Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

1 Economics Background Document Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation US Environmental Protection Agency Office of Solid Waste Economics, Methods & Risk Analysis Division 1200 Pennsylvania Avenue, NW ( Mailstop 5307W) Washington, DC 20460 USA ( 703) 308 8615 http:// www. epa. gov/ osw 17 July 2003 Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

2 Preface This document was prepared by Mark Eads, Economist, of the USEPA Office of Solid Waste ( OSW) Economics, Methods, and Risk Analysis Division ( EMRAD), based in part, on a 20 August 2000 initial economic study prepared by Northbridge Environmental Management Consultants ( 319 Littleton Road, Suite 208, Westford, MA 01886, ( 978) 392 9665), as subcontractors to Science Applications International Corporation, under USEPA Contract 68 W98 025, Work Assignment 2 5. Jim O'Leary, Program Analyst in OSW's Hazardous Waste Identification Division, was work assignment manager for the initial economic study. Stephanie Carroll, a chemical engineering undergraduate student from the University of Arizona, and 2001 summer intern with EMRAD, provided research assistance for the industrial wipes price elasticity meta analysis, which is applied in this document for simulation of potential impacts of the proposed RCRA exclusions, on the US national market for industrial wipes. The USEPA's Office of Water previously evaluated some aspects of the use and handling of industrial wipes in the US economy, with a focus on evaluating pollutants contained in wastewater discharges from industrial laundries. The Office of Water conducted its evaluation under different regulatory authority than the proposed RCRA regulatory exclusions evaluated in this Economics Background Document. Information about the Office of Water's prior regulatory investigation of industrial laundries is provided at the USEPA website http:// www. epa. gov/ ost/ guide/ laundry, and at Industrial Safety and Hygiene News (" Industrial Shop Towels: Pollutant or Solid Waste?", Aug 1998, p. 27, http:// www. ishn. com/ ishn/ cda/ articleinformation/ features/ bnp__ features__ item/ 0,2162,2602,00. html). Some information about industrial laundries in this document is borrowed from the USEPA's March 2000 economic report in support of the Office of Water's regulatory evaluation ( http:// www. epa. gov/ waterscience/ guide/ laundry/ final/ economics. pdf). The Office of Management & Budget ( OMB) reviewed a draft of this background document during their 90 day review period completed on 23 July 2003, according to the procedures set forth in White House Executive Order 12866 " Regulatory Planning & Review" ( 30 Sept 1993; http:// www. whitehouse. gov/ omb/ inforeg/ eo12866. pdf). Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

3 Table of Contents I. Introduction to Economic Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 I. A. Overview of Proposed RCRA Exclusions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 I. B. Scope of Economic Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 I. C. Economic Impact Elements of the Proposed RCRA Exclusions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 I. D. Overview of US Industrial Wipes Market . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 I. E. Summary Count of Potentially Affected Establishments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 II. Findings of Economic Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 II. A. Annualized Direct Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 II. B. First Year Direct Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 II. C. Other Benefits of Proposed Exclusions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 II. D. Benefit Cost Comparison . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25 II. E. Potential Direct Impacts of Other Regulatory Options . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 II. F. Sensitivity Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31 II. G. Induced Market Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35 II. H. Small Business Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38 II. I. Other Factors Potentially Affecting Economic Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40 II. J. Analytic Baseline . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53 III. Description of US Industrial Wipes Market & Potentially Affected Establishments . . . . . . . . . . . . . . 55 III. A. Overview of Industrial Wipes in the US Economy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 55 III. B. Types of Establishments Potentially Affected by the Proposed RCRA Exclusions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60 III. C. Types of Industries Which Use Solvent Industrial Wipes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62 IV. Attachments ( Tables & Spreadsheets) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 76 IV. A. Supplemental Data Set A: Count of Establishments & Count of Industrial Wipes Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 77 Set B: Industrial Laundry Data ( establishments which supply " reusable" industrial wipes) . . . . . . . . . . . . . . . . . . . . . . . . . . . . 103 Set C: Industrial Cleaning/ Degreasing Solvent Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 120 Set D: Price Elasticity of Demand for Industrial Wipes: Meta Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 128 IV. B. Impact Estimation Spreadsheet Model Print Outs Set E: Direct Impact Elements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 137 Set F: Induced Market Impacts ( partial equilibrium market model) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 177 Set G: Small Business Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 185 Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

1 The United States " Code of Federal Regulations" ( CFR) is published by the Office of the Federal Register, National Archives and Records Administration ( NARA). The CFR is an annual codification of the general and permanent rules published daily in the Federal Register ( FR) by the Executive departments and agencies of the Federal Government. The CFR is divided into 50 titles which represent broad topic areas subject to Federal regulation. Title 40 of the CFR is " Protection of Environment", and contains USEPA's regulations. The CFR is kept up to date by the individual daily issues of the Federal Register, and each volume of the CFR is updated annually. Full text of the CFR and the FR are available at NARA's website: http:// www. nara. gov/ fedreg or at the US Government Printing Office's website: http:// www. access. gpo. gov/ nara .

2 The USEPA's " RCRA Orientation Manual" ( report nr. EPA 530 R 98 004, May 1998, 290 pages), contains descriptive information about the USEPA's hazardous waste program and regulations, as authorized by Congress in Subtitle C of the 1976 Resource Conservation and Recovery Act ( RCRA). Hardcopies of the Manual are available to the public by calling the National Service Center for Environmental Publications ( 8980 490 9198); an electronic copy is available at http:// www. epa. gov/ epaoswer/ general/ orientat/ index. htm . Further information about RCRA, and about the the USEPA's Office of Solid Waste, is also available from the RCRA Public Information Center Hotline ( 800 424 9346 or via the Internet at http:// www. epa. gov/ epaoswer/ hotline ), and on USEPA's Office of Solid Waste website at http:// www. epa. gov/ osw .

3 The current delegation of regulatory status from Federal RCRA to state governments for solvent contaminated wipes, is based on the policy determinations described in a 23 Jan 1991 letter from the EPA's Office of Solid Waste former Director ( Sylvia K. Lowrance), to Lance R. Miller, Director, New Jersey DEP Hazardous Waste Management Division, as well as in a 14 Feb 1994 memorandum from EPA's OSW Director ( Michael Shapiro), to EPA's regional waste management directors. Prior to 1991, EPA received three petitions for excluding both disposable and reusable wipes from RCRA hazardous waste regulation ( 1985 Kimberly Clark Corp; 1987 Scott Paper Co.; 1987 Alliance of Textile Care Associations). On 20 May 1992 ( 57 FR 21450, 21473 74), EPA proposed a rule which would exclude solvent

4 I. Introduction to Economic Analysis I. A. Overview of Proposed RCRA Exclusions EPA's Office of Solid Waste is proposing a new Federal exclusion from RCRA regulations, which will potentially affect industrial facilities that generate and handle solvent contaminated wipes, rags, and shop towels. These classes of products are collectively named " industrial wipes" in this study. The proposed exclusions will constitute a new subpart in Part 261 of Title 40 of the Code of Federal Regulations ( CFR). 1 Under EPA's current RCRA hazardous waste regulations2, industrial wipes contaminated with any of the following three classes of RCRA hazardous wastes, also become RCRA hazardous wastes:

! RCRA listed solvents: One or more of 37 different chemical solvents listed under RCRA hazardous wastecodes F001 F005 ( 40 CFR 261.31), ! RCRA listed chemicals: Comparable P and U listed commercial chemical products that are spilled and cleaned up with industrial wipes, and ! RCRA characteristic solvents: Solvents exhibiting a hazardous characteristic ( i. e. D001 ignitability, D002 corrosivity, D003 reactivity, or D004 to D043 toxicity leaching as defined at 40 CFR 261 Subpart C),

Solvent or other RCRA waste contaminated wipes would otherwise be managed according to the RCRA Subtitle C " cradle to grave" hazardous waste management requirements ( 40 CFR 260 to 270). However, current EPA Federal policy ( as of 1991) is to defer the determination of the RCRA regulatory status of industrial wipes to EPA regional offices and to State governments. 3 Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

contaminated industrial wipes from RCRA regulation based on visible contamination and ignitability, toxicity or reactivity exclusion criteria. EPA withdrew the proposed rule on 30 Oct 1992 ( 57 FR 49280).

4 For example, ( 1) the State of Ohio issued Guidance No. DHWM 007 in 1994 " Solvent Contaminated Rags And Wipers", which classified solvent contaminated disposable industrial wipes as hazardous wastes, and solvent contaminated reusable industrial wipes as conditionally excluded from the definition of solid waste ( http:// www. epa. state. oh. us/ dhwm/ guidsolr. htm); ( 2) the State of Oregon Dept of Environmental Quality issued a " Hazardous Waste/ Toxic Reduction Policy Clarification" on 03 May 1996 to the Uniform & Textile Service Assoc, stating "... this exemption applies only to rags or wipers which are laundered for reuse and meet the above conditions [ no free liquids, closed transport containers with labels, and 3 other conditions]. If those rags or wipers are disposed, treated prior to disposal, or do not meet any of the above conditions, they weill be considered a solid waste and be subject to waste determination and applicable hazardous waste regulations." ( http:// www. deq. state. or. us/ wmc/ hw/ policy/ 1996 LM 001. html).

5 The proposed new regulation would essentially codify current state government policies regarding4:

! Disposable industrial wipes: Conditionally exclude from 40 CFR 261.3 RCRA definition of hazardous waste; state governments now regulate disposable wipes contaminated with RCRA listed and RCRAcharacteristic ( e. g. ignitable) hazardous waste spent solvents as hazardous waste,

! Reusable industrial wipes: Conditionally exclude from 40 CFR 261.4 RCRA definition of solid waste; state governments now conditionally exclude solvent contaminated reusable wipes from hazardous waste regulation, if the wipes contain no free liquids and will be sent to a commercial laundry for cleaning and reuse provided that generators manage wipes in accordance with certain exclusion conditions . The proposed exclusions do not apply to industrial wipes contaminated with solvents that when spent are not hazardous wastes under RCRA regulations. The Federal Register announcement of the proposed RCRA exclusions provides a detailed description of the proposed conditions. To reduce reader burden, this " Economics Background Document" does not duplicate that description but provides a simplified summary of the conditions.

I. B. Scope of Economic Analysis Element Description of Scope Element Affected Facilities: Estimation of the number of respective wipes used and the number of solvent contaminated industrial wipes " generators" ( i. e., facilities which use wipes in conjunction with solvents, thereby generating solvent contaminated wipes), and any other types of entities subject or potentially affected by the proposed exclusions; Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

Element Description of Scope Element 6 Potential Economic Impacts: Translate the conditions for the proposed exclusions into particular types of affected facility implementation activities, equipment or other incremental changes in business practices, which a typical facility is expected to require to become eligible for and maintain a regulatory exclusion, relative to the current " baseline" ( i. e. relative to the current regulatory status of affected generators and other wipes handlers, and to their respective current solvent wipes use and spent wipes management practices):

! Direct: Estimation of potential " direct" regulatory compliance impacts ( i. e., economic costs and cost savings) for the: ! Proposed exclusions ( main proposal); and ! Alternative regulatory options described in the Federal Register announcement.

! Induced: This study also includes estimation of potential " induced" market effects on the relative price of reusable and disposable industrial wipes, and on their respective marketshare in the US national economy, for the main proposal ( not the options). Direct impacts may translate into a change in the relative unit cost ( i. e. life cycle unit cost) of the two types of industrial wipes ( disposables and resusables), which may induce a marginal shift in respective national annual usage marketshare, depending upon the " price elasticity of substitution" between disposable and reusable wipes ( i. e., sensitivity of wipes users to changes in the relative life cycle unit cost of the two types of industrial wipes).

Small Business Impacts: A relatively large proportion of the facilities in each of the potentially affected industries are small businesses. This study evaluates the net effect of both direct and induced impacts on each industry, and on small businesses in particular, for the main proposal ( not the options).

Sensitivity Analysis: For purpose of comparison to the " most likely" key parameter settings applied as impact estimation factors, this document presents the impact estimation results according to alternative combinations of numerical values ( i. e. uncertainty ranges) assigned to 15 key parameters, to reflect information uncertainty. The sensitivity analysis includes three alternative cases ( i. e. combination sets of numerical assumptions for key parameters), designed to produce an overall range in economic impact estimate from low to high, respectively: ! " Lower bound": Lowest estimate of number of entities impacted, as well as minimum unit values & quantities. ! " Most likely": " Best judgement" settings for key variables ( which do not necessarily represent the mid point between the lower and upper bound). ! " Upper bound": Highest estimate of number of entities impacted, as well as maximum unit values & quantities. Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

Element Description of Scope Element 5 Generators of solvent contaminated wipes will retain the option of managing their disposables in full compliance with RCRA Subtitle C hazardous waste management requirements ( i. e. 40 CFR 260 to 270), in lieu of the proposed exclusions.

7 Other proposed regulatory options In addition to the proposed conditions for the exclusion, this document provides an estimate of the potential economic impacts associated with regulatory options described in the Federal Register announcement of the proposed rule. There are two main alternative regulatory options ( approaches), as well as at least one alternative option for each of the major conditions for the proposed exclusion.

I. C. Economic Impact Elements of the Proposed Regulatory Exclusion EPA's proposal would amend the hazardous waste management regulations under RCRA and formally codify a conditional exclusion from RCRA regulations for solvent contaminated industrial wipes. The exclusion would be granted if users and handlers of solventcontaminated industrial wipes maintain certain " conditions" as summarized in the following table. In comparison to hypothetical full compliance with the existing RCRA Subtitle C hazardous waste regulations ( 40 CFR 260 to 299), EPA's proposed exclusions potentially offer annual net cost savings to solvent contaminated wipes generators and spent wipes handlers. For example, sources of cost savings compared to full RCRA Subtitle C compliance are:

! Spent wipes reporting: Avoidance of the costs for RCRA hazardous waste activity notification, waste management permitting, and waste transport manifesting paperwork requirements for generating and managing spent solvent industrial wipes, and ! Spent wipes management: Lower costs associated with non hazardous waste management alternatives, compared to managing solvent contaminated spent industrial wipes at RCRA Subtitle C permitted hazardous waste management facilities.

