Percent
   Average Truck Load Size for Wastes Shipped to Metals Recovery Facilities
                            Pre-2008 DSW Final Rule
                                 (tons/load)*
                               Accumulation Time
                            Pre-2008 DSW Final Rule
                               Accumulation Time
                           Post-2008 DSW Final Rule
                 Number of Shipments Post-2008 DSW Final Rule
                         (full truck load of 18 tons)
                            Average Truck Load Size
                            Pre-2008 DSW Final Rule
                                  (tons/load)
Small LQG - small shipment (<13.2 tons/year)
                                      31
                                     35.6%
                                       1
                                    90 days
                                   360 days
                                       1
                                       4
Small LQG - large shipment (13.2 to <60 tons/year)
                                      36
                                     41.4%
                                       3
                                    90 days
                                   360 days
                                       1
                                      12
Large LQG shipment (60 tons/year or greater)
                                      20
                                     23.0%
                                       9
                                    90 days
                                   360 days
                                       2
                                      18
Weighted-Average
Truck Load Size

                                      3.7

                                     10.5
*  Generator Type Categories and data from Exhibit D12 of 2008 DSW RIA

SUMMARY OF ESTIMATED INDUSTRY COSTS TO MEET OPTIONS 1 TO 7 (Excluding Option 8)

   * 13% "base case" adoption scenario (see Exhibits 5N, 5O, and 5P below at 7%, 3%, and 0% discount rates, respectively):
         o The potential cost to industry to meet the seven primary sets of options to the three 2008 DSW final rule exclusions and the pre-2008 exclusions are estimated to be between:
               # $7.2 million per year (only Options 3 to 7)
               # $13.1 million per year (all Options 1 to 7)
         o These incremental compliance costs reduce the total estimated baseline cost savings from $86.7 million per year to between $73.6 million per year and $79.5 million per year at a 7% discount rate.
         o The estimates vary depending whether EPA finalizes Options 1 and 2.  The inclusion of Options 1 and 2 with the additions of Options 3, through 7 completely negate the $7.4 million per year in baseline cost savings of the 2008 DSW final rule with $8.6 million per year in compliance costs (Exhibit 5N, Column C).
               # Option 1 withdraws the transfer-based exclusion and its associated $5.7 million per year in cost savings under the 2008 DSW final rule.
               # Option 2, the corollary to Option 1, adds back in $2.6 million per year in one-year accumulation time transportation cost savings and $2.7 million per year in compliance costs for a net of $0.1 million per year in post rule costs to meet the requirements of the alternative RCRA Subtitle C regulation of offsite transfers for reclamation.
         o Only including Options 3 through 7 maintains some of the baseline cost savings of the 2008 DSW final rule.  The $7.4 million per year in baseline cost savings of the 2008 DSW final rule are reduced to $4.8 million per year (Exhibit 5N, Column D).
         o The application of Options 4, 5, and 7 to the pre-2008 exclusions add $4.5 million per year in compliance costs reducing baseline cost savings from $79.3 million per year to $74.8 million per year (Exhibit 5N, Column E).

   * 74% "upper-bound" adoption scenario (see Exhibits 5Q, 5R, and 5S below at 7%, 3%, and 0% discount rates, respectively):
         o The potential cost to industry to meet the seven primary sets of options to the three 2008 DSW final rule exclusions and the pre-2008 exclusions are estimated to be between:
               # $7.4 million per year (only Options 3 to 7)
               # $47.5 million per year (all Options 1 to 7)
         o These incremental compliance costs reduce the total estimated baseline cost savings from $131.7 million per year to between $84.1 million per year and $124.3 million per year at a 7% discount rate.
         o The estimates vary depending whether EPA finalizes Options 1 and 2.  The inclusion of Options 1 and 2 with the additions of Options 3, through 7 adds $41.4 million in compliance costs per year and reduces the $52.4 million per year in baseline cost savings of the 2008 DSW final rule to $11.0 million per year (Exhibit 5Q, Column C).
               # Option 1 withdraws the transfer-based exclusion and its associated $47.4 million per year in cost savings under the 2008 DSW final rule.
               # Option 2, the corollary to Option 1, adds back in $22.0 million per year in one-year accumulation time transportation cost savings and $13.3 million per year in compliance costs for a net of $8.7 million per year in post rule cost savings to meet the requirements of the alternative RCRA Subtitle C regulation of offsite transfers for reclamation.
         o Only including Options 3 through 7 maintains most of the baseline cost savings of the 2008 DSW final rule.  The $52.4 million per year in baseline cost savings of the 2008 DSW final rule are reduced to $51.1 million per year (Exhibit 5R, Column D).
         o The application of Options 4, 5, and 7 to the pre-2008 exclusions add $6.1 million per year in compliance costs reducing baseline cost savings from $79.3 million per year to $73.2 million per year (Exhibit 5S, Column E).

                                  Exhibit 5N
Summary of Estimated Baseline Cost Savings, Compliance Costs, and Post-Rule Cost Savings for
Industry to Implement the Seven 2011 Proposed Revisions to the DSW Recycling Exclusions (Options 1 thru 7)
 (13% Adoption Rate and 7% Discount Rate) (2011 dollars)
                                       A
                                       B
                                       C
                                       D
                                       E
                                     Item
                               Revision Options
    Revisions to 2008 DSW Final Rule Exclusions If Options 1 and 2 Selected
  Revisions to 2008 DSW Final Rule Exclusions If Options 1 and 2 NOT Selected
                       Revisions to Pre-2008 Exclusions

                                                        Baseline Cost Savings =
                                                                    $7,424,696
                                                                    $7,424,696
                                                                   $79,287,690
                                       1
Option 1 Withdraw the 2008 DSW Offsite Transfer-Based Exclusion
                                                                   ($5,671,409)

                                       2
Option 2: Implement Alternative RCRA Subtitle C Regulation for 2008 DSW Excluded Hazardous Recyclable Materials that Are Transferred Offsite for Reclamation

                                      2A
Requirement 2A Transportation Cost Savings from Extension of Accumulation Time to One Year
                                                                    $2,633,407

                                      2B
Requirement 2B  Notification Compliance Costs
                                                                         ($413)

                                      2C
Requirement 2C  Advance Arrangements Compliance Costs
                                                                      ($48,041)

                                      2D
Requirement 2D  Accumulation Restrictions Compliance Costs
                                                                   ($1,164,838)

                                     2E.1
Requirement 2E.1  Speculative Accumulation Labeling
                                                                            $0

                                     2E.2
Requirement 2E.2  Contingency Plan Compliance Costs
                                                                      ($28,338)

                                     2F.1
Requirement 2F.1  Recordkeeping of Offsite Shipments Compliance Costs
                                                                     ($192,648)

                                     2F.2
Requirement 2F.2  Transport to RCRA Permit Facility Compliance Costs
                                                                   ($1,298,353)

                                          Subtotal Option 2 Compliance Costs =
                                                                      ($99,224)

                                       3
Option 3 Revisions to Generator-controlled Exclusions

                                      3A
Option 3A  Definition of "Contained" Compliance Costs
                                                                            $0
                                                                            $0

                                      3B
Option 3B Notification (Requirement vs. Condition) Compliance Costs
                                                                            $0
                                                                            $0

                                      3C
Option 3C  Speculative Accumulation Labeling Compliance Costs
                                                                            $0
                                                                            $0

                                      3D
Option 3D  Recordkeeping Requirement for Reclamation Under Toll Manufacturing Agreements Compliance Costs
                                                                            $0
                                                                            $0

                                      3E
Option 3E  Eliminate the 2008 DSW "Toll Manufacturing" Recycling Exclusion
                                                                     ($180,753)
                                                                            $0

                                      3F
Option 3F  Re-structure the location of the non-land based and land-based unit operational requirements in 40 CFR 261 Compliance Costs
                                                                          ($39)
                                                                          ($39)

                                           Subtotal Option 3 Compliance Costs =
                                                                     ($180,792)
                                                                          ($39)

                                       4
Option 4 Revisions to Legitimacy Recycling Provisions

                                     4A/4B
Options 4A & 4B  Legitimacy Petition Compliance Costs
                                                                     ($399,473)
                                                                     ($399,473)
                                                                     ($430,903)
                                     4A/4C
Options 4A & 4C  Legitimacy Documentation Compliance Costs
                                                                   ($2,434,660)
                                                                   ($2,243,621)
                                                                   ($2,626,212)

                                           Subtotal Option 4 Compliance Costs =
                                                                   ($2,834,133)
                                                                   ($2,643,095)
                                                                   ($3,057,114)
                                       5
Option 5 Revisions to 1985 Variance and 2008 DSW Non-Waste Determination Petition Process

                                      5A
Option 5A Partial Variance and Non-waste determination re-applications
                                                                      ($28,015)
                                                                      ($28,015)
                                                                      ($15,945)
                                      5B
Option 5B Biennial Notification Compliance Costs
                                                                          ($78)
                                                                          ($78)
                                                                         ($206)
                                      5C
Option 5C: Modify the 1985 40 CFR 260.31(c) DSW Variance for Partially Recycled Materials

                                                                            $0
                                      5D
Option 5D  Non-waste Determination Petitioner Must Demonstrate Why They Cannot or Should Not Meet Existing DSW Exclusions Compliance Costs
                                                                            $0
                                                                            $0

                                      5E
Option 5E  Change the Word "Administrator" to "Regional Administrator" in 40 CFR 260.30 to 260.34.
                                                                            $0
                                                                            $0
                                                                            $0

                                           Subtotal Option 5 Compliance Costs =
                                                                      ($28,094)
                                                                      ($28,094)
                                                                      ($16,151)
                                       6
Option 6 DSW Re-Manufacturing Exclusion

                                      6A
Element 6A  Potential Future Cost Savings for Eligible Facilities (Baseline cost savings added only if Option 1 selected, otherwise included in baseline cost savings)
                                                                      $200,909
Not applicable because Option 6 is voluntary, and facilities would not incur additional costs to switch from operating under the 2008 DSW exclusions to Option 6.

