,457

                                      56
Admin, Waste, & Remediation
                                                                        $9,571
                                                                       $44,443
                                                                            $0
                                                                      $108,659
                                                                      $162,673

                                      61
Educational Services
                                                                        $1,993
                                                                        $4,284
                                                                            $0
                                                                      $219,491
                                                                      $225,769

                                      62
Health Care, Social Assistance
                                                                          $907
                                                                        $4,118
                                                                            $0
                                                                       $88,234
                                                                       $93,258

                                      71
Arts, Entertainment, Recreation
                                                                            $0
                                                                            $0
                                                                            $0
                                                                        $4,156
                                                                        $4,156

                                      81
Other Services
                                                                            $0
                                                                        $2,169
                                                                            $0
                                                                       $70,998
                                                                       $73,167

                                      92
Public Administration
                                                                            $0
                                                                        $2,155
                                                                            $0
                                                                      $255,426
                                                                      $257,582
                                                                Column totals =
                                                                      $146,477
                                                                       $90,666
                                                                      $204,860
                                                                    $5,671,510
                                                                    $6,113,514
                                   Average per affected facility ($/facility) =
                                                                       $11,010
                                                                        $8,088
                                                                       $17,144
                                                                        $9,337
                                                                        $9,495
                                Average per affected waste annual ton ($/ton) =
                                                                            $3
                                                                           $27
                                                                           $39
                                                                           $49
                                                                           $34
Impact for Exclusion 3 (NAICS code industry-by-industry impact for Exclusion 3 not estimated) =
                                                                     $1,311,182
                    Combined impact (Exclusion 1 + Exclusion 2 + Exclusion 3) =
                                                                    $7,424,696
* Reductions in state fees may influence generator waste management decisions (e.g., disposal vs. recycling) and are included in the micro-economic breakeven test. Distributive effects on state governments are not treated as social costs in this RIA for estimating the net economic impact.  Government fees often represent "transfer payments" not real resource costs.  State fees are taken out from the net economic impact.  As a result, cost savings may be negative in this table.

4C.	Baseline Regulatory Cost Savings for the Pre-2008 DSW Recycling Exclusions

As stated in Section 3C above, comprehensive data on the nationwide annual quantities of pre-2008 DSW excluded hazardous secondary materials are not readily available because they are not subject to biennial reporting to EPA under the RCRA Subtitle C hazardous waste regulations.  This RIA assumes that the avoided RCRA regulatory costs for facilities operating under the pre-2008 DSW exclusions, will on a per-facility average annual basis, be the same as the 14 RCRA regulatory requirements avoided as presented in Exhibit 4A above for the 2008 DSW exclusions.  Furthermore, net market prices from recovered commodities are assumed to be similar as those estimated for the recovered metals, solvents and acids in the 2008 DSW final rule RIA.

As displayed below in Exhibit 4M, assuming an average annual per-facility RCRA regulatory cost savings of $19,532 per year for the estimated 5,321 facilities with pre-2008 DSW exclusions (from Exhibit 3L above), produces an estimate of $103.9 million per year (2011$ @ 0% discount rate) in average annual RCRA regulatory cost savings (i.e., ($19,532 cost savings per facility per year) x (5,321 facilities)).  This cost savings is $95.1 million per year at 3% and $79.3 million per year at 7%.

