Table 6 2. Distribution of Facilities by Employment for the Petrochemical Industry Employees Per Facility Number of Facilities Percent of Facilities Percent of Total Shipments Value 1 19 11 20.4% 0.1%

20  49 5 9.3% 0.5%

50  99 10 18.5% 4.2%

100  249 13 24.1% 13.0% Table 6 2. Distribution of Facilities by Employment for the Petrochemical Industry Employees Per Facility Number of Facilities Percent of Facilities Percent of Total Shipments Value 19 U. S. Department of Commerce, US Census Bureau, 1997 Economic Census: Bridge Between NAICS and SIC.

6 3 250  499 9 16.7% 25.4%

500 & above 6 11.0% 56.8%

Total 54 100.0% 100.0%

Source: 1997 Census of Manufacturers, USDC.

<IP_ADDRESS>.3 Average Facility Size Annual sales for the average facility was estimated assuming that the largest facilities in the industry were reporting BRS waste quantities. Using this assumption, we estimated average annual sales, based on 1997 Census data, updated to 2001 dollars using the GNP Implicit Price Deflator to be $ 576,357,000.

<IP_ADDRESS> Other Organic Chemical Industry Profile The other organic chemical manufacturers are listed under the NAICS code 325199. This industry is a part of the chemical manufacturing industry ( NAICS 325) and comprises establishments primarily engaged in manufacturing basic organic chemicals ( except petrochemicals, industrial gases, and synthetic dyes and pigments). 19 <IP_ADDRESS>.1 Production and Shipment Values Table 6 3 provides a summary of the estimated U. S. total value of shipments of other organic chemical products for 1997.

Table 6 3. Estimated United States Total Value of Shipments of Other Organic Chemical Products: 1997 YEAR TOTAL VALUE OF SHIPMENTS ($ 1,000)

1997 53,542,377 Source: 1997 Census of Manufacturers, USDC. 20 U. S. Department of Commerce, US Census Bureau, 1997 Economic Census: Bridge Between NAICS and SIC.

6 4 <IP_ADDRESS>.2 Industry Size and Market Share Data used to characterize this industry are from the 1997 Census of Manufacturers and Census Current Industrial reports. The 1997 Census data indicate that there are 676 facilities located in within the U. S., owned by 487 companies. Over 70 percent of all facilities employ fewer than 100 people. While more than half of the industry, in terms of aggregate value of shipments, is dominated by approximately 5 percent of all facilities. A distribution of facilities by number of employees, and their respective share of the total value of shipments is provided in Table 6 4.

Table 6 4. Distribution of Facilities by Employment for the Other Organic Chemicals Industry Employees Per Facility Number of Facilities Percent of Facilities Percent of Total Shipments Value 1 19 251 37.1% 2.5%

20  49 136 20.1% 4.1%

50  99 100 14.8% 8.2%

100  249 118 17.5% 20.4%

250  499 33 4.9% 14.2%

500 & above 38 5.6% 50.6%

Total 676 100.0% 100.0%

Source: 1997 Census of Manufacturers, USDC.

<IP_ADDRESS>.3 Average Facility Size Annual sales for the average facility was estimated assuming that the largest facilities in the industry were reporting BRS waste quantities. Using this assumption, we estimated average annual sales, based on 1997 Census data, updated to 2001 dollars using the GNP Implicit Price Deflator to be $ 185,672,000.

<IP_ADDRESS> Other Inorganic Chemical Industry Profile The other inorganic chemical manufacturers are listed under the NAICS code 325188 ( and SIC 2819). This industry is a part of the chemical manufacturing industry ( NAICS 325) and comprises establishments primarily engaged in manufacturing basic inorganic chemicals ( except industrial gases, inorganic dyes and pigments, alkalies and chlorine and carbon black). 20 <IP_ADDRESS>.1 Production and Shipment Values 6 5 Table 6 5 provides a summary of the estimated U. S. total value of shipments of other inorganic chemical products for 1997.

Table 6 5. Estimated United States Total Value of Shipments of Other Inorganic Chemical Products: 1997 YEAR TOTAL VALUE OF SHIPMENTS ($ 1,000)

1997 17,255,506 Source: 1997 Census of Manufacturers, USDC.

<IP_ADDRESS>.2 Industry Size and Market Share Data used to characterize this industry are from the 1997 Census of Manufacturers and Census Current Industrial reports. The 1997 Census data indicate that there are 638 facilities located in within the U. S., owned by 387 companies. About 28.6 percent of all facilities employ fewer than 100 people. Almost half of the industry, in terms of aggregate value of shipments, is dominated by approximately 5 percent of all facilities. A distribution of facilities by number of employees, and their respective share of the total value of shipments is provided in Table 6 6.

Table 6 6. Distribution of Facilities by Employment for the Other Inorganic Chemicals Industry Employees Per Facility Number of Facilities Percent of Facilities Percent of Total Shipments Value 1 19 330 51.7% 5.9%

20  49 139 21.8% 10.7%

50  99 73 11.4% 12.0%

100  249 63 9.9% 25.5%

250  499 21 3.3% 12.5%

500 & above 12 1.9% 33.4%

Total 638 100.0% 100.0%

Source: 1997 Census of Manufacturers, USDC.

<IP_ADDRESS>.3 Average Facility Size Annual sales for the average facility was estimated assuming that the largest facilities in the industry were reporting BRS waste quantities. Using this assumption, we estimated average 21 U. S. Department of Commerce, US Census Bureau, 1997 Economic Census: Bridge Between NAICS and SIC.

6 6 annual sales, based on 1997 Census data, updated to 2001 dollars using the GNP Implicit Price Deflator to be $ 91,371,000.

<IP_ADDRESS> Inorganic Dye and Pigment Industry Profile Inorganic dye and pigment manufacturers are listed under the North American Industrial Classification ( NAICS) code 325131 ( and SIC 2816 and 2819). The inorganic dye and pigment manufacturers are a part of the chemical manufacturing industry ( NAICS 325) and this industry comprises establishments primarily engaged in manufacturing industrial inorganic chemicals and inorganic pigments. 21 <IP_ADDRESS>.1 Production and Shipment Values Table 6 7 provides a summary of the estimated U. S. total value of shipments of inorganic dye and pigments from 1994  1998.

Table 6 7. Estimated United States Total Value of Shipments of Inorganic Dye and Pigments: 1994  1998 YEAR TOTAL VALUE OF SHIPMENTS ($ 1,000)

1998 2,526,126 1997 2,606,048 1996 2,486,663 1995 2,284,232 1994 2,470,873 Source: U. S. Department of Commerce, Bureau of the Census, Current Industrial Reports, Inorganic Chemicals 1998, MA 325A( 98) 1, February, 2000 <IP_ADDRESS>.2 Industry Size and Market Share Data used to characterize the inorganic dye and pigment industry are from the 1997 Census of Manufacturers and Census Current Industrial reports. The 1997 Census data indicate that there are 74 facilities located in within the U. S., owned by 58 companies. About 65 percent of all 6 7 facilities employ fewer than 100 people. Almost half of the industry, in terms of aggregate value of shipments, is dominated by approximately 6 percent of all facilities. A distribution of facilities by number of employees, and their respective share of the total value of shipments is provided in Table 6 8.

Table 6 8. Distribution of Facilities by Employment for the Inorganic Dye and Pigment Industry Employees Per Facility Number of Facilities Percent of Facilities Percent of Total Shipments Value 1 19 24 32.4% 1.4%

20  49 16 21.6% 4.3%

50  99 8 10.8% 4.4%

100  249 14 18.9% 18.5%

250  499 8 10.8% 27.6%

500 & above 4 5.5% 43.9%

Total 74 100.0% 100.0%

Source: 1997 Census of Manufacturers, USDC.

<IP_ADDRESS>.3 Average Facility Size Annual sales for the average facility was estimated assuming that the largest facilities in the industry were reporting BRS waste quantities. Using this assumption, we estimated average annual sales, based on 1997 Census data, updated to 2001 dollars using the GNP Implicit Price Deflator to be $ 77,556,000.

<IP_ADDRESS> Cyclic Crudes and Intermediates Industry Profile Cyclic crudes and intermediates manufacturers are listed under the NAICS code 325192 ( and under the SIC as industry 2865). The cyclic crudes and intermediates manufacturing industry is a part of the chemical manufacturing industry ( NAICS 325). Establishments in this industry are primarily engaged in manufacturing cyclic organic crudes and intermediates, and organic dyes and pigments. Important products of this industry include: ( 1) aromatic chemicals, such as benzene, toluene, mixed xylenes naphthalene; ( 2) synthetic organic dyes; and ( 3) synthetic organic pigments. 87,345 <IP_ADDRESS>.1 Shipment Values Table 6 9 shows the estimated total value of shipments of cyclic crudes and intermediate products for 1997. 6 8 Table 6 9. Estimated United States Total Value of Shipments of Cyclic Crudes and Intermediate Products: 1997 YEAR VALUE OF SHIPMENTS ($ 1,000)

1997 5,975,157 Source: 1997 Census of Manufacturers, USDC.

<IP_ADDRESS>.2 Industry Size and Market Share Data used to characterize the cyclic crudes and intermediates industry are from the 1997 Census of Manufacturers. The 1997 Census data indicate that there are 50 facilities located in the U. S., owned by 35 companies. Over 60 percent of facilities employ fewer than 100 people. A distribution of facilities by number of employees, and their respective share of the total value of shipments is provided in Table 6 10.

Table 6 10. Distribution of Facilities by Employment for the Cyclic Crudes and Intermediates Industry Employees Per Facility Number of Facilities Percent of Facilities Percent of Total Shipments Value 1 19 12 24.0% 15.7%

20  49 9 18.0% 2.8%

50  99 11 22.0% 5.3%

100  249 7 14.0% 15.8%

250 & above 11 22.0% 60.4%

Total 50 100.0% 100.0%

Source: 1997 Census of Manufacturers, USDC.

<IP_ADDRESS>.3 Average Facility Size Annual sales for the average facility was estimated assuming that the largest facilities in the industry were reporting BRS waste quantities. Using this assumption, we estimated average annual sales, based on 1997 Census data, updated to 2001 dollars using the GNP Implicit Price Deflator to be $ 180,181,000. 22 U. S. Department of Commerce, US Census Bureau, 1997 Economic Census: Bridge Between NAICS and SIC 23 EPA. 1995. EPA Office of Compliance Sector Notebook Project: Profile of the Plastic Resin and Manmade Fiber Industry. EPA/ 310 R 97 006 24 Ibid 6 9 6.1.2 Resin, Synthetic Rubber, and Artificial and Synthetic Fibers and Filaments The Resin, Synthetic Rubber, and Artificial and Synthetic Fibers and Filaments industry ( NAICS 3252) includes a broad range of industries. For the purpose of our analysis, only the Plastic Material and Resin Manufacturing Industry will be examined.

