Former SQG $ 0 $ 522 $ 136 $ 798 1,823 $ 136 $ 798 10,085 $ 12,078,000 Former LQG $ 0 $ 1,983 $ 428 $ 6,068 54 $ 428 $ 6,068 295 $ 2,374,000 Subtotal $ 14,452,000 Original Users Also Generating Non CRT Hazardous Waste Former SQG $ 0 $ 154 $ 117 $ 236 491 $ 117 $ 236 1,602 $ 813,000 Former LQG $ 0 $ 159 $ 117 $ 243 205 $ 117 $ 243 668 $ 347,000 Subtotal $ 1,160,000 Collectors Former SQG $ 0 $ 0 $ 558 $ 3,436 48 $ 558 $ 3,436 50 $ 391,000 Former LQG $ 0 $ 0 $ 1,135 $ 3,319 240 $ 1,135 $ 3,319 250 $ 2,182,000 Subtotal $ 2,573,000 Total Cost to Regulated Generators $ 1,315,000 Total Compliance Costs under the Primary Alternative $ 19,502,000 Note: Total cost numbers rounded to nearest thousand. Costs may not add due to rounding.

4.2.2 Incremental Cost Difference Between the Subtitle C Baseline and the Primary Alternative The primary alternative generates a net savings relative to the baseline, due primarily to reduced administrative requirements and savings from reduced transportation and disposal costs. Savings from the primary alternative accrue to former generators that would no longer be regulated. The range of potential savings under the primary alternative is estimated to be from $2,401,000 33 to $5,071,000, 34 35 Assumes a 3.5 year monitor life, an average monitor weight of 35 pounds, and 90 percent of discarded monitors are color.

August 24, 2001  DRAFT Page 54 with a best estimate of $4,840,000. 35 Exhibit 4 3 summarizes the costs under the baseline and the primary alternative by cost category.

Exhibit 4 3: Costs of Primary Alternative Relative to Subtitle C Baseline Cost Category Baseline Primary Alternative Saving (Cost)

Administrative $ 1,888,000 $ 197,000 $ 1,691,000 Disposal $ 16,373,000 $ 15,128,000 $ 1,245,000 Transportation $ 5,431,000 $ 2,936,000 $ 2,495,000 Storage $ 650,000 $ 1,241,000 $ (591,000)

Total $ 24,342,000 $ 19,502,000 $ 4,840,000 Note: Cost numbers rounded to nearest thousand. Costs may not add due to rounding.

4.2.3 Sensitivity Analysis for the Primary Alternative Individual sensitivity and bounding analysis is conducted on the difference between the Subtitle C baseline and the primary alternative for the following four parameters: monitor weight, monitor lifetime, storage costs, and percent of monitors that are color. Appendix G lists the parameters to which the analysis results are relatively insensitive. The individual sensitivity analysis is conducted by changing one parameter at a time while holding all other parameters at their best estimate value. Exhibit 4 4 contains the upper and lower bounds and the best estimate values for the four parameters as well as the percent change of the lower and upper bounds from the best estimate. The upper and lower bounds were selected because they represent probable limits on the selected parameters. Exhibit 4 5 contains the model results for each individual change. Exhibit 4 6 plots the data in Exhibit 4 5 from the individual sensitivity analysis for the four parameters. The graph illustrates that the analysis is most sensitive to the monitor weight, monitor lifetime, and the percent of color monitors discarded. The graph also indicates that the model results are not linearly related with respect to percent color, monitor weight, and monitor life, since the lines for these parameters are not straight. To determine a potential maximum upper bound on the savings, a combined sensitivity analysis is conducted using a monitor weight of 41 pounds, a monitor lifetime of 3.5 years, the percent of color monitors discarded of 90 percent, and storage cost of zero dollars per square foot. The savings under the combined sensitivity analysis is $5,723,000. August 24, 2001  DRAFT Page 55 Exhibit 4 4: Parameter Values for Individual Sensitivity Analysis Lower Bound % Change from Best Estimate Best Estimate Upper Bound % Change from Best Estimate Monitor Weight 30 lbs. 14 % 35 lbs. 40 lbs. 14 %

Monitor Life 2 years 43 % 3.5 years 5 years 43 %

Storage Cost $ 0 100 % $ 8.30 $ 15 81 %

Percent Color 60 % 33 % 90 % 99 % 10 %

Exhibit 4 5: Individual Sensitivity Analysis Results Lower Bound Best Estimate Upper Bound Monitor Weight $ 4,326,000 $ 4,840,000 $ 5,091,000 Monitor Life $ 4,753,000 $ 4,840,000 $ 3,934,000 Storage Cost $ 5,431,000 $ 4,840,000 $ 4,364,000 Percent Color $ 3,861,000 $ 4,840,000 $ 4,871,000 Numbers rounded to nearest thousand.

Sensitivity analysis is also conducted for disposal costs above and below the best estimate values. By changing the cost for disposal to a hazardous waste landfill to $800 and $1700 per ton for whole CRTs (from a best estimate of $1,500), and to $50 and $250 per ton for crushed CRTs (from a best estimate of $160), the savings ranged from $5,141,000 to $4,175,000. By changing the cost for disposal to a reclaimer to $150 and $500 per ton for whole CRTs (from a best estimate of $295), to $100 and $300 per ton for bare CRTs (from a best estimate of $207), and to $75 and $250 per ton for crushed CRTs (from a best estimate of $152), the savings ranged from $4,642,000 to $4,990,000. By changing the cost for disposal to a collector to $100 and $350 per ton (from a best estimate of $271), the savings ranged from $4,821,000 to $4,879,000. The sensitivity analysis on disposal costs shows that the model is moderately sensitive to hazardous waste disposal costs and only slightly sensitive to the reclaimer and collector disposal costs. 36 The number of televisions disposed of is based on the assumption that there are 100 million households each with two televisions and that the TVs are discarded after ten years. The 20 million TVs discarded is also consistent with the number of televisions sold in 1991, which was 19.5 million. The number of computer monitor CRTs disposed of is based on data from the August 24, 2001  DRAFT Page 56 $3,500,000 $3,750,000 $4,000,000 $4,250,000 $4,500,000 $4,750,000 $5,000,000 $5,250,000 $5,500,000 150% 100% 50% 0% 50% 100%

Percent Change from Best Estimate Total Cost Savings from Baseline ($)

Monitor Weight Monitor Life Storage Cost Percent Color Exhibit 4 6: Plot of Individual Sensitivity Analysis Results for the Primary Alternative Note: Lines with relatively steeper slopes indicate greater sensitivity of the results to changes (or uncertainty) in the given parameters.

4.2.4 Incremental Cost Difference Between the Subtitle C Baseline and the Primary Alternative, Including Currently Unregulated Monitors and Televisions To help understand how the two regulatory alternatives might be affected by capacity issues, the total cost of compliance under the Subtitle C baseline and the primary alternative is calculated including CRTs from conditionally exempt small quantity generators (CESQG) and households. It is assumed that 20 million unregulated television CRTs are disposed and 16.7 million unregulated computer monitor CRTs are disposed from households and CESQGs. 36 Exhibit 4 7 contains a US Census, Survey of Computer Use, 1997, which estimates that 52 percent of households have computers.

August 24, 2001  DRAFT Page 57 summary of the costs under the baseline and the primary alternative by cost category. Disposal costs are higher under the primary alternative than the baseline because it is assumed that a greater percentage of unregulated CRTs are sent to collectors, which increases the number of CRTs that have a non zero disposal cost under the primary alternative.

Exhibit 4 7: Costs of Primary Alternative Relative to Subtitle C Baseline, Including Unregulated Monitors and Televisions Cost Category Baseline Primary Alternative Saving (Cost)

Administrative $ 1,984,000 $ 197,000 $ 1,787,000 Disposal $ 20,854,000 $ 21,824,000 $ (970,000)

Transportation $ 6,790,000 $ 5,893,000 $ 897,000 Storage $ 650,000 $ 1,241,000 $ (591,000)

Total $ 30,278,000 $ 29,155,000 $ 1,123,000 Note: Cost numbers rounded to nearest thousand. Costs may not add due to rounding.

The analysis estimates that 51,800 tons of CRT glass are sent to glass processors and that, of this, 50,700 tons of CRT glass are sent to CRT glass manufacturers. The quantity of CRTs sent to glass processors may be above the capacity limit for glass processors, since the capacity of one of the processors is not precisely known. The quantity sent to CRT glass manufacturers is below the capacity limits for CRT glass manufacturers. As the CRT recycling infrastructure grows and additional unregulated CRTs are recycled, the capacities of both glass processors and glass manufacturers will be exceeded. This analysis does not attempt to predict when this might occur.

4.3 CSI Alternative 4.3.1 Costs Under the CSI Alternative The total applicable cost of compliance under the CSI alternative is calculated for all of the entities described in Section 4.1, and for all of the entities that were formerly generators but that no longer are required to comply with the hazardous waste regulations. These are called CSI handlers. Exhibit 4 8 presents the cost per CSI handler for administrative, storage, transportation, and disposal, and for the total cost of compliance under the CSI alternative. Administrative costs are assumed to be the same for all CSI handlers in each size category (small or large). The other costs vary across the categories (based on RCRA requirements for different types of generators, on the average number of 37 Assumes a six year monitor life, an average monitor weight of 35 pounds, and 75 percent of discarded monitors are color.

38 Assumes a 3.5 year monitor life, an average monitor weight of 41 pounds, and 89 percent of discarded monitors are color.

August 24, 2001  DRAFT Page 58 CRTs discarded, and on the CRT management method used by that generator). So Exhibit 4 8 presents the average cost for CSI handlers.

The average transportation and disposal cost for SQGs and LQGs changes between the baseline and the CSI alternative because, in the baseline, five CRT management options (collector, reuse, processor, smelter, and hazardous waste landfill) are available while in the CSI alternative only two CRT management options (lead smelter and hazardous waste landfill) are available for regulated generators, and only three of the CRT management options are available (collector, reuse, and processor) for CSI handlers.

Exhibit 4 8: CSI Alternative Compliance Costs Under the Subtitle C Baseline Average Costs per Generator Number of Regulated Generators Average Costs per Potentially Regulated Generator Number of Potentially Regulated Generators Total Cost Admin. Storage Transp. Disposal Transp. Disposal CSI Handlers SQH $ 100 $ 529 $ 125 $ 809 2,452 $ 125 $ 809 10,752 $ 13,874,000 LQH $ 0 $ 0 $ 0 $ 0 0 $ 0 $ 0 0 $ 0 Subtota l $ 13,874,000 Total Cost to Regulated Generators 7,371,000 Total Compliance Costs under the CSI Alternative $ 21,244,000 Note: Total cost numbers rounded to nearest thousand. Costs may not add due to rounding.

4.3.2 Incremental Cost Difference Between the Subtitle C Baseline and the CSI Alternative The CSI alternative generates a net savings relative to the baseline, due primarily to reduced administrative requirements and savings from reduced transportation and disposal costs. Savings from the CSI alternative accrue to CSI handlers that would no longer be regulated. The range of potential savings under the CSI alternative is estimated to be from $1,504,000 37 to $3,402,000, 38 with a best 39 Assumes a 3.5 year monitor life, an average monitor weight of 35 pounds, and 90 percent of discarded monitors are color.

August 24, 2001  DRAFT Page 59 estimate of $3,098,000. 39 Exhibit 4 9 summarizes the costs under the baseline and the CSI alternative by cost category.

Exhibit 4 9: Costs of CSI Alternative Relative to Subtitle C Baseline Cost Category Baseline Primary Alternative Saving (Cost)

Administrative $ 1,888,000 $ 826,000 $ 1,062,000 Disposal $ 16,373,000 $ 15,356,000 $ 1,017,000 Transportation $ 5,431,000 $ 3,667,000 $ 1,764,000 Storage $ 650,000 $ 1,395,000 $ (745,000)

Total $ 24,342,000 $ 21,244,000 $ 3,098,000 Note: Cost numbers rounded to nearest thousand. Costs may not add due to rounding.

4.3.3 Sensitivity Analysis for the CSI Alternative Individual sensitivity and bounding analysis is conducted on the difference between the Subtitle C baseline and the CSI alternative for the following four parameters: monitor weight, monitor lifetime, storage costs, and percent of monitors that are color. Appendix G lists the parameters to which the analysis results are relatively insensitive. The individual sensitivity analysis is conducted by changing one parameter at a time while holding all other parameters at their best estimate value. Exhibit 4 10 contains the upper and lower bounds and the best estimate values for the four parameters as well as the percent change of the lower and upper bounds from the best estimate. The upper and lower bounds were selected because they represent probable limits on the selected parameters. Exhibit 4 11 contains the model results for each individual change. Exhibit 4 12 plots the data in Exhibit 4 11 from the individual sensitivity analysis for the four parameters. The graph illustrates that the analysis is most sensitive to the monitor weight, monitor lifetime, and the percent of color monitors discarded. The graph also indicates that the model results are not linearly related with respect to percent color, monitor weight, and monitor life, since the lines for these parameters are not straight. To determine a potential maximum upper bound on the savings, a combined sensitivity analysis is conducted using a monitor weight of 35 pounds, a monitor lifetime of 2 years, the percent of color monitors discarded of 99 percent, and storage cost of zero per square foot. The savings under the combined sensitivity analysis is $4,221,000. August 24, 2001  DRAFT Page 60 Exhibit 4 10: Parameter Values for Individual Sensitivity Analysis Lower Bound % Change from Best Estimate Best Estimate Upper Bound % Change from Best Estimate Monitor Weight 30 lbs. 14 % 35 lbs. 40 lbs. 14 %

Monitor Life 2 years 43 % 3.5 years 5 years 43 %

Storage Cost $ 0 100 % $ 8.30 $ 15 81 %

Percent Color 60 % 33 % 90 % 99 % 10 %

Exhibit 4 11: Individual Sensitivity Analysis Results Lower Bound Best Estimate Upper Bound Monitor Weight $ 2,677,000 $ 3,098,000 $ 3,365,000 Monitor Life $ 2,735,000 $ 3,098,000 $ 2,386,000 Storage Cost $ 3,843,000 $ 3,098,000 $2,496,000 Percent Color $ 2,343,000 $ 3,098,000 $3,157,000 Numbers rounded to nearest thousand.

Sensitivity analysis is also conducted for disposal costs above and below the best estimate values. By changing the cost for disposal to a hazardous waste landfill to $800 and $1700 per ton for whole CRTs (from a best estimate of $1,500), and to $50 and $250 per ton for crushed CRTs (from a best estimate of $160), the savings ranged from $3,336,000 to $2,580,000. By changing the cost for disposal to a reclaimer to $150 and $500 per ton for whole CRTs (from a best estimate of $295), to $100 and $300 per ton for bare CRTs (from a best estimate of $207), and to $75 and $250 per ton for crushed CRTs (from a best estimate of $152), the savings ranged from $3,171,000 to $3,050,000. By changing the cost for disposal to a collector to $100 and $350 per ton (from a best estimate of $271), the savings ranged from $3,139,000 to $3,008,000. The sensitivity analysis on disposal costs shows that the model is moderately sensitive to hazardous waste disposal costs and only slightly sensitive to the reclaimer and collector disposal costs. August 24, 2001  DRAFT Page 61 $2,200,000 $2,400,000 $2,600,000 $2,800,000 $3,000,000 $3,200,000 $3,400,000 $3,600,000 $3,800,000 $4,000,000 150% 100% 50% 0% 50% 100%

Percent Change from Best Estimate Total Cost Savings from Baseline ($)

Monitor Weight Monitor Life Storage Cost Percent Color Exhibit 4 12: Plot of Individual Sensitivity Analysis Results for the CSI Alternative Note: Lines with relatively steeper slopes indicate greater sensitivity of the results to changes (or uncertainty) in the given parameters.

4.3.4 Incremental Cost Difference Between the Subtitle C Baseline and the CSI Alternative, Including Currently Unregulated Monitors and Televisions To help understand how the two regulatory alternatives might be affected by capacity issues, the total cost of compliance under the Subtitle C baseline and the CSI alternative is also calculated including CRTs from households and CESQGs. It is assumed that 20 million unregulated television CRTs are disposed and 16.7 million unregulated computer monitor CRTs are disposed from 40 The number of televisions disposed of is based on the assumption that there are 100 million households each with two televisions and that the TVs are discarded after ten years. The 20 million TVs discarded is also consistent with the number of televisions sold in 1991, which was 19.5 million. The number of computer monitor CRTs disposed of is based on data from the US Census, Survey of Computer Use, 1997, which estimates that 52 percent of households have computers.

August 24, 2001  DRAFT Page 62 households and CESQGs. 40 Exhibit 4 13 contains a summary of the costs under the baseline and the CSI alternative by cost category.