                                      6B
Element 6B  Intermediate Facility Restriction
                                                                            $0

                                      6C
Element 6C  Possible Additional Requirements (e.g.,  Recordkeeping and Reporting Requirements, Management Standards, Financial Assurance Requirements, and Public Participation Requirements)
                  Included in Option 6A Baseline Cost Savings

                                     6D.1
Element 6D.1  Potential Future Cost Savings for Petition Facilities (Baseline cost savings added only if Option 1 selected, otherwise included in baseline cost savings)
                                                                        $5,409

                                     6D.2
Element 6D.2  Petition Process
                                                                       ($2,753)

                                     6D.3
Element 6D.3  Intermediate Facility Restriction for Petition Facilities
                                                                       ($7,571)

                                             Subtotal Option 6 Compliance Costs
                                                                      $195,994
                                                                            $0
                                                                            $0
                                       7
Option 7 Revisions to Pre-2008 Recycling Exclusions

                                      7A
Option 7A  Recordkeeping for Speculative Accumulation Compliance Costs

                                                                   ($1,051,378)
                                      7B
Option 7B  Biennial Notification Compliance Costs

                                                                      ($13,396)
                                      7C
Option 7C  Contained Standard Compliance Costs

                                                                     ($372,082)

                                           Subtotal Option 7 Compliance Costs =

                                                                   ($1,436,856)

                                                      Total Compliance Costs =
                                                                   ($8,617,658)
                                                                   ($2,671,227)
                                                                   ($4,510,121)

                                                       Post Rule Cost Savings =
                                                                   ($1,192,962)
                                                                    $4,753,469
                                                                   $74,777,569

             Total Compliance Costs if Options 1 and 2 Selected (Columns C+E) =
                                 ($13,127,779)

       Total Post Rule Cost Savings if Options 1 and 2 Selected (Columns C+E) =
                                 $73,584,607

     Total Compliance Costs if Options 1 and 2 are NOT Selected (Columns D+E) =
                                 ($7,181,348)

Total Post Rule Cost Savings if Options 1 and 2 are NOT Selected (Columns D+E) =
                                 $79,531,038

                                  Exhibit 5O
Summary of Estimated Baseline Cost Savings, Compliance Costs, and Post-Rule Cost Savings for
Industry to Implement the Seven 2011 Proposed Revisions to the DSW Recycling Exclusions (Options 1 thru 7)
 (13% Adoption Rate and 3% Discount Rate) (2011 dollars)
                                       A
                                       B
                                       C
                                       D
                                       E
                                     Item
                               Revision Options
    Revisions to 2008 DSW Final Rule Exclusions If Options 1 and 2 Selected
  Revisions to 2008 DSW Final Rule Exclusions If Options 1 and 2 NOT Selected
                       Revisions to Pre-2008 Exclusions

                                                        Baseline Cost Savings =
                                                                   $10,772,866
                                                                   $10,772,866
                                                                   $92,350,961
                                       1
Option 1 Withdraw the 2008 DSW Offsite Transfer-Based Exclusion
                                                                   ($8,645,145)

                                       2
Option 2: Implement Alternative RCRA Subtitle C Regulation for 2008 DSW Excluded Hazardous Recyclable Materials that Are Transferred Offsite for Reclamation

                                      2A
Requirement 2A Transportation Cost Savings from Extension of Accumulation Time to One Year
                                                                    $4,014,202

                                      2B
Requirement 2B  Notification Compliance Costs
                                                                         ($629)

                                      2C
Requirement 2C  Advance Arrangements Compliance Costs
                                                                      ($73,230)

                                      2D
Requirement 2D  Accumulation Restrictions Compliance Costs
                                                                   ($1,775,608)

                                     2E.1
Requirement 2E.1  Speculative Accumulation Labeling
                                                                            $0

                                     2E.2
Requirement 2E.2  Contingency Plan Compliance Costs
                                                                      ($43,196)

                                     2F.1
Requirement 2F.1  Recordkeeping of Offsite Shipments Compliance Costs
                                                                     ($293,661)

                                     2F.2
Requirement 2F.2  Transport to RCRA Permit Facility Compliance Costs
                                                                   ($1,512,266)

                                          Subtotal Option 2 Compliance Costs =
                                                                      $315,611

                                       3
Option 3 Revisions to Generator-controlled Exclusions

                                      3A
Option 3A  Definition of "Contained" Compliance Costs
                                                                            $0
                                                                            $0

                                      3B
Option 3B Notification (Requirement vs. Condition) Compliance Costs
                                                                            $0
                                                                            $0

                                      3C
Option 3C  Speculative Accumulation Labeling Compliance Costs
                                                                            $0
                                                                            $0

                                      3D
Option 3D  Recordkeeping Requirement for Reclamation Under Toll Manufacturing Agreements Compliance Costs
                                                                            $0
                                                                            $0

                                      3E
Option 3E  Eliminate the 2008 DSW "Toll Manufacturing" Recycling Exclusion
                                                                     ($275,529)
                                                                            $0

                                      3F
Option 3F  Re-structure the location of the non-land based and land-based unit operational requirements in 40 CFR 261 Compliance Costs
                                                                          ($59)
                                                                          ($59)

                                           Subtotal Option 3 Compliance Costs =
                                                                     ($275,588)
                                                                          ($59)

                                       4
Option 4 Revisions to Legitimacy Recycling Provisions

                                     4A/4B
Options 4A & 4B  Legitimacy Petition Compliance Costs
                                                                     ($465,290)
                                                                     ($465,290)
                                                                     ($501,897)
                                     4A/4C
Options 4A & 4C  Legitimacy Documentation Compliance Costs
                                                                   ($2,835,790)
                                                                   ($2,544,582)
                                                                   ($3,058,901)

                                           Subtotal Option 4 Compliance Costs =
                                                                   ($3,301,079)
                                                                   ($3,009,872)
                                                                   ($3,560,798)
                                       5
Option 5 Revisions to 1985 Variance and 2008 DSW Non-Waste Determination Petition Process

                                      5A
Option 5A Partial Variance and Non-waste determination re-applications
                                                                      ($32,247)
                                                                      ($32,247)
                                                                      ($18,569)
                                      5B
Option 5B Biennial Notification Compliance Costs
                                                                          ($90)
                                                                          ($90)
                                                                         ($319)
                                      5C
Option 5C: Modify the 1985 40 CFR 260.31(c) DSW Variance for Partially Recycled Materials

                                                                            $0
                                      5D
Option 5D  Non-waste Determination Petitioner Must Demonstrate Why They Cannot or Should Not Meet Existing DSW Exclusions Compliance Costs
                                                                            $0
                                                                            $0

                                      5E
Option 5E  Change the Word "Administrator" to "Regional Administrator" in 40 CFR 260.30 to 260.34.
                                                                            $0
                                                                            $0

                                           Subtotal Option 5 Compliance Costs =
                                                                      ($32,337)
                                                                      ($32,337)
                                                                      ($18,888)
                                       6
Option 6 DSW Re-Manufacturing Exclusion

                                      6A
Element 6A  Potential Future Cost Savings for Eligible Facilities (Baseline cost savings added only if Option 1 selected, otherwise included in baseline cost savings)
                                                                      $306,254
Not applicable because Option 6 is voluntary, and facilities would not incur additional costs to switch from operating under the 2008 DSW exclusions to Option 6.

                                      6B
Element 6B  Intermediate Facility Restriction
                                                                            $0

                                      6C
Element 6C  Possible Additional Requirements (e.g.,  Recordkeeping and Reporting Requirements, Management Standards, Financial Assurance Requirements, and Public Participation Requirements)
                  Included in Option 6A Baseline Cost Savings

                                     6D.1
Element 6D.1  Potential Future Cost Savings for Petition Facilities (Baseline cost savings added only if Option 1 selected, otherwise included in baseline cost savings)
                                                                        $8,245

                                     6D.2
Element 6D.2  Petition Process
                                                                       ($4,197)

                                     6D.3
Element 6D.3  Intermediate Facility Restriction for Petition Facilities
                                                                      ($11,541)

                                             Subtotal Option 6 Compliance Costs
                                                                      $298,761
                                                                            $0
                                                                            $0
                                       7
Option 7 Revisions to Pre-2008 Recycling Exclusions

                                      7A
Option 7A  Recordkeeping for Speculative Accumulation Compliance Costs

                                                                   ($1,224,601)
                                      7B
Option 7B  Biennial Notification Compliance Costs

                                                                      ($15,603)
                                      7C
Option 7C  Contained Standard Compliance Costs

                                                                     ($433,386)

                                           Subtotal Option 7 Compliance Costs =

                                                                   ($1,673,589)

                                                      Total Compliance Costs =
                                                                  ($11,639,777)
                                                                   ($3,042,267)
                                                                   ($5,253,275)

                                                       Post Rule Cost Savings =
                                                                     ($866,911)
                                                                    $7,730,598
                                                                   $87,097,686

             Total Compliance Costs if Options 1 and 2 Selected (Columns C+E) =
                                 ($16,893,052)

