(b) Notify EPA or the authorized state at least 30 calendar days prior to initiating a planned episodic event or within 24 hours after an unplanned episodic event;
      (c) CESQGs must obtain a RCRA ID number;
      (d) Accumulation standards: CESQGs must mark containers with the date the episodic event began; label containers "Episodic Hazardous Waste"; manage hazardous waste in a manner that minimizes the possibility of a fire, explosion, or release of hazardous waste; ensure that tanks are in good condition and compatible with the hazardous waste stored within; and identify an emergency coordinator for the duration of the event.  SQGs must mark the container or tank log book with the date the episodic event began; label the container or write in the tank log book "Episodic Hazardous Waste"; mark the container or write in the tank log book words that identify the contents and indicate the hazards of the contents; and comply with the applicable accumulation conditions in §262.34(d) and (e).
      (e) Hazardous waste generated from the episodic event must be managed on-site or shipped off-site via hazardous waste manifest to a permitted TSDF.  For purposes of analysis, this EA assumes that CESQGs and SQGs would not seek to obtain a RCRA storage or treatment permit, but would instead ship their hazardous waste off-site to a permitted TSDF.
      (f) Complete and maintain records that include (1) the beginning and end dates of the event, (2) a description of the event, (3) the types and quantities of hazardous wastes generated at the event, (4) a description of how the hazardous waste was managed, and (5) name(s) of hazardous waste transporters that transported the waste to a permitted TSDF.
   12. Special requirements for ignitable and reactive wastes (voluntary): Current regulation requires that LQGs must locate containers holding ignitable or reactive waste at least 15 meters from the facility's property line.  In urban environments, LQGs may find it impossible to meet this requirement due to the relatively small footprint of many properties in these areas.  To provide flexibility to LQGs, EPA is proposing to allow LQGs to voluntarily apply for a facility-specific waiver from their local fire department if they are unable to meet the hazardous waste accumulation property line requirement.

Report Organization
To support development of the proposed rule, EPA developed this EA examining the rule's costs, benefits, and other economic impacts.  The data, methods, and results of this analysis are presented in the following chapters:
   * Chapter 2: Characterization of the Regulated Universe.  This chapter describes the universe of facilities potentially affected by the rule.  Specifically, this chapter presents EPA's estimates of the number of LQGs, SQGs, and CESQGs in the U.S. and its territories, outlines the quantity of hazardous waste generated by these facilities, and characterizes the management of this waste across various management methods.
   * Chapter 3: Assessment of Costs.  Chapter 3 includes EPA's assessment of the rule's cost impacts.  This chapter (1) identifies portions of the generator universe affected by individual rule provisions, (2) characterizes the regulatory baseline, (3) describes the data and methods employed for the assessment of the rule's cost impacts, and (4) presents the results of the cost analysis.
   * Chapter 4: Assessment of Benefits. After presenting the rule's cost impacts, the focus shifts to EPA's assessment of the rule's benefits in Chapter 4.  To the extent possible, these benefits are quantified.  Benefits that EPA was unable to quantify are addressed qualitatively.
   * Chapter 5: Comparison of Costs and Benefits.  To synthesize the results presented in Chapters 3 and 4 and help readers understand the rule's benefits in the context of its costs, and vice versa, this EA includes a brief chapter comparing the costs and benefits of the proposed rule.
   * Chapter 6: Equity Considerations and Other Impacts. This chapter assesses distributional and other impacts of the proposed rule, including impacts to small entities, environmental justice implications, children's health, impacts to Tribal Governments, energy use and distribution effects resulting from the rule, and joint impacts with other rules.

CHAPTER 2  |  Potentially Impacted Universe
Introduction
This chapter provides an overview of the universe of facilities that may be potentially affected by the proposed Hazardous Waste Generator Improvements Rule.  The proposed rule may affect a wide range of facility types across a number of industries.  The information in this chapter provides context for the analysis of the costs and benefits associated with the proposed rulemaking.  First, this chapter provides a profile of facilities that may be affected by the proposed rule.  Second, this chapter characterizes the generation of hazardous waste by these facilities.
Universe of Facilities Affected by the Proposed Rule
According to the 2007 Economic Census, there are approximately 7.35 million employer establishments in the United States.  Of these, the majority of establishments are non-generators of RCRA hazardous waste.  Consequently, only the small percentage of facilities that generate hazardous waste is likely to be affected by the proposed rule.  As described in more detail in Chapter 3, the cost impact of the proposed rule for individual facilities will depend, in part, on their generator status under RCRA (i.e., LQG, SQG, or CESQG).  Therefore, to assess the rule's cost impacts, this EA estimates the distribution of potentially affected facilities across generator status categories.  Exhibit 2-1 describes the generation thresholds for LQGs, SQGs, and CESQGs.
EXHIBIT 2-1: RCRA SUBTITLE C HAZARDOUS WASTE GENERATION THRESHOLDS[1]
                                     CESQG
                                      SQG
                                      LQG
 * Less than or equal to 100 kg of hazardous waste per month, and
 * Less than or equal to 1 kg of acute hazardous waste per month.
 * Greater than 100 kg and less than 1,000 kg of hazardous waste per calendar month, and
 * Less than or equal to 1 kg of acute hazardous waste per month.
 * Greater than or equal to 1,000 kg of hazardous waste in a calendar month, or
 * Greater than 1 kg of acute hazardous waste per month.
Notes:
   1. Any facility that generates a total of 100 kilograms of any residue or contaminated soil, waste, or other debris resulting from the clean-up of a spill, into or on any land or water, of any acute hazardous wastes listed in §§ 261.31, or 261.33(e) would be considered an LQG.

There is considerable uncertainty regarding the number of facilities that generate hazardous waste in the United States and its territories.  The LQG universe is relatively well defined because LQGs are required to report their hazardous waste generation on a biennial basis to the EPA and/or state regulatory agencies.  SQGs are required to submit a one-time notification of their hazardous waste generation activity to EPA in order to obtain a RCRA ID for purposes of disposing hazardous waste, but they are not required to re-notify EPA of subsequent changes to their activities.  CESQGs are not required to report their hazardous waste generation to EPA.  While there are no Federal reporting requirements for SQGs and CESQGs, some states have hazardous waste reporting requirements for these facility types. The remainder of this section describes the methodology used to estimate the number of facilities that may be affected by the proposed rule by generator status category for LQGs, SQGs, and CESQGs.
This EA relies primarily on EPA's BR database and EPA's RCRAInfo database to estimate the number LQGs and SQGs in the potentially affected universe.  Estimating the number of CESQGs nationwide is complicated by the fact that EPA and most states do not have mandatory notification or reporting requirements for CESQGs.  To estimate the size of the CESQG universe, this EA extrapolates from the limited data collected from several states, including those that regulate CESQGs, and data for those CESQGs that voluntarily report to EPA.  To inform this effort, data were compiled for 14 states across the country, providing broad geographic representation across different regions and reflecting a mix of large and small states.