                                  Exhibit 4M
          Estimated Baseline Annual Cost Savings to Industry for the
             Pre-2008 DSW Industrial Recycling Exclusions (2011$)
                                       A
                                       B
                                       C
                                       D
                         Pre-2008 DSW exclusion (item)
                            Affiliated NAICS Codes
                         (from column F of Exhibit 3I)
     Count of Facilities Assumed to Have Pre-2008 DSW Recycling Exclusions
                         (from Column E of Exhibit 3L)
              Baseline RCRA Regulatory Cost Savings ($ per year)
                                       1
31 +32 + 33 manufacturing
                                                                          5,291
                                                                    $78,840,500
                                       2
Assume captured in item 1 above
                                                                      In item 1
                                                                      In item 1
                                       3
Assume captured in item 1 above
                                                                      In item 1
                                                                      In item 1
                                       4
322110 pulp mills
                                                                      In item 1
                                                                      In item 1
                                       5
325188 other basic inorganic chem mfg
                                                                      In item 1
                                                                      In item 1
                                       6
Assume captured in item 1 above
                                                                      In item 1
                                                                      In item 1
                                       7
321114 wood preservation
                                                                      In item 1
                                                                      In item 1
                                       8
324199 coke oven products
                                                                      In item 1
                                                                      In item 1
                                       9
331111 iron & steel manufacturing
                                                                      In item 1
                                                                      In item 1
                                      10
324110 petroleum refineries
                                                                      In item 1
                                                                      In item 1
                                      11
562920 materials recovery facilities
                                                                              3
                                                                        $44,703
                                      12
Assume captured in item 11 above
                                                                     In item 11
                                                                     In item 11
                                      13
2122 minerals mining
                                                                             27
                                                                       $402,323
                                      14
32519 organic chemical mfg
                                                                      In item 1
                                                                      In item 1
                                      15
Assume captured in item 1 above
                                                                      In item 1
                                                                      In item 1
                                      16
Assume captured in item 1 above
                                                                      In item 1
                                                                      In item 1
                            Non-duplicative column totals (@7% discount rate) =
                                                                          5,321
                                                                  $79.3 million
                                                            @3% discount rate =
                                                                  $95.1 million
                                                            @0% discount rate =
                                                                 $103.9 million

Because of incorrect (unnecessary) data reporting, there are actually some very limited data on the pre-2008 DSW exclusion materials available from the 2007 BR.  The 2007 BR reports on a portion of the material (303,509 tons per year) managed under the pre-2008 exclusions (see Exhibit 3H above).  The 12 conditions and their associated costs from the 2008 DSW final rule are included in the baseline cost savings estimate (presented above in Section 4B) for the excluded materials identified in the 2007 BR.  However, the 2011 DSW proposed rule for pre-2008 DSW excluded materials proposes two of these conditions (conduct due diligence to determine legitimacy of recyclers and biennial notification).  Thus, the estimate double-counts these costs, but the aggregate compliance costs are small.

For hazardous secondary materials under pre-2008 DSW exclusions, the recovery costs net out to zero due to equivalent pre-and post-2011 DSW proposed rule costs.  Therefore, recovery costs are not estimated and included in the baseline.  From Exhibit 4G above, average cost savings per facility (including costs associated with the 12 conditions of the 2008 DSW final rule) are estimated to be $19,532/facility or $70/ton.  The estimated baseline cost savings is approximately $21.2 million per year (303,509 tons/year x $70/ton).  For the 13% "base case" adoption scenario, the estimated baseline cost savings is $2.8 million per year ($21.2 million per year x 13%).  These quantities and cost savings are already captured in Section 4C above and are excluded from the totals in Exhibit 4M to avoid double-counting.

4D.	Summary of Baseline De-Regulatory Cost Savings Estimates for DSW Recycling Exclusions

   * 7% discount rate: The total baseline de-regulatory costs savings is estimated at $86.7 million per year (2011$):
         o 2008 DSW exclusions contribute $7.4 million per year to this total assuming a 13% rate of DSW exclusion notification.
         o Pre-2008 DSW exclusions contribute $79.3 million per year.
   * 3% discount rate: The total baseline de-regulatory costs savings is estimated at $103.1 million per year (2011$).
         o 2008 DSW exclusions contribute $10.8 million per year to this total assuming a 13% rate of DSW exclusion notification.
         o Pre-2008 DSW exclusions contribute $92.3 million per year.
   * 0% discount rate: The total baseline de-regulatory costs savings is estimated at $119.0 million per year (2011$).
         o 2008 DSW exclusions contribute $15.1 million per year to this total assuming a 13% rate of DSW exclusion notification.
         o Pre-2008 DSW exclusions contribute $103.9 million per year.
                                   Chapter 5
                 Estimate of Industry Costs to Comply with the
            2011 Proposed Revisions to the DSW Recycling Exclusions

This chapter estimates the potential future costs to industry to comply with eight options for revising the DSW recycling exclusions.  Seven of the options (i.e., Option 1 thru Option 7) are described in EPA's Federal Register notice for the 2011 proposed revisions to the DSW recycling exclusions.  The final option (Option 8) presented in this chapter is not described in EPA's 2011 notice, but represents a preliminary option formulated by EPA at the September 2010 launch of this RIA.