       Total Post Rule Cost Savings if Options 1 and 2 Selected (Columns C+E) =
                                 $86,230,774

     Total Compliance Costs if Options 1 and 2 are NOT Selected (Columns D+E) =
                                 ($8,295,543)

Total Post Rule Cost Savings if Options 1 and 2 are NOT Selected (Columns D+E) =
                                 $94,828,284

                                  Exhibit 5P
Summary of Estimated Baseline Cost Savings, Compliance Costs, and Post-Rule Cost Savings for
Industry to Implement the Seven 2011 Proposed Revisions to the DSW Recycling Exclusions (Options 1 thru 7)
 (13% Adoption Rate and 0% Discount Rate) (2011 dollars)
                                       A
                                       B
                                       C
                                       D
                                       E
                                     Item
                               Revision Options
    Revisions to 2008 DSW Final Rule Exclusions If Options 1 and 2 Selected
  Revisions to 2008 DSW Final Rule Exclusions If Options 1 and 2 NOT Selected
                       Revisions to Pre-2008 Exclusions

                                                        Baseline Cost Savings =
                                                                   $15,054,046
                                                                   $15,054,046
                                                                  $103,929,772
                                       1
Option 1 Withdraw the 2008 DSW Offsite Transfer-Based Exclusion
                                                                  ($11,991,206)

                                       2
Option 2: Implement Alternative RCRA Subtitle C Regulation for 2008 DSW Excluded Hazardous Recyclable Materials that Are Transferred Offsite for Reclamation

                                      2A
Requirement 2A Transportation Cost Savings from Extension of Accumulation Time to One Year
                                                                    $5,567,880

                                      2B
Requirement 2B  Notification Compliance Costs
                                                                            $0

                                      2C
Requirement 2C  Advance Arrangements Compliance Costs
                                                                     ($101,574)

                                      2D
Requirement 2D  Accumulation Restrictions Compliance Costs
                                                                   ($2,462,848)

                                     2E.1
Requirement 2E.1  Speculative Accumulation Labeling
                                                                            $0

                                     2E.2
Requirement 2E.2  Contingency Plan Compliance Costs
                                                                      ($59,915)

                                     2F.1
Requirement 2F.1  Recordkeeping of Offsite Shipments Compliance Costs
                                                                     ($407,322)

                                     2F.2
Requirement 2F.2  Transport to RCRA Permit Facility Compliance Costs
                                                                   ($1,701,872)

                                          Subtotal Option 2 Compliance Costs =
                                                                      $834,349

                                       3
Option 3 Revisions to Generator-controlled Exclusions

                                      3A
Option 3A  Definition of "Contained" Compliance Costs
                                                                            $0
                                                                            $0

                                      3B
Option 3B Notification (Requirement vs. Condition) Compliance Costs
                                                                            $0
                                                                            $0

                                      3C
Option 3C  Speculative Accumulation Labeling Compliance Costs
                                                                            $0
                                                                            $0

                                      3D
Option 3D  Recordkeeping Requirement for Reclamation Under Toll Manufacturing Agreements Compliance Costs
                                                                            $0
                                                                            $0

                                      3E
Option 3E  Eliminate the 2008 DSW "Toll Manufacturing" Recycling Exclusion
                                                                     ($382,154)
                                                                            $0

                                      3F
Option 3F  Re-structure the location of the non-land based and land-based unit operational requirements in 40 CFR 261 Compliance Costs
                                                                          ($82)
                                                                          ($82)

                                           Subtotal Option 3 Compliance Costs =
                                                                     ($382,236)
                                                                          ($82)

                                       4
Option 4 Revisions to Legitimacy Recycling Provisions

                                     4A/4B
Options 4A & 4B  Legitimacy Petition Compliance Costs
                                                                     ($523,627)
                                                                     ($523,627)
                                                                     ($564,824)
                                     4A/4C
Options 4A & 4C  Legitimacy Documentation Compliance Costs
                                                                   ($3,191,336)
                                                                   ($2,787,418)
                                                                   ($3,442,421)

                                           Subtotal Option 4 Compliance Costs =
                                                                   ($3,714,963)
                                                                   ($3,311,045)
                                                                   ($4,007,245)
                                       5
Option 5 Revisions to 1985 Variance and 2008 DSW Non-Waste Determination Petition Process

                                      5A
Option 5A Partial Variance and Non-waste determination re-applications
                                                                      ($35,420)
                                                                      ($35,420)
                                                                      ($20,900)
                                      5B
Option 5B Biennial Notification Compliance Costs
                                                                          ($99)
                                                                          ($99)
                                                                         ($445)
                                      5C
Option 5C: Modify the 1985 40 CFR 260.31(c) DSW Variance for Partially Recycled Materials

                                                                            $0
                                      5D
Option 5D  Non-waste Determination Petitioner Must Demonstrate Why They Cannot or Should Not Meet Existing DSW Exclusions Compliance Costs
                                                                            $0
                                                                            $0

                                      5E
Option 5E  Change the Word "Administrator" to "Regional Administrator" in 40 CFR 260.30 to 260.34.
                                                                            $0
                                                                            $0

                                           Subtotal Option 5 Compliance Costs =
                                                                      ($35,519)
                                                                      ($35,519)
                                                                      ($21,345)
                                       6
Option 6 DSW Re-Manufacturing Exclusion

                                      6A
Element 6A  Potential Future Cost Savings for Eligible Facilities (Baseline cost savings added only if Option 1 selected, otherwise included in baseline cost savings)
                                                                      $424,788
Not applicable because Option 6 is voluntary, and facilities would not incur additional costs to switch from operating under the 2008 DSW exclusions to Option 6.

                                      6B
Element 6B  Intermediate Facility Restriction
                                                                            $0

                                      6C
Element 6C  Possible Additional Requirements (e.g.,  Recordkeeping and Reporting Requirements, Management Standards, Financial Assurance Requirements, and Public Participation Requirements)
                  Included in Option 6A Baseline Cost Savings

                                     6D.1
Element 6D.1  Potential Future Cost Savings for Petition Facilities (Baseline cost savings added only if Option 1 selected, otherwise included in baseline cost savings)
                                                                       $11,437

                                     6D.2
Element 6D.2  Petition Process
                                                                       ($5,821)

                                     6D.3
Element 6D.3  Intermediate Facility Restriction for Petition Facilities
                                                                      ($16,008)

                                             Subtotal Option 6 Compliance Costs
                                                                      $414,395
                                                                            $0
                                                                            $0
                                       7
Option 7 Revisions to Pre-2008 Recycling Exclusions

                                      7A
Option 7A  Recordkeeping for Speculative Accumulation Compliance Costs

                                                                   ($1,378,139)
                                      7B
Option 7B  Biennial Notification Compliance Costs

                                                                      ($17,559)
                                      7C
Option 7C  Contained Standard Compliance Costs

                                                                     ($487,723)

                                           Subtotal Option 7 Compliance Costs =

                                                                   ($1,883,421)

                                                      Total Compliance Costs =
                                                                  ($14,875,179)
                                                                   ($3,346,645)
                                                                   ($5,912,012)

                                                       Post Rule Cost Savings =
                                                                      $178,867
                                                                   $11,707,401
                                                                   $98,017,760

             Total Compliance Costs if Options 1 and 2 Selected (Columns C+E) =
                                 ($20,787,191)

       Total Post Rule Cost Savings if Options 1 and 2 Selected (Columns C+E) =
                                 $98,196,627

     Total Compliance Costs if Options 1 and 2 are NOT Selected (Columns D+E) =
                                 ($9,258,657)

Total Post Rule Cost Savings if Options 1 and 2 are NOT Selected (Columns D+E) =
                                 $109,725,161

                                  Exhibit 5Q
Summary of Estimated Baseline Cost Savings, Compliance Costs, and Post-Rule Cost Savings for
Industry to Implement the Seven 2011 Proposed Revisions to the DSW Recycling Exclusions (Options 1 thru 7)
 (74% Adoption Rate and 7% Discount Rate) (2011 dollars)
                                       A
                                       B
                                       C
                                       D
                                       E
                                     Item
                               Revision Options
    Revisions to 2008 DSW Final Rule Exclusions If Options 1 and 2 Selected
  Revisions to 2008 DSW Final Rule Exclusions If Options 1 and 2 NOT Selected
                       Revisions to Pre-2008 Exclusions

                                                        Baseline Cost Savings =
                                                                   $52,378,431
                                                                   $52,378,431
                                                                   $79,287,690
                                       1
Option 1 Withdraw the 2008 DSW Offsite Transfer-Based Exclusion
                                                                  ($47,374,266)

                                       2
Option 2: Implement Alternative RCRA Subtitle C Regulation for 2008 DSW Excluded Hazardous Recyclable Materials that Are Transferred Offsite for Reclamation

                                      2A
Requirement 2A Transportation Cost Savings from Extension of Accumulation Time to One Year
                                                                   $21,997,305

                                      2B
Requirement 2B  Notification Compliance Costs
                                                                       ($3,446)

                                      2C
Requirement 2C  Advance Arrangements Compliance Costs
                                                                     ($401,292)

                                      2D
Requirement 2D  Accumulation Restrictions Compliance Costs
                                                                   ($9,730,099)

                                     2E.1
Requirement 2E.1  Speculative Accumulation Labeling
                                                                            $0

                                     2E.2
Requirement 2E.2  Contingency Plan Compliance Costs
                                                                     ($236,711)

                                     2F.1
Requirement 2F.1  Recordkeeping of Offsite Shipments Compliance Costs
                                                                   ($1,609,226)