Exhibit 4 13: Costs of CSI Alternative Relative to Subtitle C Baseline, Including Unregulated Monitors and Televisions Cost Category Baseline CSI Alternative Saving (Cost)

Administrative $ 1,984,000 $ 855,000 $ 1,129,000 Disposal $ 20,854,000 $ 18,834,000 $ 2,020,000 Transportation $ 6,790,000 $ 4,988,000 $ 1,802,000 Storage $ 650,000 $ 1,395,000 $ (745,000)

Total $ 30,278,000 $ 26,072,000 $ 4,206,000 The analysis estimates that 32,000 tons of CRT glass is sent to glass processors and that, of this, 31,300 tons of CRT glass is sent to CRT glass manufacturers. These quantities are below the capacity limits for glass processors and CRT glass manufacturers. As the CRT recycling infrastructure grows and additional unregulated CRTs are recycled, the capacities of both glass processors and glass manufacturers will be exceeded. This analysis does not attempt to predict when this might occur.

5.0 Cost Results and Sensitivity Analysis for Subtitle D Management Baseline The incremental annual savings attributable to both the primary alternative and the CSI alternative are calculated by subtracting the estimated costs under each alternative from the estimated costs under the Subtitle D baseline.

5.1 Costs Under the Subtitle D Baseline The total applicable cost of the Subtitle D management baseline is calculated for several groups of entities. As shown in Exhibit 5 1, the analysis groups affected entities based on whether they are original users or collectors, the amount of waste they generate (SQGs or LQGs), and, for original users, whether they are regulated solely because of CRT generation or because of a combination of CRT and non CRT hazardous waste generation. Collectors are all assumed to be regulated solely August 24, 2001  DRAFT Page 63 because of CRT generation. Compliance costs also are calculated for glass processors. Exhibit 5 1 presents the cost per establishment for administrative, storage, transportation, and disposal, and for the total cost of compliance under the baseline. Administrative costs are assumed to be the same for all generators in each size category (small or large). The other costs vary across the categories (based on RCRA requirements for different types of generators, on the average number of CRTs discarded, and on the disposal method used by that generator). So Exhibit 5 1 presents the average cost for each group of generators. As discussed in Section 3.11, generators sending CRTs to Subtitle D landfills only incur a disposal cost.

Exhibit 5 1: Subtitle D Baseline Compliance Costs Average Costs per Generator Number of Regulate d Generator s Average Costs per Potentially Regulated Generator Number of Potentiall y Regulate d Generator s Total Cost Admin. Storag e Transp . Disposal Except Subtitle D Subtitle D Disposal Transp. Disposal Except Subtitle D Subtitle D Disposal Original Users (Generating No Non CRT Hazardous Waste)

SQG $ 663 $ 1,304 $ 120 $ 1,139 $ 485 170 $ 120 $ 1,139 $ 485 2,260 $ 4,571,000 LQG $ 1,327 $ 3,314 $ 682 $ 8,681 $ 3,696 5 $ 682 $ 8,681 $ 3,696 66 $ 950,000 Subtota l $ 5,521,000 Original Users Also Generating Non CRT Hazardous Waste SQG $ 87 $ 386 $ 73 $ 768 $ 143 43 $ 73 $ 768 $ 143 384 $ 441,000 LQG $ 325 $ 134 $ 182 $ 792 $ 148 18 $ 182 $ 792 $ 148 160 $ 208,000 Subtota l $ 649,000 Collectors SQG $ 647 $ 0 $ 234 $ 95 $ 50 10 $ 234 $ 95 $ 50 90 $ 44,000 LQG $ 1,290 $ 0 $ 630 $ 166 $ 94 85 $ 630 $ 166 $ 94 415 $ 554,000 Subtota l $ 598,000 Glass Processors $ 1,284 $ 0 $ 1,542 $ (16,405) N/ A 5 N/ A N/ A N/ A N/ A $ (68,000)

Total Baseline Compliance Costs $ 6,700,000 Note: Total cost numbers rounded to nearest thousand. Costs may not add due to rounding.

5.2 Primary Alternative 5.2.1 Costs Under the Primary Alternative August 24, 2001  DRAFT Page 64 The total applicable cost of compliance under the primary alternative is calculated for all of the entities described in Section 5.1, and for all of the entities that were formerly generators but that no longer are required to comply with the hazardous waste regulations. These are called "former generators." Exhibit 5 2 presents the cost per establishment for administrative, storage, transportation, and disposal, and for the total cost of compliance under the primary alternative. Administrative costs are assumed to be the same for all generators in each size category (small or large). The other costs vary across the categories (based on RCRA requirements for different types of generators, on the average number of CRTs discarded, and on the disposal method used by that generator). So Exhibit 5 2 presents the average cost for each group of generators. As discussed in section 3.11, generators sending CRTs to Subtitle D landfills only incur a disposal cost.

The average transportation and disposal cost for SQGs and LQGs changes between the baseline and the primary alternative because, in the baseline, six CRT management options (collector, reuse, processor, smelter, hazardous waste landfill, and municipal landfill) are available while in the primary alternative only one disposal option (hazardous waste landfill) is available for regulated generators and five of the CRT management options are available (collector, reuse, processor, smelter, hazardous waste landfill, and municipal landfill) for former generators. The reason for the changes in average collector costs is similar. Under the baseline, six CRT management options are available (reuse, processor, smelter, hazardous waste landfill, municipal landfill, and export). Under the primary alternative, the same six CRT management options are available for regulated collectors, while former generators have five CRT management options (reuse, municipal landfill, processor, smelter, and export). 41 Assumes a two year monitor life, an average monitor weight of 40 pounds, and 95 percent of discarded monitors are color.

August 24, 2001  DRAFT Page 65 Exhibit 5 2: Primary Alternative Compliance Costs Under the Subtitle D Baseline Average Costs per Generator Number of Regulate d Generator s Average Costs per Potentially Regulated Generator Number of Potentiall y Regulate d Generator s Total Cost Admin. Storag e Trans p. Disposal Except Subtitle D Subtitle D Dispos al Transp . Disposal Except Subtitle D Subtitle D Disposal Original Users (Generating No Non CRT Hazardous Waste)

Former SQG $ 0 $ 1,304 $ 119 $ 993 $ 455 121 $ 119 $ 993 $ 455 2,260 $ 3,888,000 Former LQG $ 0 $ 3,295 $ 654 $ 7,527 $ 3,445 4 $ 654 $ 7,527 $ 3,445 66 $ 827,000 Subtotal $ 4,715,000 Original Users Also Generating Non CRT Hazardous Waste Former SQG $ 0 $ 772 $ 47 $ 294 $ 134 34 $ 47 $ 294 $ 134 384 $ 225,000 Former LQG $ 0 $ 798 $ 48 $ 304 $ 139 14 $ 48 $ 304 $ 139 160 $ 97,000 Subtotal $ 322,000 Collectors Former SQG $ 0 $ 0 $ 94 $ 199 $ 62 8 $ 94 $ 199 $ 62 90 $ 35,000 Former LQG $ 0 $ 0 $ 120 $ 255 $ 137 75 $ 120 $ 255 $ 137 415 $ 251,000 Subtotal $ 286,000 Total Cost to Regulated Generators $ 1,484,000 Total Compliance Costs under the Primary Alternative $ 6,806,000 Note: Total cost numbers rounded to nearest thousand. Costs may not add due to rounding.

5.2.2 Incremental Cost Difference Between the Subtitle D Baseline and the Primary Alternative The primary alternative generates a net savings relative to the baseline, due primarily to reduced administrative requirements and savings from reduced transportation and disposal costs. Savings from the primary alternative accrue to former generators that would no longer be regulated. The range of potential savings under the primary alternative is estimated to be from a net cost of 1,301,000 41 to a net 42 Assumes a six year monitor life, an average monitor weight of 30 pounds, and 75 percent of discarded monitors are color.

43 Assumes a three and one half year monitor life, an average monitor weight of 35 pounds, and 90 percent of discarded monitors are color.

August 24, 2001  DRAFT Page 66 savings of $291,000, 42 with a best estimate of a cost of $106,000. 43 Exhibit 5 3 summarizes the costs under the baseline and the primary alternative by cost category.

Exhibit 5 3: Costs of Primary Alternative Relative to Subtitle D Baseline Cost Category Baseline Primary Alternative Saving (Cost)

Administrative $ 251,000 $ 56,000 $ 195,000 Disposal Except Subtitle D $ 3,863,000 $ 4,485,000 $ (622,000)

Subtitle D Disposal $ 1,580,000 $ 1,479,000 $ 101,000 Transportation $ 749,000 $ 507,000 $ (242,000)

Storage $ 257,000 $ 279,000 $ 22,000 Total $ 6,700,000 $ 6,806,000 $ 106,000 Note: Cost numbers rounded to nearest thousand. Costs may not add due to rounding.

5.2.3 Sensitivity Analysis for the Primary Alternative Individual sensitivity and bounding analysis is conducted on the difference between the Subtitle D baseline and the primary alternative for the following four parameters: monitor weight, monitor lifetime, storage costs, and percent of monitors that are color. The individual sensitivity analysis is conducted by changing one parameter at a time while holding all other parameters at their best estimate value. Exhibit 5 4 contains the upper and lower bounds and the best estimate values for the four parameters as well as the percent change of the lower and upper bounds from the best estimate. The upper and lower bounds were selected because they represent probable limits on the selected parameters. Exhibit 5 5 contains the model results for each individual change. Exhibit 5 6 plots the data in Exhibit 5 5 from the individual sensitivity analysis for the four parameters. The graph illustrates that the analysis is most sensitive to the monitor weight, monitor lifetime, and the percent of color monitors discarded. To determine a potential maximum upper bound on the savings, a combined sensitivity analysis is conducted using a monitor weight of 30 pounds, a monitor lifetime of 6 years, the percent of color monitors discarded of 85 percent, and storage cost of zero dollars per square foot. The savings under the combined sensitivity analysis is $349,000. August 24, 2001  DRAFT Page 67 Exhibit 5 4: Parameter Values for Individual Sensitivity Analysis Lower Bound % Change from Best Estimate Best Estimate Upper Bound % Change from Best Estimate Monitor Weight 30 lbs. 14 % 35 lbs. 40 lbs. 14 %

Monitor Life 2 years 43 % 3.5 years 5 years 43 %

Storage Cost $ 0 100 % $ 8.30 $ 15 81 %

Percent Color 60 % 33 % 90 % 99 % 10 %

Exhibit 5 5: Individual Sensitivity Analysis Results Lower Bound Best Estimate Upper Bound Monitor Weight $ 17,000 $ (106,000) $ (247,000)

Monitor Life $ (916,000) $ (106,000) $ 93,000 Storage Cost $ (84,000) $ (106,000) $ (123,000)

Percent Color $ 120,000 $ (106,000) $ (191,000)

Note: Cost numbers rounded to nearest thousand.

Sensitivity analysis is also conducted for disposal costs above and below the best estimate values. By changing the cost for disposal to a hazardous waste landfill to $800 and $1700 per ton for whole CRTs (from a best estimate of $1,500), and to $50 and $250 per ton for crushed CRTs (from a best estimate of $160), the savings ranged from $ (61,000) to $( 259,000). By changing the cost for disposal to a reclaimer to $150 and $500 per ton for whole CRTs (from a best estimate of $295), to $100 and $300 per ton for bare CRTs (from a best estimate of $207), and to $75 and $250 per ton for crushed CRTs (from a best estimate of $152), the savings ranged from $( 330,000) to $54,000. By changing the cost for disposal to a collector to $100 and $350 per ton (from a best estimate of $271), the savings ranged from $( 236,000) to $176,000. The sensitivity analysis on disposal costs shows that the model is moderately sensitive to hazardous waste, reclaimer, and collector disposal costs. 44 The number of televisions disposed of is based on the assumption that there are 100 million households each with two televisions and that the TVs are discarded after ten years. The 20 August 24, 2001  DRAFT Page 68 ($ 950,000) ($ 700,000) ($ 450,000) ($ 200,000) $50,000 150% 100% 50% 0% 50% 100%

Percent Change from Best Estimate Total Cost Savings from Baseline ($)

Monitor Weight Monitor Life Storage Cost Percent Color Exhibit 5 6: Plot of Individual Sensitivity Analysis Results for the Primary Alternative Note: Lines with relatively steeper slopes indicate greater sensitivity of the results to changes (or uncertainty) in the given parameters.

5.2.4 Incremental Cost Difference Between the Subtitle D Baseline and the Primary Alternative, Including Currently Unregulated Monitors and Televisions To help understand how the two regulatory alternatives might be affected by capacity issues, the total cost of compliance under the Subtitle D baseline and the primary alternative is also calculated including CRTs from households and CESQGs. It is assumed that 20 million unregulated television CRTs are disposed and 16.7 million unregulated computer monitor CRTs are disposed from households and CESQGs. 44 Exhibit 5 7 contains a summary of the costs under the baseline and the million TVs discarded is also consistent with the number of televisions sold in 1991, which was 19.5 million. The number of computer monitor CRTs disposed of is based on data from the US Census, Survey of Computer Use, 1997, which estimates that 52 percent of households have computers.

August 24, 2001  DRAFT Page 69 primary alternative by cost category. Transportation and disposal costs are higher under the primary alternative than the baseline because it is assumed that a greater percentage of unregulated CRTs are sent to collectors, which increases the number of CRTs that have a non zero disposal cost under the primary alternative.

Exhibit 5 7: Costs of Primary Alternative Relative to Subtitle D Baseline Including Unregulated Monitors and Televisions Cost Category Baseline Primary Alternative Saving (Cost)

Administrative $ 269,000 $ 56,000 $ 213,000 Disposal Except Subtitle D $ 6,155,000 $ 6,677,000 $ (522,000)

Subtitle D Disposal $ 3,007,000 $ 2,789,000 $ 218,000 Transportation $ 1,063,000 $ 1,213,000 $ (150,000)

Storage $ 257,000 $ 279,000 $ (22,000)

Total $ 10,751,000 $ 11,014,000 $ (263,000)

Note: Cost numbers rounded to nearest thousand. Costs may not add due to rounding.

The analysis estimates that 9,600 tons of CRT glass is sent to glass processors and that, of this, 8,800 tons of CRT glass is sent to CRT glass manufacturers. These quantities are below the capacity limits for glass processors and CRT glass manufacturers. As the CRT recycling infrastructure grows and additional unregulated CRTs are recycled, the capacities of both glass processors and glass manufacturers will be exceeded. This analysis does not attempt to predict when this might occur.

5.3 CSI Alternative 5.3.1 Costs Under the CSI Alternative The total applicable cost of compliance under the CSI alternative is calculated for all of the entities described in Section 5.1, and for all of the entities that were formerly generators but that no longer are required to comply with the hazardous waste regulations. These are called CSI handlers. Exhibit 5 8 presents the cost per establishment for administrative, storage, transportation, and disposal, and for the total cost of compliance under the CSI alternative. Administrative costs are assumed to be the same for all CSI handlers in each size category (small or large). The other costs vary across the 45 Assumes a two year monitor life, an average monitor weight of 40 pounds, and 95 percent of discarded monitors are color.

August 24, 2001  DRAFT Page 70 categories (based on RCRA requirements for different types of generators, on the average number of CRTs discarded, and on the CRT management method used by that generator). So Exhibit 5 8 presents the average cost for CSI handlers. As discussed in section 3.11, generators sending CRTs to Subtitle D landfills only incur a disposal cost.

The average transportation and disposal cost for SQGs and LQGs changes between the baseline and the CSI alternative because, in the baseline, six CRT management options (collector, reuse, processor, smelter, hazardous waste landfill, and municipal landfill) are available while in the CSI alternative only three CRT management options (lead smelter, hazardous waste landfill, and municipal landfill) are available for regulated generators, and four of the CRT management options are available (collector, reuse, processor, and municipal landfill) for CSI handlers.

Exhibit 5 8: CSI Alternative Compliance Costs Under the Subtitle D Baseline Average Costs per Generator Number of Regulated Generator s Average Costs per Potentially Regulated Generator Number of Potentially Regulated Generators Total Cost Admin . Storage Transp. Disposal Except Subtitle D Subtitle D Disposal Transp. Disposal Except Subtitle D Subtitle D Disposal CSI Handlers SQH $ 100 $ 883 $ 114 $ 900 $ 480 200 $ 114 $ 900 $ 480 2,439 $ 4,138,000 LQH $ 0 $ 0 $ 0 $ 0 $ 0 0 $ 0 $ 0 $ 0 0 $ 0 Subtotal $ 4,138,000 Total Cost to Regulated Generators $ 2,996,000 Total Compliance Costs under the CSI Alternative $ 7,134,000 Note: Total cost numbers rounded to nearest thousand. Costs may not add due to rounding.