<IP_ADDRESS> Plastic Material and Resin Manufacturing Industry Profile Plastics material and resin manufacturers are listed under the NAICS code 325211 ( and under the SIC as industry 2821). This industry is a sub sector of the chemical manufacturing industry ( NAICS 325). This industry comprises establishments primarily engaged in the manufacturing of synthetic resins, plastics materials, and non vulcanizable elastomers. 22 The plastic resin industry produces resins which are further treated in plastics processing facilities and sold largely to the packaging, building and construction, and consumer markets. Specific product formulations and manufacturing parameters are often kept as trade secrets since the competitiveness of many companies depends on the ability to produce resins with different physical characteristics, such as strength, toughness, and flexibility. 23 Plastic resins are typically broken down into two categories: thermoplastics and thermosets. Thermoplastic resins are resins that can be heated and molded into shapes repeatedly, while thermoset resins are resins that can be heated and molded only once. Thermoplastic resins dominate plastic resin sales and production. In 1994, thermoplastics made up about 90 percent, or 63.3 billion pounds, of plastic resin production by dry weight and accounted for 82 percent, or $ 27.2 billion dollars of the total value of shipments for plastic resin. Commercially important thermoplastics include polyethylene ( all forms), polyvinyl chloride, polypropylene, and polystyrene and are shown in Figure 3. These four thermoplastics make up over 69 percent of plastic resin sales. These thermoplastics are considered general purpose, or commodity plastics since they are usually manufactured in large quantities using well established technology and are typically geared towards a small number of high volume users. 24 <IP_ADDRESS>.1 Production and Shipment Values Table 6 11 shows the estimated U. S. total value of shipments for plastic material and resins for 1997. 6 10 Table 6 11. Estimated United States Total Value of Shipments of Plastic Materials and Resin Products: 1997 YEAR TOTAL VALUE OF SHIPMENTS ($ 1,000)

1997 44,574,918 Source: 1997 Census of Manufacturers, USDC.

<IP_ADDRESS>.2 Industry Size and Market Share Data used to characterize the plastic material and resin manufacturing industry are from the 1997 Census of Manufacturers. The 1997 Census data indicate that there are 532 facilities located in the U. S., owned by 301 companies. Over 70 percent of the of all facilities employ fewer than 100 people. A distribution of facilities by number of employees, and their respective share of the total value of shipments is provided in Table 6 12.

Table 6 12. Distribution of Facilities by Employment for the Plastics Material and Resin Manufacturing Industry Employees Per Facility Number of Facilities Percent of Facilities Percent of Total Shipments Value 1 19 115 21.6% 1.5%

20  49 160 30.1% 6.9%

50  99 114 21.4% 12.1%

100  249 94 17.7% 28.1%

250 & above 49 9.2% 34.4%

Total 532 100.0% 83.0%

Source: 1997 Census of Manufacturers, USDC.

<IP_ADDRESS>.3 Typical Products Important products of this industry include: cellulose plastics materials; phenolic and other tar acid resins; urea and melamine resins; vinyl resins; styrene resins; alkyd resins; acrylic resins; polyethylene resins; polypropylene resins; rosin modified resins; coumarone indene and petroleum polymer resins; miscellaneous resins, including polyamide resins, silicones, polyisobutylenes, 25 U. S. Department of Commerce, US Census Bureau, 1997 Economic Census: Bridge Between NAICS and SIC 26 EPA. 1995. EPA Office of Compliance Sector Notebook Project: Profile of the Pharmaceutical Industry. EPA/ 310 R 97 005 27 U. S. Department of Commerce, Bureau of the Census, Current Industrial Reports, Pharmaceutical Preparations, Except Biologicals, Annual Report 2000, MA 325G( 00) 1, August 2001.

6 11 polyesters, resins, acetyl resins, and fluorohydrocarbon resins; and casein plastics. polycarbonate resins, acetyl resins, and fluorohydrocarbon resins; and casein plastics. 25 <IP_ADDRESS>.4 Average Facility Size Annual sales for the average facility was estimated assuming that the largest facilities in the industry were reporting BRS waste quantities. Using this assumption, we estimated average annual sales, based on 1997 Census data, updated to 2001 dollars using the GNP Implicit Price Deflator to be $ 170,472,000.

6.1.3 Pharmaceutical and Medicine Manufacturing The Pharmaceutical and Medicine Manufacturing Industry ( NAICS 3254) contains a broad range of industries. For the purpose of this analysis the Pharmaceutical Preparations Industry will be examined.

<IP_ADDRESS> Pharmaceutical Preparations Industry Profile Pharmaceutical preparations manufacturers are listed under the North American Industrial Classification NAICS code as 325412 ( SIC 2834 and 2835). This industry is a part of the chemical manufacturing industry ( NAICS 325). The pharmaceutical preparations industry is made up of companies that manufacture, fabricate, and process raw materials into pharmaceutical preparations for human and veterinary uses. Finished products are sold in various dosage forms including, for example, tablets, capsules, ointments, solutions, suspensions, and powders. These are 1) preparations aimed for use mainly by dental, medical, or veterinary professionals, and 2) those aimed for use by patients and the general public. 26 <IP_ADDRESS>.1 Shipment Values The total value of shipments for pharmaceutical preparations in the United States totaled $ 78.9 billion in 2000, a 12 percent increase from $ 70.2 billion in 1999. The leading product category was pharmaceutical preparations that act on the central nervous system and sense organs in humans. Table 6 13 provides a summary of estimated U. S. total value of shipments for pharmaceutical preparations. 27 6 12 Table 6 13. Estimated United States Total Value of Shipments of Pharmaceutical Preparations, Except Biologicals: 2000 and 1999 YEAR VALUE OF SHIPMENTS ($ 1,000)

Total Prescription legend Nonprescription Bulk Shipments 2000 78,907,599 63,768,674 13,999,294 1,139,631 1999 70,171,309 54,669,894 14,411,968 1,089,447 Source: U. S. Department of Commerce, Bureau of the Census, Current Industrial Reports, Pharmaceutical Preparations, Except Biologicals, Annual Report 2000, MA 325G( 00) 1, August 2001.

<IP_ADDRESS>.2 Industry Size and Market Share Data used to characterize the pharmaceutical preparations industry are from the 1997 Census of Manufacturers and Census Current Industrial reports. The 1997 Census data indicate that there are 837 facilities located in within the U. S., owned by 710 companies. More than half of this industry, in terms of aggregate value of shipments, is dominated by only 6 percent of all facilities. Over 70 percent of all facilities employ fewer than 100 people. A distribution of facilities by number of employees, and their respective share of the total value of shipments is provided in Table 6 14.

Table 6 14. Distribution of Facilities by Employment for the Pharmaceutical Preparations Industry Employees Per Facility Number of Facilities Percent of Facilities Percent of Total Shipments Value 1 19 395 47.2% 1.0%

20  49 138 16.5% 1.6%

50  99 85 10.2% 3.7%

100  249 107 12.8% 11.6%

250 & above 112 13.3% 82.1%

Total 837 100.0% 100.0%

Source: 1997 Census of Manufacturers, USDC.

<IP_ADDRESS>.3 Average Facility Size 28 U. S. Department of Commerce, US Census Bureau, 1997 Economic Census: Bridge Between NAICS and SIC 6 13 Annual sales for the average facility was estimated assuming that the largest facilities in the industry were reporting BRS waste quantities. Using this assumption, we estimated average annual sales, based on 1997 Census data, updated to 2001 dollars using the GNP Implicit Price Deflator to be $ 258,378,000.

6.1.4 Nonferrous Metal ( except Aluminum) Production and Processing Industry Profile The nonferrous metal production and processing industry includes a broad range of industries. For the purpose of this analysis we will be focusing on: Primary Smelting and Refining of Copper ( NAICS 331411), Other Nonferrous Metal Primary Smelting and Refining ( NAICS 331419), Secondary Smelting, Refining and Alloying of Copper ( NAICS 331423), and Other Nonferrous Metals Smelting, Refining and Alloying ( NAICS 331492).

<IP_ADDRESS> Primary Smelting and Refining of Copper Industry Profile This industry is listed under the NAICS code 331411 ( SIC 331). This industry is a subsector of the primary metal industry ( NAICS 331). This industry comprises establishments primarily engaged in ( 1) smelting copper ore and/ or ( 2) the primary refining of copper by electrolytic methods or other processes. 28 <IP_ADDRESS>.1 Production and Shipment Values Table 6 15 shows the estimated US total value of shipments for primary smelting an refining of copper products for 1997.

Table 6 15. Estimated United States Total Value of Shipments of Primary Smelting and Refining of Copper Products: 1997 YEAR TOTAL VALUE OF SHIPMENTS ($ 1,000)

1997 6,540,441 Source: 1997 Census of Manufacturers, USDC.

<IP_ADDRESS>.2 Industry Size and Market Share 29 1997 Census of Manufacturers, USDC 30 U. S. Department of Commerce, US Census Bureau, 1997 Economic Census: Bridge Between NAICS and SIC 6 14 Data used to characterize this industry are from the 1997 Census of Manufacturers. The 1997 Census data indicate that there are 16 facilities located in the U. S., owned by 9 companies. A distribution of facilities by number of employees, and their respective share of the total value of shipments is provided in Table 6 16.29 Table 6 16. Distribution of Facilities by Employment for the Primary Smelting and Refining of Copper Industry Employees Per Facility Number of Facilities Percent of Facilities Percent of Total Shipments Value 1 19 1 6.2% N/ A 20  49 1 6.2% N/ A 50  99 0 0.0% N/ A 100  249 3 18.8% N/ A 250  499 11 68.8% 81.8%

Total 16 100.0% 100.0%

Source: 1997 Census of Manufacturers, USDC.

<IP_ADDRESS>.3 Typical Products Establishments in this industry primarily make primary copper and copper based alloys, such as brass and bronze, from ore or concentrates. 30 <IP_ADDRESS>.4 Average Facility Size Annual sales for the average facility was estimated assuming that the largest facilities in the industry were reporting BRS waste quantities. Using this assumption, we estimated average annual sales, based on 1997 Census data, updated to 2001 dollars using the GNP Implicit Price Deflator to be $ 521,876,000. 31 U. S. Department of Commerce, US Census Bureau, 1997 Economic Census: Bridge Between NAICS and SIC 32 1997 Census of Manufacturers, USDC 6 15 <IP_ADDRESS> Other Nonferrous Metal Primary Smelting and Refining Industry Profile This industry is listed under the NAICS code 331419 ( SIC 3339). This industry is a subsector of the primary metal industry ( NAICS 331). This industry comprises establishments primarily engaged in ( 1) making ( i. e., the primary production) nonferrous metals by smelting ore and/ or ( 2) the primary refining of nonferrous metals by electrolytic methods or other processes. 31 <IP_ADDRESS>.1 Production and Shipment Values Table 6 17 shows the estimated US total value of shipments for other nonferrous metal primary smelting and refining products for 1997.