                                     2F.2
Requirement 2F.2  Transport to RCRA Permit Facility Compliance Costs
                                                                   ($1,298,353)

                                          Subtotal Option 2 Compliance Costs =
                                                                    $8,718,178

                                       3
Option 3 Revisions to Generator-controlled Exclusions

                                      3A
Option 3A  Definition of "Contained" Compliance Costs
                                                                            $0
                                                                            $0

                                      3B
Option 3B Notification (Requirement vs. Condition) Compliance Costs
                                                                            $0
                                                                            $0

                                      3C
Option 3C  Speculative Accumulation Labeling Compliance Costs
                                                                            $0
                                                                            $0

                                      3D
Option 3D  Recordkeeping Requirement for Reclamation Under Toll Manufacturing Agreements Compliance Costs
                                                                            $0
                                                                            $0

                                      3E
Option 3E  Eliminate the 2008 DSW "Toll Manufacturing" Recycling Exclusion
                                                                ($1,505,797.06)
                                                                            $0

                                      3F
Option 3F  Re-structure the location of the non-land based and land-based unit operational requirements in 40 CFR 261 Compliance Costs
                                                                          ($39)
                                                                          ($39)

                                           Subtotal Option 3 Compliance Costs =
                                                                   ($1,505,836)
                                                                          ($39)

                                       4
Option 4 Revisions to Legitimacy Recycling Provisions

                                     4A/4B
Options 4A & 4B  Legitimacy Petition Compliance Costs
                                                                     ($399,473)
                                                                     ($399,473)
                                                                     ($430,903)
                                     4A/4C
Options 4A & 4C  Legitimacy Documentation Compliance Costs
                                                                   ($2,434,660)
                                                                     ($838,881)
                                                                   ($2,626,212)

                                           Subtotal Option 4 Compliance Costs =
                                                                   ($2,834,133)
                                                                   ($1,238,354)
                                                                   ($3,057,114)
                                       5
Option 5 Revisions to 1985 Variance and 2008 DSW Non-Waste Determination Petition Process

                                      5A
Option 5A Partial Variance and Non-waste determination re-applications
                                                                      ($28,015)
                                                                      ($28,015)
                                                                      ($15,945)
                                      5B
Option 5B Biennial Notification Compliance Costs
                                                                          ($78)
                                                                          ($78)
                                                                         ($206)
                                      5C
Option 5C: Modify the 1985 40 CFR 260.31(c) DSW Variance for Partially Recycled Materials

                                                                   ($1,645,177)
                                      5D
Option 5D  Non-waste Determination Petitioner Must Demonstrate Why They Cannot or Should Not Meet Existing DSW Exclusions Compliance Costs
                                                                            $0
                                                                            $0

                                      5E
Option 5E  Change the Word "Administrator" to "Regional Administrator" in 40 CFR 260.30 to 260.34.
                                                                            $0
                                                                            $0
                                                                            $0

                                           Subtotal Option 5 Compliance Costs =
                                                                      ($28,094)
                                                                      ($28,094)
                                                                   ($1,661,328)
                                       6
Option 6 DSW Re-Manufacturing Exclusion

                                      6A
Element 6A  Potential Future Cost Savings for Eligible Facilities (Baseline cost savings added only if Option 1 selected, otherwise included in baseline cost savings)
                                                                    $1,678,230
Not applicable because Option 6 is voluntary, and facilities would not incur additional costs to switch from operating under the 2008 DSW exclusions to Option 6.

                                      6B
Element 6B  Intermediate Facility Restriction
                                                                            $0

                                      6C
Element 6C  Possible Additional Requirements (e.g.,  Recordkeeping and Reporting Requirements, Management Standards, Financial Assurance Requirements, and Public Participation Requirements)
                  Included in Option 6A Baseline Cost Savings

                                     6D.1
Element 6D.1  Potential Future Cost Savings for Petition Facilities (Baseline cost savings added only if Option 1 selected, otherwise included in baseline cost savings)
                                                                       $45,183

                                     6D.2
Element 6D.2  Petition Process
                                                                      ($22,999)

                                     6D.3
Element 6D.3  Intermediate Facility Restriction for Petition Facilities
                                                                      ($63,244)

                                             Subtotal Option 6 Compliance Costs
                                                                    $1,637,170
                                                                            $0
                                                                            $0
                                       7
Option 7 Revisions to Pre-2008 Recycling Exclusions

                                      7A
Option 7A  Recordkeeping for Speculative Accumulation Compliance Costs

                                                                   ($1,051,378)
                                      7B
Option 7B  Biennial Notification Compliance Costs

                                                                      ($13,396)
                                      7C
Option 7C  Contained Standard Compliance Costs

                                                                     ($372,082)

                                           Subtotal Option 7 Compliance Costs =

                                                                   ($1,436,856)

                                                      Total Compliance Costs =
                                                                  ($41,386,980)
                                                                   ($1,266,486)
                                                                   ($6,155,298)

                                                       Post Rule Cost Savings =
                                                                   $10,991,451
                                                                   $51,111,945
                                                                   $73,132,392

             Total Compliance Costs if Options 1 and 2 Selected (Columns C+E) =
                                 ($47,542,278)

       Total Post Rule Cost Savings if Options 1 and 2 Selected (Columns C+E) =
                                 $84,123,843

     Total Compliance Costs if Options 1 and 2 are NOT Selected (Columns D+E) =
                                 ($7,421,785)

Total Post Rule Cost Savings if Options 1 and 2 are NOT Selected (Columns D+E) =
                                 $124,244,337

                                  Exhibit 5R
Summary of Estimated Baseline Cost Savings, Compliance Costs, and Post-Rule Cost Savings for
Industry to Implement the Seven 2011 Proposed Revisions to the DSW Recycling Exclusions (Options 1 thru 7)
 (74% Adoption Rate and 3% Discount Rate) (2011 dollars)
                                       A
                                       B
                                       C
                                       D
                                       E
                                     Item
                               Revision Options
    Revisions to 2008 DSW Final Rule Exclusions If Options 1 and 2 Selected
  Revisions to 2008 DSW Final Rule Exclusions If Options 1 and 2 NOT Selected
                       Revisions to Pre-2008 Exclusions

                                                        Baseline Cost Savings =
                                                                   $63,581,974
                                                                   $63,581,974
                                                                   $92,350,961
                                       1
Option 1 Withdraw the 2008 DSW Offsite Transfer-Based Exclusion
                                                                  ($57,635,306)

                                       2
Option 2: Implement Alternative RCRA Subtitle C Regulation for 2008 DSW Excluded Hazardous Recyclable Materials that Are Transferred Offsite for Reclamation

                                      2A
Requirement 2A Transportation Cost Savings from Extension of Accumulation Time to One Year
                                                                   $26,761,816

                                      2B
Requirement 2B  Notification Compliance Costs
                                                                       ($4,192)

                                      2C
Requirement 2C  Advance Arrangements Compliance Costs
                                                                     ($488,210)

                                      2D
Requirement 2D  Accumulation Restrictions Compliance Costs
                                                                  ($11,837,592)

                                     2E.1
Requirement 2E.1  Speculative Accumulation Labeling
                                                                            $0

                                     2E.2
Requirement 2E.2  Contingency Plan Compliance Costs
                                                                     ($287,981)

                                     2F.1
Requirement 2F.1  Recordkeeping of Offsite Shipments Compliance Costs
                                                                   ($1,957,777)

                                     2F.2
Requirement 2F.2  Transport to RCRA Permit Facility Compliance Costs
                                                                   ($1,512,773)

                                          Subtotal Option 2 Compliance Costs =
                                                                   $10,673,290

                                       3
Option 3 Revisions to Generator-controlled Exclusions

                                      3A
Option 3A  Definition of "Contained" Compliance Costs
                                                                            $0
                                                                            $0

                                      3B
Option 3B Notification (Requirement vs. Condition) Compliance Costs
                                                                            $0
                                                                            $0

                                      3C
Option 3C  Speculative Accumulation Labeling Compliance Costs
                                                                            $0
                                                                            $0

                                      3D
Option 3D  Recordkeeping Requirement for Reclamation Under Toll Manufacturing Agreements Compliance Costs
                                                                            $0
                                                                            $0

                                      3E
Option 3E  Eliminate the 2008 DSW "Toll Manufacturing" Recycling Exclusion
                                                                   ($1,831,946)
                                                                            $0

                                      3F
Option 3F  Re-structure the location of the non-land based and land-based unit operational requirements in 40 CFR 261 Compliance Costs
                                                                          ($59)
                                                                          ($59)

                                           Subtotal Option 3 Compliance Costs =
                                                                   ($1,832,004)
                                                                          ($59)

                                       4
Option 4 Revisions to Legitimacy Recycling Provisions

                                     4A/4B
Options 4A & 4B  Legitimacy Petition Compliance Costs
                                                                     ($465,290)
                                                                     ($465,290)
                                                                     ($501,897)
                                     4A/4C
Options 4A & 4C  Legitimacy Documentation Compliance Costs
                                                                   ($2,835,790)
                                                                     ($894,372)
                                                                   ($3,058,901)

                                           Subtotal Option 4 Compliance Costs =
                                                                   ($3,301,079)
                                                                   ($1,359,662)
                                                                   ($3,560,798)
                                       5
Option 5 Revisions to 1985 Variance and 2008 DSW Non-Waste Determination Petition Process

                                      5A
Option 5A Partial Variance and Non-waste determination re-applications
                                                                      ($32,247)
                                                                      ($32,247)
                                                                      ($18,569)
                                      5B
Option 5B Biennial Notification Compliance Costs
                                                                          ($90)
                                                                          ($90)
                                                                         ($319)
                                      5C
Option 5C: Modify the 1985 40 CFR 260.31(c) DSW Variance for Partially Recycled Materials

                                                                   ($2,769,855)
                                      5D
Option 5D  Non-waste Determination Petitioner Must Demonstrate Why They Cannot or Should Not Meet Existing DSW Exclusions Compliance Costs
                                                                            $0
                                                                            $0

                                      5E
Option 5E  Change the Word "Administrator" to "Regional Administrator" in 40 CFR 260.30 to 260.34.
                                                                            $0
                                                                            $0
                                                                            $0

                                           Subtotal Option 5 Compliance Costs =
                                                                      ($32,337)
                                                                      ($32,337)
                                                                   ($2,788,743)
                                       6
Option 6 DSW Re-Manufacturing Exclusion

                                      6A
Element 6A  Potential Future Cost Savings for Eligible Facilities (Baseline cost savings added only if Option 1 selected, otherwise included in baseline cost savings)
                                                                    $2,041,726
Not applicable because Option 6 is voluntary, and facilities would not incur additional costs to switch from operating under the 2008 DSW exclusions to Option 6.