5.3.2 Incremental Cost Difference Between the Subtitle D Baseline and the CSI Alternative The CSI alternative generates a net savings relative to the baseline, due primarily to reduced administrative requirements and savings from reduced transportation and disposal costs. Savings from the CSI alternative accrue to CSI handlers that would no longer be regulated. The range of potential savings under the CSI alternative is estimated to be from a net cost of $1,521,000 45 to a net cost of 46 Assumes a six year monitor life, an average monitor weight of 30 pounds, and 86 percent of discarded monitors are color.

47 Assumes a three and one half year monitor life, an average monitor weight of 35 pounds, and 90 percent of discarded monitors are color.

August 24, 2001  DRAFT Page 71 $33,000, 46 with a best estimate of a net cost of $434,000. 47 Exhibit 5 9 summarizes the costs under the baseline and the CSI alternative by cost category.

Exhibit 5 9: Costs of CSI Alternative Relative to Subtitle D Baseline Cost Category Baseline Primary Alternative Saving (Cost)

Administrative $ 251,000 $ 129,000 $ 122,000 Disposal Except Subtitle D $ 3,863,000 $ 4,435,000 $ (572,000)

Subtitle D Disposal $ 1,580,000 $ 1,500,000 $ 80,000 Transportation $ 749,000 $ 875,000 $ (126,000)

Storage $ 257,000 $ 195,000 $ 62,000 Total $ 6,700,000 $ 7,134,000 $ (434,000)

Note: Cost numbers rounded to nearest thousand. Costs may not add due to rounding.

5.3.3 Sensitivity Analysis for the CSI Alternative Individual sensitivity and bounding analysis is conducted on the difference between the Subtitle D baseline and the CSI alternative for the following four parameters: monitor weight, monitor lifetime, storage costs, and percent of monitors that are color. The individual sensitivity analysis is conducted by changing one parameter at a time while holding all other parameters at their best estimate value. Exhibit 5 10 contains the upper and lower bounds and the best estimate values for the four parameters as well as the percent change of the lower and upper bounds from the best estimate. The upper and lower bounds were selected because they represent probable limits on the selected parameters. Exhibit 5 11 contains the model results for each individual change. Exhibit 5 12 plots the data in Exhibit 5 11 from the individual sensitivity analysis for the four parameters. The graph illustrates that the analysis is most sensitive to the monitor weight, monitor lifetime, and the percent of color monitors discarded. To determine a potential maximum upper bound on the savings, a combined sensitivity analysis is conducted using a monitor weight of 26 pounds, a monitor lifetime of 5.5 years, the percent of color monitors discarded of 75 percent, and storage cost of $15 per square foot. The savings under the combined sensitivity analysis is $5,000. August 24, 2001  DRAFT Page 72 Exhibit 5 10: Parameter Values for Individual Sensitivity Analysis Lower Bound % Change from Best Estimate Best Estimate Upper Bound % Change from Best Estimate Monitor Weight 30 lbs. 14 % 35 lbs. 40 lbs. 14 %

Monitor Life 2 years 43 % 3.5 years 5 years 43 %

Storage Cost $ 0 100 % $ 8.30 $ 15 81 %

Percent Color 60 % 33 % 90 % 99 % 10 %

Exhibit 5 11: Individual Sensitivity Analysis Results Lower Bound Best Estimate Upper Bound Monitor Weight $ (315,000) $ (434,000) $ (568,000)

Monitor Life $ (1,153,000) $ (434,000) $ (259,000)

Storage Cost $ (496,000) $ (434,000) $ (383,000)

Percent Color $ (223,000) $ (434,000) $ (509,000)

Numbers rounded to nearest thousand.

Sensitivity analysis is also conducted for disposal costs above and below the best estimate values. By changing the cost for disposal to a hazardous waste landfill to $800 and $1700 per ton for whole CRTs (from a best estimate of $1,500), and to $50 and $250 per ton for crushed CRTs (from a best estimate of $160), the savings ranged from $( 417,000) to $( 499,000). By changing the cost for disposal to a reclaimer to $150 and $500 per ton for whole CRTs (from a best estimate of $295), to $100 and $300 per ton for bare CRTs (from a best estimate of $207), and to $75 and $250 per ton for crushed CRTs (from a best estimate of $152), the savings ranged from $( 349,000) to $( 493,000). By changing the cost for disposal to a collector to $100 and $350 per ton (from a best estimate of $271), the savings ranged from $( 577,000) to $( 255,000). August 24, 2001  DRAFT Page 73 ($ 1,200,000) ($ 1,100,000) ($ 1,000,000) ($ 900,000) ($ 800,000) ($ 700,000) ($ 600,000) ($ 500,000) ($ 400,000) ($ 300,000) ($ 200,000)

150% 100% 50% 0% 50% 100% Percent Change from Best Estimate Total Cost Savings from Baseline ($)

Monitor Weight Monitor Life Storage Cost Percent Color Exhibit 5 12: Plot of Individual Sensitivity Analysis Results for the CSI Alternative Note: Lines with relatively steeper slopes indicate greater sensitivity of the results to changes (or uncertainty) in the given parameters.

5.3.4 Incremental Cost Difference Between the Subtitle D Baseline and the CSI Alternative, Including Currently Unregulated Monitors and Televisions To help understand how the two regulatory alternatives might be affected by capacity issues, the total cost of compliance under the Subtitle D baseline and the CSI alternative is also calculated including CRTs from households and CESQGs. It is assumed that 20 million unregulated television CRTs are disposed and 16.7 million unregulated computer monitor CRTs are disposed from 48 The number of televisions disposed of is based on the assumption that there are 100 million households each with two televisions and that the TVs are discarded after ten years. The 20 million TVs discarded is also consistent with the number of televisions sold in 1991, which was 19.5 million. The number of computer monitor CRTs disposed of is based on data from the US Census, Survey of Computer Use, 1997, which estimates that 52 percent of households have computers.

August 24, 2001  DRAFT Page 74 households and CESQGs. 48 Exhibit 5 13 summarizes the costs under the baseline and the CSI alternative by cost category.

Exhibit 5 13: Costs of CSI Alternative Relative to Subtitle D Baseline, Including Unregulated Monitors and Televisions Cost Category Baseline Primary Alternative Saving (Cost)

Administrative $ 269,000 $ 136,000 $ 133,000 Disposal Except Subtitle D $ 6,155,000 $ 6,934,000 $ (779,000)

Subtitle D Disposal $ 3,007,000 $ 2,745,000 $ 262,000 Transportation $ 1,063,000 $ 1,224,000 $ (161,000)

Storage $ 257,000 $ 195,000 $ 62,000 Total $ 10,751,000 $ 11,234,000 $ (483,000)

The analysis estimates that 9,600 tons of CRT glass is sent to glass processors and that, of this, 9,400 tons of CRT glass is sent to CRT glass manufacturers. These quantities are below the capacity limits for glass processors and CRT glass manufacturers. As the CRT recycling infrastructure grows and additional unregulated CRTs are recycled, the capacities of both glass processors and glass manufacturers will be exceeded. This analysis does not attempt to predict when this might occur.

6.0 Economic Impacts This section presents the estimated first order economic impacts associated with the incremental cost savings from the primary and CSI alternatives over the Subtitle C management baseline using the cost to sales ratio. As noted in Section 3.10, the impacts analysis is likely to overstate economic impacts (whether costs or savings) because the sales data used in the analysis represent average values for each SIC code as a whole, whereas the estimated compliance costs arise only for the entities that are large enough to be considered an SQG or LQG in the baseline. Such entities are likely to have an average sales value higher than the average for the industry as a whole. August 24, 2001  DRAFT Page 75 Primary Alternative Exhibit 6 1 shows the impacts of the cost savings for original users that were baseline small quantity generators (SQGs). Their average savings is $606 per year, due primarily to reduced administrative requirements and transportation savings. The highest impact on SQGs is on the "Personal Services" sector (SIC code 72). Establishments in SIC code 72 have average annual sales of $219,582. The incremental cost savings represents 0.28 percent of the average annual sales. Establishments in all but one other SIC code have impacts of less than 0.17 percent of the average annual sales.

Exhibit 6 2 presents the results for original users that were baseline large quantity generators (LQGs). Their average savings is $1,101 per year, due to reduced administrative requirements, and transportation and disposal costs. The LQGs under the baseline are in 25 SIC codes. The highest impact for LQHs is on the Retail Trade Administrative and Auxiliary category. The maximum incremental cost savings represents 0.30 percent of the average annual sales. Establishments in all other SIC codes have impacts of less than 0.23 percent of the average annual sales.

Exhibit 6 1: Estimated Impact of Savings Under the Primary Alternative on Former SQGs that were Baseline SQGs Industry SIC Code Average Sales per Establishment Number of Baseline Potential SQGs Savings (Cost) Impact of Primary Alternative MINING Metal Mining 10 $9,642,717 24 0.01%

Coal Mining 12 $8,841,349 21 0.01%

Oil & Gas Extraction 13 $5,338,313 52 0.01%

Non metallic minerals, except fuels 14 $2,338,749 5 0.03%

Administrative & Auxiliary 1 $1,545,768 37 0.04%

CONSTRUCTION General contractors 15 $1,280,404 8 0.05%

Heavy construction 16 $2,570,507 24 0.02%

Special trade contractors 17 $590,600 5 0.10%

MANUFACTURING Food & kindred products 20 $19,567,362 178 0.00%

Tobacco products 21 $308,752,632 10 0.00%

Textile mill products 22 $12,020,557 56 0.01%

Apparel & other textile products 23 $3,103,014 9 0.02%

Lumber & wood products 24 $2,277,901 3 0.03%

Furniture & Fixtures 25 $3,759,298 30 0.02%

Paper & allied products 26 $20,760,708 208 0.00% Industry SIC Code Average Sales per Establishment Number of Baseline Potential SQGs Savings (Cost) Impact of Primary Alternative August 24, 2001  DRAFT Page 76 Printing & publishing 27 $2,540,878 328 0.02%

Chemicals & allied products 28 $25,443,194 297 0.00%

Petroleum and Coal Products 29 $70,728,296 44 0.00%

Rubber & miscellaneous plastics products 30 $7,170,357 225 0.01%

Leather & leather products 31 $4,751,863 5 0.01%

Stone, clay, and glass products 32 $3,846,475 22 0.02%

Primary metal industries 33 $21,271,651 72 0.00%

Fabricated metal products 34 $4,571,413 62 0.01%

Industrial machinery & equipment 35 $4,793,932 483 0.01%

Electronic & other electronic equipment 36 $12,809,615 578 0.00%

Transportation equipment 37 $35,374,262 459 0.00%

Instrument & related products 38 $11,884,834 121 0.01%

Miscellaneous manufacturing 39 $2,318,656 19 0.03%

Administrative & Auxiliary 1 $3,156,356 212 0.02%

TRANSPORTATION Local & Interurban passenger transit 41 $ 710,436 7 0.09%

Trucking & Warehousing 42 $1,296,519 98 0.05%

Water transportation 44 $3,585,027 16 0.02%

Transportation by Air 45 $2,338,134 78 0.03%

Pipelines, except natural gases 46 $8,368,550 1 0.01%

Communication 48 $5,877,769 303 0.01%

Electronic, gas, & sanitary services 49 $15,510,062 255 0.00%

Administrative & Auxiliary 1 $1,766,775 43 0.03%

WHOLESALE Wholesale trade durable goods 50 $5,084,711 168 0.01%

Wholesale trade nondurable goods 51 $9,036,867 213 0.01%

Bldg. Materials & garden supplies 52 $1,422,393 1 0.04%

Administrative & Auxiliary 1 $781,548 98 0.08%

RETAIL TRADE General merchandise store 53 $7,089,224 28 0.01%

Food stores 54 $2,044,651 2 0.03%

Auto dealers & service station 55 $4,100,193 1 0.01%

Apparel & accessory stores 56 $699,117 4 0.09%

Furniture & home furnishing stores 57 $846,766 2 0.07%

Eating & drinking places 58 $450,446 6 0.13%

Miscellaneous retail 59 $607,995 31 0.10%

Administrative & Auxiliary 1 $370,918 96 0.16% Industry SIC Code Average Sales per Establishment Number of Baseline Potential SQGs Savings (Cost) Impact of Primary Alternative August 24, 2001  DRAFT Page 77 FINANCE, INSURANCE, AND REAL ESTATE Depository Institution 60 $5,091,211 339 0.01%

Nondepository Institution 61 $3,432,819 87 0.02%

Security & commodity brokers 62 $3,491,738 86 0.02%

Insurance carriers 63 $20,422,940 482 0.00%

Insurance agents, brokers, & servicers 64 $424,989 27 0.14%

Real Estate 65 $617,331 74 0.10%

Holding & other investment offices 67 $3,237,932 37 0.02%

Administrative & Auxiliary 1 $1,054,687 23 0.06%

SERVICES Personal services 72 $219,582 6 0.28%

Business services 73 $896,726 1,432 0.07%

Auto repair, services, and parking 75 $407,237 1 0.15%

Misc. repair services 76 $429,359 2 0.14%

Motion picture 78 $1,040,439 15 0.06%

Amusement & recreation services 79 $793,715 69 0.08%

Health services 80 $677,073 3,177 0.09%

Legal services 81 $641,030 52 0.09%

Educational services 82 $491,509 580 0.12%

Social services 83 $225,786 18 0.27%

Museums, botanical, zoological gardens 84 $611,305 3 0.10%

Membership organization 86 $500,857 83 0.12%

Engineering & management service 87 $827,956 365 0.07%

Services, n. e. c 89 $546,119 8 0.11%

Administrative & Auxiliary 1 $1,053,680 134 0.06%

Exhibit 6 2: Estimated Impact of Savings Under the Primary Alternative on Former LQGs that were Baseline LQGs Industry SIC Code Average Sales per Establishment Number of Baseline Potential LQGs Savings (Cost) Impact of Primary Alternative MANUFACTURING Food and kindred products 20 $19,567,362 3 0.01%

Tobacco products 21 $308,752,632 1 0.00%

Chemicals & allied products 28 $25,443,194 4 0.01%

Primary metal industries 33 $21,271,651 5 0.01% Industry SIC Code Average Sales per Establishment Number of Baseline Potential LQGs Savings (Cost) Impact of Primary Alternative August 24, 2001  DRAFT Page 78 Industrial machinery & equipment 35 $4,793,932 7 0.02%

Electronic & other electronic equipment 36 $12,809,615 12 0.01%

Transportation equipment 37 $35,374,262 51 0.00%

TRANSPORTATION Local & Interurban passenger transit 41 $710,436 1 0.16%

Trucking & Warehousing 42 $1,296,519 12 0.08%

Transportation by Air 45 $2,338,134 20 0.05%

Communication 48 $5,877,769 11 0.02%

Electronic, gas, & sanitary services 49 $15,510,062 4 0.01%

Administrative & Auxiliary 1 $1,766,775 5 0.06%

WHOLESALE Administrative & Auxiliary 1 $781,548 1 0.14%

RETAIL TRADE Food stores 54 $2,044,651 1 0.05%

Administrative & Auxiliary 1 $370,918 1 0.30%

FINANCE, INSURANCE, AND REAL ESTATE Depository Institution 60 $5,091,211 18 0.02%

Nondepository institution 61 $3,432,819 5 0.03%

Security and commodity brokers 62 $3,491,738 5 0.03%

Insurance carriers 63 $20,422,940 14 0.01%

Holding and other investment offices 67 $3,237,932 3 0.03%

SERVICES Business services 73 $896,726 22 0.12%

Motion picture 78 $1,040,439 5 0.11%

Amusement & recreation services 79 $793,715 3 0.14%

Health services 80 $677,073 65 0.16%

Educational services 82 $491,509 33 0.22%

Membership organization 86 $500,857 6 0.22%

Engineering & management service 87 $827,956 31 0.13%

Administrative & Auxiliary 1 $1,053,680 7 0.10%

CSI Alternative Exhibit 6 3 shows the impacts of the cost savings for small quantity handlers (SQHs) that were baseline small quantity generators (SQGs). Their average savings is $498 per year, due primarily to reduced administrative requirements and transportation savings. The highest impact on SQGs is on the August 24, 2001  DRAFT Page 79 "Personal Services" sector (SIC code 72). Establishments in SIC code 72 have average annual sales of $219,582. The incremental cost savings represents 0.23 percent of the average annual sales. Establishments in all but one other SIC codes have impacts of less than 0.14 percent of the average annual sales.