For estimating potential industry costs, this RIA began by updating and revising the relevant unitized (i.e., per-facility) cost savings as estimated in EPA's RIA for the 2008 DSW final rule.  The cost analysis basically involved determining the incremental cost (or cost savings) of each proposed revision, relative to the requirements promulgated in the 2008 DSW final rule.  In other words, this RIA uses the average annual cost savings estimates from the 2008 RIA, as a "baseline" for the incremental analysis of the 2011 proposed revisions.  Appendix B to this RIA provides background calculations for factors applied in estimating costs in this chapter.

Note: To avoid duplication of text in this RIA, descriptions for each DSW revision option are not re-produced in this chapter.  Refer to Chapter 2 of this RIA for descriptions and details for each option.

Option 1:  Withdraw the 2008 DSW Exclusion for Offsite Transfer Recycling

The estimated baseline cost savings for the 2008 DSW offsite transfer recycling exclusion (i.e., 2008 DSW finale rule "Exclusion 2") is $88.5 million per year (see Exhibit 4G, Column D) if all affected facilities notify.  Based on the 13% base case adoption scenario, the annual cost for withdrawing the transfer-based exclusion is estimated to be $5.7 million per year calculated as follows:
      [($89.4 million/year) x (6.3423% cost adjustment reflecting a 13% base case adoption rate and 7% discount rate for the 50-year future period of analysis)].
Option 2:  Implement Alternative RCRA Subtitle C Regulation for the 2008 DSW Offsite Transfer Recycling Exclusion

	Requirement 2A:  Extended Accumulation Time Transportation Cost Savings

Potential transportation cost savings for Option 2 were calculated as the savings resulting from extending the accumulation time up to one year which was removed from the baseline cost savings estimate under Option 1 and adjusted for the potential transportation cost savings resulting from the DSW re-manufacturing exclusion under Option 6.  One of the 14 burden costs relaxed under the 2008 DSW final rule was the allowance of accumulation up to one year.  Under the 2008 DSW final rule "speculative accumulation" provisions (40 CFR 261.1(c)(8)) it required that during a calendar year the amount of material that is recycled, or transferred to a different site for recycling, must equal at least 75% by weight or volume of the material at the beginning of the period.  The estimated accumulation baseline transportation cost savings for the speculative accumulation provisions in the 2008 DSW RIA for extending accumulation up to one year and reducing the number of shipments was $40.5 million (2007$) (from Exhibit 6C, Item 14 under Exclusion 2 of the 2008 DSW RIA).  Adjusting this number using the tonnage adjustment factor, inflation adjustment factor, and 13% "base case"  adoption scenario produces $2,633,406/year (2011 $), calculated as follows:
      [($40,530,443 per year) x (1.0505 inflation adjustment factor) x (1  -  0.0248 tonnage adjustment factor) x (6.3423% cost adjustment reflecting a 13% base case rate and 7% discount rate for the 50-year future period of analysis)].

	Requirement 2B:  Notification

Requires submittal of a notification using EPA Form 8700-12 prior to operating, and thereafter biennially, under the 2008 DSW offsite transfer recycling exclusion.  Labor hour and O&M cost estimates were obtained from EPA's ICR for the "Supporting Statement for EPA Information Collection Request Number 2310.01 Revisions to the RCRA Definition of Solid Waste (Final Rule)", October 28, 2008.  Labor rate estimates were obtained from EPA's ICR for the "Supporting Statement  for Revisions to the RCRA Definition of Solid Waste (Proposed Rule) OMB Control No. 2050-0202, EPA ICR No. 2310.02," June 30, 2011.  Labor hours include 0.1 hours of managerial time at $101.68/hour, 0.3 hours of technical labor at $69.32/hour, and 0.1 hours of clerical labor at $24.67/hour with $0.44 in postage.  The unit costs are estimated to be $33.87 per initial notification/facility and $2.91 for re-notification/facility (2011$).  The total cost is $2.91 for re-notification/facility every two years which equals $1.46/facility (2011$) under the baseline transfer-based recycling exclusion will transfer over and cover the cost to re-notify biennially under the alternative RCRA Subtitle C regulation.

In addition, facilities are required to update and submit notification that the hazardous secondary materials are no longer managed in accordance with the alternative Subtitle C standard.  This cost is assumed to be captured through the process of notifying biennially.