However, there are potential implementation costs for complying with the conditions of the proposed regulatory exclusion, which are expected in part or in whole for some facilities, to offset the magnitude of savings compared to hypothetical full RCRA compliance costs. Because such implementation costs are relatively modest in magnitude, compared to the potential full compliance cost savings, we assumed in this study that all eligible spent industrial wipes generators would take advantage of the proposed exclusions, and only considered a sensitivity analysis range in the percentage of states ( i. e. 50%, 75%, or 100%) which may adopt the exclusions after USEPA promulgates them as a final rule. 5 Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

8 Summary of Proposed Conditions for RCRA Exclusions of Solvent Contaminated Industrial Wipes Item Exclusion Condition Conditions for RCRA Exclusions Disposable Wipes ( exclusion from RCRA definition of hazardous waste) Reusable Wipes ( exclusion from RCRA definition of solid waste)

1 Applicable ( potentially eligible) solvents ! Exclusion would not apply to:   11 specific RCRA F listed chemical solvents ( any % blends involving these solvents)   wipes contaminated with other RCRA characteristically hazardous wastes ( e. g. metals or RCRA listed chemicals) ! Exclusion potentially applies to:   19 specific RCRA F listed chemical solvents ( and corresponding P and U listed commercial chemical products)   ignitable only ( D001) characteristically hazardous solvents ! All RCRA listed hazardous solvents 2 Containers for onsite accumulation of solvent wipes ! Accumulate in non leaking covered containers ! Accumulate in non leaking covered containers ! Must recycle 75% of spent wipes in calendar year 3 Containers for spent solvent wipes transportation ! Transport in non leaking & non evaporative loss containers " designed, constructed and managed to minimize loss to the environment":   covered drums ( sealed drums not required) if meet above if meet above performance standard   cinched plastic or cinched cloth bags if meet above performance standard   comply with USDOT packaging 49 CFR 173.212 4 Labels for transport containers ! Label all transport containers with " Excluded Solvent Contaminated Wipes" ! RCRA labels not required on containers Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

Item Exclusion Condition Conditions for RCRA Exclusions Disposable Wipes ( exclusion from RCRA definition of hazardous waste) Reusable Wipes ( exclusion from RCRA definition of solid waste)

9 5 Pre transport preparation of spent solvent wipes to meet " no free liquids" ! Either: ! If transport for ( a) disposal in municipal or other combustion unit**, or ( b) intermediate processing to meet " dry" standard ( i. e. < 5 grams ( i. e. less than 0.175 ounces) solvent per wipe), spent wipes and transport containers must meet " no free liquids" condition ( i. e. contain no dripping wipes and no solvents at bottom of container) ! If transport for disposal at non haz waste landfill**, spent solvent wipes must meet " dry" condition ( i. e. less than five grams solvent per wipe) by either:   spent wipes solvent centrifuge/ extraction   business records on solvent & wipes monthly use to show under " dry" threshold   spent wipes solvent sampling to show under threshold ! Removed spent solvents must be managed as hazardous wastes* ! Containers meet " no free liquids" ( i. e. contain no dripping wipes and no solvents at bottom of container) ! Removed spent solvents must be managed as hazardous wastes if RCRA listed or characteristic hazardous* Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

Item Exclusion Condition Conditions for RCRA Exclusions Disposable Wipes ( exclusion from RCRA definition of hazardous waste) Reusable Wipes ( exclusion from RCRA definition of solid waste)

10 6 Intra company transfers of spent solvent wipes to remove " free liquids" ! May transport wipes containing " free liquids":   if store/ accumulate in covered containers   if transport in non leaking & non evaporative loss containers   if containers are RCRA labeled   if within the same company   if receiving facility uses solvent recovery process   if recovered solvents sold on market for reuse or managed as hazardous waste* ! May transport wipes containing " free liquids":   if store/ accumulate in covered containers   if transport in non leaking & nonevaporative loss containers   RCRA labels not required   if within the same company   if receiving facility uses solvent recovery process   if recovered solvents sold on market for reuse or managed as hazardous waste*

7 Transfer spent solvent wipes to offsite handler to remove " free liquids" Same as item 6 Same as item 6 Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

Item Exclusion Condition Conditions for RCRA Exclusions Disposable Wipes ( exclusion from RCRA definition of hazardous waste) Reusable Wipes ( exclusion from RCRA definition of solid waste)

11 8 Subsequent off site management of spent solvent wipes after transport ! Wipes containers: Store spent solvent wipes received in non leaking & non evaporative covered containers ! Wipes disposal:   If spent wipes are " dry" and contaminated with any of 19 specific F listed solvents, may be disposed in municipal or other non haz waste landfill**.   If spent wipes meet " no free liquids" standard, may be disposed at municipal waste combustor**, or transported for processing to meet " dry" standard.   If receive spent wipes containers with " free liquids" either:   return containers ( with wipes and liquids) to generator ASAP ( but not need a haz waste manifest)   recover/ manage " free liquids" as hazardous waste* ! Wipes containers: Store spent solvent wipes received in non leaking & non evaporative covered containers ! Wipes processing ( laundering):   May launder spent wipes meeting " no free liquids" standard.   If receive spent wipes containers with " free liquids" either:   return containers ( with wipes and liquids) to generator ASAP ( but not need a haz waste manifest)   recover & manage " free liquids" as hazardous waste*

9 Compliance recordkeeping ! Comply with existing RCRA documentation requirements ( 40 CFR 261.2( f)) for demonstration of exclusion eligibility from RCRA regulation ( which requires providing appropriate documentation such as business contracts that the material is not a waste).***

10 Other possible impacts ! Read, disseminate & assess compliance requirements of exclusions ! Possible reduction in annual state fees/ taxes paid for generating & managing spent solvent wipes ( note: state fee impacts are a type of " transfer effect", not a " real resource economic" effect). Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

Item Exclusion Condition Conditions for RCRA Exclusions Disposable Wipes ( exclusion from RCRA definition of hazardous waste) Reusable Wipes ( exclusion from RCRA definition of solid waste)

12 Explanatory Notes: ( a) The USEPA's Office of Solid Waste RCRA hazardous waste program defines " free liquids" as " liquids which readily separate from the solid portion of a waste under ambient temperature and pressure" ( 40 CFR 260.10). ( b) * Spent solvent " free liquids" must be managed as RCRA hazardous waste if the spent solvent is a 40 CFR 261.31 RCRA listed hazardous waste, or if it is a 40 CFR 261 Subpart C RCRA characteristic hazardous waste. As of 1997, there were over 46 RCRA hazardous waste management facilities ( LQGs) which received spent solvent hazardous waste from offsite sources for solvent recovery onsite, according to the following solvent recovery technologies ( source: USEPA Office of Solid Waste, 1997 Hazardous Waste " Biennial Report" database query at http:// www. epa. gov/ enviro/ html/ brs/ brs_ query. html): Type of solvent recovery technology Facilities Nr. states ! Solvent fractionation/ distillation ( M021) 46 22 ! Thin film solvent evaporation ( M022) 26 10 ! Solvent extraction ( M023) 11 10 ! Other solvent recovery ( M024/ M029) 16 12 ( c) ** Non hazardous waste facilities in the US: as of year 1999 there are an estimated ( source: " Size of the United States Solid Waste Industry", R. W. Beck & Chartwell Information Publishers, Environmental Research & Education Foundation, March 2001, Table 7, p. 19): ! 3,500 active material recovery/ recycling facilities ! 3,200 active municipal solid waste landfills ! 3,100 active solid waste transfer stations ! 140 active solid waste combustion/ incineration facilities ( d) *** USEPA RCRA compliance protocols ( guidance) are available at: ! For non hazardous solid waste generator facilities: " Protocol for Conducting Environmental Compliance Audits of Facilities Regulated Under Subtitle D of RCRA", USEPA Office of Enforcement Compliance & Assurance ( OECA), EPA 300 B 00 001, March 2000, 153 pages, http:// www. epa. gov/ compliance/ resources/ policies/ incentives/ auditing/ rcradfi. pdf ! For hazardous solid waste generator facilities: " Protocol for Conducting Environmental Compliance Audits for Hazardous Waste Generators Under RCRA", USEPA Office of Enforcement Compliance & Assurance ( OECA), EPA 305 B 01 003, June 2001, 178 pages, http:// www. epa. gov/ compliance/ resources/ policies/ incentives/ auditing/ hazardous. pdf ( regulatory requirement HW. 10.2 on page 26 provides a checklist for documenting that a particular material is not a solid waste or is exempt from hazardous waste regulation). ! For hazardous solid waste treatment, storage, disposal, recycling facilities: " Protocol for Conducting Environmental Compliance Audits of Treatment, Storage and Disposal Facilities Under the Resource Conservation & Recovery Act", USEPA Office of Enforcement Compliance & Assurance ( OECA), EPA 305 B 98 006, Dec 1998, 246 pages, http:// www. epa. gov/ compliance/ resources/ policies/ incentives/ auditing/ rcra. pdf Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

13 I. D. Overview of Industrial Wipes Market US Industrial Wipes Market ( Year 2001)

Market & Affected Sub Markets Wipes Quantities Wipes Facilities ( Users & Handlers)

US industrial wipes market ( with & w/ out solvents applied) 9.6 billion annual wipes uses ! 88% reusables ( 8.5 billion used) ! 12% disposables ( 1.1 billion sold) 471,000 users ( i. e. spent wipes generators) ! 13 economic sub sectors ( see next table) ! 83% small company facilities ! 15% printers + 85% non printers 1,200 industrial laundries supply reusables ! $ 408 million/ year revenues from resusables ! 47% small company facilities Solvent industrial wipes sub market ( CESQGs+ SQGs+ LQGs) 3.8 billion wipes per year ( 40% of US industrial wipes market) 215,000 users + handler facilities Portion of industrial wipes sub market potentially affected ( only SQGs+ LQGs) 2.8 billion wipes per year ( 33% of US industrial wipes market ! 2.55 billion reusables used ! 259 million disposables sold 68,000 to 164,000 users + handler facilities Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

14 I. E. Summary Count of Potentially Affected Establishments Economic Sub Sectors Which Use or Otherwise Handle Industrial Wipes Item Sub Sector 2001 Estimate of All Establishments* ( by NAICS code) 2001 Estimate of Establishments ( SQGs + LQGs) Using RCRA Solvent Wipes & Potentially Eligible for the Exclusions**

Lower bound Most Likely Upper bound A. Count of Establishments ( Facilities) Which Use Solvent Industrial Wipes ( i. e. spent wipes generators***):

1 2 3 4 5 6 7 8 9 10 11 12 13 Printing Chemical & Allied Products Plastics & Rubber Fabricated Metal Products Industrial Machinery & Equipment Electronics & Computers Transportation Equipment Furniture & Fixtures Automobile Dealers ( retail trade) Publishing ( printed matter) Business Services ( copy shops) Automobile Repair & Maintenance Military Bases 41,600 13,700 17,900 63,800 31,100 6,600 13,900 21,100 51,900 23,600 6,400 179,300 560 18,700 1,100 1,400 4,900 2,400 550 1,100 1,600 4,000 10,600 2,900 13,500 50 31,200 1,900 2,400 8,600 4,100 1,000 2,000 2,800 7,000 17,700 4,800 23,500 90 42,000 2,900 3,700 13,000 6,300 1,500 3,000 4,300 10,700 23,600 6,400 35,900 130 Column sub totals = 471,000 63,000 107,000 153,000 B. Count of Establishments Which Otherwise Handle Spent Solvent Industrial Wipes:

14 Industrial Laundries ( reusable wipe suppliers) 1,175 590 ( if 50% states) 880 ( if 75% states) 1,175 ( if 100% states)

15 Solid Waste Management facilities 10,600 5,300 ( ibid) 8,000 ( ibid) 10,600 ( ibid)

Column totals = 482,000 68,900 115,800 164,800 Explanatory Notes: ( a) * Items 1 13 based on 1997 Census count, updated by OSW using the 15 year average annual percentage change in the Industrial Production Index ( IPI) for 1986 to 2000; items 14 & 15 from the 1997 Census without update. ( b) ** " Lower bound", " Most likely" and " Upper bound" in this document represent uncertainty about ( a) numerical values for key estimation parameters applied in this study, and ( b) the percentage of states which will likely adopt the exclusions ( i. e. 50%, 75%, and 100% states, respectively). ( c) *** Counts of spent wipes generators in this table only includes facilities which are potentially classifiable as RCRA " large quantity generators" ( LQGs) or as " small quantity generators" ( SQGs), excluding facilities potentially classifiable as " conditionally exempt small quantity generators" ( CESQGs), based on the average calendar month quantity of spent solvent generation associated with industrial wipes applications. Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

15 II. Findings of Economic Analysis II. A. Annualized Direct Impacts of Main Regulatory Proposal The following table summarizes the " direct impact" elements of the proposed exclusions ( i. e. the main proposal, not the options), as quantified and monetized in this report. Direct impacts are defined as the economic costs of implementation activities and requirements that eligible or otherwise affected entities ( i. e. entities eligible and subject to the proposed exclusion conditions) are expected to incur in compliance with the proposed exclusions. Direct impacts may occur in the initial year following finalization of the proposed exclusions, as well as in subsequent years on an annual recurring basis. As indicated in the table, some elements are expected to impact some users/ handlers differentially, according to type of industrial wipe ( i. e. reusable or disposable wipe), because of differences in the current spent wipes management practices   as a result of current state regulations   between generators of spent reusable wipes, compared to generators of spent disposable wipes.