Exhibit 6 4 presents the results for the small quantity handlers (SQHs) that were baseline large quantity generators (LQGs). Their average savings is $8,017 per year, due primarily to reduced administrative requirements and disposal costs. Fifteen percent of the LQGs under the baseline are assumed to continue following RCRA regulations because they send their waste to destinations other than glass processors. These establishments realize no cost savings under the CSI alternative. The former LQGs are regulated as SQHs under the CSI alternative, and are the main beneficiaries of the regulatory burden reduction.

The model estimates that no large quantity handlers will exist under the CSI alternative. Thus, the baseline large quantity generators that become SQHs by sending discarded CRTs to processors under the CSI alternative realize the most cost savings. The LQGs under the baseline are in 25 SIC codes. The highest impact for LQHs is on the Retail Trade Administrative and Auxiliary category. The maximum incremental cost savings represents 2.16 percent of the average annual sales. Establishments in all other SIC codes have impacts of less than 1.64 percent of the average annual sales.

Exhibit 6 3: Estimated Impact of Savings Under the CSI Alternative on Small Quantity Handlers that were Baseline SQGs Industry SIC Code Average Sales per Establishment Number of Baseline Potential SQGs Savings (Cost) Impact of Primary Alternative MINING Metal Mining 10 $9,642,717 24 0.01%

Coal Mining 12 $8,841,349 21 0.01%

Oil & Gas Extraction 13 $5,338,313 52 0.01%

Non metallic minerals, except fuels 14 $2,338,749 5 0.02%

Administrative & Auxiliary 1 $1,545,768 37 0.03%

CONSTRUCTION General contractors 15 $1,280,404 8 0.04%

Heavy construction 16 $2,570,507 24 0.02%

Special trade contractors 17 $590,600 5 0.08%

MANUFACTURING Food & kindred products 20 $19,567,362 178 0.00%

Tobacco products 21 $308,752,632 10 0.00%

Textile mill products 22 $12,020,557 56 0.00%

Apparel & other textile products 23 $3,103,014 9 0.02%

Lumber & wood products 24 $2,277,901 3 0.02% Industry SIC Code Average Sales per Establishment Number of Baseline Potential SQGs Savings (Cost) Impact of Primary Alternative August 24, 2001  DRAFT Page 80 Furniture & Fixtures 25 $3,759,298 30 0.01%

Paper & allied products 26 $20,760,708 208 0.00%

Printing & publishing 27 $2,540,878 328 0.02%

Chemicals & allied products 28 $25,443,194 297 0.00%

Petroleum and Coal Products 29 $70,728,296 44 0.00%

Rubber & miscellaneous plastics products 30 $7,170,357 225 0.01%

Leather & leather products 31 $4,751,863 5 0.01%

Stone, clay, and glass products 32 $3,846,475 22 0.01%

Primary metal industries 33 $21,271,651 72 0.00%

Fabricated metal products 34 $4,571,413 62 0.01%

Industrial machinery & equipment 35 $4,793,932 483 0.01%

Electronic & other electronic equipment 36 $12,809,615 578 0.00%

Transportation equipment 37 $35,374,262 459 0.00%

Instrument & related products 38 $11,884,834 121 0.00%

Miscellaneous manufacturing 39 $2,318,656 19 0.02%

Administrative & Auxiliary 1 $3,156,356 212 0.02%

TRANSPORTATION Local & Interurban passenger transit 41 $ 710,436 7 0.07%

Trucking & Warehousing 42 $1,296,519 98 0.04%

Water transportation 44 $3,585,027 16 0.01%

Transportation by Air 45 $2,338,134 78 0.02%

Pipelines, except natural gases 46 $8,368,550 1 0.01%

Communication 48 $5,877,769 303 0.01%

Electronic, gas, & sanitary services 49 $15,510,062 255 0.00%

Administrative & Auxiliary 1 $1,766,775 43 0.03%

WHOLESALE Wholesale trade durable goods 50 $5,084,711 168 0.01%

Wholesale trade nondurable goods 51 $9,036,867 213 0.01%

Bldg. Materials & garden supplies 52 $1,422,393 1 0.04%

Administrative & Auxiliary 1 $781,548 98 0.06%

RETAIL TRADE General merchandise store 53 $7,089,224 28 0.01%

Food stores 54 $2,044,651 2 0.02%

Auto dealers & service station 55 $4,100,193 1 0.01%

Apparel & accessory stores 56 $699,117 4 0.07%

Furniture & home furnishing stores 57 $846,766 2 0.06%

Eating & drinking places 58 $450,446 6 0.11% Industry SIC Code Average Sales per Establishment Number of Baseline Potential SQGs Savings (Cost) Impact of Primary Alternative August 24, 2001  DRAFT Page 81 Miscellaneous retail 59 $607,995 31 0.08%

Administrative & Auxiliary 1 $370,918 96 0.13%

FINANCE, INSURANCE, AND REAL ESTATE Depository Institution 60 $5,091,211 339 0.01%

Nondepository Institution 61 $3,432,819 87 0.01%

Security & commodity brokers 62 $3,491,738 86 0.01%

Insurance carriers 63 $20,422,940 482 0.00%

Insurance agents, brokers, & servicers 64 $424,989 27 0.12%

Real Estate 65 $617,331 74 0.08%

Holding & other investment offices 67 $3,237,932 37 0.02%

Administrative & Auxiliary 1 $1,054,687 23 0.05%

SERVICES Personal services 72 $219,582 6 0.23%

Business services 73 $896,726 1,432 0.06%

Auto repair, services, and parking 75 $407,237 1 0.12%

Misc. repair services 76 $429,359 2 0.12%

Motion picture 78 $1,040,439 15 0.05%

Amusement & recreation services 79 $793,715 69 0.06%

Health services 80 $677,073 3,177 0.07%

Legal services 81 $641,030 52 0.08%

Educational services 82 $491,509 580 0.10%

Social services 83 $225,786 18 0.22%

Museums, botanical, zoological gardens 84 $611,305 3 0.08%

Membership organization 86 $500,857 83 0.10%

Engineering & management service 87 $827,956 365 0.06%

Services, n. e. c 89 $546,119 8 0.09%

Administrative & Auxiliary 1 $1,053,680 134 0.05%

Exhibit 6 4: Estimated Impact of Savings Under the CSI Alternative on Small Quantity Handlers that were Baseline LQGs Industry SIC Code Average Sales per Establishment Number of Baseline Potential LQGs Savings (Cost) Impact of Primary Alternative MANUFACTURING Food and kindred products 20 $19,567,362 3 0.04%

Tobacco products 21 $308,752,632 1 0.00% Industry SIC Code Average Sales per Establishment Number of Baseline Potential LQGs Savings (Cost) Impact of Primary Alternative August 24, 2001  DRAFT Page 82 Chemicals & allied products 28 $25,443,194 4 0.03%

Primary metal industries 33 $21,271,651 5 0.04%

Industrial machinery & equipment 35 $4,793,932 7 0.17%

Electronic & other electronic equipment 36 $12,809,615 12 0.06%

Transportation equipment 37 $35,374,262 51 0.02%

TRANSPORTATION Local & Interurban passenger transit 41 $710,436 1 1.13%

Trucking & Warehousing 42 $1,296,519 12 0.62%

Transportation by Air 45 $2,338,134 20 0.34%

Communication 48 $5,877,769 11 0.14%

Electronic, gas, & sanitary services 49 $15,510,062 4 0.05%

Administrative & Auxiliary 1 $1,766,775 5 0.45%

WHOLESALE Administrative & Auxiliary 1 $781,548 1 1.03%

RETAIL TRADE Food stores 54 $2,044,651 1 0.39%

Administrative & Auxiliary 1 $370,918 1 2.16%

FINANCE, INSURANCE, AND REAL ESTATE Depository Institution 60 $5,091,211 18 0.16%

Nondepository institution 61 $3,432,819 5 0.23%

Security and commodity brokers 62 $3,491,738 5 0.23%

Insurance carriers 63 $20,422,940 14 0.04%

Holding and other investment offices 67 $3,237,932 3 0.25%

SERVICES Business services 73 $896,726 22 0.89%

Motion picture 78 $1,040,439 5 0.77%

Amusement & recreation services 79 $793,715 3 1.01%

Health services 80 $677,073 65 1.18%

Educational services 82 $491,509 33 1.63%

Membership organization 86 $500,857 6 1.60%

Engineering & management service 87 $827,956 31 0.97%

Administrative & Auxiliary 1 $1,053,680 7 0.76%

* The only LQGs under the CSI Alternative are those required to follow RCRA regulations because they send their waste to destinations other than Glass to Glass recyclers. Eighty five percent of the Baseline LQGs are regulated as SQHs under the proposed rule, the others remain RCRA LQGs and therefore realize no cost savings.

7.0 Qualitative Environmental Benefits August 24, 2001  DRAFT Page 83 The shift of waste CRTs from landfills and incinerators to glass processors, and thus to CRT glass manufacturers, has four major potential qualitative environmental benefits. The four potential qualitative benefits are (1) increase in the availability of landfill space; (2) increase in resource efficiency; (3) increase in recycling by non regulated entities; and (4) reduction of lead emissions from incinerators. This section discusses these four qualitative environmental benefits.

Landfill Capacity A qualitative benefit of both alternatives is the shift of CRTs from Subtitle C and D landfills to CRT glass processors. The analysis estimates that approximately 2,600 tons or 456,000 cubic feet of CRTs will be redirected away from landfills each year under the primary alternative. This additional space can be used for other waste. By not disposing of CRTs in Subtitle C and D landfills, the landfill capacity will not be reached as quickly and new landfills will not be needed as soon. This unused Subtitle C and D landfill capacity is seen as a minor qualitative benefit, because so few regulated CRTs currently are being sent to these landfills.

Increase in Resource Efficiency The resources that could be used more efficiently under the two regulatory alternatives include energy, CRT glass, raw materials for glass manufacturing, and landfill space. The amount of energy required to turn discarded televisions and computer monitors into an input for CRT glass manufacturers may be less than the energy required to mine, process, and transport the raw materials for glass making. Discarded CRTs are a direct replacement for raw materials to glass manufacturing, thus reserving those raw materials for future use.

Recycling by Non Regulated Entities The alternatives are designed to stimulate an increase in glass to glass CRT recycling in certain effected entities (i. e., firms that disposition a sufficient number of CRTs that they could potentially qualify as SQGs or LQGs). If the initiative is successful, the glass to glass recycling industry may develop and expand its operations. As CRT recycling infrastructure develops, it will become a more attractive option for smaller entities and for the general public. Thus, some additional entities may shift the management of their waste from Subtitle D landfills to glass recycling. This shift has the benefit of saving additional landfill space, and provides for more environmentally sound disposal of unregulated CRTs. The increased recycling infrastructure is already proving itself to be a valuable incentive for increased non regulated CRT recycling in states such as Massachusetts and Minnesota.

Reduction of Lead Emissions Exposure to lead may result in health problems to adults and children. These effects include hypertension, stroke, cancer in adults and decreased IQ and gestational age, reduced birth weight, and other neurological effects in infants and children. By shifting disposal of CRTs from municipal waste incinerators, the total lead emitted from CRT incineration can be reduced. However, the benefits of 49 Macauley et al., 2001, page 51.

50 Macauley et al., 2001, page 45.

August 24, 2001  DRAFT Page 84 reducing lead emissions from CRT incineration are reported to be small. 49 One report estimates that the value of the health effects due to a complete ban on incineration of any CRTs is on the order of $5 million. 50 8.0 Other Administrative Requirements This section describes the Agency's response to other rulemaking requirements established by statute and executive order, within the context of the proposed rule for CRTs.

8.1 Environmental Justice The EPA is committed to addressing environmental justice concerns and is assuming a leadership role in environmental justice initiatives to enhance environmental quality for all residents of the United States. The Agency's goals are to ensure that no segment of the population, regardless of race, color, national origin, or income bears disproportionately high and adverse human health and environmental impacts as a result of the EPA's policies, programs, and activities, and that all people live in clean and sustainable communities. In response to Executive Order 12898 and to concerns voiced by many groups outside the Agency, the EPA's Office of Solid Waste and Emergency Response formed an Environmental Justice Task Force to analyze the array of environmental justice issues specific to waste programs and to develop an overall strategy to identify and address these issues (OSWER Directive No. 9200.3 17).

Because CRTs are ubiquitous, it is not certain whether the environmental problems addressed by the proposed rule could disproportionately affect minority or low income communities. CRTs are used throughout the country and many are located within highly populated areas. Because the proposed rule establishes general environmental performance requirements to minimizes breakage, and helps prevent the release of glass particulates, the Agency does not believe that this rule will increase risks from CRT wastes. Moreover, the CSI alternative establishes an environmental justice procedure for new CRT processors. The procedure calls for new processors to advise the local community through notice and possibly public meeting regarding the nature of the activities conducted, including the potential for residential or worker exposure to lead or chemical coatings. It is, therefore, not expected to result in any disproportionately negative impacts on minority or low income communities relative to affluent or non minority communities. 51 An economically significant rule is defined by Executive Order 12866 as any rulemaking that has an annual effect on the economy of $100 million or more, or adversely affects in a material way the economy, a sector of the economy, productivity, competition, jobs, the environment, public health, or safety, or State, local, or tribal governments or communities.

August 24, 2001  DRAFT Page 85 8.2 Unfunded Mandates Reform Act Under Section 202 of the Unfunded Mandates Reform Act of 1995, signed into law on March 22, 1995, the EPA must prepare a statement to accompany any rule for which the estimated costs to state, local, or tribal governments in the aggregate, or to the private sector, will be $100 million or more in any one year. Under Section 205, the EPA must select the most cost effective and least burdensome alternative that achieves the objective of the rule and is consistent with statutory requirements. Section 203 requires the EPA to establish a plan for informing and advising any small governments that may be significantly affected by the rule.

An analysis of the costs and benefits of the proposed rule was conducted and it was determined that this rule does not include a federal mandate that may result in estimated costs of $100 million or more to either state, local, or tribal governments in the aggregate. The private sector also is not expected to incur costs exceeding $100 million per year in this EA.

8.3 Protection of Children from Environmental Health Risks and Safety Risks Executive Order 13045, entitled "Protection of Children from Environmental Health Risks and Safety Risks" requires all economically significant rules 51 that concern an environmental health risk or safety risk that may disproportionately affect children to comply with requirements of the Executive Order. Because the EPA does not consider the proposed rule to be economically significant, it is not subject to Executive Order 13045. Because this rulemaking establishes general environmental performance requirements, minimizes breakage, and prevents of release of glass particulates, the EPA believes that the proposed rule will not result in increased exposures to children. For these reasons, the environmental health risks or safety risks addressed by this action do not have a disproportionate effect on children.

8.4 Regulatory Flexibility The Regulatory Flexibility Act (RFA), as amended by the Small Business Regulatory Enforcement and Fairness Act, 5 U. S. C. §§ 601 612, generally requires an agency to conduct a regulatory flexibility analysis of any rule subject to notice and comment rulemaking requirements unless the agency certifies that the rule will not have a significant economic impact on a substantial number of small entities. Small entities include small businesses, small not for profit enterprises, and small governmental jurisdictions. This proposed rule does not have a significant impact on a substantial number of small entities because today's proposed rule relieves regulatory burden for CRT handlers through reduced regulatory requirements. In addition, the Agency estimates that this proposed rule August 24, 2001  DRAFT Page 86 leads to an overall cost savings in the range of $4 to 5 million annually. Accordingly, EPA believes that the rule will not have a significant economic impact on a substantial number of small entities.

9.0 Discussion of Findings and Summary The main conclusion of this analysis is that both the overall savings and the savings for individual establishments are small, and that the results are sensitive to a few key parameters (CRT life in businesses, the average weight of CRTs, storage costs, and the percent of color monitors discarded). A second conclusion is that both the glass processing and CRT glass manufacturer capacities are adequate to handle all regulated CRTs. However, if a new rule induces significantly more unregulated CRTs to be recycled than is modeled in this analysis, then both the glass processing and CRT glass manufacturer capacities may become inadequate to handle this larger volume of CRT glass.

The primary alternative, as modeled in this analysis, is expected to impact approximately 2,900 establishments in 66 different two digit SIC codes. Under the Subtitle C baseline the proposed rule will lead to total savings of approximately $4,840,000 for current generators that elect not to send their discarded CRTs for disposal. These savings are due primarily to reduced administrative, disposal, and transportation costs. Under the Subtitle D baseline the proposed rule will lead to a total savings of approximately $106,000, due to reduced administrative and transportation costs.

The CSI alternative, as modeled in this analysis, is expected to impact approximately 2,500 establishments in 66 different two digit SIC codes. Under the Subtitle C baseline the proposed rule will lead to total savings of approximately $3,098,000 for current generators that elect not to send their discarded CRTs for disposal. These savings are due primarily to reduced administrative, disposal, and transportation costs. Under the Subtitle D baseline the proposed rule will lead to a total savings of approximately $434,000, due to reduced administrative and transportation costs.