                                      6B
Element 6B  Intermediate Facility Restriction
                                                                            $0

                                      6C
Element 6C  Possible Additional Requirements (e.g.,  Recordkeeping and Reporting Requirements, Management Standards, Financial Assurance Requirements, and Public Participation Requirements)
                  Included in Option 6A Baseline Cost Savings

                                     6D.1
Element 6D.1  Potential Future Cost Savings for Petition Facilities (Baseline cost savings added only if Option 1 selected, otherwise included in baseline cost savings)
                                                                       $54,970

                                     6D.2
Element 6D.2  Petition Process
                                                                      ($27,980)

                                     6D.3
Element 6D.3  Intermediate Facility Restriction for Petition Facilities
                                                                      ($76,942)

                                             Subtotal Option 6 Compliance Costs
                                                                    $1,991,773
                                                                            $0
                                                                            $0
                                       7
Option 7 Revisions to Pre-2008 Recycling Exclusions

                                      7A
Option 7A  Recordkeeping for Speculative Accumulation Compliance Costs

                                                                   ($1,224,601)
                                      7B
Option 7B  Biennial Notification Compliance Costs

                                                                      ($15,603)
                                      7C
Option 7C  Contained Standard Compliance Costs

                                                                     ($433,386)

                                           Subtotal Option 7 Compliance Costs =

                                                                   ($1,673,589)

                                                      Total Compliance Costs =
                                                                  ($50,135,663)
                                                                   ($1,392,058)
                                                                   ($8,023,130)

                                                       Post Rule Cost Savings =
                                                                   $13,446,312
                                                                   $62,189,916
                                                                   $84,327,831

             Total Compliance Costs if Options 1 and 2 Selected (Columns C+E) =
                                 ($58,158,793)

       Total Post Rule Cost Savings if Options 1 and 2 Selected (Columns C+E) =
                                 $97,774,142

     Total Compliance Costs if Options 1 and 2 are NOT Selected (Columns D+E) =
                                 ($9,415,188)

Total Post Rule Cost Savings if Options 1 and 2 are NOT Selected (Columns D+E) =
                                 $146,517,747

                                  Exhibit 5S
Summary of Estimated Baseline Cost Savings, Compliance Costs, and Post-Rule Cost Savings for
Industry to Implement the Seven 2011 Proposed Revisions to the DSW Recycling Exclusions (Options 1 thru 7)
 (74% Adoption Rate and 0% Discount Rate) (2011 dollars)
                                       A
                                       B
                                       C
                                       D
                                       E
                                     Item
                               Revision Options
    Revisions to 2008 DSW Final Rule Exclusions If Options 1 and 2 Selected
  Revisions to 2008 DSW Final Rule Exclusions If Options 1 and 2 NOT Selected
                       Revisions to Pre-2008 Exclusions

                                                        Baseline Cost Savings =
                                                                   $73,867,654
                                                                   $73,867,654
                                                                  $103,929,772
                                       1
Option 1 Withdraw the 2008 DSW Offsite Transfer-Based Exclusion
                                                                  ($66,551,644)

                                       2
Option 2: Implement Alternative RCRA Subtitle C Regulation for 2008 DSW Excluded Hazardous Recyclable Materials that Are Transferred Offsite for Reclamation

                                      2A
Requirement 2A Transportation Cost Savings from Extension of Accumulation Time to One Year
                                                                   $30,901,942

                                      2B
Requirement 2B  Notification Compliance Costs
                                                                            $0

                                      2C
Requirement 2C  Advance Arrangements Compliance Costs
                                                                     ($563,738)

                                      2D
Requirement 2D  Accumulation Restrictions Compliance Costs
                                                                  ($13,668,899)

                                     2E.1
Requirement 2E.1  Speculative Accumulation Labeling
                                                                            $0

                                     2E.2
Requirement 2E.2  Contingency Plan Compliance Costs
                                                                     ($332,533)

                                     2F.1
Requirement 2F.1  Recordkeeping of Offsite Shipments Compliance Costs
                                                                   ($2,260,651)

                                     2F.2
Requirement 2F.2  Transport to RCRA Permit Facility Compliance Costs
                                                                   ($1,701,872)

                                          Subtotal Option 2 Compliance Costs =
                                                                   $12,374,250

                                       3
Option 3 Revisions to Generator-controlled Exclusions

                                      3A
Option 3A  Definition of "Contained" Compliance Costs
                                                                            $0
                                                                            $0

                                      3B
Option 3B Notification (Requirement vs. Condition) Compliance Costs
                                                                            $0
                                                                            $0

                                      3C
Option 3C  Speculative Accumulation Labeling Compliance Costs
                                                                            $0
                                                                            $0

                                      3D
Option 3D  Recordkeeping Requirement for Reclamation Under Toll Manufacturing Agreements Compliance Costs
                                                                            $0
                                                                            $0

                                      3E
Option 3E  Eliminate the 2008 DSW "Toll Manufacturing" Recycling Exclusion
                                                                   ($2,115,253)
                                                                            $0

                                      3F
Option 3F  Re-structure the location of the non-land based and land-based unit operational requirements in 40 CFR 261 Compliance Costs
                                                                          ($82)
                                                                          ($82)

                                           Subtotal Option 3 Compliance Costs =
                                                                   ($2,115,335)
                                                                          ($82)

                                       4
Option 4 Revisions to Legitimacy Recycling Provisions

                                     4A/4B
Options 4A & 4B  Legitimacy Petition Compliance Costs
                                                                     ($523,627)
                                                                     ($523,627)
                                                                     ($564,824)
                                     4A/4C
Options 4A & 4C  Legitimacy Documentation Compliance Costs
                                                                   ($3,191,336)
                                                                     ($949,576)
                                                                   ($3,442,421)

                                           Subtotal Option 4 Compliance Costs =
                                                                   ($3,714,963)
                                                                   ($1,473,203)
                                                                   ($4,007,245)
                                       5
Option 5 Revisions to 1985 Variance and 2008 DSW Non-Waste Determination Petition Process

                                      5A
Option 5A Partial Variance and Non-waste determination re-applications
                                                                      ($35,420)
                                                                      ($35,420)
                                                                      ($20,900)
                                      5B
Option 5B Biennial Notification Compliance Costs
                                                                          ($99)
                                                                          ($99)
                                                                         ($445)
                                      5C
Option 5C: Modify the 1985 40 CFR 260.31(c) DSW Variance for Partially Recycled Materials

                                                                   ($4,064,738)
                                      5D
Option 5D  Non-waste Determination Petitioner Must Demonstrate Why They Cannot or Should Not Meet Existing DSW Exclusions Compliance Costs
                                                                            $0
                                                                            $0

                                      5E
Option 5E  Change the Word "Administrator" to "Regional Administrator" in 40 CFR 260.30 to 260.34.
                                                                            $0
                                                                            $0

                                           Subtotal Option 5 Compliance Costs =
                                                                      ($35,519)
                                                                      ($35,519)
                                                                   ($4,086,083)
                                       6
Option 6 DSW Re-Manufacturing Exclusion

                                      6A
Element 6A  Potential Future Cost Savings for Eligible Facilities (Baseline cost savings added only if Option 1 selected, otherwise included in baseline cost savings)
                                                                    $2,357,587
Not applicable because Option 6 is voluntary, and facilities would not incur additional costs to switch from operating under the 2008 DSW exclusions to Option 6.