Estimating the Number oF LQGs
This EA relies on the BR database to estimate the number of LQGs that may be affected by the proposed rule.  Facilities that are considered LQGs under RCRA are required to report on the generation and management of their hazardous waste on a biennial basis.  The BR database is the Agency's primary repository for the information reported by these facilities.  Based on the 2011 BR data submissions by state, EPA estimates there are 14,262 LQG facilities in the United States.  Of these, more than half of the LQGs nationwide are located in just nine states; these include: New York, California, Texas, Ohio, Pennsylvania, Illinois, New Jersey, Indiana, and North Carolina.  Geographically, LQGs are heavily concentrated in the Mid-Atlantic, the Pacific Coast, and the Gulf Coast.  The concentration of LQGs varies considerably by state.  New York has the largest number of LQGs (1,471), while Wyoming has the smallest (15).
Estimating the Number of SQGs
When a facility determines for the first time they have generated more than 100 and less than 1,000 kilograms of hazardous waste in a single calendar month, they are required to notify State agencies and EPA of their SQG regulatory status to obtain a RCRA ID to manage that hazardous waste.  However, they are not required to re-notify EPA of subsequent changes in their generator status, address, ownership, or operating status (e.g., whether they have closed).  Consequently, there is no way to determine if the status of an SQG has changed over time.  SQGs are also not subject to Federal requirements for reporting hazardous waste generation to EPA on a regular basis (i.e., submitting BR records).
Despite this lack of data reported by SQGs, some SQG information is available in the BR database, as TSDFs are required to submit a waste received (WR) form for each facility (including SQGs) from whom they received hazardous waste with a hazardous waste manifest.  The WR form includes the RCRA ID of the facility that shipped the hazardous waste to the TSDF along with information about the type and quantity of hazardous waste.  Based on these data in the WR form, this EA develops two approaches to estimate the universe of SQGs that may be affected by the proposed rule.  The first approach yields a low-end estimate of the number of SQGs, while the second provides a high-end estimate.  Both approaches are described below.
Low-end Estimate of the Number of SQGs
To derive a low-end estimate of the number of SQGs, EPA relied on information in the 2011 BR and RCRAInfo databases.  Specifically, EPA used the WR form in the BR database to identify all facilities that shipped hazardous waste off-site and compared this list against the Site ID form in RCRAInfo to identify active SQGs in 2011.  EPA then also included any new SQGs that notified after July 1 and, therefore, did not have to ship their hazardous waste off-site to a TSDF in 2011.  Furthermore, as part of EPA's data collection effort, several states provided information on the number of SQGs statewide.  Therefore, where state-level data were provided, EPA relied on this information rather than estimates derived from the BR and RCRAInfo databases.  Using this approach, EPA developed a low-end estimate of approximately 45,800 SQGs in the United States and its territories.  EPA considers this a low end estimate because it may not capture SQGs that manage hazardous waste on site or SQGs that TSDFs failed to report in the BR database.
High-end Estimate of the Number of SQGs
Due to uncertainty associated with whether information in the data sources described above fully represents the universe of active SQGs, EPA used an alternative approach to derive a high-end estimate for the number of SQGs.  This approach is similar to the methodology employed in deriving the low-end estimate, but instead uses WR forms from any of the years 2007, 2009, or 2011 to identify any SQGs that shipped waste off-site in any of those three BR cycles.  This yields an estimate of the number of facilities that were SQGs sometime between 2007 and 2011.  Because some facilities may have been SQGs for one of these years but not all years, this approach may lead to overestimation of the number of SQGs.  Due to this potential for overestimation, this EA applies this approach to develop the high-end estimate for SQGs.  EPA used this approach for states from which no SQG counts were obtained, but continued to rely on the state estimates that were obtained otherwise.  Using this alternative approach, EPA developed a high-end estimate of approximately 59,700 SQGs in the United States and its territories.
Estimating the Number of CESQGs
In the absence of reliable national data on the number and location of CESQGs, EPA used information collected from the states to estimate the universe of CESQGs potentially affected by the proposed rule.  Specifically, EPA obtained estimates of the number of CESQGs statewide for 14 states, as described above.  Then, EPA calculated the ratio of (1) CESQGs to SQGs (using low-end and high-end estimates for states with an uncertain number of SQGs) and (2) CESQGs to LQGs in aggregate across the 14 states.  Exhibit 2-2 summarizes data collected from the states on the number of CESQGs within each state and the corresponding ratio values developed.  As shown in the exhibit, these ratios vary considerably across states.  This analysis uses the composite ratio of 29.67 (as opposed to the simple average) for all 14 states combined, as shown in the last row of Exhibit 2-2.
For states where data on the number of CESQGs are unavailable, the composite ratios calculated above are multiplied by the number of SQGs and LQGs in the state to estimate an approximate range for the number of CESQGs.  In aggregate, the lower-bound CESQG-to-SQG ratio (Column F) described in Exhibit 2-2 produces the lowest estimate, while the CESQG-to-LQG ratio (Column H) produces the highest estimate.  The high-end estimate is similar to the alternative estimate developed using the upper-bound CESQG-to-SQG ratio (Column G); the difference between the two is approximately seven percent.  However, because these ratios are indexed to the number of SQGs and LQGs, which vary considerably across states, on a state-by-state basis the LQG-based estimate may be higher or lower than the SQG-based estimates.  Therefore, to be

pragmatic in estimating the number of CESQGs, EPA reports the lowest and highest of these three estimates to highlight the degree of uncertainty regarding the number of CESQGs.  Finally, these estimates are combined with the CESQG estimates collected from the 14 states also described above.