Relative to the Subtitle C baseline, the economic impacts on the entities in the regulated community are expected to be negligible because the rule provides savings for all entities managing CRTs. A significant benefit of the proposed rule is the possible increase in glass to glass recycling by the non regulated community. August 24, 2001  DRAFT Page 87 Appendices Appendix A: Number of Establishments and the Number of Employees for all Two Digit SIC Codes Appendix B: Ratios of Computers per Employee Calculated for Each SIC Code Appendix C: Disposal Cost Source Details Appendix D: Flow of CRTs in Both Number and Tons Appendix E: Average Shipment Sizes for Each Type of Establishment Distributing CRTs to Each CRT Management Option Appendix F: Revenues per Establishment for All Two Digit SIC Codes Appendix G: List of Parameters to Which the Analysis Results are Relatively Insensitive Appendix H: Telephone Contacts Appendix I: Bibliography August 24, 2001  DRAFT Page A 1 Appendix A Total Employees, Establishments, and Number of Establishments by Number of Employees, and by 2 Digit SIC Code Industry SIC code Total Employees Total Est. Number of Establishments per Employee Size Range 250 to 499 500 to 999 1,000 to 1,499 1,500 to 2,499 2,500 to 4,999 5,000 or more AGRICULTURE Agricultural services 7 595,842 103,543 51 18 4 1 Forestry 8 20,488 2,512 4 1 1 Fishing, hunting, trapping 9 11,871 2,236 5 0 1 Administrative & Auxiliary  0 62 2 0 MINING Metal Mining 10 48,105 921 20 16 5 3 Coal Mining 12 104,204 2,294 82 21 Oil & Gas Extraction 13 295,990 17,513 87 37 10 5 Non metallic minerals,

except fuels 14 99,182 5,572 18 3 2 Administrative & Auxiliary  80,002 1,056 48 29 6 1 1 CONSTRUCTION General contractors 15 1,222,061 190,316 141 49 10 5 2 1 Heavy construction 16 707,811 34,168 174 60 13 11 8 5 Special trade contractors 17 3,091,307 409,114 325 66 9 5 Administrative & Auxiliary  17,660 402 11 3 MANUFACTURING Food & kindred products 20 1,525,070 21,285 872 408 118 50 10 3 Tobacco products 21 30,411 112 16 4 1 5 1 Textile mill products 22 624,005 6,452 492 200 38 11 7 Apparel & other textile products 23 910,919 24,216 513 186 19 7 2 Lumber & wood products 24 730,144 37,601 254 50 9 1 3 Furniture & Fixtures 25 505,956 11,611 291 113 16 9 4 1 Paper & allied products 26 634,737 6,552 305 153 40 15 Printing & publishing 27 1,505,794 64,690 531 200 78 37 13 Chemicals & allied products 28 826,839 12,328 352 190 58 35 14 4 Petroleum and coal products 29 111,369 2,042 53 26 12 6 Rubber & miscellaneous plastics products 30 1,001,010 16,611 526 169 26 26 4 Leather & leather products 31 95,151 1,957 68 23 3 2 Stone, clay, and glass products 32 491,795 16,214 190 75 16 6 Primary metal industries 33 684,703 6,768 365 165 34 21 17 5 Fabricated metal products 34 1,450,089 36,314 606 192 34 18 10 Industry SIC code Total Employees Total Est. Number of Establishments per Employee Size Range 250 to 499 500 to 999 1,000 to 1,499 1,500 to 2,499 2,500 to 4,999 5,000 or more August 24, 2001  DRAFT Page A 2 Industrial machinery & equipment 35 1,883,431 55,476 686 338 74 46 25 7 Electronic & other electronic equipment 36 1,503,923 17,058 775 373 101 67 37 12 Transportation equipment 37 1,543,731 11,256 463 255 75 62 67 51 Instrument & related products 38 832,706 11,378 361 177 55 33 23 10 Miscellaneous manufacturing 39 394,287 17,899 153 57 11 7 1 Administrative & Auxiliary  1,326,527 12,105 560 315 104 64 32 12 TRANSPORTATION & PUBLIC UTILITIES Local & Interurban passenger transit 41 403,025 18,900 101 22 4 2 1 1 Trucking & Warehousing 42 1,808,949 124,190 306 150 30 12 56 12 Water transportation 44 164,920 8,707 45 31 13 2 1 Transportation by Air 45 715,137 12,076 150 78 32 27 19 20 Pipelines, except natural gases 46 16,395 1,091 4 0 1 Transportation services 47 391,340 50,172 50 17 Communication 48 1,340,061 44,713 563 224 51 28 7 4 Electronic, gas, & sanitary services 49 908,820 22,455 340 152 57 35 11 4 Administrative & Auxiliary  175,605 2,682 57 30 6 3 4 5 WHOLESALE Wholesale trade durable goods 50 3,683,301 327,640 488 135 19 13 1 Wholesale tradenondurable goods 51 2,582,397 184,384 550 146 39 15 13 Administrative & Auxiliary  340,488 5,713 177 69 15 11 3 1 RETAIL TRADE Bldg. Materials & garden supplies 52 739,615 64,436 35 1 General merchandise store 53 2,290,572 36,216 1,541 217 14 13 1 Food stores 54 3,188,462 181,870 452 51 2 1 Auto dealers & service station 55 2,189,767 199,791 79 5 1 Apparel & accessory stores 56 1,147,856 135,270 37 44 4 Furniture & home furnishing stores 57 859,460 116,727 36 5 2 Eating & drinking places 58 7,208,158 456,732 209 46 4 2 Miscellaneous retail 59 2,610,918 360,787 110 53 16 8 7 Administrative & Auxiliary  849,766 16,055 433 254 65 19 12 1 Industry SIC code Total Employees Total Est. Number of Establishments per Employee Size Range 250 to 499 500 to 999 1,000 to 1,499 1,500 to 2,499 2,500 to 4,999 5,000 or more August 24, 2001  DRAFT Page A 3 FINANCE, INSURANCE, AND REAL ESTATE Depository Institution 60 2,079,264 104,666 491 223 68 48 13 5 Nondepository Institution 61 489,804 45,408 136 62 15 10 5 Security & commodity brokers 62 522,895 40,961 115 63 14 9 5 Insurance carriers 63 1,502,920 41,330 594 287 93 80 22 14 Insurance agents, brokers, & servicers 64 676,602 125,361 70 20 2 5 Real Estate 65 1,402,828 246,119 212 64 8 1 1 Holding & other investment offices 67 255,044 23,202 71 27 5 5 3 Administrative & Auxiliary  68,799 1,452 50 18 3 2 SERVICES Hotels & other lodging places 70 1,575,077 54,130 669 261 66 35 30 4 Personal services 72 1,281,898 202,349 156 12 3 2 1 Business services 73 6,824,962 352,658 2,651 1,031 217 123 61 22 Auto repair, services, & parking 75 990,658 181,336 62 18 1 Misc. repair services 76 456,425 73,562 33 5 2 Motion picture 78 511,651 42,946 40 17 5 5 5 5 Amusement & recreation services 79 1,324,194 93,500 242 107 42 19 8 3 Health services 80 10,851,331 478,286 2,528 1,525 731 611 310 65 Legal services 81 960,693 163,554 167 49 2 1 Educational services 82 2,066,531 46,224 521 323 140 80 37 33 Social services 83 2,263,314 155,846 475 97 12 6 Museums, botanical, zoological gardens 84 76,079 3,790 40 7 1 1 1 Membership organization 86 2,151,350 243,592 274 61 15 7 3 3 Engineering & management service 87 2,795,304 269,243 673 255 50 60 21 10 Service 89 100,472 14,877 14 6 1 1 Administrative & Auxiliary  477,226 9,639 221 92 31 11 4 3 Unclassified  105,336 68,916 1 Note: (D) Data withheld to avoid disclosing data for individual companies: data included in broader industry totals.

Source: US Bureau of Census, County Business Patterns 1995. August 24, 2001  DRAFT Page B 1 Appendix B Computer Use By Employees SIC Category Number of Survey Respondents Employed Respondents Using a Computer at Work Computer Use per Employee in 1993 Estimated Computer Use per Employee in 2001 All industries 118,400 51,106 0.43 0.56 Agriculture services 968 160 0.17 0.24 Other agriculture 2006 219 0.11 0.16 Mining 689 307 0.45 0.46 Construction 7,567 1,182 0.16 0.25 Lumber and wood 841 114 0.14 0.17 Furniture 665 161 0.24 0.30 Stone, clay 568 165 0.29 0.36 Primary metals 653 217 0.33 0.42 Fabricated metals 1,290 442 0.34 0.43 Machinery, excluding electric 2,238 1,233 0.55 0.69 Electrical machinery 1,689 950 0.56 0.70 Motor vehicles 1,120 428 0.38 0.48 Aircraft and parts 502 335 0.67 0.84 Other transportation 624 376 0.60 0.75 Professional photo equipment 680 406 0.60 0.75 Toys, sporting goods 128 44 0.34 0.43 Miscellaneous manufacturing 437 100 0.23 0.29 Food and kindred products 1,776 532 0.30 0.37 Tobacco manufacturing 52 25 0.48 0.60 Textile mill products 664 177 0.27 0.33 Apparel & other finished goods 970 143 0.15 0.18 Paper and allied products 740 339 0.46 0.57 Printing, publishing 1,705 857 0.50 0.63 Chemicals and allied products 1,220 729 0.60 0.75 Petroleum, coal 145 88 0.61 0.76 Rubber and plastics 791 293 0.37 0.46 Leather and leather products 107 24 0.22 0.28 Transportation 5,410 1,866 0.34 0.42 Communications 1,637 1,283 0.78 0.96 Utilities & sanitary 1,501 807 0.54 0.66 Wholesale trade 4,531 2,226 0.49 0.66 Retail trade 18,706 5,837 0.31 0.42 Banking and finance 3,417 2,888 0.85 0.99 Insurance & real estate 4,561 3,094 0.68 0.79 Private household services 1,099 16 0.01 0.02 Business services 5,038 2,646 0.53 0.75 SIC Category Number of Survey Respondents Employed Respondents Using a Computer at Work Computer Use per Employee in 1993 Estimated Computer Use per Employee in 2001 August 24, 2001  DRAFT Page B 2 Repair services 1,915 382 0.20 0.28 Personal services 3,220 662 0.21 0.29 Entertainment, recreation 1,735 538 0.31 0.44 Hospitals 5,182 3,105 0.60 0.85 Health services, excluding hospitals 5,377 1,963 0.37 0.52 Education services 9,845 5,066 0.51 0.73 Social services 2,721 753 0.28 0.39 Other professional 5,578 3,735 0.67 0.95 Forestry, fisheries 166 56 0.34 0.48 Justice, public order 2,179 1,324 0.61 0.69 Administration human resource 834 632 0.76 0.86 National security 802 597 0.74 0.85 Other public administration 2,112 1,584 0.75 0.85 Sources: 1993 Census Data, Table 7WK Uses of Computers at work, by Sex and Intermediate Industry, in "Computer Use in the United States: October 1993." and Table D Use of Computers at Work by People 18 Years and Older by Gender: October 1997, "Computer Use in the United States: October 1997." August 24, 2001  DRAFT Page C 1 Appendix C Disposal Cost Source Details Disposal Option Source Source Cost per Ton Year of cost estimate Cost (Price Paid) per Ton (2001$)

Collectors 1 $ 240 1998 2 $ 400 2001 3 $ 0 2001 4 $ 383 1997 Average $ 250 1998 $ 271 Export 4 $ 100 1999 $ 107 Reuse None $ 0 2001 $ 0 Treatment and Subtitle C or D Landfill Disposal Whole CRTs 5 $ 1,196 1998 6 $1,300 2001 7 $ 1,500 2001 Value used in analysis $ 1,500 2001 $ 1,500 Crushed CRTs 7 $ 160 2001 8 $ 100 2000 9 $ 125 2000 Value used in analysis $ 160 2001 $ 160 Subtitle D Landfill Disposal 8 $ 40 2000 $ 41 Reclaimer 4 $ 667 1997 8 $ 200 2000 8 $ 420 2000 10 $ 200 1998 Disposal Option Source Source Cost per Ton Year of cost estimate Cost (Price Paid) per Ton (2001$)

August 24, 2001  DRAFT Page C 2 10 $ 350 1998 11 $ 140 1998 12 $ 200 1997 12 $ 500 1997 13 $ 200 1997 13 $ 300 1997 14 $ 200 1998 Whole CRTs  Average $ 284 2000 $ 295 Whole bare CRTs  Average $ 200 2000 $ 207 Crushed CRTs  Average $ 140 1998 $ 152 Glass Processor Broken CRTs with no metal 15,16 $ 0 2001 $ 0 Broken CRTs with metal $ 100 2001 $ 100 Whole bare CRTs $ 192 2001 $ 192 Broken mixed color and monochrome CRTs $ 325 2001 $ 325 Whole CRTs $ 333 2001 $ 333 CRT Glass Manufacturer 15 ($ 175) 2001 ($ 175) August 24, 2001  DRAFT Page C 3 Source Number Source Title 1 DMC Recycling Inc, 1998.

2 F& M Bay Electronics Co. Inc./ SEER Inc., 2001.

3 WasteNot Recycling, 2001.

4 U. S. Environmental Protection Agency, Region 1. Analysis of Five Community Consumer/ Residential Collections, End of Life Electronic and Electrical Equipment. EPA 901 R 98 003, April 1999.

5 Personal communications with Chem Waste Management, 1998.

6 Personal communications with Clean Harbors of Braintree, 2001.

7 Personal communications with Envirosafe Services of Ohio, 2001.

8 U. S. Environmental Protection Agency, Office of Solid Waste, Economics, Methods and Risk Analysis Division. Unit Cost Compendium. September 30, 2000.

9 ETC's landfill cost survey, 2000.

10 Personal communications with Noranda, 1998.

11 Personal communications with Doe Run, 1998.

12 Aanstoos, T., Mizuki, C., Nichols, S., and Pitts, G. CRT Disposition: An Assessment of Limitations and Opportunities in Reuses, Refurbishment, and Recycling in the U. S., IEEE International Symposium on Electronics & the Environment, 1997.

13 Cutter Information Corp. 's "Product Stewardship Advisor" Vol. I, No. 4, 1997.

14 National Safety Council, Electronic Product Recovery and Recycling Baseline Report, Recycling of Selected Electronic Products in the United States. May 1999.