Table 6 17. Estimated United States Total Value of Shipments of Other Nonferrous Metal Primary Smelting and Refining Products: 1997 YEAR TOTAL VALUE OF SHIPMENTS ($ 1,000)

1997 3,538,056 Source: 1997 Census of Manufacturers, USDC.

<IP_ADDRESS>.2 Industry Size and Market Share Data used to characterize this industry are from the 1997 Census of Manufacturers. The 1997 Census data indicate that there are 141 facilities located in the U. S., owned by 128 companies. A distribution of facilities by number of employees, and their respective share of the total value of shipments is provided in Table 6 18.32 Table 6 18. Distribution of Facilities by Employment for the Other Nonferrous Metal Primary Smelting and Refining Industry Employees Per Facility Number of Facilities Percent of Facilities Percent of Total Shipments Value 1 19 76 53.9% 3.2%

20  49 21 14.9% 10.2%

50  99 18 12.8% 11.6%

100  249 13 9.2% 19.3% Table 6 18. Distribution of Facilities by Employment for the Other Nonferrous Metal Primary Smelting and Refining Industry Employees Per Facility Number of Facilities Percent of Facilities Percent of Total Shipments Value 33 U. S. Department of Commerce, US Census Bureau, 1997 Economic Census: Bridge Between NAICS and SIC 34 1997 Census of Manufacturers, USDC. 35 EPA. 1995. EPA Office of Compliance Sector Notebook Project: Profile of the Nonferrous Metal Industry EPA/ 310 R 95 010.

6 16 250  499 13 9.2% 55.7%

Total 141 100.0% 100.0%

Source: 1997 Census of Manufacturers, USDC.

<IP_ADDRESS>.3 Average Facility Size Annual sales for the average facility was estimated assuming that the largest facilities in the industry were reporting BRS waste quantities. Using this assumption, we estimated average annual sales, based on 1997 Census data, updated to 2001 dollars using the GNP Implicit Price Deflator to be $ 74,719,000.

<IP_ADDRESS> The Secondary Smelting, Refining and Alloying of Copper Industry Profile The secondary smelting, refining and alloying of copper are listed under the NAICS code 331423. This industry is a subsector of the primary metal industry ( NAICS 331). This industry comprises establishments primarily engaged in recovering copper and copper alloys from scrap and/ or alloying purchased copper. 33 <IP_ADDRESS>.1 Production and Shipment Values The secondary smelting, refining, and alloying of copper manufacturers industry produces primary forms, such as ingot, wire bar, cake, and slab from copper or copper alloys, such as brass and bronze. 34 According to the Bureau of Mines, U. S. consumption of copper in 1992 was about 2.2 million tons. Consumption rose sharply in 1993 and 1994 to almost 2.7 million tons and is expected to continue to increase throughout the 1990s due to a growing foreign market. However, in 1991, the consumption of refined copper in the U. S. decreased by four percent from 1990 levels. 35 Table 6 19 shows the estimated US total value of shipments for the products in this industry for 1997. 36 1997 Census of Manufacturers, USDC. 37 EPA. 1995. EPA Office of Compliance Sector Notebook Project: Profile of the Nonferrous Metal Industry EPA/ 310 R 95 010.

6 17 Table 6 19. Estimated United States Total Value of Shipments of Secondary Smelting, Refining, and Alloying of Copper Products: 1997 YEAR TOTAL VALUE OF SHIPMENTS ($ 1,000)

1997 1,269,088 Source: 1997 Census of Manufacturers, USDC.

<IP_ADDRESS>.2 Industry Size and Market Share Data used to characterize this industry are from the 1997 Census of Manufacturers. The 1997 Census data indicate that there are 35 facilities located in the U. S., owned by 34 companies. Over 75 percent of all facilities employ fewer than 100 people. 36 A distribution of facilities by number of employees, and their respective share of the total value of shipments is provided in Table 6 20. The secondary copper industry is concentrated in South Carolina, Georgia, Illinois, and Missouri. 37 Table 6 20. Distribution of Facilities by Employment for the Secondary Smelting, Refining and Alloying of Copper Industry Employees Per Facility Number of Facilities Percent of Facilities Percent of Total Shipments Value 1 19 6 17.1% N/ A 20  49 12 34.3% 12.3%

50  99 9 25.7% 31.0%

100  249 8 22.9% 54.9%

Total 35 100.0% 100.0%

Source: 1997 Census of Manufacturers, USDC.

<IP_ADDRESS>.3 Typical Products The secondary smelting, refining, and alloying of copper manufacturers industry produces primary forms, such as ingot, wire bar, cake, and slab from copper or copper alloys, such as brass and 38 EPA. 1995. EPA Office of Compliance Sector Notebook Project: Profile of the Nonferrous Metal Industry EPA/ 310 R 95 010. 39 U. S. Department of Commerce, US Census Bureau, 1997 Economic Census: Bridge Between NAICS and SIC 40 1997 Census of Manufacturers, USDC.

6 18 bronze. In the secondary production of copper, scrap metal goes through pretreatment and smelting. Pretreatment can be accomplished through several different methods, two of which are the hydrometallurgical method and the pyrometallurgical method. Hydrometallurgical technologies differ from pyrometallurgical processes in that the desired metals are separated from undesirable metals using techniques that capitalize on differences between constituent solubilities and/ or electrochemical properties while in aqueous solutions. After pretreatment the scrap goes through the smelting process. Within the United States, the leading end users of copper and copper alloy are the construction and electronic products industry. Transportation equipment also accounts for a fair amount of copper end usage at 11.6 percent. 38 <IP_ADDRESS>.4 Average Facility Size Annual sales for the average facility was estimated assuming that the largest facilities in the industry were reporting BRS waste quantities. Using this assumption, we estimated average annual sales, based on 1997 Census data, updated to 2001 dollars using the GNP Implicit Price Deflator to be $ 68,807,000.

<IP_ADDRESS> Other Nonferrous Metal Secondary Smelting, Refining, Alloying Manufacturing Industry Profile The other nonferrous metal secondary smelting, refining, and alloying manufacturers are listed under the NAICS code 331492 ( SIC 3341). This industry is a subsector of the primary metal industry ( NAICS 331). This industry comprises establishments primarily engaged in alloying purchased nonferrous metals and/ or recovering nonferrous metals from scrap. 39 <IP_ADDRESS>.1 Production and Shipment Values The secondary smelting, refining, and alloying of nonferrous metal manufacturers industry produces primary forms ( e. g., bar, billet, bloom, cake, ingot, slab, slug, wire) using smelting or refining processes. 40 Table 6 21 shows the estimated US total value of product shipments. 41 1997 Census of Manufacturers, USDC.

6 19 Table 6 21. Estimated United States Total Value of Shipments of Other Nonferrous Metal Secondary Smelting, Refining, Alloying Products: 1997 YEAR TOTAL VALUE OF SHIPMENTS ($ 1,000)

1997 3,750,387 Source: 1997 Census of Manufacturers, USDC.

<IP_ADDRESS>.2 Industry Size and Market Share Data used to characterize this industry are from the 1997 Census of Manufacturers. The Census data indicate that there are 252 facilities located in the U. S., owned by 236 companies. Over 85 percent of all facilities employ fewer than 100 people. 41 A distribution of facilities by number of employees, and their respective share of the total value of shipments is provided in Table 6 22.

Table 6 22. Distribution of Facilities by Employment of the Other Nonferrous Metal Secondary Smelting, Refining, Alloying Industry Employees Per Facility Number of Facilities Percent of Facilities Percent of Total Shipments Value 1 19 148 58.7% 8.2%

20  49 48 19.0% 13.5%

50  99 25 9.9% 14.9%

100  249 23 9.1% 46.3%

250  500 6 2.4% N/ A 500 & above 2 0.9% N/ A Total 252 100.0% 100.0%

Source: 1997 Census of Manufacturers, USDC.

<IP_ADDRESS>.3 Typical Products The secondary smelting, refining, and alloying of nonferrous metal manufacturers industry produce primary forms ( e. g., bar, billet, bloom, cake, ingot, slab, slug, wire) using smelting or refining processes. In the secondary production of nonferrous metals, metals are produced from scrap and waste. Two metal recovery technologies are used to make refined metals, pyrometallurgical technology and the hydrometallurgical technology. The four most widely used nonferrous metals in the United States are aluminum, copper, lead, and zinc. Within the United 42 EPA. 1995. EPA Office of Compliance Sector Notebook Project: Profile of the Nonferrous Metal Industry EPA/ 310 R 95 010. 43 U. S. Department of Commerce, US Census Bureau, 1997 Economic Census: Bridge Between NAICS and SIC.

6 20 States, the leading end users of nonferrous metals include the automotive industry, the construction industry, the power storage battery industry, and the electrical and machinery industry. 42 <IP_ADDRESS>.4 Average Facility Size Annual sales for the average facility was estimated assuming that the largest facilities in the industry were reporting BRS waste quantities. Using this assumption, we estimated average annual sales, based on 1997 Census data, updated to 2001 dollars using the GNP Implicit Price Deflator to be $ 56,266,000.

6.1.5 Coating, Engraving, Heat Treating, and Allied Activities The Coating, Engraving, Heat Treating and Allied Activities Industry ( NAICS 3328) contains a broad range of industries. For the purpose of this analysis, The Plating and Polishing Industry will be profiled.

<IP_ADDRESS> Plating and Polishing Industry Profile The plating and polishing industry is listed under the NAICS code for Paints and Coatings as 332813 ( SIC 3471). This industry is a sub sector of the fabricated metal product manufacturing industry ( NAICS 332). The plating and polishing industry is primarily engaged in all types of electroplating, plating, anodizing, coloring, and finishing of metals and formed products for the trade. Also included in this industry are establishments which perform these types of activities, on their own account, on purchased metals or formed products. 43 <IP_ADDRESS>.1 Production and Shipment Values Table 6 23 shows the estimated US total value of shipments for plating and polishing products.

Table 6 23. Estimated United States Total Value of Shipments of Plating and Polishing Products: 1997 YEAR TOTAL VALUE OF SHIPMENTS ($ 1,000)

1997 5,940,626 Source: 1997 Census of Manufacturers, USDC. 6 21 <IP_ADDRESS>.2 Industry Size and Market Share Data used to characterize the plating and polishing industry are from the 1997 Census of Manufacturers. The 1997 Census data indicate that there are 3,399 facilities located in the U. S., owned by 3,282 companies. Over 95 percent of all facilities employ fewer than 100 people. A distribution of facilities by number of employees, and their respective share of the total value of shipments is provided in Table 6 24.

Table 6 24. Distribution of Facilities by Employment for the Plating and Polishing Industry Employees Per Facility Number of Facilities Percent of Facilities Percent of Total Shipments Value 36178 2349 69.1% 19.0%

20 49 674 19.8% 25.6%

50 99 268 7.9% 27.3%

100 249 94 2.8% 20.2%

250 & above 14 0.4% 7.9%

Total 3399 100.0% 100.0%

Source: 1997 Census of Manufacturers, USDC.