EXHIBIT 2-2: NUMBER OF CESQG FACILITIES BY STATE AND CALCULATION OF RATIOS USED IN EXTRAPOLATION FOR NATIONAL ESTIMATES
                                     State
                                      [A]
                               Number of LQGs[1]
                                      [B]
                               Number of SQGs[2]
                              Number of CESQGs[2]
                                      [E]
                            Ratio of CESQGs to SQGs
                            Ratio of CESQGs to LQGs
                                    [H=E/B]

                                    Low-End
                                      [C]
                                   High-End
                                      [D]

                                    Low-End
                                    [F=E/D]
                                   High-End
                                    [G=E/C]

Alabama
                                      223
                                     1,226
                                     1,226
                                     3,390
                                      2.8
                                      2.8
                                     15.20
Arizona[3]
                                      210
                                      511
                                      770
                                     1,774
                                      2.3
                                      3.5
                                     8.45
California
                                     1,223
                                     5,915
                                     5,915
                                    21,000
                                      3.6
                                      3.6
                                     17.17
Florida
                                      279
                                     3,800
                                     3,800
                                    19,350
                                      5.1
                                      5.1
                                     69.35
Hawaii[3]
                                      31
                                      122
                                      165
                                      692
                                      4.2
                                      5.7
                                     22.32
Massachusetts
                                      402
                                     2,683
                                     2,683
                                    12,559
                                      4.7
                                      4.7
                                     31.24
Maine
                                      52
                                      304
                                      304
                                      949
                                      3.1
                                      3.1
                                     18.25
Minnesota
                                      320
                                     1,366
                                     1,366
                                    21,743
                                     15.9
                                     15.9
                                     67.95
Nevada[3]
                                      68
                                      196
                                      280
                                     3,187
                                     11.4
                                     16.3
                                     46.87
New Hampshire
                                      100
                                      201
                                      201
                                     1,818
                                      9.0
                                      9.0
                                     18.18
New Jersey
                                      575
                                      850
                                      850
                                     9,000
                                     10.6
                                     10.6
                                     15.65
Rhode Island
                                      65
                                      700
                                      700
                                     2,100
                                      3.0
                                      3.0
                                     32.31
Washington[3]
                                      412
                                      532
                                      604
                                    22,315
                                     36.9
                                     41.9
                                     54.16
Wisconsin
                                      394
                                     1,227
                                     1,227
                                     9,323
                                      7.6
                                      7.6
                                     23.66
TOTAL
                                     4,354
                                    19,633
                                    20,091
                                    129,200
                                      6.4
                                      6.6
                                     29.67
Notes:
   1. The number of LQGs appears as reported in EPA, National Biennial RCRA Hazardous Waste Report: Based on 2011 Data, Exhibit 1.1 Quantity of RCRA Hazardous Waste Generated and Number of Hazardous Waste Generators, by State, 2011, accessed at http://www.epa.gov/wastes/inforesources/data/br11/national11.pdf on July 22, 2013.
   2. Data sources for the number of SQGs and CESQGs are as follows. Alabama: E-mail communication with Ron Shell of the Alabama Department of Environmental Management; Arizona/Nevada/Hawaii: E-mail communication with Kathryn Faulkner of EPA Region 9 on May 28, 2013; California: E-mail communication with Schumin Wong of the California Department of Toxic Substances Control; Florida: Florida Department of Environmental Protection, Hazardous Waste Management Needs Assessment Report, January 2007, accessed at http://www.dep.state.fl.us/waste/quick_topics/publications/shw/hazardous/2007HazardousWasteManagementNeedsAssessmentReport.pdf  on July 10, 2013; Massachusetts: E-mail communication with Mike Hurley of the Massachusetts Department of Environmental Protection on October 16, 2012; Maine: E-mail communication with Cherie Plummer of the Maine Department of Environmental Protection on October 26, 2012; Minnesota: E-mail communication with Kathy Gedde of the Minnesota Pollution Control Agency on October 17, 2012; New Hampshire: E-mail communication with John Duclos of the New Hampshire Department of Environmental Services on June 26, 2013; New Jersey: E-mail communication with Michael Hastry of the New Jersey Department of Environmental Protection; Rhode Island: E-mail communication with Mark Dennen of the Rhode Island Department of Environmental Management of May 14, 2013;  Washington: E-mail communication with Rob Rieck of the Washington Department of Ecology on March 8, 2012; Wisconsin: E-mail communication with Pat Chabot of the Wisconsin Department of Natural Resources on December 15, 2011.
   3. Arizona, Hawaii, Nevada and Washington did not provide estimates of the number of SQGs. For these States, EPA estimated a range for the SQG universe by identifying the number of active SQGs as described earlier in this chapter.

Using this methodology, EPA estimates that there are between approximately 293,000 and 469,000 CESQGs in the United States.  Therefore, EPA estimates that the combined total number of hazardous waste generators is between approximately 353,000 and 543,000.  Exhibit 2-3 describes the total number of LQGs, SQGs, and CESQGs by State.
EXHIBIT 2-3: UNIVERSE OF FACILITIES POTENTIALLY AFFECTED BY THE PROPOSED RULE BY STATE AND GENERATOR STATUS
                                   STATE[A]
                                Number of LQGs
                                      [B]
                                Number of SQGs
                               Number of CESQGs
                          TOTAL NUMBER OF GENERATORS
LOW-END
                                      [C]
                                   High-End
                                      [D]
                                    Low-End
                                      [E]
                                   High-End
                                      [F]
                                    Low-End
                                      [G]
                                   High-End
                                      [H]
Alabama
                                                                            223
                                                                          1,226
                                                                          1,226
                                                                          3,390
                                                                          3,390
                                                                          4,839
                                                                          4,839
Alaska
                                                                             27
                                                                             96
                                                                            143
                                                                            617
                                                                            941
                                                                            740
                                                                          1,111
Arizona
                                                                            210
                                                                            511
                                                                            770
                                                                          1,774
                                                                          1,774
                                                                          2,495
                                                                          2,754
Arkansas
                                                                            123
                                                                            256
                                                                            318
                                                                          1,646
                                                                          3,650
                                                                          2,025
                                                                          4,091
California
                                                                          1,223
                                                                          5,915
                                                                          5,915
                                                                         21,000
                                                                         21,000
                                                                         28,138
                                                                         28,138
Colorado
                                                                            107
                                                                            434
                                                                            482
                                                                          2,791
                                                                          3,175
                                                                          3,332
                                                                          3,764
Connecticut
                                                                            278
                                                                            756
                                                                          1,092
                                                                          4,862
                                                                          8,249
                                                                          5,896
                                                                          9,619
Delaware
                                                                             49
                                                                            155
                                                                            218
                                                                            997
                                                                          1,454
                                                                          1,201
                                                                          1,721
District of Columbia
                                                                             23
                                                                             36
                                                                             74
                                                                            232
                                                                            682
                                                                            291
                                                                            779
Florida
                                                                            279
                                                                          3,800
                                                                          3,800
                                                                         19,350
                                                                         19,350
                                                                         23,429
                                                                         23,429
Georgia
                                                                            334
                                                                            900
                                                                          1,288
                                                                          5,788
                                                                          9,911
                                                                          7,022
                                                                         11,533
Guam
                                                                              8
                                                                              3
                                                                              8
                                                                             19
                                                                            237
                                                                             30
                                                                            253
Hawaii
                                                                             31
                                                                            122
                                                                            165
                                                                            692
                                                                            692
                                                                            845
                                                                            888
Idaho
                                                                             19
                                                                             79
                                                                             89
                                                                            508
                                                                            586
                                                                            606
                                                                            694
Illinois
                                                                            641
                                                                          2,958
                                                                          4,897
                                                                         19,021
                                                                         32,226
                                                                         22,620
                                                                         37,764
Indiana
                                                                            503
                                                                            790
                                                                          1,156
                                                                          5,080
                                                                         14,926
                                                                          6,373
                                                                         16,585
Iowa
                                                                            128
                                                                            471
                                                                            675
                                                                          3,029
                                                                          4,442
                                                                          3,628
                                                                          5,245
Kansas
                                                                            170
                                                                            480
                                                                            680
                                                                          3,087
                                                                          5,045
                                                                          3,737
                                                                          5,895
Kentucky
                                                                            269
                                                                            355
                                                                            469
                                                                          2,283
                                                                          7,982
                                                                          2,907
                                                                          8,720
Louisiana
                                                                            331
                                                                            705
                                                                          1,068
                                                                          4,534
                                                                          9,822
                                                                          5,570
                                                                         11,221
Maine
                                                                             52
                                                                            304
                                                                            304
                                                                            949
                                                                            949
                                                                          1,305