15 Personal communications with Greg Voorhees of Envirocycle, 2001.

16 Price list from Envirocycle, 2001. August 24, 2001  DRAFT Page D 1 Appendix D Flow of CRTs under Subtitle C (Number)

Total Number of CRTs To Collector To Reuse To MSW Landfill (Subtitle D) To HW Landfill (Subtitle C) To Reclaimer To Glass Processor To Exporter To CRT Manufacturer Baseline Original Users SQGs CRT only 2,036,512 1,547,749 40,730 40,730 305,477 101,826 SQGs all HW 105,753 79,315 26,438 LQGs CRT only 453,584 344,724 9,072 9,072 68,038 22,679 LQGs all HW 45,517 34,138 11,379 Collectors SQGs 167,160 33,432 3,343 38,447 41,790 50,148 LQGs 1,838,765 367,753 183,877 183,877 551,630 551,630 Glass Processor Funnel glass 245,826 4,917 240,910 Panel glass 472,098 9,442 462,656 All CRTs 2,005,925 450,987 0 274,839 610,196 717,924 601,778 703,566 Primary Alternative Original Users SQGs CRT only 40,727 40,727 SQGs all HW 2,129 2,129 LQGs CRT only 8,919 8,919 LQGs all HW 920 920 Former SQG  CRT only 1,995,785 1,556,712 39,916 299,368 99,789 Former SQG  all HW 103,624 80,827 2,072 15,544 5,181 Total Number of CRTs To Collector To Reuse To MSW Landfill (Subtitle D) To HW Landfill (Subtitle C) To Reclaimer To Glass Processor To Exporter To CRT Manufacturer August 24, 2001  DRAFT Page D 2 Former LQG  CRT only 444,665 346,839 8,893 66,700 22,233 Former LQG  all HW 44,597 34,786 892 6,690 2,230 Collectors SQGs 3,365 673 67 774 841 1,010 LQGs 37,018 7,404 740 5,553 16,658 6,663 Former SQG 164,898 32,980 41,225 41,225 49,470 Former LQG 1,813,882 362,776 308,360 816,247 326,499 Glass Processor Funnel glass 343,921 6,878 337,042 Panel glass 660,484 13,210 647,274 All CRTs 2,019,164 455,606 0 53,502 764,300 1,004,405 383,641 984,317 CSI Alternative Original Users SQGs CRT only 305,535 45,830 259,705 SQGs all HW 15,843 2,376 13,467 LQGs CRT only 67,528 10,129 57,399 LQGs all HW 6,845 1,027 5,819 Collectors SQGs 164,678 32,936 3,294 37,876 41,170 49,404 LQGs 1,811,462 362,292 36,229 235,490 815,158 362,292 Glass Processor Funnel glass 370,110 7,402 362,708 Panel glass 710,779 14,216 696,563 CSI Handlers CSI SQHs 2,245,614 1,976,140 44,912 224,561 Total Number of CRTs To Collector To Reuse To MSW Landfill (Subtitle D) To HW Landfill (Subtitle C) To Reclaimer To Glass Processor To Exporter To CRT Manufacturer August 24, 2001  DRAFT Page D 3 CSQ LQHs All CRTs 1,976,140 440,140 0 98,886 631,373 1,080,889 411,696 1,059,271 Flow of CRTs under Subtitle C (Tons)

Total Tons of CRTs To Collector To Reuse To MSW Landfill (Subtitle D) To HW Landfill (Subtitle C) To Reclaimer To Glass Processor To Exporter To CRT Manufacturer Baseline Original Users SQGs CRT only 35,639 27,086 713 713 5,346 1,782 SQGs all HW 1,851 1,388 463 LQGs CRT only 7,938 6,033 159 159 1,191 397 LQGs all HW 797 597 199 Collectors SQGs 2,925 585 35 404 439 878 LQGs 32,178 6,436 1,931 1,931 5,792 9,654 Glass Processor Funnel glass 2,581 52 2,530 Panel glass 4,957 99 4,858 All CRTs 35,104 7,892 3,499 9,022 7,538 10,531 7,387 Primary Alternative Original Users SQGs CRT only 713 713 SQGs all HW 37 37 LQGs CRT only 156 156 LQGs all HW 16 16 Total Tons of CRTs To Collector To Reuse To MSW Landfill (Subtitle D) To HW Landfill (Subtitle C) To Reclaimer To Glass Processor To Exporter To CRT Manufacturer August 24, 2001  DRAFT Page D 4 Former SQG  CRT only 34,926 27,242 699 5,239 1,746 Former SQG  all HW 1,813 1,414 36 272 91 Former LQG  CRT only 7,782 6,070 156 1,167 389 Former LQG  all HW 780 609 16 117 39 Collectors SQHs 59 12 1 8 9 18 LQHs 648 130 8 58 175 117 Former SQH 2,886 577 433 433 866 Former LQH 31,743 6,349 3,238 8,571 5,714 Glass Processor Funnel glass 3,611 72 3,539 Panel glass 6,935 139 6,796 All CRTs 35,335 7,973 931 10,743 10,546 6,714 10,335 CSI Alternative Original Users SQGs CRT only 5,347 802 4,545 SQGs all HW 277 42 236 LQGs CRT only 1,182 177 1,004 LQGs all HW 120 18 102 Collectors SQHs 2,882 576 35 398 432 865 LQHs 31,701 6,340 380 2,473 8,559 6,340 Glass Processor Total Tons of CRTs To Collector To Reuse To MSW Landfill (Subtitle D) To HW Landfill (Subtitle C) To Reclaimer To Glass Processor To Exporter To CRT Manufacturer August 24, 2001  DRAFT Page D 5 Funnel glass 3,886 78 3,808 Panel glass 7,463 149 7,314 CSI Handlers CSI SQHs 39,298 34,582 786 3,930 CSQ LQHs All CRTs 34,582 7,702 0 1,454 8,984 11,349 7,205 11,122 Bolded entries include the weight of the CRT glass only. Non bolded entries include the weight of the entire monitor. August 24, 2001  DRAFT Page D 6 Flow of CRTs under Subtitle D (Number)

Total Number of CRTs To Collector To Reuse To MSW Landfill (Subtitle D) To HW Landfill (Subtitle C) To Reclaimer To Glass Processor To Exporter To CRT Manufacturer Baseline Original Users SQGs CRT only 2,036,512 122,191 40,730 1,629,210 40,730 101,826 101,826 SQGs all HW 105,753 10,575 84,602 10,575 LQGs CRT only 453,584 27,215 9,072 362,867 9,072 22,679 22,679 LQGs all HW 45,517 4,552 36,414 4,552 Collectors SQGs 13,711 2,742 6,856 686 686 2,742 LQGs 150,822 30,164 64,853 3,016 7,541 15,082 30,164 Glass Processor Funnel glass 48,031 961 47,070 Panel glass 92,241 1,845 90,397 All CRTs 164,533 82,708 2,184,802 67,945 135,537 140,273 32,907 137,467 PrimaryAlternative Original Users SQGs CRT only 40,727 40,727 SQGs all HW 2,129 2,129 LQGs CRT only 8,919 8,919 LQGs all HW 920 920 Former SQG CRT only 1,995,785 199,579 39,916 1,496,839 139,705 119,747 Former SQG HW 103,624 10,362 2,072 77,718 7,254 6,217 Former LQG CRT only 444,665 44,467 8,893 333,499 31,127 26,680 Total Number of CRTs To Collector To Reuse To MSW Landfill (Subtitle D) To HW Landfill (Subtitle C) To Reclaimer To Glass Processor To Exporter To CRT Manufacturer August 24, 2001  DRAFT Page D 7 Former LQG HW 44,597 4,460 892 33,448 3,122 2,676 Collectors SQGs 431 86 173 9 56 43 65 LQGs 4,746 949 1,898 95 380 712 712 Former SQG 21,141 4,228 8,456 3,171 2,114 3,171 Former LQG 232,549 46,510 93,020 23,255 34,882 34,882 Glass Processor Funnel glass 66,110 1,322 64,788 Panel glass 126,962 2,539 124,422 All CRTs 39,031 17,564 405,924 9,793 29,046 30,086 5,855 29,485 CSIAlternative Original Users SQGs CRT only 305,535 183,321 45,830 76,384 SQGs all HW 15,843 9,506 2,376 3,961 LQGs CRT only 67,528 40,517 10,129 16,882 LQGs all HW 6,845 4,107 1,027 1,711 Collectors SQGs 18,713 3,743 7,111 374 1,871 1,871 3,743 LQGs 205,848 41,170 78,222 4,117 10,292 30,877 41,170 Glass Processor Funnel glass 88,106 1,762 86,344 Panel glass 169,204 3,384 165,820 CSI Handlers CSI SQHs 2,245,614 224,561 44,912 1,751,579 224,561 CSI LQHs All CRTs 258,867 103,547 2,045,051 52,798 211,930 193,072 38,830 189,210 August 24, 2001  DRAFT Page D 8 Flow of CRTs under Subtitle D (Tons)

Total Tons of CRTs To Collector To Reuse To MSW Landfill (Subtitle D) To HW Landfill (Subtitle C) To Reclaimer To Glass Processor To Exporter To CRT Manufacturer Baseline Original Users SQGs CRT only 35,639 2,138 713 28,511 713 1,782 1,782 SQGs all HW 1,851 185 1,481 185 LQGs CRT only 7,938 476 159 6,350 159 397 397 LQGs all HW 797 80 637 80 Collectors SQGs 240 48 120 0 7 7 48 LQGs 2,639 528 1,135 32 79 158 528 Glass Processor Funnel glass 504 10 494 Panel glass 969 19 949 All CRTs 2,879 1,447 38,234 1,168 2,295 1,473 576 1,443 PrimaryAlternative Original Users SQGs CRT only 713 713 SQGs all HW 37 37 LQGs CRT only 156 156 LQGs all HW 16 16 Former SQG CRT only 34,926 3,493 699 26,195 2,445 2,096 Former SQG HW 1,813 181 36 1,360 127 109 Former LQGCRT only 7,782 778 156 5,836 545 467 Former LQG HW 780 78 16 585 55 47 Total Tons of CRTs To Collector To Reuse To MSW Landfill (Subtitle D) To HW Landfill (Subtitle C) To Reclaimer To Glass Processor To Exporter To CRT Manufacturer August 24, 2001  DRAFT Page D 9 Collectors SQHs 8 2 3 0 1 0 1 LQHs 83 17 33 1 4 7 12 Former SQH 370 74 148 33 22 55 Former LQH 4,070 814 1,628 244 366 610 Glass Processor Funnel glass 694 14 680 Panel glass 1,333 27 1,306 All CRTs 4,530 1,812 35,788 923 3,494 2,027 680 1,987 CSI Alternative Original User SQGs CRT only 5,347 3,208 802 1,337 SQGs all HW 277 166 42 69 LQGs CRT only 1,182 709 177 295 LQGs all HW 120 72 18 30 Collectors SQGs 327 65 124 4 20 20 65 LQGs 3,602 720 1,369 43 108 324 720 Glass Processor Funnel glass 925 19 907 Panel glass 1,777 36 1,741 CSI Handlers CSI SQHs 39,298 3,930 786 30,653 3,930 CSI LQHs All CRTs 3,930 1,572 36,301 1,086 1,913 2,702 786 2,648 Bolded entries include the weight of the CRT glass only. Non bolded entries include the weight of the entire monitor. August 24, 2001  DRAFT Page E 1 Appendix E Average Shipment Sizes for Each Type of Establishment Distributing CRTs to Each CRT Management Option To Collector To Reuse To HW (Subtitle C) To Reclaimer To Glass Processor To Exporter To CRT Manufacturer Baseline  Subtitle C SQGs CRT only 1.4 1.4 1.4 1.4 1.4 SQGs all HW 0.4  0.4

LQGs CRT only 5.2 5.1 5.1 5.2 5.1 LQGs all HW 0.2  0.2

SQHs 11.8 7.1 7.4 7.4 11.8 LQHs 13.0 8.1 8.1 8.1 13.0 Glass Processor  Funnel 9.3 13.2 Glass Processor  Panel 13.4 13.6 Primary Alternative  Subtitle C SQGs CRT only   1.4

SQGs all HW   0.4

LQGs CRT only   5.2

LQGs all HW   0.2

SQHs 9.5 0.6 6.6 7.1 7.1 LQHs 13.1 6.3 7.8 7.8 11.8 Glass Processor  Funnel 12.7 13.5 Glass Processor  Panel 12.2 13.8 Former SQG  CRT only PA 2.8 2.8  2.8 2.8 Former SQG  HW PA 0.8 0.8  0.8 0.8 Former LQG  CRT only PA 20.7 19.8  20.7 19.8 Former LQG  HW PA 0.8 0.7  0.8 0.8 Former SQH 11.6  7.4 7.4 11.8 Former LQH 21.9  13.7 13.8 21.9 CSI Alternative  Subtitle C SQGs CRT only   1.4 1.4

SQGs all HW   0.4 0.4

LQGs CRT only

LQGs all HW   0.6 0.6

SQHs 11.6 7.0 7.3 7.3 11.6 LQHs 12.8 7.9 8.0 8.0 12.8 Glass Processor  Funnel 13.2 13.6 Glass Processor  Panel 12.7 13.6 CSI SQHs

CSI LQHs

Number of Shipments each Year Under Subtitle C August 24, 2001  DRAFT Page E 2 Collectors Reuse Subtitle C Disposal Reclaimers Glass Processors Exporters CRT Glass Manufacturers Totals Baseline Original Users SQGs CRT only 15,526 409 409 3,065 1,022 20,431 SQGs all HW 3,342 1,114 4,456 LQGs CRT only 888 24 24 176 59 1,171 LQGs all HW 2,763 921 3,684 Collectors SQGs 40 4 44 48 60 196 LQGs 400 192 192 574 600 1,958 Glass Processors Funnel glass 2 94 96 Panel glass 4 172 176 Primary Alternative Original Users SQGs CRT only 408 408 SQGs all HW 90 90 LQGs CRT only 24 24 LQGs all HW 72 72 Former SQG CRT only 15,616 401 3,003 1,001 20,021 Former SQG all HW 1,703 44 328 110 2,185 Former LQG CRT only 2,454 63 472 158 3,147 Former LQG all HW 705 19 136 46 906 Collectors SQGs 1 1 1 1 2 6 LQGs 8 1 6 18 8 41 Former SQGs 40 47 47 59 193 Former LQGs 294 211 633 294 1,432 Glass Processors Funnel glass 3 128 131 Panel glass 5 241 246 CSI Alternative Collectors Reuse Subtitle C Disposal Reclaimers Glass Processors Exporters CRT Glass Manufacturers Totals August 24, 2001  DRAFT Page E 3 Original Users SQGs CRT only 460 2,605 3,065 SQGs all HW 101 568 669 LQGs CRT only 27 150 177 LQGs all HW 83 470 553 Collectors SQHs 40 4 44 48 60 196 LQHs 400 39 287 861 360 1,947 Glass Processors Funnel glass 3 138 141 Panel glass 6 260 266 CSI Handlers CSI SQHs 30,643 697 3,483 34,823 CSI LQHs August 24, 2001  DRAFT Page F 1 Appendix F Average Annual Sales per Establishment by 2 Digit SIC Code Industry SIC Code Average Sales per Establishment ($)

AGRICULTURE Agricultural services 7 $

Forestry 8 $

Fishing, hunting, trapping 9 $

Administrative & Auxiliary MINING Metal Mining 10 $ 9,642,717 Coal Mining 12 $ 8,841,349 Oil & Gas Extraction 13 $ 5,338,313 Non metallic minerals, except fuels 14 $ 2,338,749 Administrative & Auxiliary  $ 1,545,768 CONSTRUCTION General contractors 15 $ 1,280,404 Heavy construction 16 $ 2,570,507 Special trade contractors 17 $ 590,600 Administrative & Auxiliary  $ 2,207,600 MANUFACTURING Food & kindred products 20 $ 19,567,362 Tobacco products 21 $ 308,752,632 Textile mill products 22 $ 12,020,557 Apparel & other textile products 23 $ 3,103,014 Lumber & wood products 24 $ 2,277,901 Furniture & Fixtures 25 $ 3,759,298 Paper & allied products 26 $ 20,760,708 Printing & publishing 27 $ 2,540,878 Chemicals & allied products 28 $ 25,443,194 Petroleum and coal products 29 $ 70,728,296 Rubber & miscellaneous plastics products 30 $ 7,170,357 Leather & leather products 31 $ 4,751,863 Stone, clay, and glass products 32 $ 3,846,475 Primary metal industries 33 $ 21,271,651 Fabricated metal products 34 $ 4,571,413 Industrial machinery & equipment 35 $ 4,793,932 Electronic & other electronic equipment 36 $ 12,809,615 Industry SIC Code Average Sales per Establishment ($)

August 24, 2001  DRAFT Page F 2 Transportation equipment 37 $ 35,374,262 Instrument & related products 38 $ 11,884,834 Miscellaneous manufacturing 39 $ 2,318,656 Administrative & Auxiliary  $ 3,156,356 TRANSPORTATION Local & Interurban passenger transit 41 $ 710,436 Trucking & Warehousing 42 $ 1,296,519 Water transportation 44 $ 3,585,027 Transportation by Air 45 $ 2,338,134 Pipelines, except natural gases 46 $ 8,368,550 Transportation services 47 $ 512,735 Communication 48 $ 5,877,769 Electronic, gas, & sanitary services 49 $ 15,510,062 Administrative & Auxiliary  $ 1,766,775 WHOLESALE TRADE Wholesale trade durable goods 50 $ 5,084,711 Wholesale trade nondurable goods 51 $ 9,036,867 Administrative & Auxiliary  $ 781,548 RETAIL TRADE Bldg. Materials & garden supplies 52 $ 1,422,393 General merchandise store 53 $ 7,089,224 Food stores 54 $ 2,044,651 Auto dealers & service station 55 $ 4,100,193 Apparel & accessory stores 56 $ 699,117 Furniture & home furnishing stores 57 $ 846,766 Eating & drinking places 58 $ 450,446 Miscellaneous retail 59 $ 607,995 Administrative & Auxiliary  $ 370,918 FINANCE, INSURANCE, AND REAL ESTATE Depository Institution 60 $ 5,091,211 Nondepository Institution 61 $ 3,432,819 Security & commodity brokers 62 $ 3,491,738 Insurance carriers 63 $ 20,422,940 Insurance agents, brokers, & servicers 64 $ 424,989 Real Estate 65 $ 617,331 Holding & other investment offices 67 $ 3,237,932 Administrative & Auxiliary  $ 1,054,687 Industry SIC Code Average Sales per Establishment ($)