The unit cost is applied to transfer-based exclusion facilities minus re-manufacturing exclusion facilities (4,656  -  201 = 4,455).  The aggregate annual cost for notification is $413 per year, calculated as follows:
      [(4,455 facilities) x ($1.46/facility/year) x (6.3423% cost adjustment reflecting the 13% base case adoption scenario, and 7% discount rate for the 50-year future period of analysis)].

      Requirement 2C: Require Advance Arrangements (Reclamation Plan)

Requires advance arrangements (including reclamation plan) for 2008 DSW excluded recycling.  The rationale is that it would prevent the problem of generators accumulating potentially unrecyclable hazardous secondary materials.  Documenting contractual arrangements will result in incurred costs.  As a proxy for this cost, unit cost estimates for the notification of intent to export were used for 40 CFR 262.53 and 262.83(e).  Unit cost estimates were obtained from EPA's ICR for the "Supporting Statement for EPA Information Collection Request Number 0820.10 Hazardous Waste Generator Standards (Renewal)," January 2008.  Exporters to OECD countries (262.83(e)) are required to provide the following information in their notification to export waste for recycling:

   * Fax number
   * Serial number/identifier of notification form
   * Intended carrier(s) and/or agents
   * Countries of export, import, and transit and relevant authorities
   * Certification of the existence of written contract, chain of custody, or equivalent arrangement with consignee, between exporter and importer
   * Certification that the information is complete and correct
   * Certification of financial guarantee if required by any concerned country (importing and transit).

The requirement for advance arrangements is assumed to be a contract similar to the costs for exporting to OECD countries which includes "certification of the existence of written contract, chain of custody, or equivalent arrangement with consignee, between exporter and importer."  The cost to collect the specific information under 40 CFR 262.83(e) includes 1.5 hours of technical labor at $69.32/hour and $0.55 for copies for a total of $104.58 per facility (2011$).  It is assumed this information is to be kept on file and submitted to EPA only upon request.  The cost to prepare and maintain on file for a minimum of three years advance arrangement documents (reclamation plan) includes 0.1 hours of managerial labor at $101.68/hour, 0.3 hours of technical labor at $69.32/hour and 1.5 hours of clerical labor at $24.67/hour  for a total of $65.26/facility (2011$).  As a proxy, assume that EPA requests documentation of the reclamation plan once every 20 facilities which includes 0.16 hours of clerical labor at $24.67/hour and $0.44 in postage for a total cost of $0.22/facility (2011$).  The total cost is $170.02 per facility (2011$).

This cost is applied to transfer-based exclusion facilities only.  From Exhibits 4E and 4G (columns D of both), respectively, minus re-manufacturing exclusion counts from Exhibits 5G and 5H (Column C of both), respectively, there are 4,455 affected offsite recycling exclusion facilities and 833,499 affected tons from transfer-based facilities.  The aggregate annual cost to prepare advance arrangements is $48,000 per year, calculated as follows:
      [(4,455 facilities x $170.02/facility/year x 6.3423% cost adjustment reflecting the 13% base case adoption scenario, and 7% discount rate for the 50-year future period of analysis[)][]].

	Requirement 2D:  Accumulation Restrictions

Allows accumulation of hazardous recyclable materials by the generator for up to one year, but prohibits accumulation of no more than two shipments of hazardous recyclable materials at any one time.  The rational is that limiting the time period to a maximum of 12 months (as opposed to up to two years) reduces the possibility of discard from over-accumulation of materials.

The 2008 DSW final rule "speculative accumulation" provisions (40 CFR 261.1(c)(8)) require that during a calendar year the amount of material that is recycled, or transferred to a different site for recycling, must equal at least 75% by weight or volume of the material at the beginning of the period.  Under the new requirement restricting accumulation to up to one year, the remaining 25% by weight or volume of the material can no longer be carried over into a second calendar year.  Increased cost from shorter speculative accumulation time limits for recycled materials will occur because of increases in shipping and transportation costs. A 12-month time limit for speculative accumulation (rather than two years) will increase the number of shipments for affected hazardous secondary material.  This RIA assumes that 15% of the annual tonnage is speculatively accumulated longer than a year.  The number of shipments (or loads) is determined by dividing the tons recycled by 18 tons per truck load (typical truck size).  From the 2008 DSW RIA, DPRA used professional judgment and RACER cost estimating software and inflated RACER 2005 unit costs to 2007$ using the GDP implicit price deflator to estimate waste testing and transport unit costs.  Waste testing is estimated to cost $346/load (2007$) and an average transport cost for recovery is $2,517/load (2007$).