<IP_ADDRESS>.3 Average Facility Size Annual sales for the average facility was estimated assuming that the largest facilities in the industry were reporting BRS waste quantities. Using this assumption, we estimated average annual sales, based on 1997 Census data, updated to 2001 dollars using the GNP Implicit Price Deflator to be $ 9,392,000.

6.1.6 Semiconductor and Other Electronic Component Manufacturing The Semiconductor and Other Electronic Component Manufacturing Industry ( NAICS 3344) contains a broad range of industries. For the purpose of this analysis, The Printed Circuit Board Industry will be examined.

<IP_ADDRESS> Printed Circuit Board Industry Profile The printed circuit board industry is listed under the NAICS code as 334412 ( and SIC 3672). The printed circuit board industry is a part of the computer and electronic product manufacturing industry ( NAICS 334). This industry comprises establishments primarily engaged in manufacturing bare ( i. e., rigid or flexible) printed circuit boards without mounted electronic 44 U. S. Department of Commerce, US Census Bureau, 1997 Economic Census: Bridge Between NAICS and SIC.

6 22 components. These establishments print, perforate, plate, screen, etch, or photoprint interconnecting pathways for electric current on laminates. 44 <IP_ADDRESS>.1 Production and Shipment Values Table 6 25 shows the estimated US total value of shipments for printed circuit wire boards.

Table 6 25. Value of Shipments of Printed Circuit Boards: 1995  2000 ( Value in millions of dollars)

YEAR TOTAL VALUE OF SHIPMENTS 2000 11,129 1999 9,150 1998 8,473 1997 8,702 1996 8,217 1995 8,367 Source: U. S. Department of Commerce, Bureau of the Census, Current Industrial Reports, Inorganic Chemicals 1998, MA 334Q( 00) 1, September, 2001 <IP_ADDRESS>.2 Industry Size and Market Share Data used to characterize the printed circuit board industry are from the 1997 Census of Manufacturers and the 2000 Census Current Industrial Report. The 1997 Census data indicate that there are 1,389 facilities located in the U. S., owned by 1,315 companies. Close to 90 percent of all facilities employ fewer than 100 people. A distribution of facilities by number of employees, and their respective share of the total value of shipments is provided in Table 6 26. 6 23 Table 6 26. Distribution of Facilities by Employment for the Printed Circuit Board Industry Employees Per Facility Number of Facilities Percent of Facilities Percent of Total Shipments Value 1 19 801 57.7% 5.2%

20 49 268 19.3% 8.3%

50 99 144 10.4% 11.5%

100 249 114 8.2% 22.6%

250 & above 62 4.4% 52.4%

Total 1,389 100.0% 100.0%

Source: 1997 Census of Manufacturers, USDC.

<IP_ADDRESS>.3 Average Facility Size Annual sales for the average facility was estimated assuming that the largest facilities in the industry were reporting BRS waste quantities. Using this assumption, we estimated average annual sales, based on 1997 Census data, updated to 2001 dollars using the GNP Implicit Price Deflator to be $ 25,240,000.

6.2 Facility Level Impacts In this section an overview of facility level impacts is presented. Impacts are presented for average size facilities profiled in the previous section which reported waste generation in the 1999 Biennial Report database.

Facility revenues were estimated using Census of Commerce data from 1997, updated to 2002 dollars using the GDP Implicit Price Deflator. In order to approximate facility level revenues the assumption was made that only the largest facilities ( in terms of revenue generation) would report waste in the BRS database.

Profitability for these facilities was estimated using data from Robert Morris Associates. Financial data were averaged over a 3 year period ( 1999 2001) for various sizes of facilities in terms of annual sales. All financial data were updated to a 2002 basis using the GDP Implicit Price Deflator. Profitability estimates were developed for various sizes of facilities, expressed as profit before taxes as a percent of sales. With average sales data developed using Census data ( described above), profits before taxes were estimated for average size facilities.

Table 6 27 presents impacts from excluding reclaimed wastes from RCRA jurisdiction if reclaimed on site or reclaimed off site within the same Industry Group ( 4 digit NAICS). Impacts 6 24 for each of the major industries presented are typically less than 0.1 percent of sales. Impacts on profitability are significantly larger, with profitability increasing by as much as 2.9 percent in NAICS 3252 ( Resin, Synthetic Rubber, and Artificial and Synthetic Fibers and Filaments Manufacturing).

Table 6 27. Facility Impacts for Major Industry Groups ( NAICS) 1/

NAICS Number of Facilities Affected Estimated Annual Average Sales 2/ Estimated Annual Profit Before Taxes 3/ Estimated Annual Average Cost Savings 4/ Cost Savings as a Percent of Sales 5/ Cost Savings as a Percent of Profits 6/

3251 302 $ 186,090,000 $ 11,537,000 $ 53,230 0.03% 0.46%

3252 112 $ 179,369,000 $ 6,458,000 $ 185,520 0.10% 2.87%

3254 124 $ 271,863,000 $ 31,264,000 $ 57,330 0.02% 0.18%

3312 152 $ 447,372,000 $ 16,085,000 $ 258,580 0.06% 1.61%

3314 105 $ 119,793,000 $ 4,911,000 $ 29,120 0.02% 0.59%

3328 431 $ 9,882,000 $ 514,000 $ 1,440 0.01% 0.28%

3344 464 $ 26,558,000 $ 1,062,000 $ 24,860 0.09% 2.34%

Other 1038   $ 40,770

NA 165   $ 165,900

NA Not available from BRS 1/ Includes both 1999 and 1997 generators who recycled some portion of their waste. For off site recovery, wastes recovered at facilities in the same Industry Group ( 4 digit NAICS) as the generator and off site outside generatorindustry recycled wastes which are economical to recover on site are included. 2/ Estimated average sales per large quantity generator reporting waste generation in BRS. Calculated as the average value of shipments for the facilities with more than 50 employees as reported in 1997 Census ( updated to 2002 $). 3/ Average 3 year profits in 2002 $ based on Robert Morris Associates data ( 1998 2000) 4/ Based on cost calculations presented in Chapter 5 5/ Annual average cost savings divided by annual average sales 6/ Annual average cost savings divided by annual average profits In addition to these cost savings there will likely be additional savings as facilities in other industries which were not explicitly considered will recycle wastes which are currently disposed. The volume of additional waste which will be recycled will depend on the quality of the waste, 6 25 especially the value/ concentration of the recovered component. Accordingly the above estimates likely understate the total cost reducing impacts.

6.3 Distributional Impacts In addition to the impacts presented in the previous sections there will also be certain distributional impacts, especially resulting from changes in taxes levied on the generation of hazardous waste. State imposed hazardous waste generation taxes and fees have been identified for facilities located in 27 states. These state taxes and fees are listed in Appendix F.

Table 6 28 presents a summary of the estimated decreases in tax revenue resulting from the hazardous waste generation taxes. In total, waste generation taxes will decline by approximately $ 12.2 million for the 27 states analyzed. In addition to the waste generation distributional impacts there will be other distributional impacts stemming from increased corporate income taxes which have not been quantified. No tax effect is included for wastes that are currently being disposed but may be recovered post rule due to the uncertainties about the quality of waste and the total amount which would be recovered.

Table 6 28. Estimated Changes in Hazardous Waste Generation Tax Revenues State 1/ Total Decrease in State Tax Revenue ($/ yr) Number Facilities with Tax Decrease Average Savings per Facility ($/ yr) AR 1,000 1 626 AZ 13,835 21 5,879 CA 2,046,553 47 7,516 CO 19,696 16 1,231 CT 4,678 12 390 GA 29,520 29 1,018 ID 18,152 3 6,051 KS 13,142 9 1,460 KY 104,775 37 2,832 ME 30,051 11 2,732 MN 2,560,691 47 54,483 MO 65,444 23 2,845 MS 2,500 1 2,500 MT 1,800 3 600 Table 6 28. Estimated Changes in Hazardous Waste Generation Tax Revenues State 1/ Total Decrease in State Tax Revenue ($/ yr) Number Facilities with Tax Decrease Average Savings per Facility ($/ yr)

6 26 NC 10,603 37 287 NH 60,674 6 10,112 NJ 21,071 36 585 NM 23,070 2 11,535 NY 648,752 16 40,547 OK 11,754 6 1,959 OR 507,636 31 16,375 SC 538,023 19 28,317 TN 4,500 4 1,125 TX 229,288 61 3,759 VA 9,021 4 2,255 WA 678 15 45 WI 10,707 23 466 6,987,614 520 13,438 1/ Estimates are not included for DE, IL, NE, NV, OH, and WV where further analysis needs to be conducted to determine tax rates. In addition, all potential taxes are not included in the estimates for NY and TX where further analysis is needed to determine tax rates. 45 U. S. EPA, Office of Solid Waste and Emergency Response, " RCRA: Reducing Risk From Waste OSWER," EPA530 K 97 004, September 1997, pp 14 15. 46 U. S. Geological Survey   Minerals Information, " Recycling   Metals," 1996, p. 1. 47 Ibid.

7 1 7.0 BENEFITS Providing exclusions from the RCRA Definition of Solid Waste to generators of metal bearing, solvent, and other wastes ( e. g., acid) that recover wastes either on site or within the same industry, provides an economic incentive for more generators to recover metals, solvents, and acids from wastes instead of placing it in a landfill, reusing it as fuel, or neutralizing the acid and discharging it as wastewater, respectively. In addition, it provides an incentive to generators recovering wastes to continue the practice in markets with fluctuating product values ( e. g., metal prices). Also, depending on the recovery technology implemented, such as, ion exchange, it may promote recycling treated wastewater back into process units. Increased recovery of metals, solvents and other values, such as acid, and treated wastewater may result in a net benefit to both society and the environment.

7.1 Qualitative Benefits Some of the expected benefits include the following:

° Landfill Capacity: Approximately 23 million tons of hazardous waste are land disposed annually. In 1995, 1 million tons of the land disposed hazardous waste were disposed in landfills along with 208 million tons of municipal waste. 45 Available landfill space is limited and as overcapacity issues are eminent, any increase in recycling will lessen the future burden on landfills.

° Resource Conservation: The supply of metals used in processes such as electroplating are ultimately fixed by nature. Many metals are easily recycled and today recycled metals make up a large portion of the available metals supply. For instance, the U. S. Geological Survey reported that in 1996, 78 million metric tons of metals were recycled in the U. S. The value of these recycled metals was estimated to be approximately $ 18 billion. 46 As the U. S. Geological Survey states, " Recycling, a significant factor in the supply of many of the key metals used in our society, provides environmental benefits in terms of energy savings, reduced volumes of waste, and reduced emissions. These reductions, in turn, result in reduced disturbance to land, reduced pollution, and reduced energy use." 47 ° Resource Conservation: In some portions of the United States water is scarce. Technologies such as ion exchange remove metal and other ions from wastewater to concentrations below levels typically achieved by metals precipitation technologies. Treated wastewater from ion exchange technologies can be reused in the electroplating process reducing demand on scarce water resources. 48 Based on the difference between imports and exports of each commodity as reported in Jacqueline A. McClaskey and Stephen D. Smith, " Survey Methods and Statistical Summary of Nonfuel Minerals," U. S. Department of the Interior, Bureau of Mines, 1991. As reported, supra, Note 38, USEPA, p. 134. 49 A strategic metal is a metal which is required for critical military and/ or civilian use and for which the United States is dependent upon from vulnerable sources of supply. As reported, Borst, Paul A., " Recycling of Wastewater Treatment Sludges From Electroplating Operations, F006," USEPA, OSW. 50 Supra, Note 38, pp. 138 139. 51 Borst, Paul A., " Recycling of Wastewater Treatment Sludges From Electroplating Operations, F006," USEPA, OSW.