August 24, 2001  DRAFT Page F 3 SERVICES Hotels & other lodging places 70 $ 1,423,393 Personal services 72 $ 219,582 Business services 73 $ 896,726 Auto repair, services, & parking 75 $ 407,237 Misc. repair services 76 $ 429,359 Motion picture 78 $ 1,040,439 Amusement & recreation services 79 $ 793,715 Health services 80 $ 677,073 Legal services 81 $ 641,030 Educational services 82 $ 491,509 Social services 83 $ 225,786 Museums, botanical, zoological gardens 84 $ 611,305 Membership organization 86 $ 500,857 Engineering & management service 87 $ 827,956 Services, n. e. c 89 $ 546,119 Administrative & Auxiliary  $ 1,053,680 Unclassified  NA Source: U. S. Bureau of the Census (1992). Includes County Business Patterns data and data from the Enterprise Statistics Program. August 24, 2001  DRAFT Page G 1 Appendix G Detailed Sensitivity Analysis Results on All Parameters Tested Parameter Names Sensitivity Test Parameter Values Percent Change from Best Estimate Savings Under Primary Alternative Savings Under Primary Alternative Using the Sensitivity Test Parameter Values Percent increase (decrease) in amount saved Savings Under CSI Alternative Savings Under CSI Alternative Using the Sensitivity Test Parameter Values Percent increase (decrease) in amount saved Entry/ exit rate for establishments Best Estimate 1 %

Low Range 0.10 % 90 % $ 4,840,000 $ 4,811,000 1 % $ 3,098,000 $ 3,095,000 0 %

High Range 5 % 400 % $ 4,840,000 $ 4,962,000 3 % $ 3,098,000 $ 3,109,000 0 %

Percent laptops disposed Best Estimate 18 %

Low Range 10 % 44 % $ 4,840,000 $ 4,830,000 0 % $ 3,098,000 $ 3,127,000 1 %

High Range 33 % 83 % $ 4,840,000 $ 4,132,000 15 % $ 3,098,000 $ 2,582,000 17 %

Percent funnel glass (vs panel glass)

Best Estimate 34 %

Low Range 30 % 12 % $ 4,840,000 $ 4,840,000 0 % $ 3,098,000 $ 3,098,000 0 %

High Range 40 % 18 % $ 4,840,000 $ 4,840,000 0 % $ 3,098,000 $ 3,098,000 0 %

Percent of shipments that include broken CRTs Best Estimate 100 %

Low Range 25 % 75 % $ 4,840,000 $ 4,754,000 2 % $ 3,098,000 $ 3,005,000 3 %

High Range 100 % 0 % $ 4,840,000 $ 4,840,000 0 % $ 3,098,000 $ 3,098,000 0 %

Percent of CRTs sent to SQ Collectors Best Estimate 8 %

Low Range 2 % 75 % $ 4,840,000 $ 4,812,000 1 % $ 3,098,000 $ 3,152,000 2 %

High Range 50 % 525 % $ 4,840,000 $ 5,002,000 3 % $ 3,098,000 $ 2,850,000 8 %

Percent of CRTs sent to former SQ Collectors (Primary Alternative only)

Best Estimate 98 %

Low Range 50 % 49 % $ 4,840,000 $ 4,347,000 10 % N/ A N/ A N/ A High Range 99 % 1 % $ 4,840,000 $ 4,849,000 0 % N/ A N/ A N/ A Percent of generators sending to reuse Parameter Names Sensitivity Test Parameter Values Percent Change from Best Estimate Savings Under Primary Alternative Savings Under Primary Alternative Using the Sensitivity Test Parameter Values Percent increase (decrease) in amount saved Savings Under CSI Alternative Savings Under CSI Alternative Using the Sensitivity Test Parameter Values Percent increase (decrease) in amount saved August 24, 2001  DRAFT Page G 2 Best Estimate 2 %

Low Range 0 % 100 % $ 4,840,000 $ 4,767,000 2 % $ 3,098,000 $ 3,195,000 3 %

High Range 15 % 650 % $ 4,840,000 $ 4,893,000 1 % $ 3,098,000 $ 2,851,000 8 %

Percent of CRTs sent for export (Baseline only)

Best Estimate 30 %

Low Range 10 % 67 % $ 4,840,000 $ 4,630,000 4 % $ 3,098,000 $ 2,888,000 7 %

High Range 50 % 67 % $ 4,840,000 $ 4,764,000 2 % $ 3,098,000 $ 3,022,000 2 %

Percent of CRTs sent for export (Primary Alternative only)

Best Estimate 30 % or 18 %

Low Range 5 % 83 % or 72 % $ 4,840,000 $ 5,244,000 8 % N/ A N/ A N/ A High Range 30 % 0 % or 66 % $ 4,840,000 $ 4,523,000 7 % N/ A N/ A N/ A Percent of CRTs sent for export (CSI Alternative only)

Best Estimate 30 % or 20 %

Low Range 5 % 0 % or 75 % N/ A N/ A N/ A $ 3,098,000 $ 3,487,000 13 %

High Range 40 % 33 % or 100 % N/ A N/ A N/ A $ 3,098,000 $ 2,627,000 15 %

Maximum shipment weight (in tons) for whole CRTs Best Estimate 22 Low Range 18 18 % $ 4,840,000 $ 4,670,000 4 % $ 3,098,000 $ 3,085,000 0 %

High Range 24 9 % $ 4,840,000 $ 4,897,000 1 % $ 3,098,000 $ 3,104,000 0 %

Maximum shipment weight (in tons) for crushed CRTs Best Estimate 23 Low Range 20 13 % $ 4,840,000 $ 4,932,000 2 % $ 3,098,000 $ 3,104,000 0 %

High Range 25 9 % $ 4,840,000 $ 4,788,000 1 % $ 3,098,000 $ 3,091,000 0 %

Shipping Distances (in miles):

to Handler Best Estimate 20 Low Range 5 75 % $ 4,840,000 $ 4,840,000 0 % $ 3,098,000 $ 3,096,000 0 %

High Range 50 150 % $ 4,840,000 $ 4,838,000 0 % $ 3,098,000 $ 3,100,000 0 %

to Reuse Best Estimate 20 Parameter Names Sensitivity Test Parameter Values Percent Change from Best Estimate Savings Under Primary Alternative Savings Under Primary Alternative Using the Sensitivity Test Parameter Values Percent increase (decrease) in amount saved Savings Under CSI Alternative Savings Under CSI Alternative Using the Sensitivity Test Parameter Values Percent increase (decrease) in amount saved August 24, 2001  DRAFT Page G 3 Low Range 5 75 % $ 4,840,000 $ 4,840,000 0 % $ 3,098,000 $ 3,097,000 0 %

High Range 50 150 % $ 4,840,000 $ 4,839,000 0 % $ 3,098,000 $ 3,099,000 0 %

to Subtitle C Landfill Best Estimate 250 Low Range 100 60 % $ 4,840,000 $ 4,738,000 2 % $ 3,098,000 $ 3,018,000 3 %

High Range 500 100 % $ 4,840,000 $ 5,008,000 3 % $ 3,098,000 $ 3,230,000 4 %

to Glass Processor Best Estimate 200 Low Range 100 50 % $ 4,840,000 $ 4,767,000 2 % $ 3,098,000 $ 3,137,000 1 %

High Range 400 100 % $ 4,840,000 $ 4,984,000 3 % $ 3,098,000 $ 3,017,000 3 %

to CRT Glass Manufacturer Best Estimate 100 Low Range 50 50 % $ 4,840,000 $ 4,844,000 0 % $ 3,098,000 $ 3,104,000 0 %

High Range 200 100 % $ 4,840,000 $ 4,829,000 0 % $ 3,098,000 $ 3,085,000 0 %

to Reclaimer (from Generator or Collectors)

Best Estimate 300 Low Range 100 67 % $ 4,840,000 $ 4,744,000 2 % $ 3,098,000 $ 3,116,000 1 %

High Range 500 67 % $ 4,840,000 $ 4,935,000 2 % $ 3,098,000 $ 3,080,000 1 %

to Reclaimer (from Glass Processors)

Best Estimate 350 Low Range 200 43 % $ 4,840,000 $ 4,839,000 0 % $ 3,098,000 $ 3,099,000 0 %

High Range 500 43 % $ 4,840,000 $ 4,839,000 0 % $ 3,098,000 $ 3,096,000 0 %

Costs for Disposal to Glass Processor (per ton):

Broken CRTs, no metal Best Estimate $ 0 Low Range $ 0 N/ A $ 4,840,000 $ 4,840,000 0 % $ 3,098,000 $ 3,098,000 0 %

High Range $ 10.00 N/ A $ 4,840,000 $ 4,820,000 0 % $ 3,098,000 $ 3,136,000 1 %

Broken CRTs, with metal Best Estimate $ 100.00 Low Range $ 50.00 50 % $ 4,840,000 $ 4,859,000 0 % $ 3,098,000 $ 3,115,000 1 % Parameter Names Sensitivity Test Parameter Values Percent Change from Best Estimate Savings Under Primary Alternative Savings Under Primary Alternative Using the Sensitivity Test Parameter Values Percent increase (decrease) in amount saved Savings Under CSI Alternative Savings Under CSI Alternative Using the Sensitivity Test Parameter Values Percent increase (decrease) in amount saved August 24, 2001  DRAFT Page G 4 High Range $ 150.00 50 % $ 4,840,000 $ 4,818,000 0 % $ 3,098,000 $ 3,077,000 1 %

Whole Bare CRTs Best Estimate $ 192.00 Low Range $ 100.00 48 % $ 4,840,000 $ 4,859,000 0 % $ 3,098,000 $ 3,115,000 1 %

High Range $ 300.00 56 % $ 4,840,000 $ 4,814,000 1 % $ 3,098,000 $ 3,073,000 1 %

Broken mixed color/ monochrome Best Estimate $ 325.00 Low Range $ 250.00 23 % $ 4,840,000 $ 4,868,000 1 % $ 3,098,000 $ 3,124,000 1 %

High Range $ 400.00 23 % $ 4,840,000 $ 4,808,000 1 % $ 3,098,000 $ 3,067,000 1 %

Whole CRTs with casing Best Estimate $ 333.33 Low Range $ 200.00 40 % $ 4,840,000 $ 4,853,000 0 % $ 3,098,000 $ 3,332,000 8 %

High Range $ 450.00 35 % $ 4,840,000 $ 4,825,000 0 % $ 3,098,000 $ 2,889,000 7 %

Exporter, Disposal Best Estimate $ 107.00 Low Range $ 0 100 % $ 4,840,000 $ 4,431,000 8 % $ 3,098,000 $ 2,741,000 12 %

High Range $ 200.00 87 % $ 4,840,000 $ 5,195,000 7 % $ 3,098,000 $ 3,407,000 10 %

CRT Glass Manufacturer, Disposal Best Estimate $ (175.00)

Low Range $ (250.00) 43 % $ 4,840,000 $ 4,914,000 2 % $ 3,098,000 $ 3,191,000 3 %

High Range $ 0 100 % $ 4,840,000 $ 4,661,000 4 % $ 3,098,000 $ 2,871,000 7 %

Number of TVs from unregulated users Best Estimate 20,000,000 LowRange 15,000,000 25 % $ 1,117,000 $ 1,660,000 49 % $ 4,202,000 $ 4,024,000 4 %

High Range 30,000,000 50 % $ 1,117,000 $ (10,000) 101 % $ 4,202,000 $ 4,552,000 8 %

Number of monitors from unregulated users Best Estimate 16,886,411 Low Range 10,000,000 41 % $ 1,117,000 $ 1,621,000 45 % $ 4,202,000 $ 4,033,000 4 %

High Range 25,000,000 48 % $ 1,117,000 $ 434,000 61 % $ 4,202,000 $ 4,402,000 5 % August 24, 2001  DRAFT Page G 5 August 24, 2001  DRAFT Page H 1 Appendix H Telephone Contacts Contacts made by Sue Chotikajan:

Tony Catareno, I. G. Inc., 3476 Saint Rocco CT., Cleveland, OH 44109, (216) 631 7710. November 6, 1998.

Questions: (1) Where do you get your discarded CRTs? (2) What types of industries/ manufacturers are your sources (TV and computer manufacturers or post consumer)? (3) How much do you charge for taking discarded CRTs (Specifically for a 30 pound monitor)? (4) What do you with the glass? Is it landfilled, sent to smelters, or sent to CRT glass manufacturers? (5) What is the percentage of this allocation? (6) What is the cost of sending glass to each disposal or recycling alternative? (7) What is the total number of CRTs processed annually and total weight processed? (8) Do you have information on the number of color vs. monochrome monitors processed?

Responses: C I. G. Inc. receives used CRTs from leasing companies, a few from households, but none from manufacturers.

C I. G. Inc. charges $3$ 5 per monitor for pick up services of discarded computers, and leasing companies pay for their own transportation.

C CRTs are pulled out of monitor and processed. Some parts (phosphorous, metals, glass) are sent to recycling companies and glass manufacturers.

C All CRT glass is sent to CRT glass manufacturers.

C Information on cost sent to each glass manufacturers isn't shared with the public.

C The total number of CRTs processed annually is approximately 5,000 monitors. C Since I. G., Inc. is only processing CRTs as a sideline, we do not track down the types of monitors processed. August 24, 2001  DRAFT Page H 2 Jim Weber, Federal Prison Industries, Ohio, (330) 424 –7448 (ext. 1313). November 6, 1998.

Questions: (1) Where do you get your discarded CRTs? (2) What types of industries/ manufacturers are your sources (TV and computer manufacturers or post consumer)? (3) How much do you charge for taking discarded CRTs (Specifically for a 30 pound monitor)? (4) What do you with the glass? Is it landfilled, sent to smelters, or sent to CRT glass manufacturers? (5) What is the percentage of this allocation? (6) What is the cost of sending glass to each disposal or recycling alternative? (7) What is the total number of CRTs processed annually and total weight processed? (8) Do you have information on the number of color vs. monochrome monitors processed?

Responses: C Federal Prison Industries receives discarded computers from GE, Motorola, computer manufacturers, and schools. Federal Prison Industries doesn't receive any discarded televisions.

C Federal Prison Industries charges $4$ 5 per monitor, and the manufacturer or entity discarding the computer monitors pays for the shipping.

C Generally, Federal Prison Industries' picks up and sorts the computer monitors and then sends them to Envirocycle, a CRT glass to glass recycling center. None of the discarded CRTs are landfilled or sent to smelters.

C All discarded CRTs are sent to CRT glass manufacturers, through CRT glass to glass recyclers, such as Envirocycle.

C Envirocycle pays $0.25 per pound of glass or $500 per ton of glass.

C Federal Prison Industries processes around 4,000 monitors per year.

C On average, they process an equal number of color and monochrome monitors. The most common types of color monitors discarded are GEA and CEA. They separate the glass into four types: PB, color, NPHS, and miscellaneous plastic filament.

Gary DiRusso, DMC Recycling, New Hampshire, gdirusso@ dmcrecycling. com. October 30, 1998.

Questions: (1) Where do you get your discarded CRTs? August 24, 2001  DRAFT Page H 3 (2) What types of industries/ manufacturers are your sources (TV and computer manufacturers or post consumer)? (3) How much do you charge for taking discarded CRTs (Specifically for a 30 pound monitor)? (4) What do you with the glass? Is it landfilled, sent to smelters, or sent to CRT glass manufacturers? (5) What is the percentage of this allocation? (6) What is the cost sent to each? (7) What is the total number of CRTs processed annually and total weight processed? (8) Do you have information on the number of color vs. monochrome monitors processed?

Responses: C DMC receives monitors from a government agency (NSA), businesses such as (SunMicro, AT& T, etc) and computer monitor manufacturers, such as Nissei, Sangyo (Hitachi).

C Approximately 50 percent by weight of the monitors that DMC receives from the government can be reused; the other 50 percent is disassembled and recycled. Reusable computer monitors represent approximately 30 percent of the total materials received from the government. The remaining 70 percent is computers, telecommunications equipment, and other electronic equipment.

C DMC charges $0.11 – 0.13 per pound (based on quantity) for recycling monitors.

C DMC receives shipments of 10,000 to 30,000 pounds at a time from monitor manufacturers.

C DMC currently processes approximately 1 million pounds of monitors per year with expectations that this could increase considerably because of the landfill ban pending in Massachusetts effective July 1999. [One million pounds of monitors is approximately 33,000, 30 pound computer monitors.]

C DMCs current capacity is 6.5 million pounds in a 40 hour workweek. DMC can process this large capacity because all of their equipment is automated to recycle whole monitors or CRTs.

C DMC recycles glass, steel, copper, plastic, and aluminum from the computer monitors.

C All the glass from CRTs that DMC recycles is sent to a lead smelter. Typically they ship the glass by rail in quantities of about 100,000 pounds (50 tons). C The primary lead smelter uses the glass silicate in place of a commercial fluxing agent and recovers the lead.