The average annual cost for reducing the speculative accumulation time period to one year inflated to 2011$ is $2,644/load.  There are 4,455 affected transfer-based exclusion facilities generating 833,499 tons per year (from Exhibit 4E and Exhibit 4FColumn D, respectively, minus Exhibit 5G and Exhibit 5H Column C, respectively).  The aggregate annual cost to reduce the speculative accumulation time period is $1.2 million per year, calculated as follows:
      [(833,499 tons per year) / (18 tons per truck load) x ($2,644/load) x (15% of tonnage speculatively accumulated longer than one year) x (6.3423% cost adjustment reflecting the 13% base case adoption scenario, and 7% discount rate for the 50-year future period of analysis))].

      Requirement 2E.1: Speculative Accumulation Labeling

Requires the speculative accumulation start date to be labeled on each container, and allowing other procedures (such as posting of accumulation dates or entering dates in inventory logs) to ensure against speculative accumulation in other types of units not amenable to labeling.  The rationale is that without a record of a start date for accumulation, this provision is difficult to enforce.  While it is possible to use 40 CFR 261.2(f) to enforce speculative accumulation provisions, making the recordkeeping explicit would render the provision much more enforceable.  The net cost impact of this revision is zero because it is likely that facilities already are placing the accumulation start date on containers to ensure compliance with the one year accumulation limit: "Speculative accumulation" provisions (40 CFR 261.1(c)(8)) require that during a calendar year (beginning Jan 1) the amount of material that is recycled, or transferred to a different site for recycling, must equal at least 75% by weight or volume, of material at the beginning of the period.

	Requirement 2E.2: Contingency and Emergency Plans

Requires facilities to develop a spill control/contingency plan including personnel training and a chemical analysis plan, and allows facilities to use existing plans developed for other statutes if applicable.  The rationale is it helps prevent or limit the potential for discard through spills, accidents or fires.  Five percent of damage cases were from accidents.  All offsite transfer recyclers will incur costs to develop contingency plans and emergency plans.  Unit cost estimates were obtained and estimated from EPA's ICR for the "Supporting Statement for EPA Information Collection Request Number 0820.10 Hazardous Waste Generator Standards (Renewal)," January 2008.  Under contingency planning requirements in 265.37(b), 265.51, 265.52, and 265.53(a) the following costs are incurred by LQGs and SQGs:
         * Collecting job-related data uses 0.5 hours of clerical labor at $24.67/hour and equals $12.34/LQG and $12.34/SQG (2011$).
         * Maintaining information at facility uses 0.1 hours of clerical labor at $24.67/hour and equals $2.47/LQG and $2.47/SQG (2011$).

Total personnel training costs for LQGs are $14.81/LQG and for SQGs are $14.81/SQG (2011$).
   *             Collect data required in contingency plan uses 2.0 hours technical labor at $69.32/hour and 1.0 hour of clerical labor at $24.67/hour and equals $163.32/LQG (2011$).
   *             Document whether authorities decline arrangement includes 0.1 clerical hours at $24.67/hour and equals $2.47/LQG (2011$).
   *             Write contingency plan includes 6.0 technical labor at $69.32/hour and 2.0 clerical hours at $24.67/hour and equals $466.29/LQG (2011$).
   *             Maintain contingency plan includes 0.1 clerical hours at $24.67/hour and equals $2.47/LQG (2011$).
   *             Submit contingency plan to relevant emergency centers includes 0.16 clerical hours at $24.67/hour and equals $3.95/LQG and $4.07/LQG in postage and copying (2011$).
   *             Amend contingency plan when appropriate includes 1.0 hour technical labor at $69.32/hour and 1.0 hour clerical labor at $24.67/hour and $0.11 in photocopying and equals $94.10/LQG (2011$).

Total contingency plan cost for LQGs is $736.67/LQG (2011$).  SQGs and CESQGs are not required to have contingency plans.

Under emergency procedure requirements in 40 CFR 265.56(d) the following costs are incurred by LQGs:
   *             Collecting information required in emergency report includes 1.0 hour technical labor at $69.32/hour and 1.0 hour clerical labor at $24.67/hour and equals $93.99/LQG (2011$).
   *             Writing an emergency report includes 0.17 hours of legal at $133.37/hour and 1.0 hour of technical labor at $69.32/hour and equals  $91.99/LQG (2011$).
   *             Calling OSC or notifying NRC and notifying local authorities if advisable includes 0.1 hours managerial labor at $101.68/hour and 0.9 hours technical labor at $69.32/hour and equals $72.56/LQG and $10.38 in O&M costs (2011$).
   *             The total cost is $268.92/LQG (2011$).