Summary of Annualized Direct Impact Elements: Estimated Potential Incremental Costs and Cost Savings to Solvent Contaminated Industrial Wipes Generators & Handlers for Compliance With the Proposed Exclusions ! Estimates Below Based on " Most Likely" Uncertainty Parameter Settings ! Dollar Impacts in Parentheses Below ( i. e. Negative Costs) Denote Cost Savings or Other Economic Benefits Item Direct Impact Element Potential Average Annualized* Impact ($/ year) on Spent Wipes Generators & Other Handlers**

Disposable Wipes Reusable Wipes Net Impact ( row totals)

1. Wipes solvent eligibility 1A. Determine eligibility ( i. e. read/ disseminate scope, applicability & conditions of exclusions) Solvent wipes generators > $ 58,000 $ 774,000 $ 832,000 Other handlers ( e. g. solid waste mgmt, laundries)> $ 13,000 $ 4,000 $ 17,000 Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

Item Direct Impact Element Potential Average Annualized* Impact ($/ year) on Spent Wipes Generators & Other Handlers**

Disposable Wipes Reusable Wipes Net Impact ( row totals)

16 1B. Contact/ assess RCRA regulatory status of reusable wipes customers ( i. e. determine solvent types applied to wipes) Cost to laundries >

Not applicable $ 262,000 $ 262,000 Cost to laundry customers > $ 218,000 $ 218,000 2. Onsite wipes containers Covered containers for on site accumulation of spent solvent wipes by generators ( assumes purchase of steel foot lever closeable solvent wipes canisters) $ 1,130,000 $ 1,617,000 $ 2,747,000 3. Wipes transport containers 3A. Closed containers for spent wipes transport If tied plastic bags > If closable metal drums > $ 19,000 to $ 2,836,000 $ 499,000 to $ 1,094,000 $ 518,000 to $ 3,930,000 3B. Avoided RCRA manifest paperwork for spent wipes ($ 3,455,000) $ 0 ( baseline) ($ 3,455,000)

4. Transport container labels Labels for wipes transport containers & labor affix cost If tied plastic bags > If closable metal drums > $ 61,000 to $ 80,000 Not required $ 61,000 to $ 80,000 5. Pretransport preparation of wipes 5A. Labor cost for decanting accumulation containers $ 22,000 $ 6,201,000 $ 6,223,000 5B. Haz waste mgt cost for decanted solvents Manifest & transport > $ 0 ( include on manifest & truck with other wastes)

If fuel blender > If solvent recycler# > $ 8,000 to ($ 6,000) $ 2,873,000 to ($ 2,326,000) $ 2,881,000 to ($ 2,332,000)

5C. Wipes sampling to meet " dry" standard ( sampling not required; may use business records or extraction*** ). $ 69,000 Not applicable $ 69,000 Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

Item Direct Impact Element Potential Average Annualized* Impact ($/ year) on Spent Wipes Generators & Other Handlers**

Disposable Wipes Reusable Wipes Net Impact ( row totals)

17 6. Intracompany transfers Intra company transfers of spent wipes containing " free liquids", for recovery & management of solvent as haz waste $ 4,000 to $ 146,000 Not expected if laundries control wipes handling & distribution $ 4,000 to $ 146,000 7. Transfers to offsite handler Transfer to an intermediate handling facility ( another company) to remove & manage " free liquids" as haz waste $ 4,000 to $ 146,000 $ 4,000 to $ 146,000 8. Offsite management of wipes Subsequent off site management of spent solvent wipes ( and " free liquids") after transport 8A. Avoided Subtitle C disposal of spent wipes ($ 32,971,000) Not applicable ($ 32,971,000)

8B. Labor for decanting percolated " free liquids" $ 10,000 $ 121,000 $ 131,000 8C. Manage percolated " free liquids" as haz waste Manifest & truck > $ 0 ( remain onsite) $ 1,514,000 $ 1,514,000 If fuel blender > If solvent recycler# > $ 10,000 to ($ 8,000) $ 187,000 to ($ 151,000) $ 197,000 to ($ 159,000)

9. Compliance recordkeeping 9A. Demonstrate RCRA exclusion to inspectors ( per 40 CFR 261.2( f)) Cost to wipes generators> $ 3,000 $ 33,000 $ 37,000 Cost to other handlers > $ 152,000 <$ 1,000 $ 152,000 Cost to state agencies> $ 52,000 $ 380,000 $ 432,000 9B. Avoided RCRA paperwork costs to SQGs that may become CESQGs ($ 784,000) $ 0 ( baseline) ($ 784,000) Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

Item Direct Impact Element Potential Average Annualized* Impact ($/ year) on Spent Wipes Generators & Other Handlers**

Disposable Wipes Reusable Wipes Net Impact ( row totals)

18 Sub total annualized implementation impacts ( items 1 to 9; range reflects low cost and high cost options, respectively) = ($ 32.5) to ($ 35.6) million/ year $ 9.1 to $ 15.3 million/ year ($ 17.2) to ($ 26.5) million/ year Potential fraction of reusable wipes impacts incurred by industrial laundries ( range reflects low cost options of 1A+ 1B+ 3A+ 4+ 5B+ 8B+ 8C+ 9A, to if also include item 5A + high cost options, respectively) ($ 0.1) to $ 12.3 million/ year 10. Impact on state government annual revenues from waste fees**** ($ 29.7 to ($ 41.0) million/ year ($ 2.4) to ($ 5.7) million/ year ($ 32.1) to ($ 46.7) million/ year 11. Other potential impacts on industrial laundries 11A. Cachet benefit to industrial laundries from avoided waste " stigma" for reusable wipes Not applicable ($ 3.4) to ($ 6.9) million/ year 11B. Avoided RCRA Subtitle C paperwork costs to industrial laundries ( under alternative baseline) ($ 1.5) to ($ 3.0) million/ year 11C. Avoided costs for managing industrial laundry sludges as RCRA " derived from" haz wastes ( under alternative baseline) ($ 46 to ($ 92) million/ year Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

Item Direct Impact Element Potential Average Annualized* Impact ($/ year) on Spent Wipes Generators & Other Handlers**

Disposable Wipes Reusable Wipes Net Impact ( row totals)

19 Explanatory Notes: ( a) * Annualized impacts include both: ! Initial lump sum impacts in first implementation year after final rule promulgation ( e. g. equipment purchase costs), plus ! Net effect of recurring annual expenses or savings ( e. g. equipment operation or maintenance costs). ( b) ** Other handlers = Solid waste management establishments + industrial laundries which supply reusable industrial wipes. ( c) *** Depending upon economy of scale and market value of recovered solvent, the cost for solvent extraction ( e. g. using centrifugation) of solventcontaminated wipes may be a relatively more expensive option for many industrial wipes generators, compared to decanting " free liquids". However, some industrial facilities already use on site centrifuge technology to extract spent solvents from industrial wipes. For example, the Printing Industry of Minnesota, Inc. purchased a $ 15,000 centrifuge to spin its reusable industrial wipes before sending them to the industrial laundry, extracting 2.5 to 3.5 gallons of spent solvent for every centrifuge load of about 220 reusable wipes. The company reuses the captured solvent, thereby saving $ 34,000/ year from avoided purchase of one drum/ week of virgin solvent ( source: USEPA Design for the Environment: Lithography Project Case Study No. 1, Oct 1995, 4 pages, http:// www. epa. gov/ opptintr/ dfe/ pubs/ lithography/ case_ studies/ case1/ lithocs1. pdf). ( d) **** State fee impacts represent a form of " transfer payment" ( i. e. not a form of real resource economic cost) which are not traditionally included ( combined) with estimates of " real resource" costs/ savings, in a national economic analysis framework. ( e) # Solvent recycling impact estimated by subtracting $ 2.54/ gallon unit cost for solvent recycling ( average for onsite & offsite), from the $ 3.28/ gallon US median solvent price to reflect $ 0.74/ gallon resale ( reuse) net value of recycled solvent; $ 1.73/ gallon recycling cost represents midpoint between: ! onsite recycling cost of $ 1.00/ gallon ( http:// rapidimaging. com/ TSR/ TSR% 20R 07% 20Platemaking% 20Productivity% 20for% 20Web. pdf). ! offsite vendor recycling service price of $ 2.45/ gallon ( http:// www. iwrc. org/ pubs/ IPPIMetal. pdf), and $ 4.16/ gallon ( http:// www. epaonline. com/ enews. html, 14 April 2003). ( f) ## Re containerization costs ( either for new containers if initial transport containers owned by generator, and/ or for labor if using consolidation recontainerization into existing 20 cubic yard truck roll offs), and associated re containerization labeling costs, estimated for both intra company transfer ( item 6) and transfer to offsite handler ( item 7), by multiplying wipes transport container costs ( item 3A) and wipes transport container label costs ( item 4), by 5%, which represents assumption that 5% of disposables ( not reusables) may be transported for intra company processing, and another 5% of disposables ( not reusables) may be transported to an offsite handler ( another company). Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

20 II. B. Potential First Year Implementation Impact The direct impacts in the table above are " average annualized" impacts, consisting of the sum of ( a) single year ( upfront lump sum) impacts which have been annualized into a uniform future stream according to the " equivalent uniform annual cost" ( i. e. equal paymentseries " capital recovery factor") method, plus ( b) annually recurring impacts. The table below presents the potential first year ( lumpsum impacts without annualization.

Summary of First Year Direct Impact Elements: Estimated Potential Incremental Costs and Cost Savings to Solvent Contaminated Industrial Wipes Generators & Handlers for Compliance With the Proposed Exclusions ! Estimates Below Based on " Most Likely" Uncertainty Parameter Settings ! Dollar Impacts in Parentheses Below ( i. e. Negative Costs) Denote Cost Savings or Other Economic Benefits Item Direct Impact Element Potential First Year Impact on Spent Wipes Generators & Other Handlers**

Disposable Wipes Reusable Wipes Net Impact ( row totals)

1. Wipes solvent eligibility 1A. Determine eligibility ( i. e. read/ disseminate scope, applicability & conditions of exclusions) Spent wipes generators > $ 439,000 $ 5,815,000 $ 6,254,000 Other wipes handlers > $ 96,000 $ 26,000 $ 122,000 1B. Contact/ assess RCRA regulatory status of reusable wipes customers ( i. e. determine solvent types applied to wipes) Cost to laundries >

Not applicable $ 735,000 $ 735,000 Cost to laundry customers > $ 613,000 $ 613,000 2. Onsite wipes containers Covered containers for on site accumulation of spent solvent wipes by generators ( assumes purchase of metal foot lever closeable canisters) $ 5,694,000 $ 8,146,000 $ 13,840,000 Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

Item Direct Impact Element Potential First Year Impact on Spent Wipes Generators & Other Handlers**

Disposable Wipes Reusable Wipes Net Impact ( row totals)

21 3. Wipes transport containers 3A. Closed containers for spent wipes transport If tied plastic bags > If closable metal drums > $ 19,000 to $ 12,442,000 $ 499,000 to $ 4,801,000 $ 518,000 to $ 17,243,000 3B. Avoided RCRA manifest paperwork for spent wipes ($ 3,455,000) $ 0 ( baseline) ($ 3,455,000)

4. Transport container labels Labels for wipes transport containers & labor affix cost If tied plastic bags > If closeable metal drums > $ 61,000 to $ 702,000 Not required $ 61,000 to $ 702,000 5. Pretransport preparation of wipes 5A. Labor cost for decanting accumulation containers $ 22,000 $ 6,201,000 $ 6,223,000 5B. Haz waste mgt cost for decanted solvents Manifest & truck waste > $ 0 ( include on manifest & truck with other wastes)

If fuel blender > If solvent recycler# > $ 8,000 to ($ 6,000) $ 2,873,000 to ($ 2,326,000) $ 2,881,000 to ($ 2,332,000)

5C. Wipes sampling to meet " dry" standard ( sampling not required; may use business records or extraction***) $ 520,000 Not applicable $ 520,000 6. Intracompany transfers Intra company transfers of spent wipes containing " free liquids", for recovery & management of solvent as haz waste $ 4,000 to $ 657,000 Not expected if laundries control wipes handling & distribution $ 4,000 to $ 657,000 7. Transfers to offsite handler Transfer to an intermediate handling facility ( another company) to recover & manage " free liquids" as haz wastes $ 4,000 to $ 657,000 $ 4,000 to $ 657,000 8. Offsite management of wipes Subsequent off site management of spent solvent wipes and any percolated " free liquids" after transport 8A. Avoided Subtitle C disposal of spent wipes ($ 32,971,000) Not applicable ($ 32,971,000) Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

Item Direct Impact Element Potential First Year Impact on Spent Wipes Generators & Other Handlers**

Disposable Wipes Reusable Wipes Net Impact ( row totals)

22 8B. Labor for decanting percolated " free liquids" $ 10,000 $ 121,000 $ 131,000 8C. Manage percolated " free liquids" as haz waste Manifest & truck > $ 0 ( remain onsite) $ 1,514,000 $ 1,514,000 If fuel blender > If solvent recycler# > $ 10,000 to ($ 8,000) $ 187,000 to ($ 151,000) $ 197,000 to ($ 159,000)

9. Compliance recordkeeping 9A. Demonstrate RCRA exclusion to inspectors ( per 40 CFR 261.2( f)) Cost to wipes generators> $ 3,000 $ 33,000 $ 37,000 Cost to other handlers> $ 152,000 <$ 1,000 $ 152,000 Cost to state agencies> $ 52,000 $ 380,000 $ 432,000 9B. Avoided RCRA paperwork costs to SQGs that may become CESQGs ($ 784,000) $ 0 ( baseline) ($ 784,000)

Sub total first year implementation impacts ( items 1 to 9; range reflects low cost & high cost options, respectively) = ($ 15.8) to ($ 30.2) million $ 21.6 to $ 31.5 million ($ 8.5) to $ 15.7 million Potential fraction of reusable wipes impacts incurred by industrial laundries ( range reflects low cost options of 1A+ 1B+ 3A+ 4+ 5B+ 8B+ 8C+ 9A, to if also include item 5A + high cost options, respectively) $ 0.4 to $ 16.5 million Note: for explanatory footnotes, see previous table. Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

23 II. C. Other Benefits of the Proposed Exclusions Other Potential Benefits of the Proposed Rule In Addition to RCRA Regulatory Compliance Burden Reduction Direct Impact Item ( from table above) Associated Non Monetary Benefit Element Disposable Wipes Reusable Wipes Row Totals A. Environmental & Human Health Benefits:

Pre transport preparation of spent wipes Solvent " free liquids" captured by decanting from accumulation containers 32 tons/ year ( 8,300 gallons/ year) 12,270 tons/ year ( 3,146,000 gallons/ year) 12,300 tons/ year ( 3,154,000 gallons/ year)

Offsite management of transported spent wipes Solvent " free liquids" captured by decanting from transportation containers 42 tons/ year ( 11,000 gallons/ year) 797 tons/ year ( 204,000 gallons/ year) 839 tons/ year ( 215,000 gallons/ year)

Column totals = 74 tons/ year ( 19,300 gallons/ year) 13,067 tons/ year ( 3.35 million gallons/ year) 13,139 tons/ year*** ( 3.37 million gallons/ year)

Potential human health benefit* = $ 0.05 to $ 0.21 million/ year $ 8.0 to $ 36.2 million/ year $ 8 to $ 36.4 million/ year B. Fire Safety Benefits:

Structure related fires attributed to spontaneous ignition of " oily wipes"** $ 0.04 to $ 1.1 million/ year $ 0.26 to $ 8.1 million/ year $ 0.3 to $ 9.2 million/ year Total other benefits ( A + B) = $ 0.09 to $ 1.3 million/ year $ 8.3 to $ 44.3 million/ year $ 8.3 to $ 45.6 million/ year Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

24 Explanatory Notes: ( a) * In addition to potential annual cost savings benefit for avoiding future purchases of virgin solvents if captured spent solvent " free liquids" are recycled, the potential environmental benefit of capturing ( removing) the annual solvent quantities displayed in this table, from loading either into the air, land, or surface waters ( via evaporation/ volatilization, spills/ leakages, or laundry effluent wastewaters, is not monetized in this table, but may also be significant. USEPA is targeting the national reduction in urban air emissions of at least six industrial solvents ( i. e. benzene, carbon tetrachloride, chloroform, methyl chloride, methylene chloride, tetrachloroethylene, trichloroethylene, and 27 other chemicals) that present the greatest threat to public health in the largest number of US urban areas, many of which are emitted from smaller stationary commercial and industrial operations (" National Air Toxics Program: The Integrated Urban Strategy", Federal Register, Vol. 64, No. 137, 19 July 1999). Many chemical solvents are volatile organic compounds ( VOCs) which when released into the environment may become precursors to formation of ground level ozone. For example, solvent and paint VOCs are the second largest contributor ( 18%) to ozone pollution in the four county region surrounding Los Angeles, with on road vehicles ( 49%), trains/ planes ( 13%), power plants & other fuel burning industries ( 11%), and other sources ( 9%); source: http:// www. wastenews. com, 09 April 2003. For purpose of monetization, this table applies a unit value benefit range of $ 612 to $ 2,767 per ton ( 1998$) " free liquids" solvent captured, which is the unit value for VOC emissions reduction health benefits USEPA applied in three recent rulemakings: ! 1997: USEPA Office of Air & Radiation, " Regulatory Impact Analyses for the Particulate Matter and Ozone National Ambient Air Quality Standards and Proposed Regional Haze Rule", http:// www. epa. gov/ ttn/ oarpg/ naaqsfin/ ria. html. ! 1998: USEPA Office of Water, " Environmental Assessment of the Final Effluent Limitations Guidelines and Standards for the Pharmaceutical Manufacturing Industry", EPA 821 R B 98 008, 30 July 1998, http:// www. epa. gov/ ost/ guide/ pharm/ econanal/ econanal. pdf. ! 2000: USEPA Office of Water, " Effluent Guidelines for the Oil and Gas Extraction Point Source Category: Proposed Rule", Federal Register, Vol. 65, No. 78, 21 April 2000, p. 21567, http:// www. epa. gov/ waterscience/ guide/ sbf/ sbfnoda. pdf. In comparison, two other recent ( 2001 & 2002) economic studies applied a range of $ 340 to $ 2,000 per ton for VOC air emission reduction health benefits ( http:// www. tc. gc. ca/ programs/ environment/ urbantransportation/ transitstudies/ docs/ Cost Benefit. pdf; and http:// www. translink. bc. ca/ files/ mae_ report/ appendix_ airemission_ eval. pdf). ( b) ** Source for " oily wipes" fire damages: See Section V. F " Damage Cases Associated With Solvent Contaminated Industrial Wipes" of the Technical Background Document identified in the preamble for this rulemaking. OSW derived benefit range to reflect unknown contributions of ( 1) solvent " free liquids" wipes or ( 2) " no free liquids" wipes, to annual fire damage cases; and applied the relative marketshare ( 88% reusables: to: 12% disposables) to estimate proporational share of wipe types in fire damages incidents: ! Upper bound: Spent solvent wipes share of $ 40.2 million/ year damages associated with " oily wipes" ( from source document), assigned in proportion to estimate of solvent wipes share of 471,000 total US establishments in 13 industrial subsectors using industrial wipes with & without RCRA solvents ( 107,000/ 471,000 establishments = 23%). ! Lower bound: Assumes that only 3.5% of upper bound damages attributed to solvent wipes, which represents the overall average percentage of wipes containers estimated arriving at final destinations with solvent " free liquids". ( c) *** For benchmarking, this estimated quantity of solvent " free liquids" potentially captured in closed accumulation and transport containers, represents 13% to 16% of the estimated 82,000 to 103,000 tons/ year of solvents applied to industrial wipes. Compared to 25% to 40% solvent evaporative loses ( i. e. 20,500 to 41,200 tons/ year), this " free liquids" capture quantity represents potential reduction in evaporative loss by 32% to 64%, if non captured " free liquids" would completely evaporate from uncovered containers. Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

25 II. D. Benefit Cost Comparison Comparison of Annualized Benefits of Regulatory Exclusions to Annualized Direct Implementation Costs for Meeting Exclusion Conditions Note: numbers in parentheses denote benefits or cost savings Item Impact Indicator Average Annualized Impacts ($ millions)

Disposable Wipes Reusable Wipes Net Impact ( row totals)

1 Direct implementation costs for meeting conditions of regulatory exclusions $ 1.59 to $ 4.73 $ 11.63 to $ 15.28 $ 13.22 to $ 20.01 2 Regulatory compliance cost savings ( and/ or solvent capture reuse value) resulting from conditional exclusions ($ 37.22) ($ 2.48) ($ 39.70)

3 Other annualized benefits ( environmental, human health & fire safety) ($ 0.09) to ($ 1.3) ($ 8.3) to ($ 44.3) ($ 8.3 to $ 45.6)

4 Total annualized benefits ( 2 + 3) = ($ 37.3) to ($ 38.5) ($ 10.8) to ($ 46.8) ($ 48.0 to $ 85.3)

5 Net effect = Net benefits ( 4  1) = ($ 32.6) to ($ 36.9) ($ 35.2) to $ 4.5 ($ 28.0) to ($ 72.1)

6 Benefit cost ratio ( 4 / 1) = 7.9 to 24.2 0.7 to 4.0 2.4 to 6.5 Explanatory Note: The annualized direct implementation costs ( item 1), the total annualized benefits ( item 4), and the net annual effect ( item 5) do not exceed Executive Order 12866' s $ 100 million " annual effect" threshold, so the proposed exclusions are not classifiable as an economic " major rule" ( http:// www. whitehouse. gov/ omb/ inforeg/ eo12866. pdf). Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

26 II. E. Potential Direct Impacts of Regulatory Options Alternative Regulatory Options Described in the Federal Register Announcement for the Proposed Exclusion Direct Impact Element Alternative Regulatory Option Potential Economic Impacts of Regulatory Options Disposable Wipes Reusable Wipes 1. Wipes solvent eligibility Provide RCRA hazardous waste exclusion for all disposable solventcontaminated wipes ! Removes landfill constraint for estimated 11% of solvent wipes under main proposal. ! Increases potential annual disposal cost savings by a factor of 1.12 ( i. e. 100% / ( 100% 11%)). Not applicable 2. Onsite wipes storage containers Rely on existing OSHA regulations for storing flammable or combustible liquids, wastes, residues, in covered containers or tanks. Real resource ( economic) impact same as main proposal, regardless of whether RCRA or OSHA regulations cited.

3. Wipes transport containers Transport in impermeable closed ( sealed) containers ! Assume " sealed" container costs are similar to metal drum costs estimated for main proposal. ! Sealed containers may unintentionally result in redistribution of free liquid management costs estimated for the main proposal, from spent wipes generators, to waste management facilities ( disposal wipes) or industrial laundries ( reusable wipes), if free liquids form from solvent condensation or solvent gravity flow inside containers, after generator seals containers prior to transporting off site.

4. Wipes transport container labels Do not require a RCRA specific label Eliminates cost associated with this element of main proposal Labels not required under main proposal Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

Direct Impact Element Alternative Regulatory Option Potential Economic Impacts of Regulatory Options Disposable Wipes Reusable Wipes 27 5. Wipes pretransport preparation " No free liquids when wrung" to qualify for exclusion $ 0.3 to $ 1.1 million annual cost to wipes generators for wringing wipes prior to transport ( source: spreadsheet attachment) $ 2.2 to $ 8.1 million annual cost to wipes generators ( or laundry pick up) for wringing wipes prior to transport ( source: factored 88/ 12 relative to disposables estimate).

6. Intracompany transfer of wipes One time notification of transfer activities to state agencies ! Cost to wipes generators: ( 5,058 to 12,483 disposable wipes generators) x ( 5% engage in transfer*) x ($ 105/ facility) = $ 27,000 to $ 66,000 one time cost. ! Cost to states to review notice:   Initial: ( same number of facilities above) x ($ 30/ notification) = $ 8,000 to $ 19,000.   Annual subsequent: 55% of initial cost = $ 4,400 to $ 10,500 per year. ! Cost to wipes generators: ( 57,633 to 140,379 reusable wipes generators) x ( 5% engage in transfer*) x ($ 105/ facility) = $ 0.30 to $ 0.74 million one time cost. ! Cost to states to review notice:   Initial: ( same number of facilities above) x ($ 30/ notification) = $ 87,000 to $ 211,000.   Annual subsequent: 55% of initial cost = $ 48,000 to $ 116,000 per year.

Maintain business records about wipes transferred Assume $ 0 additional cost because based on business records which are usually retained for at least 3 years for tax reporting or other legal purposes.

Comply with RCRA employee training ( 5,058 to 12,483 disposable wipes generators) x ( 5% engage in transfer*) x ($ 5,000/ facility/ year**) = $ 1.3 to $ 3.1 million/ year ( 57,633 to 140,379 reusable wipes generators) x ( 5% engage in transfer*) x ($ 5,000/ facility/ year**) = $ 14.4 to $ 35.1 million/ year. Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

Direct Impact Element Alternative Regulatory Option Potential Economic Impacts of Regulatory Options Disposable Wipes Reusable Wipes 28 Transfer wipes in sealed containers ! Assume " sealed" container costs are similar to metal drum costs estimated for main proposal. ! Sealed containers may unintentionally result in redistribution of free liquid management costs estimated for the main proposal, from spent wipes generators, to waste management facilities ( disposal wipes) or industrial laundries ( reusable wipes), if free liquids form from solvent condensation or solvent gravity flow inside containers, after generator seals containers prior to transporting off site.

7. Transfer to offsite handler ( different company) One time notification of transfer activities to state agencies ! Cost to wipes generators: ( 5,058 to 12,483 disposable wipes generators) x ( 5% engage in transfer*) x ($ 105/ facility) = $ 27,000 to $ 66,000 one time cost. ! Cost to states to review notice:   Initial: ( same number of facilities above) x ($ 30/ notification) = $ 8,000 to $ 19,000.   Annual subsequent: 55% of initial cost = $ 4,400 to $ 10,500 per year. $ 0 ( assume industrial laundries maintain complete control over reusable wipes handling)

Maintain business records about wipes transferred Assume $ 0 additional cost because based on business records which are usually retained for at least 3 years for tax reporting or other legal purposes. $ 0 ( assume industrial laundries maintain complete control over reusable wipes handling)

Comply with RCRA employee training ( 5,058 to 12,483 disposable wipes generators) x ( 5% engage in transfer*) x ($ 5,000/ facility/ year**) = $ 1.3 to $ 3.1 million/ year $ 0 ( assume industrial laundries maintain complete control over reusable wipes handling) Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

Direct Impact Element Alternative Regulatory Option Potential Economic Impacts of Regulatory Options Disposable Wipes Reusable Wipes 29 Transfer wipes in sealed containers ! Assume " sealed" container costs are similar to metal drum costs estimated for main proposal. ! Sealed containers may unintentionally result in redistribution of free liquid management costs estimated for the main proposal, from spent wipes generators, to waste management facilities ( disposal wipes) or industrial laundries ( reusable wipes), if free liquids form from solvent condensation or solvent gravity flow inside containers, after generator seals containers prior to transporting off site. $ 0 ( assume industrial laundries maintain complete control over reusable wipes handling)

8. Offsite management of wipes See element 1 above affecting eligibility for landfilling disposable wipes See element 1 above Not applicable Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

Direct Impact Element Alternative Regulatory Option Potential Economic Impacts of Regulatory Options Disposable Wipes Reusable Wipes 30 9. Compliance recordkeeping Certify that solvent wipes shipments meet either " no free liquids" or " dry" conditions.   Assume 145,000 spent wipes containers/ year transported equals 18,000 truck shipments/ year.   Assume each shipment requires 0.25 hours labor time for certification & recordkeeping by generator: ( 18,000 shipments) x ( 0.25 hours) x ($ 22/ hour) = $ 99,000/ year   Assume each shipment equally requires 0.25 hours labor time for certification & recordkeeping by receiver: $ 99,000/ year   Assume 2.7 million spent wipes containers/ year transported equals 335,000 truck shipments/ year.   Assume each shipment requires 0.25 hours labor time for certification & recordkeeping by generator: ( 335,000 shipments) x ( 0.25 hours) x ($ 22/ hour) = $ 1.84 million/ year.   Assume each shipment equally requires 0.25 hours labor time for certification & recordkeeping by receiver: $ 1.84 million/ year.

Streamlined RCRA manifest for returning wipes with free liquids to generators   Assume streamlined manifest is 15% social cost of traditional manifest: ($ 300/ manifest***) x $ 15% = $ 45/ manifest.   ( 18,000 truck shipments/ year) x ( 3.5% contain free liquids) x ($ 45/ manifest) = $ 28,400/ year. $ 0; assumes that industrial laundries will ( a) provide " full service" business approach to their customers, and ( b) desire to avoid disrupting weekly pick up/ delivery routings, and not return free liquids to generators, but manage at the industrial laundry.