                                                                          1,305
Maryland
                                                                            132
                                                                            974
                                                                          1,780
                                                                          3,917
                                                                         11,714
                                                                          5,023
                                                                         13,626
Massachusetts
                                                                            402
                                                                          2,683
                                                                          2,683
                                                                         12,559
                                                                         12,559
                                                                         15,644
                                                                         15,644
Michigan
                                                                            342
                                                                          1,486
                                                                          2,194
                                                                          9,556
                                                                         14,438
                                                                         11,384
                                                                         16,974
Minnesota
                                                                            320
                                                                          1,366
                                                                          1,366
                                                                         21,743
                                                                         21,743
                                                                         23,429
                                                                         23,429
Mississippi
                                                                            128
                                                                            210
                                                                            286
                                                                          1,350
                                                                          3,798
                                                                          1,688
                                                                          4,212
Missouri
                                                                            282
                                                                          1,279
                                                                          1,727
                                                                          8,225
                                                                         11,365
                                                                          9,786
                                                                         13,374
Montana
                                                                             41
                                                                             55
                                                                             77
                                                                            354
                                                                          1,217
                                                                            450
                                                                          1,335
Navajo Nation
                                                                              1
                                                                              6
                                                                              6
                                                                             30
                                                                             39
                                                                             37
                                                                             46
Nebraska
                                                                             64
                                                                            226
                                                                            273
                                                                          1,453
                                                                          1,899
                                                                          1,743
                                                                          2,236
Nevada
                                                                             68
                                                                            196
                                                                            280
                                                                          3,187
                                                                          3,187
                                                                          3,451
                                                                          3,535
New Hampshire
                                                                            100
                                                                            201
                                                                            201
                                                                          1,818
                                                                          1,818
                                                                          2,119
                                                                          2,119
New Jersey
                                                                            575
                                                                            850
                                                                            850
                                                                          9,000
                                                                          9,000
                                                                         10,425
                                                                         10,425
New Mexico
                                                                             39
                                                                            156
                                                                            236
                                                                          1,003
                                                                          1,553
                                                                          1,198
                                                                          1,828
New York
                                                                          1,471
                                                                          1,983
                                                                          3,255
                                                                         12,752
                                                                         43,650
                                                                         16,206
                                                                         48,376
North Carolina
                                                                            437
                                                                          1,169
                                                                          1,786
                                                                          7,518
                                                                         12,967
                                                                          9,124
                                                                         15,190
North Dakota
                                                                             19
                                                                             62
                                                                             78
                                                                            399
                                                                            564
                                                                            480
                                                                            661
Ohio
                                                                            716
                                                                          2,041
                                                                          3,240
                                                                         13,125
                                                                         21,322
                                                                         15,882
                                                                         25,278
Oklahoma
                                                                            179
                                                                            379
                                                                            502
                                                                          2,437
                                                                          5,312
                                                                          2,995
                                                                          5,993
Oregon
                                                                            181
                                                                            235
                                                                            285
                                                                          1,511
                                                                          5,371
                                                                          1,927
                                                                          5,837
Pennsylvania
                                                                            671
                                                                          2,721
                                                                          4,293
                                                                         17,498
                                                                         28,251
                                                                         20,890
                                                                         33,215
Puerto Rico
                                                                             80
                                                                             96
                                                                            115
                                                                            617
                                                                          2,374
                                                                            793
                                                                          2,569
Rhode Island
                                                                             65
                                                                            700
                                                                            700
                                                                          2,100
                                                                          2,100
                                                                          2,865
                                                                          2,865
South Carolina
                                                                            257
                                                                            485
                                                                            722
                                                                          3,119
                                                                          7,626
                                                                          3,861
                                                                          8,605
South Dakota
                                                                             33
                                                                            182
                                                                            256
                                                                            979
                                                                          1,685
                                                                          1,194
                                                                          1,974
Tennessee
                                                                            334
                                                                            442
                                                                            710
                                                                          2,842
                                                                          9,911
                                                                          3,618
                                                                         10,955
Texas
                                                                          1,006
                                                                          1,471
                                                                          2,164
                                                                          9,460
                                                                         29,852
                                                                         11,937
                                                                         33,022
Trust Territories
                                                                              1
                                                                              3
                                                                              5
                                                                             19
                                                                             33
                                                                             23
                                                                             39
Utah
                                                                            111
                                                                            174
                                                                            205
                                                                          1,119
                                                                          3,294
                                                                          1,404
                                                                          3,610
Vermont
                                                                             39
                                                                            185
                                                                            250
                                                                          1,157
                                                                          1,645
                                                                          1,381
                                                                          1,934
Virgin Islands
                                                                              2
                                                                              6
                                                                              5
                                                                             33
                                                                             59
                                                                             41
                                                                             66
Virginia
                                                                            219
                                                                          1,274
                                                                          2,029
                                                                          6,499
                                                                         13,352
                                                                          7,992
                                                                         15,600
Washington
                                                                            412
                                                                            532
                                                                            604
                                                                         22,315
                                                                         22,315
                                                                         23,259
                                                                         23,331
West Virginia
                                                                             98
                                                                            280
                                                                            376
                                                                          1,801
                                                                          2,908
                                                                          2,179
                                                                          3,382
Wisconsin
                                                                            394
                                                                          1,227
                                                                          1,227
                                                                          9,323
                                                                          9,323
                                                                         10,944
                                                                         10,944
Wyoming
                                                                             15
                                                                             75
                                                                             99
                                                                            445
                                                                            651
                                                                            535
                                                                            765
TOTAL
                                                                         14,262
                                                                         45,762
                                                                         59,702
                                                                        292,912
                                                                        469,378
                                                                        352,936
                                                                        543,342

Exhibits 2-4(A) and 2-4(B) show the geographic distribution of the universe of facilities potentially affected by the proposed rule across the United States using the low-end and high-end estimates.