                                      6B
Element 6B  Intermediate Facility Restriction
                                                                            $0

                                      6C
Element 6C  Possible Additional Requirements (e.g.,  Recordkeeping and Reporting Requirements, Management Standards, Financial Assurance Requirements, and Public Participation Requirements)
                  Included in Option 6A Baseline Cost Savings

                                     6D.1
Element 6D.1  Potential Future Cost Savings for Petition Facilities (Baseline cost savings added only if Option 1 selected, otherwise included in baseline cost savings)
                                                                       $63,473

                                     6D.2
Element 6D.2  Petition Process
                                                                      ($32,309)

                                     6D.3
Element 6D.3  Intermediate Facility Restriction for Petition Facilities
                                                                      ($88,845)

                                             Subtotal Option 6 Compliance Costs
                                                                    $2,299,906
                                                                            $0
                                                                            $0
                                       7
Option 7 Revisions to Pre-2008 Recycling Exclusions

                                      7A
Option 7A  Recordkeeping for Speculative Accumulation Compliance Costs

                                                                   ($1,378,139)
                                      7B
Option 7B  Biennial Notification Compliance Costs

                                                                      ($17,559)
                                      7C
Option 7C  Contained Standard Compliance Costs

                                                                     ($487,723)

                                           Subtotal Option 7 Compliance Costs =

                                                                   ($1,883,421)

                                                      Total Compliance Costs =
                                                                  ($57,743,304)
                                                                   ($1,508,803)
                                                                   ($9,976,750)

                                                       Post Rule Cost Savings =
                                                                   $16,124,350
                                                                   $72,358,851
                                                                   $93,953,022

             Total Compliance Costs if Options 1 and 2 Selected (Columns C+E) =
                                 ($67,720,054)

       Total Post Rule Cost Savings if Options 1 and 2 Selected (Columns C+E) =
                                 $110,077,372

     Total Compliance Costs if Options 1 and 2 are NOT Selected (Columns D+E) =
                                 ($11,485,553)

Total Post Rule Cost Savings if Options 1 and 2 are NOT Selected (Columns D+E) =
                                 $166,311,873

                                   Chapter 6
                             Sensitivity Analyses
                    (6 Cost Estimation Uncertainty Factors)

This chapter derives six sensitivity analysis factors which are applied in the Executive Summary of this RIA to the average annualized total cost estimate.  The purpose of these factors is to illustrate the relative degree by which the industry impact estimates of this RIA --- which are in large part founded on affected industrial facility counts from the 2007 RCRA Biennial Report data year --- may fluctuate in any given future year.  These cost estimation uncertainty factors are not necessarily additive; for example, sensitivity analysis factor #3 is a sub-component of sensitivity analysis factor #2.  A potential 7th cost estimation uncertainty factor is future fluctuations in market prices of recovered commodities from recycled materials.  However, the 7th factor is not applied in this RIA because it influences the micro-economic decisions by facilities to switch from disposal to recycling of their hazardous secondary materials, which is only a relatively small fraction of the total industry implementation cost savings estimate for the 2008 DSW recycling exclusions and the 2011 proposed revisions..

Note: To avoid duplication of text and numerical Exhibits in this RIA, refer to Exhibit C of the "Executive Summary" at the front of this RIA to view how each of these six sensitivity factors potentially affects the total industry cost estimate for the 2011 proposed revisions to the DSW recycling exclusions.

Sensitivity Analysis #1:	State Government Adoption Uncertainty

Perhaps the largest uncertainty factor in this RIA is the future count and annual rate of state government adoption of the finalized DSW revisions.  The future state government adoption rate will affect the discounted present value of both future costs and future benefits associated with the final revisions, as well as the ultimate count of industrial facilities and annual waste volumes (tonnages) that are affected.  To illustrate this uncertainty, Exhibit 6A below displays this RIA's "base case" adoption scenario for the 50-year period of analysis (i.e., 2015 to 2064), and the alternative "upper-bound" adoption scenario.  The alternative rate is based on the premise that a lower adoption rate occurred after the October 2008 DSW final rule because of the limitations in its implementation conditions (as identified in the Chapter 1 "Problem Statement" of this RIA), and the 2011 DSW proposed rule is designed to remedy these conditions.  Therefore, a higher future adoption rate could occur after the 2011 proposed rule is finalized in 2013.

To illustrate an upper-bound adoption potential, Exhibit 6A below displays an upper-bound facility adoption rate associated with the counts of entities in the 44 states identified as potential adopters in Exhibit 6A of EPA's September 2008 RIA for the October 2008 DSW final rule.  The upper-bound estimate assumes all facilities in 44 states will adopt the 2008 DSW rule (as revised) within a four-year period beginning in 2015, at a rate of 25% of the 3,655 facilities located in these 44 states per year.  This factor results in a cost multiplier equal to 432%.
                                  Exhibit 6A
                            Sensitivity Analysis #1
Alternative Implementation Scenarios "Base Case" & "Upper-Bound" for Future Adoption of 2008 DSW Exclusions
                              Period of Analysis
                                     Year
                     13% "Base Case" Adoption Scenario
                    Count of Industrial Facilities Adopting
                    74% "Upper-Bound" Adoption Scenario
                    Count of Industrial Facilities Adopting

                                 Annual Count
                               Cumulative Count
                                 Annual Count
                               Cumulative Count
                                      -4
                                     2011
                                      21
                                      63
                                      21
                                      63
                                      -3
                                     2012
                                      21
                                      84
                                      21
                                      84
                                      -2
                                     2013
                                      21
                                      105
    (2011 DSW proposed revisions assumed finalized in the Federal Register)
                                      21
                                      105
                                      -1
                                     2014
                                      21
                                      126
                                      21
                                      126
                                       1
                                     2015
                                      21
                                      147
(state government adoption of the 2013 finalized DSW revisions assumed to begin*)
                                      914
       (25% x 3,655 facilities located in estimated 44 adopting states)
                                     1,040
                                       2
                                     2016
                                      21
                                      168
                                      914
       (25% x 3,655 facilities located in estimated 44 adopting states)
                                     1,954
                                       3
                                     2017
                                      21
                                      189
                                      914
       (25% x 3,655 facilities located in estimated 44 adopting states)
                                     2,867
                                       4
                                     2018
                                      21
                                      210
                                      914
       (25% x 3,655 facilities located in estimated 44 adopting states)
                                     3,781
                                       5
                                     2019
                                      21
                                      231
                                       0
                                     3,781
                                       6
                                     2020
                                      21
                                      252
                                       0
                                     3,781
                                       7
                                     2021
                                      21
                                      273
                                       0
                                     3,781
                                       8
                                     2022
                                      21
                                      294
                                       0
                                     3,781
                                       9
                                     2023
                                      21
                                      315
                                       0
                                     3,781
                                      10
                                     2024
                                      21
                                      336
                                       0
                                     3,781
                                      11
                                     2025
                                      21
                                      357
                                       0
                                     3,781
                                      12
                                     2026
                                      21
                                      378
                                       0
                                     3,781
                                      13
                                     2027
                                      21
                                      399
                                       0
                                     3,781
                                      14
                                     2028
                                      21
                                      420
                                       0
                                     3,781
                                      15
                                     2029
                                      21
                                      441
                                       0
                                     3,781
                                      16
                                     2030
                                      21
                                      462
                                       0
                                     3,781
                                      17
                                     2031
                                      21
                                      483
                                       0
                                     3,781
                                      18
                                     2032
                                      21
                                      504
                                       0
                                     3,781
                                      19
                                     2033
                                      21
                                      525
                                       0
                                     3,781
                                      20
                                     2034
                                      21
                                      546
                                       0
                                     3,781
                                      21
                                     2035
                                      21
                                      567
                                       0
                                     3,781
                                      22
                                     2036
                                      21
                                      588
                                       0
                                     3,781
                                      23
                                     2037
                                      21
                                      609
                                       0
                                     3,781
                                      24
                                     2038
                                      21
                                      630
                                       0
                                     3,781
                                      25
                                     2039
                                      21
                                      651
                                       0
                                     3,781
                                      26
                                     2040
                                      21
                                      672
                                       0
                                     3,781
                                      27
                                     2041
                                      21
                                      693
                                       0
                                     3,781
                                      28
                                     2042
                                      21
                                      714
                                       0
                                     3,781
                                      29
                                     2043
                                      21
                                      735
                                       0
                                     3,781
                                      30
                                     2044
                                      21
                                      756
                                       0
                                     3,781
                                      31
                                     2045
                                      21
                                      777
                                       0
                                     3,781
                                      32
                                     2046
                                      21
                                      798
                                       0
                                     3,781
                                      33
                                     2047
                                      21
                                      819
                                       0
                                     3,781
                                      34
                                     2048
                                      21
                                      840
                                       0
                                     3,781
                                      35
                                     2049
                                      21
                                      861
                                       0
                                     3,781
                                      36
                                     2050
                                      21
                                      882
                                       0
                                     3,781
                                      37
                                     2051
                                      21
                                      903
                                       0
                                     3,781
                                      38
                                     2052
                                      21
                                      924
                                       0
                                     3,781
                                      39
                                     2053
                                      21
                                      945
                                       0
                                     3,781
                                      40
                                     2054
                                      21
                                      966
                                       0
                                     3,781
                                      41
                                     2055
                                      21
                                      987
                                       0
                                     3,781
                                      42
                                     2056
                                      21
                                     1008
                                       0
                                     3,781
                                      44
                                     2057
                                      21
                                     1,029
                                       0
                                     3,781
                                      43
                                     2058
                                      21
                                     1,050
                                       0
                                     3,781
                                      45
                                     2059
                                      21
                                     1,071
                                       0
                                     3,781
                                      46
                                     2060
                                      21
                                     1,092
                                       0
                                     3,781
                                      47
                                     2061
                                      21
                                     1,113
                                       0
                                     3,781
                                      48
                                     2062
                                      21
                                     1,134
                                       0
                                     3,781
                                      49
                                     2063
                                      21
                                     1,155
                                       0
                                     3,781
                                      50
                                     2064
                                      21
                                     1,176
                                       0
                                     3,781
                                                  Average annual 2015 to 2064 =
                                      662
                              (662 / 5,007 = 13%)
                                                  Average annual 2015 to 2064 =
                                     3,671
                             (3,671 / 5,007 = 74%)
* Note:  To establish a future period-of-analysis, this RIA assumes that state governments begin adoption of the 2013 finalized DSW revisions two years after, to account for a time lag for state governments to make legislative changes to their RCRA-authorized program hazardous waste statutes and regulations.  By=umber may not add due to rounding.