7 2 ° Metal Recovery: An increase in recycling of domestic metals will lessen the dependance of the United States on foreign metal supplies. In 1991, the United States ran a $ 9.8 billion balance of trade deficit for metal commodities. 48 Copper, nickel, and zinc, three of the most common metals recovered from electroplating waste, accounted for more than $ 2 billion of this total. Additionally, several metal recyclers of F006 waste, which is one of many potential wastes affected by the proposed rule, reported that metal recovery of nickel, chromium and zinc bearing secondary materials was more efficient in terms of conserving energy, and reducing solid waste residuals associated with primary metal/ mineral production. Finally, in its Report to Congress on Metal Recovery, Environmental Regulation and Hazardous Waste, EPA reported that chromium, a strategic metal, 49 is found in sources of secondary materials such as electroplating waste. The report also indicates that these secondary materials are underutilized as a potential source of secondary chromium to reduce U. S. dependence on foreign primary sources. 50 51 ° Solvent/ Acid Recovery: An increase in the recovery of solvents/ acids on site will reduce the amount of energy used and feedstock material used to produce and transport virgin solvents and acids.

7.2 Quantitative Benefits The following salvage value estimates were derived only considering waste currently recovered in 1999 and waste previously recovered in 1997. These salvage values ( revenues) are included in the cost estimates in Section 5. The estimates do not take into consideration that there will be additional benefits beyond those quantified as generators recycle more and more of their waste as a result of the rule.

° Value of Recovered Metal Products: In 1999, plants affected by this rulemaking reported recovering 409,315 tons of metal bearing waste on site and 18,647 tons off site within the same Industry Group. In addition an estimated 168,695 tons of metal bearing waste are recovered off site in other industries, which may be recovered on site due to the potential rule change if it is economically feasible to construct on site recovery facilities. In the analysis, it is assumed that these recovered wastes contain 20 percent recoverable metals. At a $ 4,770 per ton average market price ( assuming a 90 percent assay value) for copper, chromium, and 7 3 nickel, the estimated metal value is $ 569 million. This proposed rule encourages these plants to continue recovering these metals and maintaining these benefits.

Plants that reported recovering wastes in 1997 and not in 1999 recovered 2,778 tons of metalbearing waste on site and 229 tons off site within the same Industry Group. The estimated metal value is $ 2.9 million. In addition, facilities that dispose two waste types ( 48,235 tons of emission control dust  K061, 19,108 tons of metal containing liquids from the printed circuit board industry, and 10,869 tons of spent catalyst from the petroleum refining industry  K171/ K172) are estimated to switch over to on site recovery. In the analysis, it is assumed that these recovered emission control dust wastes contain 15 percent recoverable zinc at $ 643 per ton ( assuming a 90 percent assay value), the metal containing liquids contain 0.02 percent copper at $ 1,397 per ton ( assuming a 90 percent assay value), and the spent catalyst contains five percent molybdenum at $ 23,940 per ton ( assuming a 90 percent assay value). The estimated metal value from these disposed wastes is $ 17.7 million. This proposed rule may encourage these new benefits.

The total estimated recovered metal value is $ 590 million.

° Value of Recovered Solvent Products: In 1999, plants affected by this rulemaking reported recovering 160,119 tons of solvent waste on site and 35,585 tons off site within the same Industry Group. In addition an estimated 72,040 tons of solvent bearing waste are recovered off site in other industries, which may be recovered on site due to the potential rule change if it is economically feasible to construct on site facilities. In the analysis, it is assumed that these recovered wastes contain 67 percent of recoverable solvents. At a $ 1,542 per ton average market price for solvents, assuming 90 percent effectiveness, the estimated solvent value is nearly $ 277 million. This proposed rule encourages these plants to continue recovering these solvents and maintaining these benefits.

Plants that reported recovering wastes in 1997 and not in 1999 recovered 8,448 tons of solvent waste on site and 4,031 tons off site within the same Industry Group. The estimated solvent value is $ 12.9 million if these facilities choose to switch back to solvent recovery instead of off site energy recovery. This proposed rule may encourage these new benefits.

The total estimated recovered solvent value is $ 290 million.

° Value of Other Recovered Products ( Acids and Fluoride): In 1999, plants affected by this rulemaking reported recovering 248,914 tons of " other" waste on site and 5,205 tons off site within the same Industry Group. In addition an estimated 15,952 tons of other waste are recovered off site in other industries, which may be recovered on site due to the potential rule change. In the analysis, it is assumed that these recovered wastes contain 74 percent recoverable acids. At a $ 298 per ton average market price for acid, assuming 90 percent effectiveness, the estimated acid value is over $ 60 million. Other wastes were primarily acids. 52 Note, characteristic sludges and byproducts from recycling processes that are themselves recycled are not solid wastes or hazardous wastes currently ( 40 CFR § 261.2( c)( 3) and would not be under today's proposal.

7 4 This proposed rule encourages these plants to continue recovering these acids and maintaining these benefits.

Plants that reported recovering wastes in 1997 and not in 1999 recovered 16,318 tons of other ( acid) waste on site and 245 tons off site within the same Industry Group. The estimated acid value is $ 3.7 million if these facilities choose to switch back to acid recovery instead of on site acid neutralization. In addition, facilities that dispose two waste types ( 71,698 tons of spent aluminum potliner, K088, and 254,109 tons of spent pickle liquor from the steel works industry) are estimated to switch over to on site recovery. In the analysis, it is assumed that these recovered spent aluminum potliner wastes contain two percent recoverable fluoride at $ 1,240 per ton and the spent pickle liquor contains 74 percent recoverable acids at $ 298 per ton ( assuming a 90 percent assay value). The estimated metal value from these disposed wastes is $ 57.8 million. This proposed rule may encourage these new benefits.

The total estimated recovered acid and fluoride value is $ 122 million.

7.3 Qualitative Discussion of Potential Risk of Hazardous Secondary Materials The Agency acknowledges that some 1.4 million tons of hazardous secondary materials would be no longer subject to regulation as hazardous waste under subtitle C of RCRA under this proposal. As part of this rulemaking, EPA has not evaluated any potential for changes resulting in either higher or lower releases to the environment of hazardous constituents from different handling methods for affected secondary materials. The Agency notes that most hazardous waste that is currently recycled is stored in tanks, containers or buildings prior to the reclamation process. And this practice is likely to continue post rule both because most affected entities have already purchased these storage units and as a means of avoiding legal liability for releases to groundwater from land based units ( materials excluded from RCRA subtitle C regulation if recycled under this proposal would still be considered hazardous wastes if released to the environment and then abandoned). Also, residuals from excluded recycling processes would still be considered hazardous wastes if they exhibit a hazardous characteristic and are discarded. 52 However, residuals from formerly listed hazardous wastes would not be considered hazardous wastes under the derived from rule if recycled under this proposal. In such cases, these residuals could be land disposed in units other than hazardous waste landfills. The Agency has not evaluated the potential for such management of these materials to result in a change in releases to the environment.

The Agency notes that there is the potential for hazardous wastes to be released over time from land based units ( that may or may not result in a risk to human health or the environment). EPA also notes that there is potential risk from extracting natural resources and processing them into goods for public consumption. It is difficult to assess the net 7 5 effects of this proposal on the probability of releases of toxic constituents to the environment. The Agency solicits comment on this question. 8 1 8.0 REFERENCES Anonymous, 1999, Personal Communication, Sun Glo Plating, Florida.

Anonymous, 1999, Personal Communication, Dearborn Brass, Texas.

Bagsarian, Tom, " Cashing in on Steelmaking Byproducts," New Steel Web Extra, March 1999, http:// www. newsteel. com/ features/ NS9903f2. htm Bates, Peter, and Muir, Adrian, " HIsmelt Low Cost Iron Making", Gorham conference June 2000, Commercializing New Hot Metal Process  Beyond the Blast Furnace.

Borst, Paul A., U. S. EPA, Office of Solid Waste, Economic, Methods and Risk Analysis Division, " Recycling of Wastewater Treatment Sludges from Electroplating Operations," F006, 18th AESF/ EPA Pollution Prevention and Control Conference, January 27 29, 1997.

Coplan, Myron J, C. E., " Comments on the Relative Cost of Fluoride from NAF and FSA", http:// www. dartmouth. edu/~ rmasters/ AHABS/ Costof. html Cushnie, George C., CAI Engineering, " Pollution Prevention and Control Technology for Plating Operations," prepared for NCMS/ NAMF.

Environmental Cost Handling Options and Solutions ( ECHOS), Environmental Remediation Cost Data Unit Price, 4th Annual Edition, published by R. S. Means and Delta Technologies Group, Inc., 1998.

Envirosource Technologies corporate webpage, " Summary of Envirosource and the Super Detox Technology for Treatment of Electric Arc Furnace Dust," http:// www. enso. net/ detox. html Finnder, Earl , October 2001, Personal Communication, U. S. Filter.

Furukawa, Tsukasa, " Recovering Zinc and Iron from EAF Dust at Chiba Works," New Steel, June 1997, http:// www. newsteel. com/ features/ NS9706F4. htm Griscom, Frank, " FastMelt! Your Waste to Profit," Midrex 4th Quarter, 1998, www. midrex. com Hazardous Waste Resource Center, January 2002 Landfill Cost Data, www. etc. org.

HIsmelt corporate webpage, http:// www. hismelt. com Hoffman, Glenn E., " Waste Recycling with FastMet and FastMelt," Midrex 4th Quarter, 2000, www. midrex. com 8 2 International Zinc Association ZincWorld organization website, " Concentration, e. g. Waelz Process," http:// www. zincworld. org/ zwo_ org/ Applications/ Zinc/ 031204 pdf. pdf Jarvis, 1999, Personal Communication, Eritech, North Carolina.

Lamancusa, James P., P. E., CEF, " Strategies at a Decorative Chromium Electroplating Facility: On line vs. Off line Recycling," Plating and Surface Finishing, April 1995.

Logistics Management Institute, Hazardous Waste Manifest Cost Benefit Analysis, dated October 2000.

Minnesota Pollution Control Agency, Small and Large Quantity Generator License Fees and Generator ( Superfund) Tax, Waste/ Hazardous Waste # 1.03b, March 2002.