Under emergency procedure requirements in 265.34(d) the following costs are incurred by SQGs:
         * Observing scene of hazardous waste discharge includes 0.5 hours of technical labor at $69.32/hour and equals $34.66/SQG (2011$);
         * Reporting by phone requested data for NRC includes 0.5 hours of technical labor at $69.32/hour and $5.19 in other charges and equals $39.85/SQG (2011$);
         * Documenting that local officials declines to enter into arrangements for coordinating response includes 0.1 hour technical labor at $69.32/hour and equals $6.93/SQG (2011$); and
         * Providing post-emergency information by phone includes 0.1 hours clerical labor at $24.67/hour and equals $2.47/SQG (2011$).
         * The total cost is $83.91/SQG (2011$).

Under certification of compliance in 265.56(i) the following costs are incurred by LQGs and SQGs:
         * Collect information required in emergency notification report includes 0.5 hours technical labor at $69.32/hour and 0.5 hours of clerical labor at $24.67/hour and equals $47.00/LQG (2011$).
         * Write emergency notification report includes 0.17 hours of legal labor at $133.37/hour, 0.5 hours of technical labor at $69.32/hour and 0.5 hours of clerical labor at $24.67/hour and equals $69.67/LQG (2011$).
         * Submit report to Regional Administrator includes 0.16 hours of clerical labor at $24.67/hour and $0.99 for postage and photocopies and equals $4.94/LQG (2011$).
         * Compile information demonstrating compliance includes 0.5 hours of technical labor at $69.32/hour and 0.5 hours of clerical labor at $24.67/hour and equals $47.00/LQG (2011$).
         * Total cost is $168.61/LQG (2011$).  This RIA assumes the total cost for SQGs is two-thirds of the LQG labor cost at $112.73/SQG plus $0.99/SQG for postage and photocopies (2011$).

Cumulative total cost is $1,201.25/LQG, $194.64/SQG and $0/CESQG (2011$).  Because of the withdrawal of the 2008 DSW offsite transfer-based exclusion under Option 1 the RCRA generator status for these facilities revert to their baseline status.  From Column B of Exhibit 4I, the 4,656 transfer-based facilities are comprised of 3,752 LQGs (80.6%), 829 SQGs (17.8%), and 75 CESQGs (1.6%).  The weighted-average cumulative cost calculates to $1,002.86/facility (2011$).  Assume contingency plans are revised every 10 years.  The average annual cost is $100.29/facility/year (2011$).  It is applied to transfer-based exclusion facilities only.  From Exhibit 4E, there are 4,455 affected transfer-based exclusion facilities (minus 201 re-manufacturing exclusion facilities).  The aggregate annual cost to prepare advance arrangements is $28,000 per year calculated as follows:
      (4,455 facilities) x ($100.29 per facility per year) x (6.3423% cost adjustment reflecting the 13% base case adoption scenario, and 7% discount rate for the 50-year future period of analysis).

	Requirement 2F.1: Recordkeeping of Off-site Shipments

Retains current shipment requirements with no changes (i.e., all parties must retain records of off-site shipments and confirmation of receipts for three years).  The rationale is that materials most likely to pose a hazard during transport will still be subject to DOT standards.  Creating a new form or adopting the hazardous waste manifest form will be time-consuming and may not be worth the additional level of protection.  All generators will incur cost.  In the 2008 DSW RIA, costs were assumed to be direct labor costs for a staff engineer to conduct annual record keeping associated with RCRA hazardous waste management.  Labor hours and labor costs are estimated based on DPRA professional judgment (2007$):  LQGs use 9.0 hours of labor at a cost of $702 per year per facility, SQGs use 6.0 hours of labor at a cost of $468 per year per facility, and CESQGs use 3.0 hours of labor at a cost of $234 per year per facility.  Because of the withdrawal of the 2008 DSW offsite transfer-based exclusion under Option 1 the RCRA generator status for these facilities revert to their baseline generator status.  From Column B of Exhibit 4I, the 4,656 transfer-based facilities are comprised of 3,752 LQGs (80.6%), 829 SQGs (17.8%), and 75 CESQGs (1.6%).  The weighted-average cumulative cost calculates to $649/facility (2007$).  The average annual cost for recordkeeping of off-site shipments inflated to 2011$ is $682 per facility.  It is applied to transfer-based exclusion facilities only.  From Exhibit 4E, there are 4,455 affected transfer-based exclusion facilities minus the 201 re-manufacturing exclusion facilities.  The aggregate annual cost to prepare advance arrangements is $193,000 per year, calculated as follows:
      [(4,455 facilities x $682/facility/year x 6.3423% cost adjustment reflecting the 13% base case adoption scenario, and 7% discount rate for the 50-year future period of analysis)].