EXHIBIT 2-4(A): GEOGRAPHIC DISTRIBUTION OF FACILITIES USING LOW-END ESTIMATE
EXHIBIT 2-4(B): GEOGRAPHIC DISTRIBUTION OF FACILITIES USING HIGH-END ESTIMATE
HAZARDOUS WASTE GENERATION OF POTENTIALLY AFFECTED FACILITIES
This section characterizes the hazardous waste generation of facilities in the potentially regulated universe.  The overall tonnages of hazardous waste and the number of waste streams are relevant to estimating the cost of managing this waste in compliance with the provisions of the proposed rule.  The methodology for estimating the quantities of hazardous waste generation varies by generator status due to limitations in the available data.  Where possible, this EA relies on generation data from EPA's 2011 BR database.  The BR database is used to develop annual aggregate and per facility generation estimates for LQG facilities.  For other facility types, however, the data available from the BR database are, alone, insufficient to develop nationwide hazardous waste generation estimates.  Consequently, this EA derives generation estimates for SQGs and CESQGs by combining the limited data available in the BR database with facility-level generation data obtained from individual states.
LQG Hazardous Waste Generation
EPA's 2011 BR database is the primary data source for estimating hazardous waste generation for LQG facilities.  In 2011, LQGs generated approximately 34.5 million tons of hazardous waste in aggregate.  Combining this value with the LQG facility count presented above suggests that LQGs, on average, generate approximately 2,420 tons of hazardous waste per facility per year.  The BR data also suggest that LQGs reported an average of 17 different waste streams per facility, with a few large facilities reporting several thousand waste streams.
Exhibit 2-5 reports the overall and average per facility hazardous waste quantities generated on an annual basis as well as the average number of waste streams per facility for LQGs by state.  As shown in the exhibit, the Gulf States of Texas, Louisiana, and Mississippi account for approximately 64 percent of all hazardous waste generated by LQGs in the United States.  In contrast, New York and California, which have the largest number of LQG facilities, collectively account for just 2.1 percent of all hazardous waste generated by LQGs.
Exhibit 2-6 provides information on the distribution of LQGs by industry.  Facilities in the BR database may be characterized by one or several North American Industry Classification System (NAICS) codes.  To avoid double-counting, this EA uses the first NAICS codes listed in the BR database for a facility, which is considered to be the primary NAICS code.  As shown in the exhibit, the four largest industries account for more than 95 percent of all hazardous waste generated by LQGs.  These include: chemical manufacturing (NAICS 325); petroleum and coal products manufacturing (NAICS 324); primary metal manufacturing (NAICS 331); and waste management and remediation services (NAICS 562).  Overall, the nine largest industries account for more than half the LQGs in the affected universe.  In addition to those listed above, these also include: fabricated metal product manufacturing (NAICS 332); transportation equipment manufacturing (NAICS 336); electrical equipment, appliance, and component manufacturing (NAICS 335); national security and international affairs (NAICS 928); and computer and electronic product manufacturing (NAICS 334).

EXHIBIT 2-5: LQG HAZARDOUS WASTE QUANTITIES AND NUMBER OF WASTE STREAMS GENERATED BY STATE
                                   STATE[A]
                      NUMBER OF FACILITIES IN BR DATA[B]
                   TOTAL HAZARDOUS WASTE GENERATED(TONS) [C]
                      PERCENTAGE OF TOTAL HAZARDOUS WASTE
                                      [D]
              HAZARDOUS WASTE GENERATED PER FACILITY(TONS)[E=C/B]
                AVERAGE NUMBER OF WASTE STREAMS PER FACILITY[F]
Alabama
                                                                            223
                                                                        586,799
                                                                           1.7%
                                                                          2,631
                                                                             19
Alaska
                                                                             27
                                                                          1,940
                                                                           0.0%
                                                                             72
                                                                             24
Arizona
                                                                            210
                                                                        202,842
                                                                           0.6%
                                                                            966
                                                                             15
Arkansas
                                                                            123
                                                                        985,790
                                                                           2.9%
                                                                          8,015
                                                                             25
California
                                                                          1,223
                                                                        558,941
                                                                           1.6%
                                                                            457
                                                                             18
Colorado
                                                                            107
                                                                         31,065
                                                                           0.1%
                                                                            290
                                                                             48
Connecticut
                                                                            278
                                                                         24,738
                                                                           0.1%
                                                                             89
                                                                             12
Delaware
                                                                             49
                                                                         35,207
                                                                           0.1%
                                                                            719
                                                                             45
District of Columbia
                                                                             23
                                                                          1,134
                                                                           0.0%
                                                                             49
                                                                             12
Florida
                                                                            279
                                                                        201,980
                                                                           0.6%
                                                                            724
                                                                             18
Georgia
                                                                            334
                                                                        210,858
                                                                           0.6%
                                                                            631
                                                                             11
Guam
                                                                              8
                                                                             86
                                                                           0.0%
                                                                             11
                                                                             47
Hawaii
                                                                             31
                                                                        423,550
                                                                           1.2%
                                                                         13,663
                                                                             51
Idaho
                                                                             19
                                                                          3,482
                                                                           0.0%
                                                                            183
                                                                             32
Illinois
                                                                            641
                                                                        675,522
                                                                           2.0%
                                                                          1,054
                                                                              9
Indiana
                                                                            503
                                                                        888,022
                                                                           2.6%
                                                                          1,765
                                                                             13
Iowa
                                                                            128
                                                                         49,366
                                                                           0.1%
                                                                            386
                                                                              9
Kansas
                                                                            170
                                                                      1,244,754
                                                                           3.6%
                                                                          7,322
                                                                              9
Kentucky
                                                                            269
                                                                        208,463
                                                                           0.6%
                                                                            775
                                                                             27
Louisiana
                                                                            331
                                                                      4,399,502
                                                                          12.7%
                                                                         13,292
                                                                             10
Maine
                                                                             52
                                                                          2,292
                                                                           0.0%
                                                                             44
                                                                              9
Maryland
                                                                            132
                                                                         43,590
                                                                           0.1%
                                                                            330
                                                                             10
Massachusetts
                                                                            402
                                                                         32,886
                                                                           0.1%
                                                                             82
                                                                             16
Michigan
                                                                            342
                                                                        316,360
                                                                           0.9%
                                                                            925
                                                                             86
Minnesota
                                                                            320
                                                                        353,037
                                                                           1.0%
                                                                          1,103
                                                                              8
Mississippi
                                                                            128
                                                                      1,828,854
                                                                           5.3%
                                                                         14,288
                                                                              8
Missouri
                                                                            282
                                                                        252,895
                                                                           0.7%
                                                                            897
                                                                             12
Montana
                                                                             41
                                                                          5,883
                                                                           0.0%
                                                                            143
                                                                              8
Navajo Nation
                                                                              1
                                                                             23
                                                                           0.0%
                                                                             23
                                                                              7
Nebraska
                                                                             64
                                                                         34,404
                                                                           0.1%
                                                                            538
                                                                             27
Nevada
                                                                             68
                                                                         12,030
                                                                           0.0%
                                                                            177
                                                                             10
New Hampshire
                                                                            100
                                                                          3,237
                                                                           0.0%
                                                                             32
                                                                             50
New Jersey
                                                                            575
                                                                        290,495
                                                                           0.8%
                                                                            505
                                                                             62
New Mexico
                                                                             39
                                                                      1,037,384
                                                                           3.0%