MR3 Systems Incorporated, http:// www. mr3systems. com Remedial Action Cost Engineering and Requirements ( RACER) cost estimating software, 2002 Robert Morris Associates. Annual Statement Studies. Various years including 1999, 2000, and 2001. RMA, One Liberty Place, Philadelphia, PA.

Shields, 1999, Personal Communication, American Nickeloid, Illinois.

Toon, Hohn, " The Cost of Cleaning the Air: Study Shows Permit Application Costs Lower Than Expected  With Key Benefits to Industry", Georgia Tech Research News, September 21, 1999.

Warski, Kristine. SIC vs. NAICS: Understanding the Difference, Miller Brooks Inc.

U. S. Army Corp of Engineers, Public Works Technical Bulletin 200 01 04, dated August 31, 1999 ( USACE Tech Bulletin).

U. S. Army Corps of Engineers, HTRW Center of Expertise Information  TDSF, Section 8.2, obtained from http:// www. environmental. usace. army. mil/ library/ pubs/ tsdf/ sec8 2/ sec8 2. html on September 11, 2002.

U. S. Department of Commerce, US Census Bureau, Development of NAICS, http:// www. census. gov/ epcd/ www/ naicsdev. htm..

U. S. Department of Commerce, Census of Manufacturers, Cyclic Crudes and Intermediates, EC97M 3251I, August 1999.

U. S. Department of Commerce, Census of Manufacturers, Alkalies and Chlorine Manufacturing, EC97M 3251I, September 1999. 8 3 U. S. Department of Commerce, Census of Manufacturers, All Other Basic Inorganic Chemical Manufacturing, EC97M 3251G, October 1999.

U. S. Department of Commerce, Census of Manufacturers, All Other Basic Organic Chemical Manufacturing, EC97M 3251K, November 1999.

U. S. Department of Commerce, 1997 Census of Manufacturers, 1999.

U. S. EPA 1999 and 1997 Hazardous Waste Report ( Biennial Reports).

U. S. EPA, Office of Regulatory Enforcement, Estimating Costs for the Economic Benefits of RCRA Noncompliance, dated September 1994.

U. S. EPA, Economic Assessment of the Revised LDR Treatment Standards for Spent Aluminum Potliner ( K088), prepared by DPRA Incorporated, March 1, 2000.

U. S. EPA, Office of Management and Budget, " Economic Analysis of Federal Regulations under Executive Order 12866" ( OMB Circular A 94), dated January 11, 1996.

U. S. EPA, Regulatory Impact Analysis of the Final Rule for a 180 Day Accumulation Time for F006 Wastewater Treatment Sludges, November 10, 1999 ( F006 180 Day Accumulation Rule).

U. S. EPA, Office of Solid Waste, Economics, Methods and Risk Analysis Division, Unit Cost Compendium ( UCC), prepared by DPRA Incorporated, September 30, 2000.

U. S. EPA  New England, Pilot of the Pollution Prevention Technology Application Analysis Template Utilizing Acid Recovery System prepared by Zero Discharge Technologies, Inc, dated October 1999. A 1 Appendix A Co Proposal Option for the Regulatory Modifications to the Definition of Solid Waste for the Association of Battery Recyclers Notice of Proposed Rulemaking This appendix presents the estimated cost savings ( economic benefits) for a regulatory option referred to as the Co Proposal Option. Under the ( approximately $ 63 million) ( approximately $ 81 million). If facilities construct on site recovery units they qualify for the exclusion under the Co Proposal Option.

Co Proposal Option Incremental Costs ( 2002 $)

Quantity ( tons) Total Costs ($/ year)

On Site Recovery  1999 818,348 ($ 10,962,000)

On Site Recovery  1997 27,544 ($ 16,151,000)

Off Site Recovery Within Industry Group  1999 26,069 ($ 419,000)

Off Site Recovery Within Industry Group  1997 1,059 ($ 905,000) Co Proposal Option Incremental Costs ( 2002 $)

Quantity ( tons) Total Costs ($/ year)

A 2 Off Site Recovery Outside Industry Group Switch to On site Recovery  1999 257,743 ($ 63,346,000)

On Site/ Off Site Disposal Switch to On Site Recovery for Four Waste Types ( K061, K062, K088, and metal containing liquids from printed circuit board industry) 404,019 ($ 80,827,000)

Total 1,534,782 ($ 172,610,000)

Note: Numbers in parentheses, "( )", represent negative costs that reflect revenues or cost savings.

1999 Off site Recovery Quantity NAICS 3254, pharmaceutical and medicine NAICS 3312, steel product manufacturing from purchased steel, recovered 6,700 tons ( 25.8 percent) of the total off site recovery quantity. All of this quantity was managed by metals recovery.

NAICS 3252, resin, synthetic rubber, and artificial synthetic fibers and filaments manufacturing, recovered 2,400 tons ( 9.3 percent) of the total off site recovery quantity. All of this quantity was managed by other recovery.

. A 3 the total off site recovery quantity. Nearly all of this quantity was managed by metals recovery.

The remaining 10 NAICS codes that recover less than 30 tons off site in 1999 account for 95 tons ( 0.36 percent) of the total off site recovery quantity.

Potential Additional Recovery Approximately 1,000 tons of hazardous waste were recovered off site in 1997 but not in 1999 within the same Industry Group ( 4 digit NAICS) by 8 plants within 4 NAICS codes. Facilities that recovered their waste in 1997 and not in 1999 potentially waste under the proposed rule.

One NAICS code recovered 950 tons in 1997 off site but not in 1999. This NAICS code accounts for 90 percent of the total quantity recovered off site. Metals recovery, solvents recovery, and other recovery account for 16 tons, 819 tons, and 225 tons of the total, respectively. Table A 2 presents the quantity of hazardous waste managed off site by NAICS code and . This quantity was managed by metals recovery.

Summary of Potential Cost Savings Incremental cost savings ( post rule costs minus pre rule costs) were estimated for the total number of plants currently recovering wastes in 1999 or recovered wastes in 1997. These plants reclaim metal, solvent and other values from 873,000 tons of waste. The sum of the pre rule costs, post rule costs, and incremental cost savings for all plants are presented in Table A 3 by individual unit cost item. A 4 The potential incremental annual cost savings range from $ 12 million if only 1999 plants benefit to $ 28 million if the plants that recovered wastes in 1997 and not in 1999 switch back to recovery.

For the 1999 on site recovery plants, the total estimated annual cost savings is $ 11 million. This total includes one time ( first year) contingency planning cost savings of $ 0.8 million that likely are sunk and one time notification of exclusion costs of $ 0.5 million. The greatest annual savings result from a portion of the residual quantity generated by the recovery processes being classified as nonhazardous ($ 5.3 million in residual hazardous waste landfill cost savings  $ 3.0 million in new non hazardous waste landfill costs + $ 2.3 million in nonhazardous transportation cost savings = $ 4.6 million in cost savings). The second largest annual cost savings is from a reduction in hazardous materials training costs ($ 2.8 million in cost savings). The third largest annual cost savings is from a reduction in waste characterization testing costs ($ 2.1 million).

For the 1997 on site recovery plants, the total estimated annual cost savings is $ 16.2 million. This total includes one time ( first year) contingency planning cost savings of $ 0.2 million that likely are not sunk because plants are switching management technologies and one time notification of exclusion costs of $ 0.2 million. The greatest annual savings result from a portion of the residual quantity generated by the recovery processes being classified as nonhazardous ($ 4.3 million in pre rule baseline management costs  $ 1.5 million in post rule residual hazardous waste landfill costs  $ 0.2 million in post rule non hazardous waste landfill costs  $ 8.0 million in post rule recovery system costs + $ 2.0 million in nonhazardous transportation cost savings + $ 16.9 million in value from the recovered products = $ 13.5 million in cost savings). The second largest annual cost savings is from a reduction in waste characterization testing costs ($ 1.7 million). The third largest annual cost savings is from a reduction in hazardous materials training costs ($ 0.6 million).

For those 1999 plants that recovered wastes off site within the same 4 digit NAICS, the total estimated annual cost savings is $ 0.4 million. The largest annual cost savings is from a reduction in the cost to transport wastes for recovery because of fewer shipments, i. e., longer storage times ($ 0.15 million in cost savings). The second largest annual savings result from a portion of the residual quantity generated by the recovery processes being classified as nonhazardous ($ 0.28 million in residual hazardous waste landfill cost savings  $ 0.21 million in post rule non hazardous waste landfill costs + $ 0.06 million in nonhazardous transportation cost savings = $ 0.13 million in cost savings). The third largest annual cost savings is from a reduction in hazardous materials training costs ($ 0.07 million).

For those 1997 plants that recovered wastes off site within the same 4 digit NAICS, the total estimated annual cost savings is $ 0.9 million. The greatest annual cost savings is from a portion of the residual quantity generated by the recovery processes being classified as nonhazardous ($ 0.32 million in pre rule hazardous waste management costs  $ 0.11 million in post rule residual hazardous waste landfill costs  $ 0.01 million in post rule non hazardous waste landfill costs  $ 0.22 million in post rule recovery system costs + $ 0.04 million in post rule nonhazardous transportation cost savings  $ 0.09 million in post rule off site recovery transport costs + $ 0.9 million in value from the recovered products = $ 0.83 million in cost savings). The second largest A 5 annual savings result from a reduction in waste characterization testing costs ($ 0.06 million in cost savings). There were no cost savings predicted that would result from a change in generator status from LQG to SQG, etc. ( e. g., decreased training, BRS/ general administrative duty, contingency planning, and initial characterization costs). A 6 Table A 1 Co Proposal Option: 1999 Offsite Recovery Within Same Industry Group ( 4 digit NAICS Code) ( Tons)

NAICS METALS RECOVERY Total Metals SOLVENTS RECOVERY Total Solvents OTHER RECOVERY Total Other TOTALS Code M011 M012 M013 M014 M019 Recovery M021 M022 M023 M024 M029 Recovery M031 M032 M039 Recovery Quantity % Cumulative %

3254 0 14,467 14,467 0 14,467 55.495 55.495 3312 6,734 6,734 0 0 6,734 25.832 81.327 3252 0 0 2,429 2,429 2,429 9.319 90.646 3314 489 242 730 0 0 730 2.802 93.448 3363 0 688 688 0 688 2.638 96.086 3251 0 389 389 121 121 510 1.957 98.043 6113 16 398 414 1 1 0 415 1.591 99.634 3372 0 29 29 0 29 0.111 99.745 3344 12 16 28 0 0 0 28 0.107 99.852 8129 17 17 0 0 17 0.064 99.916 3255 0 15 15 0 15 0.059 99.975 5622 0 0 4 4 4 0.016 99.991 9281 1 1 1 0 0 1 0.005 99.997 3399 0 0 0 0 0 0.002 99.998 3325 0 0 0 0 0 0.001 99.999 9241 0 0 0 0 0 0.001 100.000 3231 0 0 0 0 0 0.000 100.000 TOTAL6,735 0 489 45 657 7,925 15,589 0 0 0 0 15,589 2,429 4 121 2,555 26,069 100.000   A 7 Table A 2 Co Proposal Option: 1997 Offsite Recovery Within Same Industry Group ( 4 digit NAICS Code) ( Tons)