      Requirement 2F.2: Transport to RCRA Permit Facility

Replaces the 2008 DSW offsite transfer recycling exclusion with an alternative hazardous waste regulation that requires that material be sent to a RCRA-permitted facility for recycling.  The rationale is that it would allow EPA to add conditions without linking each one to "discard."  TSDRFs will incur costs as a result of maintaining RCRA permits.  Before the 2008 DSW final rule, generators were transferring RCRA hazardous waste to RCRA permitted facilities and this practice would now resume under Requirement 2E.2.  The estimated cost savings in the 2008 DSW final rule was $1,620,000 per year (2007$) for not having to renew RCRA permits.  The cost of renewing RCRA permits will continue under the 2011 DSW proposed rule at a total cost of $1,620,000 per year (2007$).  The total cost in 2011$ is $1,702,000.  Discounting these costs from 2015 to 2011 equals $1,298,000 reflecting a 7% discount rate for the 50-year period of analysis ($1,702,000/(1.07)[4]).

   Option 2 (Plus Option 1) Total Cost

Option 2 is implemented in conjunction with Option 1.  The total cost for Option 2 equals baseline cost savings plus Option 1 plus Option 2.
   * 7% discount rate:  The modified baseline cost savings estimate is $7.4 million from the 2008 DSW rule minus $5.7 million from the withdrawal of the off-site transfer exclusion under Option 1 plus $2.6 million under Option 2 for the retention of the one-year accumulation time and its associated transportation cost savings equals $4.3 million per year.  Costs associated with meeting the requirements of Option 2 are $2.7 million per year.  Baseline cost savings associated with the 2008 DSW final rule are reduced from $7.4 million per year under the 2008 DSW rule to $1.6 million per year post 2011 DSW proposed rule (Exhibit 5A).
   * 3% discount rate:  The modified baseline cost savings estimate is $10.8 million from the 2008 DSW rule minus $8.6 million from the withdrawal of the off-site transfer exclusion under Option 1 plus $4.0 million under Option 2 for the retention of the one-year accumulation time and its associated transportation cost savings equals $6.2 million per year.  Costs associated with meeting the requirements of Option 2 are $3.7 million per year.  Baseline cost savings associated with the 2008 DSW final rule are reduced from $10.8 million per year under the 2008 DSW rule to $2.4 million per year post 2011 DSW proposed rule (Exhibit 5B; totals in text due not match exhibit due to rounding).
   * 0% discount rate:  The modified baseline cost savings estimate is $15.1 million from the 2008 DSW rule minus $12.0 million from the withdrawal of the off-site transfer exclusion under Option 1 plus $5.6 million under Option 2 for the retention of the one-year accumulation time and its associated transportation cost savings equals $8.7 million per year.  Costs associated with meeting the requirements of Option 2 are $4.7 million per year.  Baseline cost savings associated with the 2008 DSW final rule are reduced from $15.1 million per year under the 2008 DSW rule to $4.0 million per year post 2011 DSW proposed rule (Exhibit 5C; totals in text due not match exhibit due to rounding).