C DMC's recycling process entails 5 steps to breakup and separate the computer monitor materials: (1) shredding; (2) ferrous separation; (3) pulverizing the glass; (4) sifting the glass; (5) containerizing the copper, aluminum, and plastic. August 24, 2001  DRAFT Page H 4 Contacts made by Tom Uden:

Robert Bouma, Noranda, Toronto, Ontario, (416) 982 7237. November 4, 1998.

Questions: (1) What is the cost for disposal/ recycling of CRTs at your facility? (2) Where do CRTs fit in your process? (3) How many CRTs are processed each year? (4) What types of companies/ organizations typically provide you CRTs? (5) Any other general information?

Responses: C The price for taking CRTs is several hundred dollars, but typically less than $500 per ton. This value is closely guarded, because various companies "compete" for monitors. The fee is the money maker in this operation, not the copper, silica, and precious metal values recovered. CRT glass is less valuable than a whole monitor, because there are no precious metals or copper in the CRT glass.

C CRTs are introduced whole, or shredded into a copper smelter. Copper (principally from the yoke) and small amounts of precious metal are recovered. Lead is discarded in the furnace slag to a secure impoundment. CRTs also contain silica, which is useful as a fluxing agent.

C Noranda accepts approximately 1,000  2,000 tons of monitors per year. [This weight range represents between 50,000 to 130,000 monitors.] Weight assumptions would allow calculation of absolute numbers. The principle input is whole monitors, as opposed to broken CRT glass, or only the CRT. TVS are generally too large for the shredder. Some non viable TV tubes are obtained from OEMs.

C Generally electronic scrap brokers supply the CRTs. Often, these brokers will go into an office facility, to obtain the highest value components (the computer "boxes"). They may attempt to refurbish and sell monitors. However, most brokers take the monitors even though they do not want them. They take the monitors as part of a package deal, to get the computers which contain much greater levels of precious metals. Another source of monitors is from OEMs. If an OEM (e. g., IBM, Digital, HP) replaces an entire office's PCS, the broker, as part of a package deal, will take away the old systems, including monitors. Taking the monitors is part of the service.

C CRT glass direct from OEMs (broken in manufacturing for example) is an ideal input for their lead smelter in New Brunswick. The glass must be clean, because plastic fouls the sulfuric acid plant that is part of the process. August 24, 2001  DRAFT Page H 5 Cliff Asbury, Doe Run, Glover, MO, (573) 546 7492, x 237. November 10, 1998.

Questions: (1) What is the cost for disposal/ recycling of CRTs at your facility? (2) Where do CRTs fit in your process? (3) How many CRTs are processed each year? (4) What types of companies/ organizations typically provide you CRTs? (5) Any other general information?

Responses: C A general number for disposal of CRTs at Doe Run is $140 per ton of CRT glass. The number will vary depending on the quality of the glass, and the volume (Doe Run offers high volume discounts).

C CRT glass is introduced as a fluxing agent at the primary smelter. Some lead is recovered from the lead content in the glass, but the primary value is as a fluxing agent. The CRTs are exempt from being manifested to the smelter, under a 50% material substitution provision.

C 100 125 tons of CRT glass are processed each year. [This weight range represents between 5,000 to 8,000 monitors.] CRT glass is generally shipped in "gaylord" boxes. These are 1 cubic yard cardboard boxes. Doe Run would like to receive the glass in dump trucks, or rail cars. This would eliminate the need to dispose of several thousand boxes a year.

C CRT glass comes from recovery services, that scavenge used computers. Some try to refurbish the computers, often sending them overseas. A lot of these companies are primarily interested in the precious metal and copper values in the computer "box." They take the monitors as part of the deal, and have to get rid of the glass. They only dump the glass after fully disassembling and recovering valuable components from the monitor.

C One broker/ processor (DMC) sends glass to Doe Run crushed to 3/ 8 inch particles. The crushing is good for the broker/ processor (because they can use magnetic separation techniques to get the metal out), and for Doe Run (because fewer contaminants remain in the glass, and the glass is already crushed for introduction into the smelting furnace).

C Mr. Asbury mentioned three brokers/ processors: C Asset Recovery, MN; 612 602 0789, Bruce Janovic. This may be an affiliate of Digital Corp. C DMC, NH; 603 772 7236, Mike Mogliano. C SEER, FL; 800 376 7888, Mike Flynn.

C Mr. Asbury expressed concern that the current CSI proposal favors glass to glass recycling. Doe Run does not want to lose CRTs as an input and revenue generator. [CRTs may represent an important revenue source, especially when the price of lead is low.] August 24, 2001  DRAFT Page H 6 Mike Flynn, SEER (Secure Environmental Electronic Recovery), Tampa, FL. (888) 600 7337. November 11, 1998.

Questions: (1) What is the cost for disposal/ recycling of CRTs at your facility? (2) Where do CRTs fit in your process? (3) How many CRTs are processed each year? (4) What types of companies/ organizations typically provide you CRTs? (5) Any other general information?

Responses: C SEER charges $7.50 per computer monitor, $12.50 per table top television, and $35.00 per console television.

C Typically whole computer systems are recovered from companies. Usually this results from a modernization of company hardware. Very often, these companies have old equipment in a warehouse that is removed at the same time. SEER determines if the equipment (including monitor) has resale or refurbishment value. If re sale or refurbishment is not an option (as with older equipment that has been stored for a while) demanufacturing occurs. Some consumers give SEER computer monitors and televisions, if they are concerned with "doing the right thing" environmentally.

C For monitors, the mercury switches, and valuable parts are removed. The vacuum is released. The front panel is cut away. CRTs are shipped in gaylord boxes. 950 pounds of CRTs fit in one box, although Mike could not say how many CRTs this represents. [950 pounds of CRTs is approximately 30 CRTs.] They currently ship to Doe Run only. Mr. Flynn is going to visit Envirocycle next week to look into sending some CRT glass to them. He predicts that there will be increased disposal in the near future, and that he will need more than one outlet for CRTs. If SEER contracts with Envirocycle, the monitor flow would be: (1) end user, (2) SEER, (3) Envirocycle, (4) Techniglass.

C Mr. Flynn did not have the number of CRTs processed per year available at the time of the call.

C Companies with a large computer base, usually located in large office buildings or complexes, are SEER's typical customers. They find out about SEER through Subtitle D landfills. For instance, many CWM Inc. Subtitle D landfills in the area refer companies with large CRT volumes to SEER. It was not apparent whether this is a formal arrangement, although it seems unlikely.

C Florida recently adopted Universal Waste Regulations, and SEER is a Universal Waste Handler and Transporter. This allows them to handle batteries and mercury switches. Mr. Flynn claimed that when the CRTs are brought to SEER, they are in monitor format and are August 24, 2001  DRAFT Page H 7 therefore still potentially a viable product. They are therefore exempt from RCRA manifest and other requirements. When they are sent to Doe Run, they are exempt because they are primary process feed. He is not sure what the RCRA status of shipping to Envirocycle would be; he intends to find out next week.

C Mr. Flynn also expressed concern that the CSI proposal will preferentially treat the glass toglass channel. He thinks that any increased regulations on smelters would create a problem, because the glass to glass processors do not have the capacity to handle the projected increase in CRT disposal.

Various, Chemical Waste Management (CWM). November 2 3, 1998.

Questions: (1) What is the cost for disposal/ recycling of CRTs at your facility? (2) Where do CRTs fit in your process? (3) How many CRTs are processed each year? (4) What types of companies/ organizations typically provide you CRTs? (5) Any other general information?

Responses: C The disposal cost is $285/ cu yard for macroencapsulation, and $150 175 for 55 gal drum of whole monitors/ CRTs (Street, AL). In addition, for Model City NY, if the shipment is from out of state it is subject to a $27/ ton state hazardous waste tax. All shipments to the facility are subject to a 6% town tax, and a 7% sales tax (Customer Service, NY). Mr. Street mentioned that LA has a more favorable tax structure.

C CWM is a RCRA Subtitle C facility, with the ability to stabilize lead leaching components. Monitors would be encapsulated (without crushing/ breakage) in impermeable containers, with a concrete type substance poured around them (Customer Service, NY).

C Model City (Buffalo) NY and Emelle AL could not think of specific instances of CRT disposal. (Although Dr. Street in Emelle thought that the NY facility would likely deal with CRTs; he suggested talking to their environmental person, Jill Knickerbocker, who did not return my calls). The Lake Charles LA facility contact could recall one shipment of CRTs that was macroencapsulated (Grant, LA).

C The contact at Emelle thought that shipments of monitors would likely come from Fortune 500 companies with strong environmental programs. He thinks that many monitors are being recycled, some by the same facilities that recycle Hg lamps (Street, AL).

C Contacts: CWM Model City NY (716) 754 8231 Jill Knickerbocker August 24, 2001  DRAFT Page H 8 CWM Emelle AL (205) 652 9721 Dr. Jim Street CWM Lake Charles LA (318) 583 2144 Chuck Grant Heather McCarthy, Clean Harbors of Braintree. May 9 and 24, 2001.

Questions: (1) Have you mostly received CRTs from the users, brokers, or other types of businesses? (2) Are the CRTs mostly sent to you whole or crushed? (3) What are your rates for stabilization and disposal of bulk waste? (4) Can you estimate how many CRTs or how many tons of CRTs your facility has processed in the last year? (5) Does your company provide transportation services?

Responses: C CRTs are mostly received from businesses, but some are received from brokers.

C CRTs are received whole in flex bins, which are similar to but smaller than gaylord boxes.

C CRTs are dismantled and recycled to the maximum extent possible in their Bristol, CT facility. Clean Harbors charges $300 to $500 per flex bin depending on the size and frequency of shipments. The CRT glass is sent to Canada where it is crushed, treated, and disposed. Clean Harbors does not have a minimum charge for shipments of CRTs C Do not have a current estimate of the number or tons of CRTs processed.

C Clean Harbors provides transportation services and charges a flat rate of $150 per shipment for the Boston area. For locations farther away (e. g., Maine) they charge about $300 per shipment.

Lisa Humfry, Envirosafe Services of Ohio. May 10, 2001.

Questions: (1) Have you mostly received CRTs from the users, brokers, or other types of businesses? (2) Are the CRTs mostly sent to you whole or crushed? (3) What are your rates for stabilization and disposal of bulk waste? (4) Can you estimate how many CRTs or how many tons of CRTs your facility has processed in the last year? (5) Does your company provide transportation services?

Responses: August 24, 2001  DRAFT Page H 9 C CRTs are mostly received from brokers, but some are received from businesses. One customer consolidated CRTs from many of its facilities and crushed the CRTs before sending them to Envirosafe. Envirosafe macro encapsulates CRTs sent in poly drums, and encapsulates whole CRTs. If the CRTs are sent crushed in a roll off container, they will stabilize the CRTs for disposal.

C CRTs sometimes are received whole, but mostly crushed in roll off containers.

C The rate for crushed CRTs in a roll off container is $160 per ton. The rate for whole monitors is $360 per cubic yard. The rate for whole CRTs in drums is $150 per drum. Envirosafe does not have a minimum charge for shipments of CRTs.

C Envirosafe received no CRTs last year and about 20 to 30 tons the previous year.

C Envirosafe subcontracts out transportation.

Mark Cardamone, F& M Bay Electronics Co. Inc./ SEER Inc., Tampa, FL. (813) 621 8870. May 14, 2001.

Questions: (1) What do you do with the CRTs you receive? (2) Who do you receive CRTs from? e. g., the users, brokers, or other types of businesses? (3) What are your rates for processing monitors? (4) Can you estimate how many CRTs or how many tons of CRTs your facility has processed in the last year? (5) What do you do with the CRT glass? (6) Does your company provide transportation services?

Responses: C All monitors that were manufactured during or after 1996 are tested to see if they are operational. About 10 percent of the CRTs received are resold. The remaining monitors are demanufactured and the plastic, steel, aluminum, and copper are recycled. The bare CRTs are cut in half to separate the panel from the funnel. The CRT glass is sent to Envirocycle and to Dlubeck Glass.

C Most of the monitors are received from original users. Monitors are also obtained from municipal solid waste facilities that remove the CRTs from the solid waste stream at landfills or transfer stations.

C For monitors that are 17 inches or less, they charge $6 to $7.50 per monitor. For monitors that are larger than 17 inches, they charge $9.50 per monitor. For bare CRTs, they charge $4.00 per bare CRT. August 24, 2001  DRAFT Page H 10 C The facility processed 40,000 CRTs in the last year. This includes both TVs and monitors.

C The CRT glass is sent to Envirocycle and to Dlubeck Glass.

C Transportation services are provided and include scheduled pickups through common carriers and their own trucks. Local pickup includes a range of 50 miles and costs $25 per pickup. In Florida transportation costs are generally $25 to $150 per pickup.

Jack Hope, WasteNot Recycling, Sterling, VA. (703) 787 0200. May 15, 2001.

Questions: (1) What do you do with the CRTs you receive? (2) Who do you receive CRTs from? e. g., the users, brokers, or other types of businesses? (3) What are your rates for processing monitors? (4) Can you estimate how many CRTs or how many tons of CRTs your facility has processed in the last year?

Responses: C WasteNot Recycling is a not for profit organization that trains and employs developmentally disabled adults. They only take functional monitors right now. They are looking into the options for demanufacturing monitors in the future.

C Monitors are received from local companies, such as ATT, SAIC, and Boeing.

C There is no charge for donating monitors.

C Mr. Hope did not have an estimate of the number of computer or monitors received.

Greg Voorhees, Envirocycle, Halstead, PA. (570) 879 2862. April 25, 2001.

Questions: (1) What percent of the CRT glass that you receive is sold as fines? (2) What percent of Envirocycle's processed CRT glass is sent to lead smelters? (3) What is Envirocycle's recycling capacity? (4) Is the facility in North Carolina that is mentioned on your web site open yet? (5) What do you charge for intact whole monitors? (6) What percent of CRTs are received as whole monitors, bare CRTs, or crushed glass?

Responses: August 24, 2001  DRAFT Page H 11 C None.

C All of the fines generated in the processing of CRTs are sent to a primary lead smelter, for which Envirocycle must pay. The processing of CRTs generates about two percent fines by weight. Envirocycle is working to improve the efficiency of its process to reduce the generation of fines.

C Envirocycle is currently operating at about 20 percent of its capacity in its Halstead, PA facility. Envirocycle's current operating tempo is about 1.5 million pounds per month C The North Carolina facility will not be opened. Two other locations are being pursued and will be open by the end of the year. One facility will be located in the north east and the other will be on the west coast.

C Envirocycle charges about $5 to $6 per monitor for whole monitors. The actual price paid is volume dependant.

C About 50 to 60 percent of the glass received is "dirty mix with no metals." This glass comes from other demanufacturing facilities. Envirocycle still receives about the same amount of CRT glass from OEMs as in 1996. August 24, 2001  DRAFT Page I 1 Appendix I Bibliography Aanstoos, T., Mizuki, C., Nichols, S., and Pitts, G. CRT Disposition: An Assessment of Limitations and Opportunities in Reuses, Refurbishment, and Recycling in the U. S., IEEE International Symposium on Electronics & the Environment, 1997.

"April Showers Grew May Color TV Sales," Consumer Electronics Manufacturing Association Homepage, www. cemacity. org/ cemacity/ gazette/ files2/ vidmay98. htm, October 6, 1998.

"Closed Loop CRT Recycling: Why Europe and the U. S. Differ?" Cutter Information Corporation, Product Stewardship Advisor, www. cutter. com/ psa/ fulltext/ 1997/ 09, Volume I, No. 4: September 1997.

"Consumer Electronics Industry Forecast for 1997 – 27.6 Million New TV Sets and Much More," Consumer Electronics Manufacturing Association Homepage, www. cemacity. org/ cemacity/ gazette/ files2/ vidmay98. htm.

DPRA Incorporated. "Regulatory Impact Analysis of the Proposed Rule for a 180 Day Accumulation Time for F006 Wastewater Treatment Sludges," August 4, 1998.

Notes from personal communication with Greg Voorhees from Envirocycle, 1996.

Data series for Personal Computers, Color TV Receivers, Color TV Receivers, Monochrome TV Receivers – U. S. Sales to Dealers, Electronic Industries Alliance, 1998.

Department of Environmental Protection, DEP's 1998 CRT/ Electronics Recycling Strategy Cost/ Benefit Analysis, May 1, 1998.

DMC Monitor Recycling, DMC Electronics Homepage, www. nh. ultranet. com/~ dmc/ monitor. html, accessed October 20, 1998.

Electronic Industries (EIA) Sector, Cathode Ray Tube Industry Subsector Presentation, September 26 28, 1994.