                                                                         26,600
                                                                             46
New York
                                                                          1,471
                                                                        186,479
                                                                           0.5%
                                                                            127
                                                                              6
North Carolina
                                                                            437
                                                                         81,678
                                                                           0.2%
                                                                            187
                                                                             24
North Dakota
                                                                             19
                                                                        455,867
                                                                           1.3%
                                                                         23,993
                                                                              7
Ohio
                                                                            716
                                                                      1,601,885
                                                                           4.6%
                                                                          2,237
                                                                             15
Oklahoma
                                                                            179
                                                                         44,688
                                                                           0.1%
                                                                            250
                                                                              5
Oregon
                                                                            181
                                                                         93,514
                                                                           0.3%
                                                                            517
                                                                              9
Pennsylvania
                                                                            671
                                                                        294,971
                                                                           0.9%
                                                                            440
                                                                             11
Puerto Rico
                                                                             80
                                                                         37,222
                                                                           0.1%
                                                                            465
                                                                             26
Rhode Island
                                                                             65
                                                                          8,406
                                                                           0.0%
                                                                            129
                                                                             15
South Carolina
                                                                            257
                                                                        176,964
                                                                           0.5%
                                                                            689
                                                                             10
South Dakota
                                                                             33
                                                                          1,334
                                                                           0.0%
                                                                             40
                                                                              8
Tennessee
                                                                            334
                                                                         90,121
                                                                           0.3%
                                                                            270
                                                                              6
Texas
                                                                          1,006
                                                                     15,683,407
                                                                          45.4%
                                                                         15,590
                                                                              8
Trust Territories
                                                                              1
                                                                              6
                                                                           0.0%
                                                                              6
                                                                              1
Utah
                                                                            111
                                                                         49,706
                                                                           0.1%
                                                                            448
                                                                             30
Vermont
                                                                             39
                                                                          2,773
                                                                           0.0%
                                                                             71
                                                                             13
Virgin Islands
                                                                              2
                                                                          1,251
                                                                           0.0%
                                                                            626
                                                                             12
Virginia
                                                                            219
                                                                         68,300
                                                                           0.2%
                                                                            312
                                                                             17
Washington
                                                                            412
                                                                        349,508
                                                                           1.0%
                                                                            848
                                                                             17
West Virginia
                                                                             98
                                                                         54,511
                                                                           0.2%
                                                                            556
                                                                             11
Wisconsin
                                                                            394
                                                                        287,938
                                                                           0.8%
                                                                            731
                                                                             10
Wyoming
                                                                             15
                                                                          4,058
                                                                           0.0%
                                                                            271
                                                                             11
TOTAL
                                                                         14,262
                                                                     34,522,000
                                                                           100%
                                                                          2,421
                                                                             17
Notes:
   1. The number of LQGs appears as reported in EPA, National Biennial RCRA Hazardous Waste Report: Based on 2011 Data, Exhibit 1.1 Quantity of RCRA Hazardous Waste Generated and Number of Hazardous Waste Generators, by State, 2011, accessed at http://www.epa.gov/wastes/inforesources/data/br11/national11.pdf on July 22, 2013.
   2. Hazardous waste quantities based on analysis of 2011 BR database. Figures may differ from those reported in EPA's National Biennial RCRA Hazardous Waste Report due to minor discrepancies associated with rounding error in converting different units of measurement to tons. The quantities reported above are within +/-1 percent of the national data reported by EPA.
   3. Number of waste streams based on analysis of 2011 BR database.

EXHIBIT 2-6: LQG HAZARDOUS WASTE QUANTITIES AND NUMBER OF WASTE STREAMS GENERATED BY INDUSTRY
                                   NAICS[A]
                               NAICS DESCRIPTION
                                      [B]
                      NUMBER OF FACILITIES IN BR DATA[C]
                   TOTAL HAZARDOUS WASTE GENERATED(TONS) [D]
              HAZARDOUS WASTE GENERATED PER FACILITY(TONS)[E=D/C]
                AVERAGE NUMBER OF WASTE STREAMS PER FACILITY[F]
                                      325
Chemical manufacturing
                                                                          2,197
                                                                     21,309,876
                                                                          9,700
                                                                             17
                                      324
Petroleum and coal products manufacturing
                                                                            188
                                                                      6,643,349
                                                                         35,337
                                                                             20
                                      331
Primary metal manufacturing
                                                                            580
                                                                      2,517,470
                                                                          4,340
                                                                              8
                                      562
Waste management and remediation services
                                                                            577
                                                                      2,493,110
                                                                          4,321
                                                                            153
                                      332
Fabricated metal product manufacturing
                                                                          1,724
                                                                        324,267
                                                                            188
                                                                              6
                                      336
Transportation equipment manufacturing
                                                                            861
                                                                        155,444
                                                                            181
                                                                             13
                                      335
Electrical equipment, appliance, and component manufacturing
                                                                            222
                                                                        127,740
                                                                            575
                                                                              9
                                      928
National security and international affairs
                                                                            220
                                                                         89,824
                                                                            408
                                                                             61
                                      334
Computer and electronic product manufacturing
                                                                            579
                                                                         89,800
                                                                            155
                                                                             13
                                      481
Air transportation
                                                                             22
                                                                         78,162
                                                                          3,553
                                                                             19
                                      327
Nonmetallic mineral product manufacturing
                                                                            149
                                                                         59,550
                                                                            400
                                                                              7
                                      326
Plastics and rubber products manufacturing
                                                                            360
                                                                         51,127
                                                                            142
                                                                              7
                                      311
Food manufacturing
                                                                             51
                                                                         45,472
                                                                            892
                                                                             13
                                      493
Warehousing and storage
                                                                            285
                                                                         44,736
                                                                            157
                                                                              8
                                      488
Support activities for transportation
                                                                            259
                                                                         42,427
                                                                            164
                                                                              5
                                      561
Administrative and support services
                                                                             33
                                                                         40,265
                                                                          1,220
                                                                              9
                                      541
Professional, scientific, and technical services
                                                                            462
                                                                         32,137
                                                                             70
                                                                             21
                                      221