NAICS METALS RECOVERY Total Metals SOLVENTS RECOVERY Total Solvents OTHER RECOVERY Total Other TOTALS Code M011 M012 M013 M014 M019 Recovery M021 M022 M023 M024 M029 Recovery M031 M032 M039 Recovery Quantity % Cumulative %

3251 16 16 803 15 818 116 116 950 89.680 89.680 3312 0 0 94 94 94 8.873 98.552 5417 0 0 0 15 15 15 1.437 99.990 3314 0 0 0 0 0 0.010 100.000 TOTAL 0 16 0 0 0 16 804 0 0 0 15 819 94 0 131 225 1,059 100.000   A 8 Table A 3. Co Proposal Option: Summary of Pre and Post Rule Costs and Incremental Costs Cost Item 1999 Plants 1997 Plants Total Costs ($/ yr)

Pre Rule Costs ($/ yr) Post Rule Costs ($/ yr) Incremental Costs ($/ yr) Pre Rule Costs ($/ yr) Post Rule Costs ($/ yr) Incremental Costs ($/ yr)

On site Recovery Residual Hazardous Landfill Disposal $ 60,719,000 $ 55,431,000 ($ 5,288,000) $ 0 $ 1,525,000 $ 1,525,000 ($ 3,763,000)

Residual Non

Hazardous Landfill Disposal $ 0 $ 2,976,000 $ 2,976,000 $ 0 $ 165,000 $ 165,000 $ 3,141,000 1997 Pre Rule Management ( Hazardous Landfill,

Energy Recovery,

on site Acid Neutralization) $ 0 $ 0 $ 0 $ 4,257,000 $ 0 ($ 4,257,000) ($ 4,257,000)

Pre Rule and Post

Rule Metal/

Solvent/ Acid Recovery $ 167,814,000 $ 167,814,000 $ 0 $ 0 $ 7,953,000 $ 7,953,000 $ 7,953,000 Waste Characterization Testing $ 24,026,000 $ 21,961,000 ($ 2,065,000) $ 3,245,000 $ 1,581,000 ($ 1,664,000) ($ 3,729,000)

Manifesting $ 3,701,000 $ 3,383,000 ($ 318,000) $ 500,000 $ 243,000 ($ 257,000) ($ 575,000)

Loading $ 4,371,000 $ 4,371,000 $ 0 $ 71,000 $ 224,000 $ 153,000 $ 153,000 Waste Transportation $ 23,184,000 $ 20,903,000 ($ 2,281,000) $ 3,749,000 $ 1,734,000 ($ 2,015,000) ($ 4,296,000) Table A 3. Co Proposal Option: Summary of Pre and Post Rule Costs and Incremental Costs Cost Item 1999 Plants 1997 Plants Total Costs ($/ yr)

Pre Rule Costs ($/ yr) Post Rule Costs ($/ yr) Incremental Costs ($/ yr) Pre Rule Costs ($/ yr) Post Rule Costs ($/ yr) Incremental Costs ($/ yr)

A 9 Recovery Transportation $ 0 $ 0 $ 0 $ 0 $ 0 $ 0 $ 0 Salvage Revenue ($ 610,881,000) ($ 610,881,000) $ 0 $ 0 ($ 16,898,000) ($ 16,898,000) ($ 16,898,000)

Hazardous Materials Training $ 7,479,000 $ 4,719,000 ($ 2,760,000) $ 2,291,000 $ 1,659,000 ($ 632,000) ($ 3,392,000)

Manifest Training $ 1,539,000 $ 1,095,000 ($ 444,000) $ 459,000 $ 382,000 ($ 77,000) ($ 521,000)

BRS/ General Administrative Duties $ 1,927,000 $ 1,423,000 ($ 504,000) $ 584,000 $ 473,000 ($ 111,000) ($ 615,000)

One Time Contingency Planning $ 2,072,000 $ 1,252,000 ($ 820,000) $ 640,000 $ 442,000 ($ 198,000) ($ 1,018,000)

Initial Characterization $ 7,066,000 $ 7,066,000 $ 0 $ 1,805,000 $ 1,805,000 $ 0 $ 0 One Time Notification of Exclusion $ 0 $ 542,000 $ 542,000 $ 0 $ 162,000 $ 162,000 $ 704,000 On site Recovery Subtotal ($ 306,983,000) ($ 317,945,000) ($ 10,962,000) $ 17,601,000 $ 1,450,000 ($ 16,151,000) ($ 27,113,000)

Off site Recovery Within the Same Industry Group ( 4 Digit NAICS Code) and Recovery Facilities Do Not Receive Shipments From Multiple NAICS Codes Table A 3. Co Proposal Option: Summary of Pre and Post Rule Costs and Incremental Costs Cost Item 1999 Plants 1997 Plants Total Costs ($/ yr)

Pre Rule Costs ($/ yr) Post Rule Costs ($/ yr) Incremental Costs ($/ yr) Pre Rule Costs ($/ yr) Post Rule Costs ($/ yr) Incremental Costs ($/ yr)

A 10 Table A 3. Co Proposal Option: Summary of Pre and Post Rule Costs and Incremental Costs Cost Item 1999 Plants 1997 Plants Total Costs ($/ yr)

Pre Rule Costs ($/ yr) Post Rule Costs ($/ yr) Incremental Costs ($/ yr) Pre Rule Costs ($/ yr) Post Rule Costs ($/ yr) Incremental Costs ($/ yr)

A 11 Table A 3. Co Proposal Option: Summary of Pre and Post Rule Costs and Incremental Costs Cost Item 1999 Plants 1997 Plants Total Costs ($/ yr)

Pre Rule Costs ($/ yr) Post Rule Costs ($/ yr) Incremental Costs ($/ yr) Pre Rule Costs ($/ yr) Post Rule Costs ($/ yr) Incremental Costs ($/ yr)

A 12 ($ 372,000) [$ 470,000 pre rule and $ 98,000 ($ 166,000) [$ 191,000 pre rule and $ 25,000 ($ 1,552,000) [$ 3,364,000 pre rule and $ 1,812,000 $ 29,000) [$ 393,000 pre rule and $ 364,000 $ 1,581,000). B 1 Appendix B Review of Recycled Waste Quantities by Manufacturing Industries One option considered in the ABR related rulemaking was the limitation that only waste generated by manufacturing industries ( NAICS 31 33) would be excluded as solid waste. This appendix presents a review of the generators of waste, in manufacturing and other industries, so that the impacts of this limitation can be more readily identified.

The following is a summary of findings relating to the waste currently being recycled within the same NAICS code from the 1999 BRS as well as the waste recycled within an industry in 1997, but not recycled in 1999. Given the amount of waste generated in 1997 and 1999, the manufacturing industry, defined by NAICS codes 31 through 33, represents the industry which would be most affected by the ruling. According to the data in Table 1, the manufacturing industry generated 97.5 percent of the total waste generated in 1999 and 88.4 percent of the total waste generated was in 1997.

Table B 1. Total Waste Generation for 1999 and 1997, including Waste Generated by the Manufacturing Industry 1/

Generation Year Total Onsite and Offsite Managed Waste ( tons) Total Onsite and Offsite Managed Waste with NAICS Identified ( tons) Total Waste Generated by the Manufacturing Industry ( tons) Waste Generated by Manufacturers (%) 3/

1999 884,648 678,463 661,180 97.5 1997 2/ 31,957 28,993 25,624 88.4 Total 916,605 707,456 686,804 97.1 1/ Waste quantities recycled ( BRS management codes M011 M039) within the generating industry NAICS. 2/ Waste quantities recycled within an industry in 1997 but not in 1999. 3/ Manufacturers defined by NAICS codes 31 through 33.

Based on the 1999 and 1997 biennial report data, limiting the waste that would be excluded as solid waste would be a relatively minor limitation. Less than three percent of all waste generated would be affected by this limitation. C 1 Appendix C Limitation on Use of Reclaimed Product One option considered in the ABR related rulemaking is the limitation that any reclaimed material will have to be consumed by the same industry ( or facility) that generated the waste. This appendix presents a preliminary review of the potential implications of this option, so that the impacts of this limitation can be more readily identified.

There are broad classes of materials being recovered through recycling that will be affected by any rule revising the definition of solid waste. Products recovered through recycling primarily consist of solvents, metals and acids. This discussion is limited to current on site and off site ( within the same industry) recovery, and wastes recycled off site in industries different from the generator which may be recovered on site as a result of the rule.

It is not expected that waste currently being recycled will be affected by this potential limitation. Waste currently being recovered will likely continue to be recovered. It is expected that without the limitation additional waste will be recovered. The quantity of waste added as a result of the rule will be some component of the waste highlighted in Table 4 7, nearly 700,000 tons. If generators can only take advantage of the revised definition of solid waste if the recovered material is used by the generator, the amount of waste recovered will be less than the amount without the limitation. Unfortunately the total amount of waste which will be recovered with and without the limitation cannot be determined at this time. D 1 Appendix D MEMORANDUM Date: February 4, 2003 To: Paul Borst, EPA/ OSW/ EMRAD Tom Walker, IEc From: Dave Gustafson and Shauna Lehmann, DPRA Re: Recoverable Waste Type Analysis for the Economic Assessment of the Association of Battery Recyclers Proposed Rulemaking; EPA Contract No. 68 W 02 007, WA 1 05 ____________________________________________________________________________

This memorandum presents the results of DPRA's review of the waste stream types reported being recovered in the 1999 BRS. DPRA assumes that based on these recoverable waste types we can search the list of waste streams currently not recovered ( i. e., land disposed or thermally destroyed) that may be recovered under post rule conditions. DPRA limited its initial review of waste streams to those SIC codes that reported recovering more than 30,000 tons either on site or off site in 1999. A more detailed summary of this review is presented in the two sections below. The following table presents a summary of DPRA's recommendations for each SIC reviewed. Based on the waste type commonalities identified from this review we may wish to expand the search for potentially recoverable wastes to include all SIC codes rather than limiting it to the SIC reviewed.

Summary of DPRA Recommendations SIC Code On site Recovery Off Site Recovery 3341 Secondary Smelting Lead Battery Wastes ( D008 waste code) Lead Battery Wastes ( D008 waste code)

2869 Organic Chemicals Organic Liquids ( B201  B219 form codes, except B205 ( oil water emulsion or mixture), B206 ( waste oil), B207 ( concentrated aqueous solution of other organics), B210 ( adhesives or epoxies), and B212 ( reactive or polymerizable organic liquid). Organic Liquids ( B201  B219 form codes, except B205 ( oil water emulsion or mixture), B206 ( waste oil), B207 ( concentrated aqueous solution of other organics), B210 ( adhesives or epoxies), and B212 ( reactive or polymerizable organic liquid); and Spent Carbon ( B404 form code)

2819 Inorganic Chemicals No Recommendations. Not Reviewed (< 30,000 tons). Summary of DPRA Recommendations SIC Code On site Recovery Off Site Recovery D 2 2491 Wood Preserving Chlorophenolic Liquid Wastes ( F032 EPA waste code). Exclude any waste streams with solid or sludge waste form codes. Not Reviewed (< 30,000 tons).