                                  Exhibit 6B
                      Sensitivity Analysis #1 (continued)
Graph of Two Alternative Implementation Scenarios for the 2008 DSW Exclusions Based on Facility Counts from Exhibit 6A

Sensitivity Analysis #2:	Future Annual Fluctuation in Affected Materials Quantities

Because this RIA is based on 2007 RCRA Biennial Report data, it is important to recognize the year-to-year variability (fluctuations) in hazardous waste generation and management tonnage as reported to the Biennial Report in prior data years (i.e., 1991, 1993, 1995, 1997, 1999, 2001, 2003, 2007; prior years are at: http://www.epa.gov/epaoswer/hazwaste/data/biennialreport/index.htm ).  This variability is an indicator of the extent to which future year tonnages may fluctuate.  In particular, year-to-year fluctuations in the tonnages of hazardous waste recycling and hazardous waste disposal affected by the DSW final rule exclusions  -  which would otherwise be RCRA-regulated in absence of this final rule  -  implies that the actual impacts of the DSW final rule will fluctuate in future years, compared to the estimates presented in this RIA based on the 2007 single-year data snapshot.

For purpose of illustrating the potential magnitude of future annual fluctuations in recycling and disposal tonnages, Exhibits 6C and 6D present 1997-2007 historical time-trend data for annual facility counts and annual hazardous waste quantities (tons/year) recycled (Exhibit 6C) and disposed (Exhibit 6D).  This retrospective is truncated at 1997 rather than extending to 1991 because the RCRA Biennial Report methodology included wastewater data until 1995.  As a result, 1995 and prior years include both wastewater and non-wastewater data (i.e., sludge, solids, gases), and are inconsistent with later years.  The data in the Exhibits below are from the RCRA Hazardous Waste Biennial Report "National Analysis" report.  Exhibits 6C and 6D provide annual percentage deviations for two time-trend metrics (i.e., annual facility counts and annual tonnages), relative to the annual average values for the 1997-2007 historical time period.  The 1997-2007 hazardous waste data trends show that:

   * Baseline hazardous waste recycling has varied (from Exhibit 6C):
      o -58% to +42% by annual recycler facility count
      o -40% to +40% by annual tonnage recycled
   * Baseline hazardous waste disposal has varied (from Exhibit 6D):
      o -22% to +32% by annual disposal facility count
      o -19% to +20% by annual tonnage disposed.

Based on the minimum and maximum annual deviation percentages over these four ranges, the national impacts of the DSW rule could range from -58% to +42% on any given future year, compared to the average annualized impact estimates presented in this RIA.  This range is not a statistical confidence interval; it represents the overall minimum and maximum range in percentage variation between 1997-2007 annual counts of industrial facilities which reported recycling RCRA hazardous wastes to the RCRA Biennial Report, compared to the average count over that 11-year time period.  The purpose of this time-trend deviation computation is to provide an aggregate indicator of how national waste quantities fluctuate year-to-year.

There are at least four reasons for annual fluctuations in the quantity of hazardous wastes reported as disposed and recycled:

   1. Within-year discrepancies between generation tonnage and management tonnage (addressed as Sensitivity Analysis #3 in this RIA).
   2. The economic level of industrial activity in any given year (addressed by Sensitivity Analysis #4 of this RIA).
   3. Data over-reporting to the Biennial Report by LQGs and TSDRFs involving reporting of non-required data for state-regulated hazardous wastes.
   4. Although not in itself quantified as a separate factor in this chapter, EPA may add or subtract industrial secondary materials to the RCRA hazardous waste regulatory program, such that in any given year, the number and types of wastes covered by the RCRA program may vary:
         a. Adding new waste streams to the program using the 40 CFR 261.11 "listing" procedure.
         b. Removing waste streams from RCRA regulation using the 40 CFR 260.22 "delisting" procedure.

Such changes may influence the types of industries, industrial facilities, and hazardous wastes that may be affected in any future year by the DSW rulemaking.  EPA publishes in the Federal Register its Regulatory Agenda twice per year.  EPA's Fall 2010 Regulatory Agenda published on December 20, 2010, lists 32 planned future actions for OSWER, of which 12 may affect (i.e., increase or decrease) future annual waste quantities managed under the RCRA hazardous waste regulatory program for certain industries and waste types.
                                  Exhibit 6C
                           Sensitivity Analysis #2:
11-Year Time-Trend (1997-2007) Data for RCRA Hazardous Waste Recycling (Onsite + Offsite)
                                   Data Item
                                     Year
                                       A
                                       B
                                       C
                                       D
                                       E
                                       F
                                   G (A+C+E)
                                   H (B+D+F)

                               Metals Recovery*
                            (M011 to M019, or H010)
                               Solvent Recovery*
                            (M021 to M029, or H020)
                               Other Recovery**
                            (M031 to M039, or H039)
                             Row Total Recovery**
                    (%s represent deviations from average)

                                  Facilities
                                 Million tons
                                  Facilities
                                 Million tons
                                  Facilities
                                 Million tons
                                 Facilities***
                                 Million tons
                                       1
                                     1997
                                      96
                                     1.078
                                      154
                                     0.617
                                      52
                                     0.443
                                  302 (-48%)
                                  2.138 (+3%)
                                       2
                                     1999
                                      88
                                     0.720
                                      111
                                     0.368
                                      46
                                     0.152
                                  245 (-58%)
                                 1.240 (-40%)
                                       3
                                     2001
                                      191
                                     1.462
                                      534
                                     0.425
                                      97
                                     1.026
                                  822 (+42%)
                                 2.913 (+40%)
                                       4
                                     2003
                                      159
                                     1.152
                                      523
                                     0.263
                                      85
                                     0.729
                                  767 (+33%)
                                  2.144 (+3%)
                                       5
                                     2005
                                      137
                                     1.420
                                      493
                                     0.297
                                      74
                                     0.328
                                  704 (+22%)
                                  2.045 (-2%)
                                       7
                                     2007
                                      137
                                     1.330
                                      456
                                     0.329
                                      65
                                     0.335
                                   624 (+8%)
                                  1.995 (-4%)
                                                              11-year average =
                                      577
                                     2.079
                                                              Deviation range =
                                 -58% to +42%
                                 -40% to +40%
Explanatory Notes:
 (1) Data source: EPA RCRA Hazardous Waste "National Analysis" Biennial Reports: http://www.epa.gov/epawaste/inforesources/data/biennialreport/index.htm
 (2) * EPA RCRA Biennial Report waste management "method codes" changed in 2001 from M-codes to H-codes.
 (3) ** "Other Recovery" in this exhibit excludes (1) energy recovery and (2) fuel blending because they are not eligible for the DSW final rule exclusions.
 (4) *** Facility row total counts overstate actual counts because row totals are duplicative of facilities operating two or more recycling methods.

                                  Exhibit 6D
                            Sensitivity Analysis #2
11-Year Time-Trend (1997-2007) Data for RCRA Hazardous Waste Disposal (Onsite + Offsite)
                                   Data Item
                                     Year
                                       A
                                       B
                                       C
                                       D
                                       E
                                       F
                                   G (A+C+E)
                                   H (B+D+F)

     Landfill or Surface Impoundment Disposal (M132 & M133, or H132)*
                             Incineration Disposal
                            (M041 to M049, or H040)
                               Other Disposal**
                          (M131, or H131, H134, H135)
                              Row Total Disposal
                      (%s represent deviations from avg)

                                  Facilities
                                 Million tons
                                  Facilities
                                 Million tons
                                 Facilities***
                                 Million tons
                                 Facilities***
                                 Million tons
                                       1
                                     1997
                                      72
                                     2.539
                                      166
                                     1.656
                                      104
                                    26.452
                                  342 (-12%)
                                 30.647 (+20%)
                                       2
                                     1999
                                      62
                                     2.115
                                      149
                                     1.454
                                      92
                                    17.473
                                  303 (-22%)
                                 21.042 (-18%)
                                       3
                                     2001
                                      69
                                     1.807
                                      174
                                     1.646
                                      268
                                    24.177
                                  511 (+32%)
                                 27.630 (+8%)
                                       4
                                     2003
                                      72
                                     1.676
                                      162
                                     1.273
                                      184
                                    17.856
                                   418 (+8%)
                                 20.805 (-19%)
                                       5
                                     2005
                                      68
                                     2.038
                                      164
                                     1.564
                                      184
                                    24.225
                                   415 (+7%)
                                 27.827 (+9%)
                                       7
                                     2007
                                      66
                                     1.939
                                      140
                                     1.031
                                      135
                                    22.694
                                  341 (-12%)
                                 25.664 (+0%)
                                                              11-year average =
                                      388
                                    25.603
                                                              Deviation range =
                                 -22% to +32%
                                 -19% to +20%
Explanatory Notes:
 (1) Data source: EPA RCRA Hazardous Waste "National Analysis" Biennial Reports: http://www.epa.gov/epawaste/inforesources/data/biennialreport/index.htm
 (2) * EPA RCRA Biennial Report waste management "method codes" changed in 2001 from M-codes to H-codes.
 (3) ** "Other Disposal" includes (1) discharge to sewer/POTW or NPDES, (2) deepwell injection, (3) land application.
 (4) *** Facility counts for "Other Disposal" overstate actual counts because totals are duplicative of facilities operating two or more disposal methods.
 Sensitivity Analysis #3:	Within-Year Discrepancy Between Generation Tons & Management Tons

This factor may be a sub-component, in part or in whole, of Sensitivity Analysis #2.  For any single data year, the total tons of hazardous wastes reported as "generated" in the RCRA Biennial Report by LQGs does not match the total tons of hazardous wastes reported as "managed" by TSDRFs.  This discrepancy may to a large degree result from the fact that typically 15% to 24% of hazardous wastes generated in recent years (1997-2007) are reported as transported (i.e., shipped) either (1) to another industrial unit with a separate EPA ID number within the same LQG facility or (2) offsite for management at a TSDRF, rather than managed onsite by the LQG.  Because the economic impacts estimated in this RIA are proportional to the annual tonnage of affected materials, this within-year discrepancy suggests that the estimated net cost savings in this RIA based on 2007 BR data, could vary between -34% to +39% for any future year.  This range is not a statistical confidence interval; it represents the overall minimum and maximum range in percentage variation between 1997-2007 generation quantities of RCRA hazardous wastes compared to the within-year management quantities reported to the Biennial Report over that 11-year period as displayed in Exhibit 6E below.