Utilities
                                                                            589
                                                                         26,954
                                                                             46
                                                                              4
                                      212
Mining (except oil and gas)
                                                                             30
                                                                         25,838
                                                                            861
                                                                             11
                                      424
Merchant wholesalers, nondurable goods
                                                                            368
                                                                         24,257
                                                                             66
                                                                              8
                                      423
Merchant wholesalers, durable goods
                                                                             81
                                                                         24,214
                                                                            299
                                                                              5
                                      333
Machinery manufacturing
                                                                            324
                                                                         21,403
                                                                             66
                                                                              8
                                      237
Heavy and civil engineering construction
                                                                            179
                                                                         19,204
                                                                            107
                                                                              1
                                      621
Ambulatory health care services
                                                                            116
                                                                         18,751
                                                                            162
                                                                              6
                                      611
Educational services
                                                                            361
                                                                         18,079
                                                                             50
                                                                             37
                                      236
Construction of buildings
                                                                             17
                                                                         17,696
                                                                          1,041
                                                                              2
                                      323
Printing and related support activities
                                                                            262
                                                                         17,656
                                                                             67
                                                                              4
                                      486
Pipeline transportation
                                                                            180
                                                                         14,522
                                                                             81
                                                                              3
                                      322
Paper manufacturing
                                                                            157
                                                                         14,321
                                                                             91
                                                                              6
                                      321
Wood product manufacturing
                                                                            140
                                                                         13,571
                                                                             97
                                                                              3
                                      339
Miscellaneous manufacturing
                                                                            248
                                                                         13,451
                                                                             54
                                                                              9
                                      926
Administration of economic programs
                                                                             39
                                                                         11,944
                                                                            306
                                                                              2
                                      811
Repair and maintenance
                                                                             89
                                                                         10,116
                                                                            114
                                                                              7
                                      924
Administration of environmental quality programs
                                                                             20
                                                                          9,920
                                                                            496
                                                                             27
                                      337
Furniture and related product manufacturing
                                                                            139
                                                                          8,881
                                                                             64
                                                                              3
                                      211
Oil and gas extraction
                                                                             48
                                                                          8,554
                                                                            178
                                                                              6
                                      483
Water transportation
                                                                             29
                                                                          7,655
                                                                            264
                                                                              5
                                      531
Real estate
                                                                             41
                                                                          6,309
                                                                            154
                                                                              4
                                      622
Hospitals
                                                                            345
                                                                          5,610
                                                                             16
                                                                             15
                                      482
Rail transportation
                                                                             34
                                                                          4,824
                                                                            142
                                                                              3
                                      313
Textile mills
                                                                             52
                                                                          4,515
                                                                             87
                                                                              6
                                      812
Personal and laundry services
                                                                             99
                                                                          4,111
                                                                             42
                                                                              2
                                      532
Rental and leasing services
                                                                             16
                                                                          4,057
                                                                            254
                                                                              6
                                      921
Executive, legislative, and other general government support
                                                                             34
                                                                          2,569
                                                                             76
                                                                             13
                                      485
Transit and ground passenger transportation
                                                                             58
                                                                          1,990
                                                                             34
                                                                              2
                                      422
Wholesale trade, nondurable goods
                                                                             27
                                                                          1,804
                                                                             67
                                                                             12
                                      452
General merchandise stores
                                                                            745
                                                                          1,235
                                                                              2
                                                                             10
                                      484
Truck transportation
                                                                             59
                                                                          1,127
                                                                             19
                                                                             19
                                      927
Space research and technology
                                                                             15
                                                                            992
                                                                             66
                                                                             27
                                      213
Support activities for mining
                                                                             38
                                                                            986
                                                                             26
                                                                              5
                                      238
Specialty trade contractors
                                                                             61
                                                                            976
                                                                             16
                                                                              2
                                      314
Textile product mills
                                                                             10
                                                                            965
                                                                             96
                                                                              4
                                      421
Wholesale trade, durable goods
                                                                             10
                                                                            919
                                                                             92
                                                                              4
                                      713
Amusement, gambling, and recreation industries
                                                                             11
                                                                            892
                                                                             81
                                                                             10
                                      712
Museums, historical sites, and similar institutions
                                                                              9
                                                                            637
                                                                             71
                                                                              4
                                      623
Nursing and residential care facilities
                                                                              1
                                                                            628
                                                                            628
                                                                              1
                                      234
Heavy construction
                                                                              3
                                                                            535
                                                                            178
                                                                              7
                                      447
Gasoline stations
                                                                             45
                                                                            446
                                                                             10
                                                                              2
                                      446
Health and personal care stores
                                                                            144
                                                                            365
                                                                              3
                                                                              6
                                      454
Non-store retailers
                                                                              8
                                                                            340
                                                                             43
                                                                              4
                                      444
Building material and garden equipment and supplies dealers
                                                                             31
                                                                            315
                                                                             10
                                                                              8
                                      492
Couriers and messengers
                                                                             22
                                                                            315
                                                                             14
                                                                             19
                                      813
Religious, grant-making, civic, professional, and similar orgs.