Other options Exclude reusable wipes from RCRA Definition of Hazardous Waste, rather than from RCRA Definition of Solid Waste Not applicable Because conditions identical as main proposal, only " catchet" benefit from avoided stigma lost. Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

Direct Impact Element Alternative Regulatory Option Potential Economic Impacts of Regulatory Options Disposable Wipes Reusable Wipes 31 Explanatory Notes: ( a) * 5% applied to both the intra company and offsite handler transfer assumption represents OSW's best judgement, in absence of data. ( b) ** $ 5,000 annual cost ( year 2000$) per facility for RCRA employee training   source: USEPA Office of Solid Waste " Unit Cost Compendium", 30 Sept 2000, DPRA Incorporated, cost item 6, p. 2). ( c) *** $ 300 social cost of paperwork burden per RCRA hazardous waste transport manifest ( EPA Form 8700 22) consists of 38% cost to waste generators, 39% to waste transporters, 20% to waste receivers ( i. e. waste treatment, storage disposal, recycling facilities), and 3% to state agencies ( 24 states distribute manifests, collect manifest information, and/ or levy manifest fees); source: USEPA Office of Solid Waste, " Hazardous Waste Manifest Cost Benefit Analysis", Logistics Management Institute, Oct 2000, Table 3 9, page 3 7, http:// www. epa. gov/ epaoswer/ hazwaste/ gener/ manifest/ pdf/ cba rprt. pdf II. F. Sensitivity Analysis For purpose of quantifying the potential economic impacts of the proposed exclusions, this study assigned numerical values to different parameters representing current ( baseline) regulatory conditions, as well as representing expected post regulatory conditions ( i. e. after the proposed exclusions are is promulgated as a final rule). The numerical values were based on different sources of data and information such as:

! USEPA Office of Solid Waste industrial survey findings ! Other Federal government databases ! Published commercial data sources ( e. g. industrial supply catalogs) ! USEPA Office of Solid Waste best judgement based on fieldtrip observations, and meetings and telephone contacts with affected industry representatives.

The following table presents the numerical value uncertainty ranges assigned in this study to 20 impact estimation key parameters. Most of the parameters reflect uncertainty about baseline conditions, while a few others reflect different cost options for meeting the conditions of the regulatory exclusions. This set of parameters affects both estimation of direct and induced impacts in this study. In comparison to the key parameter settings as defined earlier in this study ( i. e. most likely values), the sensitivity analysis of this section reestimates economic impacts ( direct + induced), according to three alternative sets of parameter settings: Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

32 ! " Lower bound": Lowest estimate of number of entities directly impacted, as well as minimum unit values & quantities ( note: for reusable wipes this scenario represents minimal direct impacts on industrial laundries, by assuming a 100% cost pass thru of implementation costs, to industrial laundry wipes customers).

! " Most likely": OSW's " best judgement" settings for key parameters ( which do not necessarily represent the mid point between the lower and upper bound).

! " Upper bound": Highest estimate of number of entities impacted, as well as maximum unit values & quantities.

Assignment of Numerical Values to Key Baseline and Incremental Regulatory Impact Parameters For Sensitivity Analysis of Economic Impact Estimation ( percentages relative to baseline)

Item Direct Impact Element Impact Estimation Baseline Parameter Lower Bound Most Likely Upper Bound 1 1. Wipes solvent eligibility Percentage of wipes using facilities which currently use RCRA solvents on industrial wipes ( i. e. " generators") Printers ( 3 of 13 subsectors) 90% 100% 100%

2 Non printers ( 10 of 13 subsectors) 30% 35% 40%

3 2. Onsite wipes covered* accumulation containers Percentage of spent RCRA solvent wipes not currently accumulated on site in covered containers Reusables 25% 50% 80% 4 Disposables 5 3. Wipes transport containers Percentage of spent RCRA solvent wipes not currently transported off site in closed containers Reusables 25% 50% 80% 6 Disposables 7 Type of containers purchased for spent solvent wipes transport Plastic bags Average of two options Metal drums Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

33 8 4. Wipes transport container labels Percentage of RCRA solvent wipes transport containers currently without regulatory exclusion labels Reusables Not required in proposal 9 Disposables 100%

10 5. Wipes pretransport preparation Percentage of spent RCRA solvent wipes not " dry" as currently generated Printers 90% 100% 100%

11 Non printers 40% 50% 60%

12 Method for managing spent solvent " free liquids" recovered from spent wipes accumulation containers and from spent wipes transportation containers Solvent recycling ( net savings) Average of two options Fuel blending ( net cost)

13 6. Intra company transfer of wipes Percentage of RCRA solvent spent wipes generators making intra company transfers for " free liquids" removal Reusables 0% ( assume distribution controlled by laundries)

Disposables 5%

14 7. Transfer to offsite handler Percentage of RCRA solvent wipes generators making transfers to offsite handlers for " free liquids" removal Reusables 0% ( assume distribution controlled by laundries)

15 Disposables 5%

16 8. Offsite management of spent disposables arriving at waste mgt facilities & spent reusables at laundries Percentage of RCRA solvent wipes containers that arrive at final destination with " free liquids" Printers 1% 5% 10%

17 Non printers 0.5% 2.5% 5%

18 Method for managing spent solvent " free liquids" recovered from spent wipes accumulation containers and from spent wipes transportation containers Solvent recycling ( net savings) Average of two options Fuel blending ( net cost) Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

34 19 Other impact estimation parameters " Cross price" elasticity of demand as percentage of " own price" elasticity magnitude ( higher percentage simulates greater induced effect on relative price and marketshare between disposables & reusables; based on meta analysis presented in this document) 11% 26% 26%

20 Percentage of states assumed to adopt voluntarily the exclusions after final rule promulgation 50% 75% 100%

21 Industrial laundry exclusion implementation cost pass thru to reusable wipes customers For laundry direct impact> 100%

32% 0%

For simulating induced impact on wipes market> 0% 100%

Explanatory Notes: ( a) Sources for Numerical Values Assigned in This Table: ! Items 1 to 7: USEPA OSW assigned numerical values for the three sensitivity analysis cases ( i. e. lower, most likely, and upper) based on either ( a) field trip research to wipes users or handlers, ( b) from meetings or telephone contacts with representatives of affected industries, or ( c) best judgement in absence of data. ! Other items: ! Cross price elasticity: Most likely value based on meta analysis of price elasticity data contained in other economic studies; identical upper bound value assigned because reusable and disposable wipes are reportedly not interchangeable in some industrial applications; lower bound based on two standard deviations below the most likely elasticity ratios derived from the meta analysis. ! State adoption: Percentages shown have two possible alternative economic modeling interpretations: ! The percent of states/ territories which may adopt the exclusions after promulgation by USEPA, or ! The resultant percent of entities affected by the proposed rule, as a result of a different percent of states adopting the proposed exclusions. ! Laundry cost pass thru: Most likely value from: USEPA Office of Water, " Economic Assessment for the Final Action Regarding Pretreatment Standards for the Industrial Laundries Point Source Category", EPA 821 R 00 004, March 2000, p. A 23 ( http:// www. epa. gov/ ost/ guide/ laundry/ final/ economics. pdf). ( b) * Accumulating spent solvent industrial wipes in covered/ closed containers on site is an existing ( baseline) " best management practice" in some industries. For example, the Printers' National Environmental Assistance Center ( PNEAC) provides a pollution prevention checklist for use by lithographic printers, which specifies the use of closed containers for accumulating solvent industrial wipes, among other solvent and solvent wipes management tips ( http:// www. pneac. org/ sheets/ litho/ p2_ cklist_ litho. html). Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

35 The result of applying the above uncertainty ranges for estimation of direct impacts for the proposed exclusions ( main proposal) are:

Uncertainty Range for Estimate of Potential Average Annualized Direct Impact ($/ year) on Spent Wipes Generators & Other Handlers** ( parentheses indicate net cost savings; other benefits categories not included in this table)

Uncertainty Range ($ Millions/ year)

Disposable Wipes Reusable Wipes Net Impact ( row totals)

Lower bound ($ 18.9) to ($ 20.5) $ 2.9 to $ 4.6 ($ 14.3) to ($ 17.6)

Most likely ($ 32.5) to ($ 35.6) $ 9.1 to $ 15.3 ($ 17.2) to ($ 26.5)

Upper bound ($ 47.9) to ($ 53.3) $ 20.3 to $ 33.9 ($ 14.0) to ($ 33.0)

II. G. Induced Market Impacts In addition to direct impacts, this study also estimates potential " induced impacts" of the proposed exclusions, in the form of potential effects on the relative prices and national marketshare of reusable and disposable industrial wipes. This study simulates potential induced impacts by building upon the direct impacts estimated for each respective wipes category, and includes simulation of potential induced impacts on the industrial laundry sub sector, which is also subject to some of the requirements of the proposed exclusions. For simulating induced impacts, this study developed a simple cobweb type partial equilibrium market model, which translates the estimated average annualized national direct impacts ( i. e. implementation costs and cost savings), into a " per wipe" unitized basis. The model then adds the unitized per wipe direct impact to the current national average prices ($/ wipe) for each respective wipe, for the purpose of simulating an implied post regulatory " new price" ( under both zero and full direct impact " pass thru" assumptions). For this analysis, the wipes " price" includes both the direct cost to wipes users of purchasing ( disposables) or leasing ( reusables) industrial wipes, as well as the unitized per wipe cost for managing spent wipes ( i. e. the " effective unit cost" per wipe). The implied percentage changes in the relative prices ( effective unit costs) to wipes users, provides a basis for the model to simulate potential shifts in marketshare between disposable and reusable wipes, to the extent that wipes users actually consider and are sensitive to relative prices ( effective unit costs) in their purchasing choices between disposable and reusable industrial wipes. Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

36 The degree to which relative price ( relative effective unit cost) is a factor in the selection between product substitutes, is referred to as the " price elasticity of substitution" for a product. The degree to which the demand for a particular product is influenced by the price of that same product is referred to as the " own price elasticity". The degree to which the demand for a particular product is influenced by the price of a substitute product is the " cross price elasticity". This document derived both an " own" and " cross" price elasticity for simulation of the potential composite effect of changes to both reusable and disposable wipes effective cost, in estimating potential induced market impacts. Own price elasticity was derived from actual US historical data on national average price and quantities sold for reusable wipes, whereas in absence of historical data for the US disposable wipes market, this study derived an estimate of cross price elasticity based on meta analysis of cross elasticity data published in other economic studies. A series of spreadsheets which follow in this document present the findings for both the direct and induced impact categories, including supporting data tables and computation spreadsheets for some of the key parameters applied in this document.

Simulated Induced Impact on Relative Unit Cost of Industrial Wipes in the US ( based on the potentially affected sub market of 2.8 billion solvent industrial wipes/ year)

Type of Industrial Wipe > Reusables ( laundry cost pass thru assumptions) Disposables Lowerbound ( 0%) Most likely ( 32%) Upperbound ( 100%) Lowerbound Most likely Upperbound Current ( baseline) average unit cost $ 0.0535 $ 0.2368 Post final rule estimated average unit cost $ 0.0535 $ 0.0565 $ 0.0627 $ 0.0961 $ 0.1020 $ 0.1096 Estimated percentage change in unit cost 0% 5.6% 17.2% ( 59%) ( 56%) ( 53%) Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

37 Simulated Induced Impact on Industrial Wipes US National Marketshare ( based on the potentially affected sub market of solvent industrial wipes)

Type of Industrial Wipe> Reusables Disposables Row totals Lowerbound Mostlikely Upperbound Lowerbound Mostlikely Upperbound Lowerbound Mostlikely Upperbound Current ( baseline) marketshare Annual solvent wipes uses affected by exclusions 1.49 billion 2.55 billion 3.68 billion 0.15 billion 0.26 billion 0.39 billion 1.64 billion 2.81 billion 4.07 billion Relative marketshare 91% 9% 100%

Possible induced market impact Change in annual wipes uses ( 48 million) ( 218 million) ( 574 million) 48 million 218 million 218 million 0 Percentage change ( 3.2%) ( 8.5%) ( 15.6%) 32% 88% 148% 0%

Possible marketshare after final rule implementation Annual wipes uses 1.44 billion 2.33 billion 3.11 billion 0.20 billion 0.48 billion 0.96 billion 1.64 billion 2.81 billion 4.07 billion Relative marketshare 88% 83% 76% 12% 17% 24% 100% Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

38 II. H. Small Business Impacts ! Small businesses: Because of the fact that 96% of companies which use industrial wipes across the 13 sub sectors, as well as 94% of industrial laundry companies are small businesses ( i. e. " companies" or " firms"), this study assessed the potential magnitude of impacts on small businesses.

! Small facilities: Establishments ( i. e. facilities) owned and operated by small businesses are: ! 94% small facilities in 13 generator sub sectors ! 47% small facilities in industrial laundry industry Baseline Count of Facilities Owned & Operated by Small Businesses Facility size Spent Wipes Generators ( 13 sub sectors) Industrial Laundries Both Sub Groups Combined Lowerbound Most likely Upperbound Lowerbound Mostlikely Upperbound Lowerbound Mostlikely Upperbound All sizes 62,400 106,100 151,800 588 881 1,175 63,000 107,000 153,000 Small only 53,700 92,700 131,400 275 414 551 54,000 93,000 132,000 ! Based on the zero impact findings summarized in the table below for the " most likely" case, as well as the relatively small percentage of small businesses potentially affected above the 3% threshold level, OSW presumes that the proposed RCRA regulatory exclusions are eligible for a " No SISNOSE" ( i. e. no significant impact on a substantial number of small entities) determination for Regulatory Flexibility Act ( RFA) certification. Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

39 Screening Analysis Findings for Regulatory Flexibility Act Small Business Impact Certification ( Direct Compliance Costs + Induced Market Effects)

USEPA's March 1999 RFA Guidance* thresholds Potentiall affected sub group Estimated count of small facilities potentially exceeding thresholds % of small facilities in associated sub group exceeding thresholds % of all small facilities potentially affected Lowerbound Mostlikely Upperbound Lowerbound Mostlikely Upperbound Lowerbound Mostlikely Upperbound > 1% of revenues Industrial laundries 0 0 72 0% 0% 13.1% 0% 0% 0.054% Wipes generators 0 0 0 0% 0% 0%

> 3% of revenues Industrial laundries 0 0 16 0% 0% 2.9% 0% 0% 0.012% Wipes generators 0 0 0 0% 0% 0%

Explanatory Notes: ( a) The estimated number of entities ( wipes generators & wipes handlers) potentially affected by the proposed exclusions is subject to three sensitivity analysis factors, combinations of which produce these three baseline uncertainty cases: ( a) Percentage of states which may adopt the final rule ( b) Percentage of wipes using printer entities which apply RCRA solvents to industrial wipes ( c) Percentage of wipes using non printer entities which apply RCRA solvents to industrial wipes ( b) * USEPA's 29 March 1999 Regulatory Flexibility Act ( RFA) Guidance ( 100 pages) is available at http:// www. epa. gov/ sbrefa/ documents/ iguid99. pdf Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

40 II. I. Other Factors Potentially Affecting Economic Impacts ! Wipes Limited Substitutability In addition to wipes price ( unit cost) differences, there are at least three qualitative differences between disposables and reusables, which suggest that wipes relative marketshare and product switching ( substitution), are not solely a function of wipes relative price:

Factors Influencing Market Substitutability Between Reusable & Disposable Wipes Factor Definition Wipes performance: Wipes ( a) lint residue, ( b) absorbency, and ( c) durability, dictate consumer choice in wipes for many industrial applications where these qualities are critical ( e. g. electronic manufacturing cannot tolerate lint).