                                  Exhibit 5A
Estimated Baseline Cost Savings, Compliance Costs, and Post-Rule Cost Savings for Implementing
Alternative RCRA Subtitle C Regulation for the 2008 Offsite Transfer Recycling Exclusion (Option 2)
               (13% Adoption Rate, 2011$, and 7% Discount Rate)
                                     Item
                               Industry 2-digit
                                  NAICS code
                                       A
                                       B
                                       C
                                       D
                                       E
                                       F
                                       G
                                       H
                                       I
                                  J (C+...+I)

                  Count of Affected Transfer-Based Facilities
                        Affected Transfer-Based Tonnage
Baseline Cost Savings under 2008 DSW Rule - Option 1 Withdrawn Savings + Req. 2A Accum.. Transp. Cost Savings
 Requirement 2B Notification Compliance Costs (incremental to
2008 DSW Rule)
                                Requirement 2C
     Advance Arrangements Compliance Costs (incremental to 2008 DSW Rule)
Requirement 2D Accumulation Restriction Compliance Costs (incremental to 2008 DSW Rule)
Requirement 2E.2 Contingency Plan Compliance Costs (incremental to 2008 DSW Rule)
Requirement 2F.1 Record-keeping of Offsite Shipments Compliance Costs (incremental to 2008 DSW Rule)
Requirement 2F.2 Transport to RCRA Permit Facility Compliance Costs (incremental to 2008 DSW Rule)
                                   Option 2

          Post-Rule Cost Savings (relative to 2008 DSW Rule baseline)
                                       1
                                      11
Ag, For, Fish, Hunt
                                                                              3
                                                                             12
                                                                           $488
                                                                           ($0)
                                                                          ($29)
                                                                          ($17)
                                                                          ($17)
                                                                         ($117)
                                                                          ($17)
                                                                          $291
                                       2
                                      21
Mining
                                                                             21
                                                                            122
                                                                        $25,401
                                                                           ($2)
                                                                         ($223)
                                                                         ($170)
                                                                         ($131)
                                                                         ($894)
                                                                         ($179)
                                                                       $23,802
                                       3
                                      22
Utilities
                                                                             94
                                                                          1,418
                                                                        $80,097
                                                                           ($9)
                                                                       ($1,017)
                                                                       ($1,982)
                                                                         ($600)
                                                                       ($4,080)
                                                                       ($2,079)
                                                                       $70,330
                                       4
                                      23
Construction
                                                                             21
                                                                            789
                                                                        $15,823
                                                                           ($2)
                                                                         ($223)
                                                                       ($1,103)
                                                                         ($131)
                                                                         ($894)
                                                                       ($1,157)
                                                                       $12,314
                                       5
                                      31
Manufacturing
                                                                             34
                                                                            299
                                                                        $36,633
                                                                           ($3)
                                                                         ($368)
                                                                         ($418)
                                                                         ($217)
                                                                       ($1,476)
                                                                         ($439)
                                                                       $33,711
                                       6
                                      32
Manufacturing
                                                                            975
                                                                        110,970
                                                                     $1,693,191
                                                                          ($90)
                                                                      ($10,515)
                                                                     ($155,084)
                                                                       ($6,203)
                                                                      ($42,168)
                                                                     ($241,327)
                                                                    $1,237,803
                                       7
                                      33
Manufacturing
                                                                          2,244
                                                                        668,158
                                                                     $2,950,712
                                                                         ($208)
                                                                      ($24,193)
                                                                     ($933,770)
                                                                      ($14,271)
                                                                      ($97,018)
                                                                     ($979,646)
                                                                      $901,607
                                       8
                                      42
Wholesale Trade
                                                                            105
                                                                         27,448
                                                                       $109,565
                                                                          ($10)
                                                                       ($1,134)
                                                                      ($38,359)
                                                                         ($669)
                                                                       ($4,546)
                                                                      ($40,244)
                                                                       $24,603
                                       9
                                      44
Retail Trade
                                                                             30
                                                                            229
                                                                        $11,726
                                                                           ($3)
                                                                         ($320)
                                                                         ($320)
                                                                         ($189)
                                                                       ($1,282)
                                                                         ($336)
                                                                        $9,277
                                      10
                                      45
Retail Trade
                                                                              4
                                                                             52
                                                                         $5,785
                                                                           ($0)
                                                                          ($48)
                                                                          ($73)
                                                                          ($29)
                                                                         ($194)
                                                                          ($76)
                                                                        $5,365
                                      11
                                      48
Transportation
                                                                            104
                                                                          1,559
                                                                       $120,416
                                                                          ($10)
                                                                       ($1,124)
                                                                       ($2,179)
                                                                         ($663)
                                                                       ($4,507)
                                                                       ($2,286)
                                                                      $109,647
                                      12
                                      49
Postal, Msgrs, Stor.
                                                                             28
                                                                          1,172
                                                                        $36,719