                                                                              5
                                                                            302
                                                                             60
                                                                              6
                                      551
Management of companies and enterprises
                                                                             12
                                                                            261
                                                                             22
                                                                             23
                                      925
Administration of housing programs, urban planning, and community development
                                                                              4
                                                                            252
                                                                             63
                                                                              1
                                      512
Motion picture and sound recording industries
                                                                              4
                                                                            217
                                                                             54
                                                                              7
                                      312
Beverage and tobacco product manufacturing
                                                                             10
                                                                            199
                                                                             20
                                                                             12
                                      111
Crop production
                                                                              5
                                                                            194
                                                                             39
                                                                              4
                                      425
Wholesale electronic markets and agents and brokers
                                                                              2
                                                                            182
                                                                             91
                                                                              2
                                      922
Justice, public order, and safety activities
                                                                             14
                                                                            178
                                                                             13
                                                                             11
                                      522
Credit intermediation and related activities
                                                                              3
                                                                            139
                                                                             46
                                                                              5
                                      511
Publishing industries (except Internet)
                                                                              6
                                                                            129
                                                                             22
                                                                             11
                                      525
Funds, trusts, and other financial vehicles
                                                                              6
                                                                            115
                                                                             19
                                                                             13
                                      235
Special trade contractors
                                                                              7
                                                                             98
                                                                             14
                                                                              4
                                      711
Performing arts, spectator sports, and related industries
                                                                              5
                                                                             92
                                                                             18
                                                                              2
                                      441
Motor vehicle and parts dealers
                                                                              9
                                                                             86
                                                                             10
                                                                              2
                                      515
Broadcasting (except Internet)
                                                                              1
                                                                             66
                                                                             66
                                                                              1
                                      115
Support activities for agriculture and forestry
                                                                              3
                                                                             43
                                                                             14
                                                                              3
                                      315
Apparel manufacturing
                                                                              2
                                                                             34
                                                                             17
                                                                              2
                                      316
Leather and allied product manufacturing
                                                                              2
                                                                             34
                                                                             17
                                                                              2
                                      443
Electronics and appliance stores
                                                                              1
                                                                             30
                                                                             30
                                                                              1
                                      453
Miscellaneous store retailers
                                                                              6
                                                                             26
                                                                              4
                                                                              1
                                      722
Food services and drinking places
                                                                              1
                                                                             21
                                                                             21
                                                                              1
                                      517
Telecommunications
                                                                              4
                                                                             13
                                                                              3
                                                                              1
                                      445
Food and beverage stores
                                                                             31
                                                                             12
                                                                              0
                                                                              1
                                      112
Animal production
                                                                              3
                                                                             11
                                                                              4
                                                                              4
                                      518
Data processing, hosting and related services
                                                                              1
                                                                             10
                                                                             10
                                                                             61
                                      491
Postal Service
                                                                              1
                                                                             10
                                                                             10
                                                                             76
                                      233
Building, developing, and general contracting
                                                                              2
                                                                              9
                                                                              5
                                                                              2
                                      448
Clothing and clothing accessories stores
                                                                              1
                                                                              9
                                                                              9
                                                                              1
                                      923
Administration of Human Resource Programs
                                                                              3
                                                                              6
                                                                              2
                                                                             12
                                      524
Insurance carriers and related activities
                                                                              2
                                                                              6
                                                                              3
                                                                              7
                                      814
Private households
                                                                              1
                                                                              5
                                                                              5
                                                                              1
                                      514
Information services and data processing services
                                                                              1
                                                                              2
                                                                              2
                                                                              3
                                      624
Social assistance
                                                                              1
                                                                              2
                                                                              2
                                                                              1
TOTAL
                                                                         14,262
                                                                     34,522,000
                                                                          2,421
                                                                             17
Notes:
   1. Data based on analysis of 2011 BR database.

AS DESCRIBED ABOVE, LQG FACILITIES GENERATE ON AVERAGE APPROXIMATELY 17 WASTE STREAMS PER FACILITY PER YEAR.  HOWEVER, LQG HAZARDOUS WASTE GENERATION DATA IN THE BR ARE HEAVILY SKEWED BASED ON A SMALL NUMBER OF FACILITIES GENERATING THOUSANDS OF DIFFERENT WASTE STREAMS on an annual basis.  Specifically, in the 2011 BR data, half of the LQGs in the potentially affected universe manage five hazardous waste streams each year (the median) or less -- while, in total, facilities generate an average of approximately 17 waste streams (the mean).  Therefore, as described later in Chapter 3, this EA presents a range of cost estimates based on both the median and mean values presented above.
In reporting for the BR, facilities report waste codes for each waste stream to provide information on its contents and properties.  However, the BR data do not include a quantitative analysis of the composition of a waste stream with respect to its reported waste codes (e.g., it does not report what percentage of the waste stream represents waste code F001).  Therefore, it is not possible to determine the exact prevalence of individual constituents in each waste stream.
Exhibit 2-7 describes the percentage of LQG waste streams associated with each waste code category.  As shown in the exhibit, LQGs reported D waste codes for approximately 92 percent of their waste streams in aggregate.  F waste codes and U waste codes account for the next most frequently reported waste codes among LQGs in the BR data.  Expanding on the data reported in Exhibit 2-7, Exhibit 2-8 reports the waste codes that appear in the highest percentage of all LQG waste streams.  As shown in the exhibit, the 12 most frequently reported waste codes are contained in 89 percent of all LQG waste streams.
EXHIBIT 2-7: PERCENTAGE OF LQG WASTE STREAMS CONTAINING INDIVIDUAL WASTE CODE CATEGORIES
                              Waste Code Category
                                      [A]
                          Percentage of Waste Streams
                                    [B][1]
D Waste Codes
92%
F Waste Codes
26%
U Waste Codes
11%
P Waste Codes
4%
K Waste Codes
1%
Lab Packs[2]
1%
TOTAL NUMBER OF LQG WASTE STREAMS IN BR DATA
247,154
Notes:
   1. Waste streams may be comprised of multiple waste codes; therefore rows do not add up to 100 percent.
   2. Facilities may consolidate different types of hazardous waste in small containers and, in some cases, not report individual waste codes.
EXHIBIT 2-8: PERCENTAGE OF LQG WASTE STREAMS CONTAINING MOST FREQUENTLY REPORTED WASTE CODES
                                EPA Waste Code
                                      [A]
                               Waste Description
                                      [B]
                          Percentage of Waste Streams
                                    [C][1]
D001
Ignitable Waste
                                      53%
D002
Corrosive Waste
                                      27%
F003
Non-halogenated Solvents[2]
                                      20%
D007
Chromium
                                      15%
F005
Non-halogenated Solvents[3]
                                      13%
D008
Lead
                                      13%
D035
Methyl Ethyl Ketone
                                      10%
D003
Reactive Waste
                                      9%
F002
Halogenated Solvents[4]
                                      8%
D018
Benzene
                                      8%
D006
Cadmium
                                      7%
D005
Barium
                                      7%
TOTAL ABOVE LISTED WASTE CODES
                                    89%[5]
Notes:
   1. The 2011 BR database contains 247,154 waste stream records for LQGs. Waste streams may be comprised of multiple waste codes; therefore rows do not add up to 100 percent.
   2. F003 wastes include: xylene, acetone, ethyl acetate, ethyl benzene, ethyl ether, methyl isobutyl ketone, n-butyl alcohol, cyclohexanone, and methanol.
   3. F005 wastes include: toluene, methyl ethyl ketone, carbon disulfide, isobutanol, pyridine, benzene, 2-ethoxyethanol, and 2-nitropropane.
   4. F002 wastes include: tetrachloroethylene; methylene chloride; trichloroethylene; 1,1,1-trichloroethane; chlorobenzene; 1,1,2-trichloro-1,2,2-trifluoroethane; ortho-dichlorobenzene; trichlorofluoromethane; and 1,1,2-trichloroethane.