Wipes market supply: Industrial laundries provide reusable wipes users with the benefit of full " cradle to grave" service, thereby avoiding need to manage wipes; in contrast, users of disposable wipes must manage their spent wipes as waste. Furthermore, contracts with industrial laundries are often multi year, which serve to " lock in" customers.

Small portion of industry operating costs: Compared to total operating costs ( equipment + energy + materials + labor), annual baseline costs to a business of using industrial wipes is very small, averaging 0.08% of operating cost ( sub sector averages range from 0.01% to 3.47% across the 13 sub sectors). Consequently, changes in the relative price of disposable and reusable wipes may go unnoticed by wipes users ( i. e. " price inelastic demand").

! Annual Solvent Quantities Purchased for Industrial Wipes:

Possible induced decrease in future annual growth of US demand for newly produced solvents applied in industrial wipes operations, as a consequence of induced increase in the annual quantity of solvents recovered from solvent contaminated wipes to meet the proposed " no free liquids" regulatory exclusion condition. Recovered solvents may be reused on wipes, thereby reducing demand for newlyproduced solvents. Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

6 The statistical " z score" is defined in most university level statistics textbooks ( e. g. James McClave & P. George Benson, Statistics for Business and Economics, ( Section 6.3: The Normal Distribution), 4th edition, Dellen/ MacMillan Publishers, 1988).

41 ! Solvent Types Purchased for Industrial Wipes: Possible induced change in the proportional mix of US annual demand for solvents applied in industrial wipes operations, as a consequence of induced decrease in demand for certain types of solvents which may no longer be landfilled, and an induced compensating increase in demand for solvents not restricted from landfills. This study estimates the potential induced shift in national marketshare between the two types of industrial wipes, but not in the chemical types of solvents applied to wipes. Analysis of 1999 price data ( standardized to $/ gallon) for 43 different industrial cleaning/ degreasing solvents used in the US economy ( compiled from the Stanford Research Institute " Chemical Economics Handbook", http:// ceh. sric. sri. com), reveals that the $ 3.17/ gallon average cost of 27 RCRA F listed solvents, is 4% less expensive than the $ 3.30/ gallon average cost of 16 non F listed solvents. This difference presents a slight purchase price advantage for F listed solvent users, but users of F listed solvents would also incur a relatively higher life cycle cost of using F listed solvents because of RCRA hazardous waste management requirements. Consequently, comparison of average prices does not suggest an overall cost advantage which would induced current users to switch from non F to F listed solvents. However, at the minimum end of the price range for each solvent grouping, the $ 0.75/ gallon minimum price for F listed solvents, is 48% less expensive compared to the $ 1.44/ gallon minimum price for non F listed solvents, which suggests there may be a clear cost advantage ( incentive) for some current users of non F listed solvents to switch over to using F listed solvents, as a result of the exclusion of disposable wipes from hazardous waste regulation. At the maximum end of the respective price ranges, the group of 27 F listed solvents has a maximum price of $ 6.19/ gallon, which is 15% higher than the $ 5.38/ gallon maximum price for the group of 16 non F listed solvents. Given that some users currently pay higher prices for F listed solvents suggests that F solvents may offer preferred chemical performance characteristics in some industrial solvent applications. If this is the case, it is conceivable that some non F listed solvent users may be induced to switch to using higher priced F listed solvents to enhance industrial performance characteristics, as a result of the exclusion possibly lowering the lifecycle cost of using F listed solvents. In absence of detailed and comprehensive marketshare data on these two groups of industrial cleaning/ degreasing solvents, OSW modeled this potential comparative price switch over, by the following mathematical device: by estimating the respective marketshare areas represented by overlaying a normal ( bell shaped) distribution curve over the solvent price range data, and then computing statistical z scores ( standard normal random variable6) to represent the area under the distribution curve, according to a normal distribution statistical probability table ( note that the distribution is not perfectly normal shaped, as the skewness is 0.17 ( normal = 0), and the kurtosis is  1.00 ( normal = 0), based on the price data analysis presented in an earlier spreadsheet in this document). The range between the minimum and maximum ( i. e. lower tail and upper tail) across the price distribution for all 43 solvent prices combined, is compared to the respective tail areas for a normal distribution fit to the F listed solvent price range. For purpose of developing an estimate in this study, it is assumed that the tail areas of the overall price distribution after promulgation of the final rule, will be identical to the tail area proportions under the F listed solvent price range distribution curve. Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

42 Estimation of Potential Switch in National Solvent Usage After Promulgation of RCRA Exclusions ! Respective min/ max price distribution tail areas for the combined sample of 43 solvents:

Price distribution characteristics: mean = $ 3.22; standard deviation = $ 1.34 Price distribution ( range) Z score computation Distribution area Lower tail area ($ 1.44$ 3.22)/$ 1.34 =  1.33 9%

Upper tail area ($ 5.38$ 3.22)/$ 1.34 = 1.61 5%

Total = 15%

! Respective min/ max price distribution tail areas for the sample of 26 F listed solvents:

Price distribution characteristics: mean = $ 3.17; standard deviation = $ 1.38 Price distribution ( range) Z score computation Distribution area Lower tail area ($ 1.44$ 3.17)/$ 1.38 =  1.25 11%

Upper tail area ($ 5.38$ 3.17)/$ 1.38 = 1.60 5%

Total = 16%

Possible percentage of non F listed solvents switching to F listed solvents = ( 1 35%) x 16% = 10%

From the above computations, according to an assumed normal distribution across solvent prices, the minimum end price tail between the $ 0.75/ gallon F listed minimum price, and the $ 1.44/ gallon non F solvent minimum price, represents 9% of the solvent price distribution. The upper end tail of this distribution between the maximum $ 5.38/ gallon non F listed solvent price and the $ 6.19/ gallon Flisted solvent price, represents 5% ( totaling 14% for both tails of the distribution). By computing statistical probability z scores to represent these distribution tail areas, and then proportioning the new respective tail areas in proportion to the F listed group of 27 solvents ( totaling 16% for both tails), provides an estimate that 10% of non F listed solvent users, may switch to using F listed solvents. In addition to solvent purchase price and solvent usage life cycle cost considerations, there are environmental considerations that facilities may consider, so the 10% switch over should be considered as an " upper bound" estimate. For example, some facilities may want to minimize the use of F listed solvents that contain hazardous air pollutants ( HAPs) to meet any air permitting requirements they may have. Based on the same list of 43 industrial solvents, 27 are F listed ( 63%), and 16 of the 27 F listed solvents ( 59%) are HAPs, so there a number of F listed candidate solvents ( at least 11) that would not present a HAP concern, under the year 2001 USEPA HAP list. Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

43 ! Future Annual Generation of Solvent Contaminated Industrial Wipes Industrial production   and hence, industrial demand   for wipes has grown an average of 3.05% annually in the US economy for the last 15 years ( 1986 2000 data trend). This average annual growth represents the overall rate of growth in industrial production over the 13 economic sub sectors which are known to use industrial wipes, including both " printer" ( n= 3) and " non printer" ( n= 10) sub sectors. This factor could be applied in both the economics and risk assessment as a sensitivity analysis of impacts and risk estimates, respectively, according to a future " period of analysis" ( i. e. stream of future years), by applying the multiplier [( 1+ 0.0305)^ n], where n = number of future years. The following two tables display the projected future quantity of affected industrial wipes, and the projected future annualized economic impact of the exclusions, respectively, with this annual industrial growth factor applied for 30 years.

Projected Growth in Future Generation of Solvent Contaminated Spent Industrial Wipes ( Disposable + Reusable Wipes Generated by SQGs & LQGs)

Uncertainty Range RCRA Solvent Industrial Wipes Affected by Exclusions ( billions/ year)

2001 Baseline* 10 years ( factor 1.35) 30 years ( factor 2.46)

Lower bound 1.6 2.2 3.9 Most likely 2.8 3.8 6.9 Upper bound 4.1 5.5 10.1 * Note: This key parameter ( i. e. estimated number of solvent contaminated industrial wipes generated per year) is subject to three sensitivity analysis factors, combinations of which produce these three baseline uncertainty cases: ! Percentage of states which may adopt the exclusions after promulgation as a final rulemaking ! Percentage of wipes using printer entities which apply RCRA solvents to industrial wipes. ! Percentage of wipes using non printer entities which apply RCRA solvents to industrial wipes. Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

44 Projection of Future Annualized Impacts Over 30 Years Based on 15 Year Historical Growth in Industrial Production Index ( 1986 2000)

IPI Annual Growth Maximum Net Savings ( lowest costs + highest savings) Maximum Net Cost ( highest costs + lowest savings) 3.05% 3.05% 3.05% 3.05% 3.05% 3.05% Item Year Disposables Reusables Combined Disposables Reusables Combined 1 2004 ($ 35,630,000) $ 9,150,000 ($ 26,480,000) ($ 32,480,000) $ 15,280,000 ($ 17,200,000) 2 2005 ($ 36,717,738) $ 9,429,338 ($ 27,288,400) ($ 33,471,573) $ 15,746,479 ($ 17,725,094) 3 2006 ($ 37,838,683) $ 9,717,203 ($ 28,121,480) ($ 34,493,417) $ 16,227,198 ($ 18,266,218) 4 2007 ($ 38,993,849) $ 10,013,857 ($ 28,979,992) ($ 35,546,456) $ 16,722,594 ($ 18,823,862) 5 2008 ($ 40,184,281) $ 10,319,567 ($ 29,864,714) ($ 36,631,644) $ 17,233,113 ($ 19,398,530) 6 2009 ($ 41,411,056) $ 10,634,610 ($ 30,776,446) ($ 37,749,960) $ 17,759,218 ($ 19,990,743) 7 2010 ($ 42,675,282) $ 10,959,271 ($ 31,716,011) ($ 38,902,418) $ 18,301,384 ($ 20,601,034) 8 2011 ($ 43,978,103) $ 11,293,844 ($ 32,684,260) ($ 40,090,059) $ 18,860,102 ($ 21,229,957) 9 2012 ($ 45,320,698) $ 11,638,630 ($ 33,682,068) ($ 41,313,957) $ 19,435,876 ($ 21,878,080) 10 2013 ($ 46,704,281) $ 11,993,942 ($ 34,710,338) ($ 42,575,218) $ 20,029,228 ($ 22,545,990) 11 2014 ($ 48,130,102) $ 12,360,102 ($ 35,770,000) ($ 43,874,985) $ 20,640,695 ($ 23,234,290) 12 2015 ($ 49,599,452) $ 12,737,440 ($ 36,862,012) ($ 45,214,432) $ 21,270,829 ($ 23,943,603) 13 2016 ($ 51,113,659) $ 13,126,298 ($ 37,987,362) ($ 46,594,770) $ 21,920,200 ($ 24,674,570) 14 2017 ($ 52,674,093) $ 13,527,027 ($ 39,147,067) ($ 48,017,248) $ 22,589,395 ($ 25,427,853) 15 2018 ($ 54,282,166) $ 13,939,989 ($ 40,342,176) ($ 49,483,153) $ 23,279,020 ($ 26,204,133) 16 2019 ($ 55,939,330) $ 14,365,559 ($ 41,573,771) ($ 50,993,810) $ 23,989,699 ($ 27,004,111) 17 2020 ($ 57,647,086) $ 14,804,121 ($ 42,842,965) ($ 52,550,585) $ 24,722,073 ($ 27,828,512) 18 2021 ($ 59,406,977) $ 15,256,072 ($ 44,150,905) ($ 54,154,887) $ 25,476,806 ($ 28,678,080) 19 2022 ($ 61,220,595) $ 15,721,820 ($ 45,498,775) ($ 55,808,166) $ 26,254,580 ($ 29,553,585) 20 2023 ($ 63,089,581) $ 16,201,787 ($ 46,887,794) ($ 57,511,917) $ 27,056,099 ($ 30,455,818) 21 2024 ($ 65,015,625) $ 16,696,407 ($ 48,319,218) ($ 59,267,682) $ 27,882,087 ($ 31,385,595) 22 2025 ($ 67,000,468) $ 17,206,126 ($ 49,794,342) ($ 61,077,048) $ 28,733,291 ($ 32,343,757) 23 2026 ($ 69,045,906) $ 17,731,407 ($ 51,314,499) ($ 62,941,651) $ 29,610,481 ($ 33,331,170) 24 2027 ($ 71,153,789) $ 18,272,724 ($ 52,881,064) ($ 64,863,179) $ 30,514,451 ($ 34,348,728) 25 2028 ($ 73,326,022) $ 18,830,567 ($ 54,495,455) ($ 66,843,368) $ 31,446,018 ($ 35,397,350) 26 2029 ($ 75,564,571) $ 19,405,440 ($ 56,159,131) ($ 68,884,010) $ 32,406,024 ($ 36,477,985) 27 2030 ($ 77,871,460) $ 19,997,863 ($ 57,873,597) ($ 70,986,950) $ 33,395,338 ($ 37,591,611) 28 2031 ($ 80,248,775) $ 20,608,372 ($ 59,640,403) ($ 73,154,090) $ 34,414,855 ($ 38,739,235) 29 2032 ($ 82,698,667) $ 21,237,519 ($ 61,461,148) ($ 75,387,390) $ 35,465,496 ($ 39,921,894) 30 2033 ($ 85,223,351) $ 21,885,873 ($ 63,337,478) ($ 77,688,870) $ 36,548,212 ($ 41,140,658)

Summary: Column totals = ($ 1,709,700,000) $ 439,100,000 ($ 1,270,600,000) ($ 1,558,600,000) $ 733,200,000 ($ 825,300,000) NPV = ($ 653,110,000) $ 167,720,000 ($ 485,390,000) ($ 595,370,000) $ 280,090,000 ($ 315,280,000) AAE = ($ 49,189,000) $ 12,632,000 ($ 36,557,000) ($ 44,840,000) $ 21,095,000 ($ 23,745,000)

Note: Percent annual growth based on the Industrial Production Index ( US Federal Reserve data); average annual percentage growth in the IPI over the 15 year historical period 1986 2000 for 13 sub sector spent wipes generators ( http:// www. federalreserve. gov/ releases/ G17/ table1_ 2. htm). Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

7 $ 1.00/ gallon onsite recycling unit cost based on a case study for the printing industry: http:// www. rapidimaging. com/ TSR/ TSR% 20R 07% 20Platemaking% 20Productivity% 20for% 20Web. pdf 8 $ 2.45/ gallon offsite commercial hazardous waste solvent recycling cost based on a case study on parts washing in the metal manufacturing industry ( http:// www. iwrc. org/ pubs/ IPPIMetal. pdf); $ 4.65/ gallon offsite hazardous waste solvent recycler based on a case study of solvent cleaning of industrial painting equipment in the plastics manufacturing industry ( http:// www. eponline. com; 13 April 2003).