                                  Exhibit 6E
                            Sensitivity Analysis #3
11-Year Time Trend (1997-2007) in Hazardous Waste Generation & Management Tonnages
                                   Indicator
                                     1997
                                     1999
                                     2001
                                     2003
                                     2005
                                     2007
1. Million tons generated
                                     40.7
                                     40.0
                                     40.8
                                     30.2
                                     38.3
                                     46.7
2. Million tons managed
                                     37.7
                                     26.3
                                     45.4
                                     42.1
                                     43.9
                                     50.5
Percent discrepancy indicated by ratio of tons managed:to:generated ((2-1) / 1)
                                     -7.4%
                                    -34.3%
                                    +11.3%
                                    +39.4%
                                    +14.6%
                                     +7.5
Notes
Data source: EPA RCRA Hazardous Waste Biennial Reports at: http://www.epa.gov/osw/inforesources/data/biennialreport/index.htm.

   * Sensitivity Analysis #4:	RCRA SQGs in this RIA

Small quantity generators generate between 100 and 1,000 kilograms of hazardous waste per month, whereas large quantity generators (LQGs) generate more than 1,000 kilograms per month.  Because the impact estimates of this RIA are built upon the RCRA Biennial Report which contains data reported by LQGs and TSDFs but not by SQGs, the complete SQG facility universe count is not included in this RIA, only the small fraction of TSDFs which are also SQGs.  The cost estimated in this RIA is likely under-estimated by the following percentage range:

Between 1993 and 2005, there was a low estimate of 84,000 SQGs (1993) to a high estimate of 236,000 SQGs (Source: page 4 of "Work Assignment 7 Task 5 Quick Response Task 1 Memorandum: Study of Impact of Imposing Part 262 Manifest Requirements on Generators of HWIR-Exited Waste," prepared 01 Feb 1999 by Dynamac Corp for EPA Office of Solid Waste).

      Step 1:	Apply the same 26% ratio of LQGs who recovery waste/all LQGs (source: 4,321 recycling LQGs from Exhibit 3A Column A divided by 16,387 total LQGs from Exhibit 3B Column A), to these SQG counts suggest that 22,150 to 62,230 SQGs generate hazardous wastes which are managed by recovery or recycling.
      Step 2:	Subtract the 846 SQGs included in this RIA (Exhibit 4I Column D) produces a range of about 21,300 to 61,400 SQGs omitted from this RIA.
      Step 3:	Cost impacts for SQGs are estimated to be $316/facility/year [(assume half the transportation accumulation time savings in Exhibit 5N, Option 2, Item 4 at $1.32 million/year to reflect SQG accumulation time increasing from 180 days to 360 days instead of LQGs increasing from 90 to 360 days and subtract costs for requirements listed in Items 5 through 11 at $2.73 million/year)/4,455 facilities from Exhibit 5A, Column A = $316/facility/year) assuming the 13% base case adoption scenario, and a 7% discount rate.  Multiply the 21,300 to 61,400 SQGs by the $316 per-facility average annual costs to comply with the set of revisions to the 2008 DSW final rule transfer-based exclusion = $6.7 million to $19.4 million per year in additional industry compliance costs.
      Step 4:	Compare these estimates to the net impact estimate for the 2011 DSW proposed rule (Exhibit 5N, Item 49) to establish percentage range for this sensitivity analysis factor [($6.7 million to $19.4 million per year) / ($13.1 million/year)] results in +51% to +148% in additional cost impacts.

Sensitivity Analysis #5:	Physical/Chemical Quality of Secondary Materials for Viable Recovery/Recycling

The methodology applied in Chapter 5 of this RIA for identifying baseline disposal wastes for potential switchover to recycling under the DSW final rule, may be overly inclusive in the physical/chemical types and industrial sources identified.  Exhibit 6F below identifies nine categories of baseline disposed wastes that may not be suitable for recycling, and their corresponding tonnages in the 2007 Biennial Report, as an indicator of potential industry cost savings over-estimation in this RIA from possible over-estimation of the baseline disposal tonnage that may switch-over to recycling under the DSW final rule.

                                  Exhibit 6F
                            Sensitivity Analysis #5
            Criteria to Identify Baseline Disposal Hazardous Wastes
Unlikely Suitable for Potential Future Switchover to Recovery/Recycling Under the 2008 DSW Final Rule
         Types of Disposed Haz Wastes Unlikely Suitable for Recycling
                                  Criterion A
                                  Criterion B
                                  Criterion C
                                2007 Generation
                                    (tons)

                         Physical/ Chemical Form Codes
                            Industrial Source Codes
                          RCRA Hazardous Waste Codes

1. Probably better suited for energy recovery or use as fuel (e.g., oily wastes, tarry wastes, PAHs, heavy ends, petroleum refining wastes)
For wastes not reporting source code G61 include:
* W205 oil-water emulsion
* W206 waste oil
* W403 solid resins, plastics or polymerized organics
* W409 other organic solids
* W603 oily sludge
* W604 paint or ink sludges, still bottoms in sludge form
* W606 other organic sludge

For wastes with no form codes and not reporting source codes G01 through G06, G24, G26, or G61, or RCRA waste codes listed in Exhibit 3H or item 8 below include RCRA waste codes:
* F024 heavy end, tars reactor clean-out process wastes
* F032, F034 chlorophenolic & creosote wood preservative wastewaters
* F037, F038 petroleum refinery oil/water separation sludge
* K001 wood preserving bottom sediment sludges
* K018, K030, K035, K042, K048, K049, K050, K051, K052, K087, K096, K101, K107, K108, K115 heavy ends, overheads
* K141, K142, K143, K144, K147, K148 coking operation tars
* K169, K170 oil tank sediment
                                    470,042
2. Likely contains acutely toxic (dioxins/furans) or multiple mixed hazardous constituents

For wastes with no reported form codes include source code:
* G26 leachate collection
For wastes with no form codes and not reporting source codes G01 through G06, G24, G26, or G61 or RCRA waste codes listed in Exhibit 3H or item 8 below include RCRA waste codes:
* F020, F021, F022, F023 listed for dioxins/furans
* F026, F027, F028, F032 listed for dioxins/furans
* F039 land disposal leachate
* K032, K033, K034 listed for carcinogen hexachlorocyclopentadiene
* K174 listed for dioxins/furans
* P001 to P205 (i.e., all Pxxx) acutely hazardous discarded or off-spec commercial chemical products, container residues
                                    11,968
3. Explosive or reactive material
For wastes not reporting source code G61 include:
* W210 reactive or polymerizable organic liquids and adhesives
* W405 explosives or reactive organic solids

For wastes with no form codes and not reporting source codes G01 through G06, G24, G26, or G61 or RCRA waste codes listed in Exhibit 3H or item 8 below include RCRA waste codes:
* K044, K045, K046, K047 explosives mfg wastewaters, sludge, spent carbon
                                    80,690
4. Already subject to recovery/ recycling
4a. Distillation residuals (may be better suited for energy recovery)
For wastes not reporting source code G61 include:
* W200 still bottoms in liquid form
For wastes with no reported form codes include source code:
* G24 solvent or product distillation or recovery
For wastes with no form codes and not reporting source codes G01 through G06, G24, G26, or G61 or RCRA waste codes listed in Exhibit 3H or item 8 below include RCRA waste codes:
* K009, K010, K015, K016, K019, K020, K022, K023, K024, K025, K026, K027, K036, K083, K085, K093, K094, K095, K116, K136, K149 chemical mfg product distillation bottoms or solvent recovery residues
                                    63,172

4b. Acid recovery residuals

For wastes with no form codes and not reporting source codes G01 through G06, G24, G26, or G61 or RCRA waste codes listed in Exhibit 3H or item 8 below include RCRA waste codes:
* K150 hydrochloric acid recovery residuals
                                       0
5. Material unlikely to contain recoverable constituents of recycling value
For wastes not reporting source code G61 include:
* W301 contaminated soil
* W512 sediment or lagoon dragout, drilling or other muds

For wastes with no form codes and not reporting source codes G01 through G06, G24, G26, or G61 or RCRA waste codes listed in Exhibit 3H or item 8 below include RCRA waste codes:
* F028 residues from incineration of contaminated soil
* K060 ammonia still lime sludge
* K102 residue from use of activated carbon for de-colorization
                                    845,749
6. Materials not eligible for DSW final rule exclusions*
For wastes not reporting source code G61 include:
* W309 (lead-acid batteries)
* W320 electrical devices (lamps, thermostats, CRTs)

                                    276,367
7. Materials not currently widely recovered/ recycled**
* W401 used or discarded pesticide solids
* W503 gypsum sludges