45 ! Solvent Recycling ! Recycling Assumptions Applied in this Study One source of uncertainty, among others, in this economic impact study, is how facilities currently manage spent solvent " free liquids" which may appear in on site spent wipes accumulation container, and/ or appear in spent wipes transport containers, and how facilities may decide to manage any incremental increase in " free liquids" captured as a result of complying with the conditions of the exclusions. This study estimated the economic impact for two possible " free liquids" management options:

! Fuel blending: Shipping solvent " free liquids" to offsite hazardous waste fuel blenders ( at an average net cost of $ 0.91 per gallon, based on average unit cost reported for hazardous waste fuel blending from the OSW Sept 2000 " Unit Cost Compendium"). ! Recycling: Recycling solvent " free liquids" for reuse as solvents ( at an average net cost savings of $ 0.74 per gallon, based on the $ 2.54 average unit cost from the three data points below, minus the $ 3.28 average price of virgin solvent avoided cost from solvent price data in an attachment to this document).

The solvent recycling option in this study represents an average unit cost for two recycling scenarios:

! Onsite: $ 1.00/ gallon unit cost reported for an onsite solvent recycling operation in the printing industry7 ! Offsite: $ 2.45 to $ 4.16/ gallon unit cost for offsite commercial solvent recycling8 This study does not estimate the proportion of industrial wipes users which currently fuel blend, or which currently recycle onsite or offsite, or which may find solvent recycling economically attractive if compliance with the conditions of the exclusions result in an incremental increase in the quantity of " free liquids" captured onsite by the spent wipes generator. Furthermore, this study does not estimate the proportion of facilities which currently, or may be induced by compliance with the exclusions, to operate onsite, or ship spent solvent wipes offsite to, a solvent extraction device ( e. g. centrifuge machine) to capture solvents from spent wipes as allowed by the RCRA regulatory exclusions ( although a following section presents a sample of equipment cost data for solvent wipes centrifugation). Adoption of either onsite or offsite spent wipes centrifugation ( and other solvent extraction techniques) may incrementally increase the annual quantity of solvent to be managed in fuel blending or recycling processes. Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

46 ! Quantity of Solvents Applied to Industrial Wipes The amount of solvents applied annually in the US to industrial wipes is a relatively large absolute quantity. A supplemental data attachment to this document contains annual national data on solvent production and consumption. Based on published estimates from 1991 and 1997, respectively, the US produced at least 27.0 million tons per year ( about 6.93 billion gallons) of 43 different chemicals used as solvents, and consumed at least 6.33 million tons ( about 1.62 billion gallons) of these solvent chemicals in actual solvent applications, ( i. e. excluding use of solvent chemicals as chemical manufacturing feedstocks). As displayed in the table below, at least 0.90 million tons per year ( about 231 million gallons) of at least 23 different chemicals are reportedly used as solvents in cleaning/ degreasing applications, of which OSW estimates that 82,000 to 103,000 tons per year ( about 21 to 26 million gallons ) are applied to industrial wipes. This estimate of solvent application to industrial wipes represents about 11% to 14% of the consumption of cleaning/ degreasing solvents, and represents 1.3% to 1.6% of all solvent applications ( excluding solvents used as chemical feedstocks). The 23 chemicals reportedly used as cleaning/ degreasing solvents represent nine different chemical classes: ( 1) alcohols, ( 2) aliphatic hydrocarbons, ( 3) aromatic hydrocarbons, ( 4) chlorinated aliphatic hydrocarbons, ( 5) chlorinated aromatic hydrocarbons, ( 6) esters, ( 7) ketones, ( 8) glycols, and ( 9) ethers.

Annual Quantity of Solvents Applied to Industrial Wipes Compared to the Industrial Solvent Universe Solvent subset Annual Solvent Quantity ( equivalency metrics) Relative percent Million tons/ year Million gallons/ year Universe: Manufacture of 43 industrial chemicals which may be used as solvents* ( other chemicals may also be used but not as prevalent) 27.0 6,930 Subset 1: All industrial solvent applications* 6.3 1,620 100%

Subset 2: Only industrial solvent cleaning/ degreasing applications* 0.9 231 14%

Subset 3: Only solvents applied to industrial wipes ( for cleaning/ degreasing) Reusable wipes** 0.072 to 0.091 18.6 to 23.3 1.3% to 1.6% Disposable wipes*** 0.010 to 0.012 2.5 to 3.2 Subtotal wipes 0.082 to 0.103 21.1 to 26.5 Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

9 These micro economic factors are described in " Fact Sheet: Considerations in Selecting a Commercial ( Off Site) Solvent Recycling Service", Michigan Dept of Environmental Quality, Environmental Assistance Division Publication # 9204, Dec 1998, http:// www. deq. state. mi. us/ documents/ deq ead recycle solrecyc. pdf. Two other references about the micro economics of solvent recycling provide facility level benefit/ cost worksheets to compute economic feasibility ( profitability) of solvent recycling: ! " A Guide for Choosing and Operating an On Site Distillation Unit", Washington State Dept of Ecology Publication # 94 31, 31 Oct 1995, http:// es. epa. gov/ techninfo/ facts/ washington/ wsde3. html. ! Iowa Pollution Prevention Initiative, Small Business Development Center, Iowa Waste Reduction Center," Pollution Prevention Implementation Plan for Metal Manufacturers", see Section 3: Painting Equipment Cleaning; and Section 4: Parts Washing, http:// www. iwrc. org/ pubs/ IPPIMetal. pdf 47 Explanatory Notes: ( a) * Source: See supplementary attachment with industrial solvent data at end of this document. ( b) ** Source: Based on USEPA Office of Water survey data on 1994 annual quantity of reusable wipes processed by US industrial laundries ( Tables 4 2 and 4 3 in report EPA 821 R 00 006, March 2000, http:// www. epa. gov/ waterscience/ guide/ laundry/ final/ section1. pdf): ! Non printer reusables: Wipes: ( 9.360 billion lbss/ year total items laundered) x ( 3.7% non printer reusables) = 346.3 million lbs/ year wipes Solvent: [( 346.3 million lbs/ year wipes) x ( 12.5% solvent weight)]/( 60% to 75% non evaporation****) = 57.7 to 72.2 million lbs/ year = 28,800 to 36,100 tons/ year = 7.4 to 9.3 million gallons/ year solvents ! Printer reusables: Wipes: ( 9.360 billion lbs/ year total items laundered) x ( 1.4% printer reusables) = 131.0 million lbs/ year wipes Solvent: [( 131.0 million lbs/ year wipes) x ( 50% solvent weight)]/( 60% to 75% non evaporation****) = 87.4 to 109.2 million lbs/ year = 43,700 to 54,600 tons/ year = 11.2 to 14.0 million gallons/ year solvents ! Total reusables: Wipes: 477.3 million lbs/ year wipes= 0.239 million tons/ year wipes Solvents: 145.1 to 181.4 million lbs/ year = 72,000 to 91,000 tons/ year = 18.6 to 23.3 million gallons/ year solvents ( c) *** Source: Disposable wipes solvents estimated as proportionate to US national marketshare of 12% disposables: to: 88% reusables. ( d) **** Source: Possible 25% to 40% solvent evaporation loses reported from non covered containers with solvents in the automobile service industry, by the Alabama Dept of Environmental Management Pollution Prevention Unit, and by the Virginia Office of Small Business Assistance ( http:// www. deq. state. va. us/ osba/ factsheets/ autoserv. html); this evaporation loss range is applied in this table as a generic ( average) for all solvent wipes applications.

! Economic Feasibility of Solvent Recycling There are many economic factors   both macro and micro   which determine the economic feasibility of spent solvent recycling for any individual facility. Because many chemicals used as solvents are derived from petroleum, their prices fluctuate according to the price of crude oil. Consequently, the potential value ( economic feasibility) of recycling spent solvents, as opposed to buying virgin solvents and disposing of spent solvents by blending for use as fuel, also fluctuates with the price of oil ( http:// www. envirobiz. com/ news/ 011901_ 11. htm). High crude oil prices might increase spent solvent generators' incentives to recover solvents, rather than blend them for use as fuels. Micro economic factors include transportation access to offsite recycling facilities or via mobile recycling unit, recycled solvent quality, and minimum purity specifications ( higher quality specifications require higher processing costs), addition of acid inhibitors or metal stabilizers, batch size of recycling operations ( increasing batch size lowers unit costs for recycling), still bottom disposal, and resale value of the recycled solvent. 9 The map below displays the location of 51 commercial spent solvent hazardous waste recycling facilities identified in the " 2003 Directory of US Commercial Recycling Facilities" ( Hazardous Waste Consultant, Vol. 21, Nr. 3, Aspen Publishers Inc.). Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

48 Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

49 ! Solvent Extraction ( Centrifugation)

The following tables and graphs ( below and next three pages) present ( a) wipes centrifuge capital and O& M cost data, ( b) wipes centrifuge and solvent recycling net costs ( reflecting hypothetical cost offset for reuse value of recycled solvents), and ( c) break even curve to illustrate the solvent reuse values required to achieve cost break even, based on a sample of five wipes centrifuge machine sizes ( i. e. five alternative annual wipes processing capacities).

Wipes Centrifuge & Recovered Solvent Management Costs For Processing Solvent Contaminated Industrial Wipes Facility Size*

Centrifuge Wipes Capacity: 1999 Reference Cost Data:* 2001$ Cost Update:****

Facility size classes % Centrifuge capital cost ( initial year) Annualized*** equivalent cap. cost ($/ year) Centrifuge O& M cost ($/ year) Total annualized cost ($/ year) Total annualized cost ($/ year) Implied Average Cost/ Wipe:

Reusables ($/ wipe) Disposables ($/ wipe) Base capacity ( lbs/ year) Reusables ( wipes/ year)** Disposables ( wipes/ year)**

1 20% 8,800 70,400 162,800 $ 37,076 $ 4,250 $ 9,435 $ 13,685 $ 13,839 $ 0.1966 $ 0.0850 2 50% 130,000 1,040,000 2,405,000 $ 40,034 $ 4,589 $ 25,721 $ 30,310 $ 30,652 $ 0.0295 $ 0.0127 3 84% 650,000 5,200,000 12,025,000 $ 73,517 $ 8,427 $ 49,032 $ 57,459 $ 58,107 $ 0.0112 $ 0.0048 4 95% 1,794,000 14,352,000 33,189,000 $ 154,130 $ 17,666 $ 128,477 $ 146,143 $ 147,793 $ 0.0103 $ 0.0045 5 99% 3,500,000 28,000,000 64,750,000 $ 297,043 $ 34,047 $ 249,216 $ 283,263 $ 286,460 $ 0.0102 $ 0.0044 Explanatory Notes: ( a) * 1999 cost data source: Eastern Research Group, Inc., 04 April 2000 memorandum to USEPA EAD ( George Denning), " Revised Draft Documentation for Operating and Installing a Centrifuge at Industrial Laundries", 3 pages + 17 calculation sheets. Facility size categories ( i. e. centrifuge annual processing capacity categories) established based on USEPA Office of Water sample of 145 industrial wipes laundries. ( b) The above cost estimates exclude/ include the following costs associated with RCRA Subtitle C hazardous waste solvent management requirements:   Exclude costs associated with RCRA Subtitle C permitting, which is not required for solvent extraction processes in OSW's proposed solvent wipes rule.  Include costs for solvent storage tanks, tank secondary containment, & RCRA hazardous waste manifest transport of solvent to offsite reclaimers ( e. g. recyclers).  Include RCRA administrative costs to generating facility ($ 1,800 per facility). ( c) ** Nr. annual wipes estimated by multiplying annual pounds, times average lbs per solvent contaminated wipe: Reusable wipes Disposable wipes   Average weight of wet solvent contaminated industrial wipe ( lbs/ wipe) = 0.1250 0.0541 100%   Average weight of dry industrial wipe ( lbs/ wipe) = 0.0750 0.0324 60%   Average weight of solvent contained in a contaminated industrial wipe ( lbs/ wipe) = 0.0500 0.0216 40% ( d) *** Cost annualization factors: Discount rate = 7.0% Centrifuge equipment lifespan = 12.5 years ( e) **** Cost update multiplier ( http:// www. che. com): 1999 Chem. Eng. Plant Cost Index ( reference cost data source) = 389.9 2001 Chem. Eng. Plant Cost Index = 394.3 Cost update multiplier ( 2001/ 1999) = 1.011 Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

50 Net Cost for Wipes Centrifuging & Solvent Recycling For Processing Solvent Contaminated Industrial Wipes Reference facility size categories Facility size percentile Annual Quantity Wipes Solvent Recovered Solvent Recovery Costs: Net Cost ( 2001$):

Solvent reuse value needed for break even A Annualized centrifuge cost ($/ year) B Solvent recycling cost ($/ year) C ( A+ B) Centrifuge + recycling cost ($/ gallon) D Reuse value** recycled solvent ($/ year) E ( C+ D) Net cost ($/ year) Average Net Cost Per Wipe:

Average net cost per gallon Reusables ($/ wipe) Disposables ($/ wipe) ( lbs/ year)* ( gals/ year)*

1 20% 2,746 352 $ 13,839 $ 893 $ 41.85 ($ 1,153) $ 13,579 $ 0.1929 $ 0.0834 $ 38.58 $ 41.85 2 50% 40,560 5,200 $ 30,652 $ 13,191 $ 8.43 ($ 17,035) $ 26,807 $ 0.0258 $ 0.0111 $ 5.16 $ 8.43 3 84% 202,800 26,000 $ 58,107 $ 65,953 $ 4.77 ($ 85,176) $ 38,884 $ 0.0075 $ 0.0032 $ 1.50 $ 4.77 4 95% 559,728 71,760 $ 147,793 $ 182,031 $ 4.60 ($ 235,086) $ 94,738 $ 0.0066 $ 0.0029 $ 1.32 $ 4.60 5 99% 1,092,000 140,000 $ 286,460 $ 355,133 $ 4.58 ($ 458,640) $ 182,953 $ 0.0065 $ 0.0028 $ 1.31 $ 4.58 Explanatory Notes: ( a) * Quantity solvent recovered independent of wipes type under full capacity loading, given assumption that both types contain average 40% solvent by weight. Solvent recovered estimated by multiplying annual wipes processed, by recovery efficiency, and by average lbs solvent per contaminated wipe: Average weight of wet solvent contaminated reusable industrial wipe ( lbs/ wipe) = 0.1250 100% Average weight of dry reusable industrial wipe ( lbs/ wipe) = 0.0750 60% Average weight of solvent contained in a contaminated reusable industrial wipe ( lbs/ wipe) = 0.0500 40% Average weight of wet solvent contaminated disposable industrial wipe ( lbs/ wipe) = 0.0541 100% Average weight of dry disposable industrial wipe ( lbs/ wipe) = 0.0324 60% Average weight of solvent contained in a contaminated disposable industrial wipe ( lbs/ wipe) = 0.0216 40% ( b) ** Other assumptions: Centrifuge solvent recovery efficiency ( ERG Memorandum to OSW, 04 April 2000, sheet 13 of 17) = 78% Average cost based on data sample of onsite and offsite hazardous waste solvent recycling services ($/ gal) = $ 2.54 Average reuse value of recycled solvent based on median price for sample of 43 solvents ranging in price from $ 0.75 to $ 6.19/ gallon ($/ gal) = $ 3.28 Assumed average specific gravity ( density) of solvents applied to reusable industrial wipes ( pounds per gallon of solvent) = 7.8 Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

51 8,800 130,000 650,000 1,794,000 3,500,000 Annual Pounds of Solvent Contaminated Industrial Wipes Processed Per Facility ( Five Centrifuge Size/ Capacity Classes) $ 0.0000 $ 0.0100 $ 0.0200 $ 0.0300 $ 0.0400 $ 0.0500 $ 0.0600 $ 0.0700 $ 0.0800 $ 0.0900 $ 0.1000 $ 0.1100 $ 0.1200 $ 0.1300 $ 0.1400 $ 0.1500 $ 0.1600 $ 0.1700 $ 0.1800 $ 0.1900 $ 0.2000 $ 0.2100 Net Cost Per Wipe for Centrifuge & Solvent Recycling Reusable wipes Disposable wipes Note: $ 3.28/ gallon reuse value based on median price for a sample of 43 solvents ranging in price from $ 0.75 to $ 6.19/ gallon. Average Net Cost Per Wipe for Centrifuge & Solvent Recovery ( Including Average $ 3.28/ Gallon Cost Offset Credit for Hypothetical Reuse Value of Recycled Solvent) Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

52 8,800 130,000 650,000 1,794,000 3,500,000 Annual Pounds of Solvent Contaminated Industrial Wipes Processed Per Facility ( Five Centrifuge Size/ Capacity Classes) $ 0 $ 2 $ 4 $ 6 $ 8 $ 10 $ 12 $ 14 $ 16 $ 18 $ 20 $ 22 $ 24 $ 26 $ 28 $ 30 $ 32 $ 34 $ 36 $ 38 $ 40 $ 42 $ 44 $ Per Gallon Recovered Wipes Solvent Breakeven curve Net cost curve Note: Net cost curve based on average of $ 3.28/ gallon reuse value assigned to recovered solvent, to offset average cost of wipes solvent centrifuging & recycling. Solvent Processing ( Centrifuge & Recycling) Breakeven Curve & Net Cost Curve Breakeven = Market Reuse Value ($/ Gallon) of Recycled Solvent Needed to Cover Centrifuge & Recycling Costs The graph below illustrates the hypothetical solvent reuse values required to achieve cost break even for each of the five centrifuge size classes, relative to an average cost of $ 2.54/ gallon for onsite and offsite solvent recycling, in addition to the costs for wipes centrifuging shown in the prior tables and graphs. The break even curve displayed below suggests that onsite wipes centrifugation may only be beneficial ( cost effective) for the largest 16% of solvent wipes generating facilities and industrial laundry ( i. e. generating or handling > 650,000 pounds solvent contaminated wipes per year), or for intra company consolidation of centrifuge capacity for processing solvent wipes generated by multiple facilities, or for facilities which require premium priced solvents ( i. e. >$ 5.00/ gallon in price) which capture relatively high reuse value from recycled premium priced solvents. Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

53 II. J. Analytic Baseline ! State Policy Baseline:

Since 1991, the Federal RCRA policy has been to defer the regulatory disposition of solvent industrial wipes to EPA regional offices and to state regulatory agencies. This policy resulted in many states conditionally excluding reusable wipes from hazardous waste regulations. Consequently, the anticipated impact of the proposed exclusions will not be incremental relative to full RCRA regulatory compliance, but incremental to current state exclusions. This is the analytic baseline applied in this study.

! Full RCRA Subtitle C Baseline:

This alternative baseline is defined as hypothetical full compliance with Federal RCRA Subtitle C hazardous waste generation and treatment regulations, without either a Federal or state level exclusion. This baseline includes hypothetical compliance with the RCRA hazardous waste " derived from" rule ( 40 CFR 261.3( c)( 2)( i)) which would hypothetically affect industrial laundry sludges, as well as the industrial wipes. Hypothetically, industrial laundry sludges could be regulated as RCRA hazardous wastes because of RCRA's " derived from" rule. If the Federal RCRA Subtitle C hazardous waste standards governed current operations at industrial wipes laundries, the proposed exclusion would represent a relatively larger annual regulatory cost savings to industrial laundries, incremental to this hypothetical alternative RCRA Subtitle C compliance baseline. To estimate this hypothetical cost savings, it is assumed that the annual costs associated with hypothetical full compliance with the RCRA Subtitle C regulations for hazardous waste generators ( 40 CFR 262), would be incurred by the 590 to 1,175 estimated range of industrial laundries which manage reusable industrial wipes contaminated with RCRA listed solvents ( see attached spreadsheets).

! Incomplete Compliance Baseline:

Assume partial non compliance with existing state exclusions, such that the incremental implementation costs of the proposed exclusions would be greater, and the potential cost savings less, relative to the assumed full compliance baseline with the current state exclusions. Because USEPA does not have comprehensive information about the rate of non compliance of industrial wipes users and handlers relative to this alternative third baseline, it is not presented in this report. Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

54 ! Disposable Wipes Baseline Non Compliance:

In itself, the Federal regulatory relief provided to disposables wipes users in form of cost savings for avoided RCRA Subtitle C disposal, largely drives the resultant difference in relative prices, and the consequent induced impact on industrial wipes marketshare between disposables and reusables. The findings summarized above are based on the baseline assumption that 100% of spent disposable solvent wipes generators currently manage their waste under RCRA Subtitle C requirements ( baseline). However, baseline non compliance will reduce the annual dollar value of the regulatory relief, thereby diminishing the difference in resultant relative prices, and consequent induced marketshare impact. Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

55 III. Description of US Industrial Wipes Market & Potentially Affected Establishments III. A. Overview of " Industrial Wipes" in the US Economy " Industrial wipes" come in a wide variety of types and brands to meet a broad range of applications. The major division is between reusable wipes, which are laundered or dry cleaned and used again, and disposable wipes which are used for a single or limited number of applications, and then discarded. Disposable wipes include both non woven and woven wipes, which are used by numerous industries in conjunction with solvents, to clean surfaces, parts, accessories, products, machines, and physical plant & equipment.

Definitions of " Industrial Wipes" Applied in This Study Category Definitions of Wipes Disposable industrial wipes Industrial wipes: Non woven towel consisting of wood pulp*, polyester blends or 100 percent polypropylene. These materials come in all sizes and thicknesses. They generally are designed for one time use and are used to wipe small quantities of solvents off hands, tools, equipment, or floors.

Industrial rags: Non homogeneous material consisting of cotton or polyester fabric blends. Rags are made from old ( waste) clothing, sheets, towels, or from cloth remnants from textile mills, and vary in size, color and type of fabric. Rags are typically used by facilities such as gas stations to apply and/ or remove small quantities of solvents, grease, and oil from auto parts over the course of a day. After use, most rags are disposed of as part of a facility's regular, nonhazardous solid waste.

Paper towels: Sometimes used in conjunction with solvents in the workplace. These materials are made from wood pulp* with binders. Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

Category Definitions of Wipes 56 Reusable industrial wipes Industrial shop towels: Woven textile consisting of cotton ( e. g. flannel, corduroy, terry, chenille, denim, sheeting, muslin, scrim) or polyester blends. These materials are a finite reusable item that are primarily water wash laundered or solvent dry cleaned a number of times ( usually 10 to 15), before they outlive their usefulness and must be recycled or discarded. Shop towels are rented by industrial launderers to manufacturing, automotive, chemical, and other similar facilities for use in heavy duty cleaning and wiping. Soiled shop towels are either washed or dry cleaned at commercial laundry facilities.

Explanatory Notes: ( a) * For the purpose of encouraging paper and paper product recycling in the US, Subtitle F ( Section 6002) of the 1976 RCRA requires Federal agencies to buy paper products ( and other items) composed of the highest percentage of recovered materials practicable. ! In 1988 USEPA established the first " buy recycled" guidelines for paper and paper products containing recovered materials. ! In 1998 USEPA updated these guidelines, which currently recommend 40% to 100% recovered fiber content for industrial wipes, which should include at least 40% post consumer fiber content ( i. e. paper recovered from homes and offices); USEPA OSWER, " 1998 Buy Recycled Series: Paper Products", EPA 530 F 98 012, July 1998, 8 pp., http:// www. epa. gov/ epaoswer/ non hw/ procure/ pdf/ paper. pdf. ! In 2000 EPA identified 40 paper mill companies in the US and Canada which produce paper products from recovered paper, some of which manufacture industrial wipes: USEPA OSWER, EPA 530 B 99 012, Jan 2000, pp., http:// www. epa. gov/ cpg/ products/ tissue. htm. ( b) It is important to note that " institutional wipes"   another category of wipes which are used mainly by janitorial services, hospitals, schools, restaurants, hotels, and other service related establishments   may also be affected by the proposed exclusions, but are not within the scope of this economic study as an itemized separate category of wipes, because the lack of explicit data on the extent to which institutional wipes are used in conjunction with RCRA listed solvents suggests that there may be relatively small solvent wipes quantities involved, compared to the industrial categories covered in this study.

Industrial wipes are distinguished by their respective price, material composition ( fabric type), color, size, durability, usage suitability characteristics, and disposal methods. The type of industrial wipe   paper or cloth wipe, shop towel, or rag   suitable for each application depends on a number of factors, some of which are summarized in the table below. Industrial wipes may be flat packed or folded for delivery in 10, 25 or 50 pound boxes, or in 100, 150 or 1,000 pound bales, and dispensed to users in bulk cartons, pop up box dispensers, or roll dispensers. Economic Analysis for Solvent Industrial Wipes USEPA Office of Solid Waste ( 17 July 2003)

10 " Solvent" = Usually a liquid used to dissolve, disperse, extract or mix one or more other substances or materials ( other liquids or solids). Substances dissolved by solvents are usually called " solutes". " Solvation" is the physical and chemical process by which one or more substances dissolve into a solvent. The resultant " solution" ( i. e. mixture of solvent and solutes) may be " concentrated" ( i. e. a large proportional quantity of solutes are dissolved in the solvent) or " dilute" ( i. e. small proportion of solutes relative to quantity of solvent). Solvents have many different applications, are used in many different industrial processes, appear in many different household products, and consist of many different chemical ( molecular) types. Water, which is one of the most abundant chemicals in nature, serves as a good solvent for many types of substances. During the last century, the largest manufactured chemical class of solvents used globally for industrial applications has been chlorinated aliphatic hydrocarbon chemicals, although other classes of chemicals may serve as solvents: cyclic hydrocarbons, aromatic hydrocarbons, ketones, amines, esters, ethers, glycols, alcohols, aldehydes, and carboxylic acids. By 1981 there were approximately 350 different solvents commonly in use in the USA ( source: OSHA website), but there are over 30,000 industrial solvents ( Corn, 1993, p. 506). Depending upon the physical and chemical characteristics of solvents compared to solutes, some substances may be completely miscible ( soluble), partially miscible, or totally immiscible ( not soluble) in a particular solvent. The solution process nearly always occurs with either an absorption or release of energy ( heat); the quantity of energy that is absorbed ( endothermic) or released ( exothermic) when a substance is dissolved by a solvent is called the " heat of solution". For human health and safety information about solvents see the US Occupational Safety & Health Administration ( OSHA) websites: http:// www. osha slc. gov/ SLTC/ solvents/ and http:// www. osha. gov/ oshinfo/ priorities/ solvents. html , and the reference book: Handbook of Hazardous Materials, Morton Corn ( ed.), Academic Press Inc., 1993 (" Industrial Solvents" pp. 387 398; " Organic Solvents Health Effects" pp. 505 519).

57 Physical Factors Affecting User Selection of Industrial Wipes Products Wipes Lint The amount of lint residue   the loose, small particles of fuzz, fine ravelings and short fibers of fabrics and fabric like materials   allowed in a particular industrial worktask or other wipes application, plays a large role in the selection of an appropriate industrial wipe, since some electronic equipment manufacturing or printing applications, for example, cannot tolerate any lint, while other industrial applications can tolerate large amounts of lint.

Wipes Absorbency Wipes absorbency capacity   as measured by the relative quantity of solvent or other substances wipes are able to take up   and wipes absorbency rate ( the amount of time it takes a wipe to absorb a particular quantity of solvent or other substance), also are two important factors in some industrial worktasks and wipes applications, while not in others.