2851 Paints & Allied Products Organic Liquids ( B201  B219 form codes, except B205 ( oil water emulsion or mixture), B206 ( waste oil), B207 ( concentrated aqueous solution of other organics), B210 ( adhesives or epoxies), and B212 ( reactive or polymerizable organic liquid). Not Reviewed (< 30,000 tons).

2834 Pharmaceutical Preparations Organic Liquids ( B201  B219 form codes, except B205 ( oil water emulsion or mixture), B206 ( waste oil), B207 ( concentrated aqueous solution of other organics), B210 ( adhesives or epoxies), and B212 ( reactive or polymerizable organic liquid). Not Reviewed (< 30,000 tons)

3312 Steel Works Spent pickle liquor wastes ( K062 waste code). Note that only one waste stream is reported recovered on site. Approximately five waste streams are shipped off site for recovery. DPRA tentatively recommends pulling nonrecovered waste streams with EPA waste code K062 for evaluation as potentially recoverable waste streams post rule. If neutralization is the common management practice it may not be cost effective to recover this waste. Emission control dust ( K061 waste code).

3672 Printed Circuit Boards Not Reviewed (< 30,000 tons). a.) Metal containing liquid wastes ( B103, B106, or B107 form codes); b.) Lead solder dross waste ( D008 waste code with form codes B304, B307, and B319); c.) electroplating wastewater treatment sludges ( F006 waste code); d.) Solutions containing gold ( F007 waste code); or e.) Solutions containing silver ( D011 waste code).

2911 Petroleum Refining Not Reviewed (< 30,000 tons). Oily Sludges ( B603 form code; may already be exempt if recovered); Spent Carbon ( B404 form code); and Spent Catalysts ( K171 and K172 waste codes)

3691 Storage Batteries Not Reviewed (< 30,000 tons). Lead Battery Wastes ( D008 waste code) Summary of DPRA Recommendations SIC Code On site Recovery Off Site Recovery D 3 2821 Plastic Materials & Resins Not Reviewed (< 30,000 tons). Organic Liquids ( B201  B219 form codes, except B205 ( oil water emulsion or mixture), B206 ( waste oil), B207 ( concentrated aqueous solution of other organics), B210 ( adhesives or epoxies), and B212 ( reactive or polymerizable organic liquid).

On Site Recovery: SIC codes recovering greater than 30,000 tons on site SIC Code 3341: Secondary Smelting and Refining of Nonferrous Metals 98% of the managed quantity has a system type of M011 M019 ( metals recovery). Four waste streams contribute to approximately 88% of the quantity for this system type and are as follows:

Filter Press Cake from Wastewater Treatment System o EPA Code: D008  Lead o Form Code: B319  Other Waste Inorganic Solids o Quantity Managed: 42,972 tons

Battery Components from Lead Acid Storage Batteries o EPA Code: D008  Lead o Form Code: B309  Batteries or battery parts, casings, cores o Quantity Managed: 26,347 tons

Lead Groups from Battery Breaking/ Desulfurization Operation o EPA Code: D008  Lead o Form Code: B309  Batteries or battery parts, casings, cores o Quantity Managed: 21,851 tons

Slag Furnace By Product Solid Originating from Recycling Operations o EPA Code: D008  Lead o Form Code: B304  Other dry ash, slag, or thermal residue o Quantity Managed: 10,645 tons Of the 32 waste streams with metals being recovered on site 22 ( 69%) are reported containing lead ( D008 EPA waste code). Recommend pulling non recovered waste streams within SIC 3341 that potentially contain recoverable amounts of lead ( EPA waste code D008) post rule.

SIC Code 2869: Industrial Organic Chemicals, nec 75% of the managed quantity has a system type of M031 M039 ( other recovery). Three waste streams contribute to approximately 61% of the quantity for this system type and are as follows:

Acidic Process Water D 4 o EPA Code: D002  Corrosive Waste o Form Code: B105  Acidic Aqueous Waste o Quantity Managed: 43,542 tons

EDC Heavy Ends from Ethylene Dichloride Manufacturing o EPA Codes: D028  1,2 Dichloroethane D034  Hexachloroethane D039  Tetrachloroethylene K019  Heavy Ends from the Distillation of Ethylene Dichloride in Ethylene Dichloride Production o Form Code: B219  Other Organic Liquids o Quantity Managed: 13,623 tons

Acid By Product from Production o EPA Code: D002  Corrosive Waste o Form Code: B105  Acidic Aqueous Waste o Quantity Managed: 10,610 tons Even though two of the three largest waste streams are wastewater most waste streams have organic liquid waste form codes ( B201  B219). For waste streams being recovered by other methods on site 13 out of 18 ( 72%) have an organic liquid form code. For waste steams being recovered for solvents on site 12 of 15 ( 80%) have an organic liquid form code. Recommend pulling non recovered waste streams within SIC 2869 that are organic liquid form codes as potentially recoverable post rule. Include all waste streams with B200 form codes except B205 ( oil water emulsion or mixture), B206 ( waste oil), B207 ( concentrated aqueous solution of other organics), B210 ( adhesives or epoxies), and B212 ( reactive or polymerizable organic liquid) which are unlikely to be recoverable.

SIC Code 2819: Industrial Inorganic Chemicals, nec Virtually 100% of the managed quantity has a system type of M011 M019 ( metals recovery). One waste stream contributes to approximately 96% of the quantity for this system type and is as follows:

Rinse Waters, Process Wash Waters, and Rain Water o EPA Codes: D002  Corrosive Waste D008  Lead o Form Code: B106  Caustic Solution with Metals but no Cyanides o Quantity Managed: 68,462 tons No clear search pattern could be determined to identify potential waste streams that may be recovered post rule. DPRA recommends conducting no additional searches for this SIC code. D 5 SIC Code 2491: Wood Preserving 100% of the managed quantity has a system type of M031 M039 ( other recovery). One waste stream contributes to approximately 96% of the quantity for this system type and is as follows:

Wastewater From Wood Preserving Process, Containing Creosote o EPA Codes: F032  Wastewaters, Process Residuals, Preservative Drippage, and Spent Formulations from Wood Preserving Processes Generated at Plants that Currently Use, or Have Previously Used Chlorophenolic Formulations F034  Wastewaters, Process Residuals, Preservative Drippage, and Spent Formulations from Wood Preserving Processes Generated at Plants that Use Creosote Formulations o Form Code: B102  Aqueous Waste with Low Other Toxic Organics o Quantity Managed: 31,067 tons Two of the three waste streams are reported under the F032 EPA waste code. Recommend pulling non recovered waste streams within SIC 2491 that contain the F032 EPA waste code. Exclude any waste streams with solid or sludge waste forms.

SIC Code 2851: Paints and Allied Products 71% of the managed quantity has a system type of M021 M029 ( solvents recovery). Two waste streams contribute to approximately 46% of the quantity for this system type and are as follows:

Spent Solvent o EPA Codes: D001  Ignitable Waste D005  Barium D007  Chromium D008  Lead D035  Methyl ethyl ketone F003  Select List of Spent Non Halogenated Solvents ( see list) F005  Select List of Spent Non Halogenated Solvents ( see list) o Form Code: B201  Concentrated Solvent Water Solution o Quantity Managed: 9,792 tons

Spent Organic Non Halogenated Solvents o EPA Codes: ( same as above) o Form Code: B203  Nonhalogenated Solvent o Quantity Managed: 4,892 tons Most waste streams have organic liquid waste form codes ( B201  B219). For waste streams being recovered for solvents on site 48 out of 53 ( 91%) have an organic liquid form code. Most D 6 waste streams contain F003 or F005 EPA waste codes. Recommend pulling non recovered waste streams within SIC 2851 that are organic liquid form codes as potentially recoverable post rule. Include all waste streams with B200 form codes except B205 ( oil water emulsion or mixture), B206 ( waste oil), B207 ( concentrated aqueous solution of other organics), B210 ( adhesives or epoxies), and B212 ( reactive or polymerizable organic liquid) which are unlikely to be recoverable.

SIC Code 2834: Pharmaceutical Preparations 100% of the managed quantity has a system type of M021 M029 ( solvents recovery). Four waste streams contribute to approximately 95% of the quantity for this system type and are as follows:

( No Waste Description Listed) o EPA Code: D001  Ignitable Waste o Form Code: B203  Nonhalogenated Solvent o Quantity Managed: 10,548 tons

Ignitable Spent Solvent from Pharmaceutical Manufacturing Process o EPA Codes: D001  Ignitable Waste F003  Select List of Spent Non Halogenated Solvents ( see list) o Form Code: B201  Concentrated Solvent Water Solution o Quantity Managed: 8,061 tons

( No Waste Description Listed) o EPA Code: D001  Ignitable Waste o Form Code: B203  Nonhalogenated Solvent o Quantity Managed: 5,742 tons

Ignitable Spent Solvent from Pharmaceutical Manufacturing Process o EPA Codes: D001  Ignitable Waste D038  Pyridine F005  Select List of Spent Non Halogenated Solvents ( see list) o Form Code: B201  Concentrated Solvent Water Solution o Quantity Managed: 8,061 tons Most waste streams have organic liquid waste form codes ( B201  B219). For waste streams being recovered by other methods on site 13 out of 18 ( 72%) have an organic liquid form code. All 12 waste steams being recovered for solvents have an organic liquid form code. Recommend pulling non recovered waste streams within SIC 2851 that are organic liquid form codes as potentially recoverable post rule. Include all waste streams with B200 form codes except B205 ( oil water emulsion or mixture), B206 ( waste oil), B207 ( concentrated aqueous solution of other organics), B210 ( adhesives or epoxies), and B212 ( reactive or polymerizable organic liquid) which are unlikely to be recoverable.

SIC Code 3312: Steel Works, Blast Furnaces, and Rolling Mills D 7 100% of the managed quantity has a system type of M031 M039 ( other recovery). One waste stream contributes 100% of the quantity for this system type and is as follows:

Spent Pickle Liquor HCl from Steel Processing o EPA Codes: D002  Corrosive Waste K062  Spent Pickle Liquor from Steel Finishing Operations of Plants that Produce Iron or Steel o Form Code: B103  Spent Acid with Metals o Quantity Managed: 30,222 tons Recommend pulling non recovered waste streams within SIC 3312 that contain the EPA waste code K062. Note that only one waste stream is reported recovered on site. Approximately five waste streams are shipped off site for recovery. DPRA tentatively recommends pulling non recovered waste streams with EPA waste code K062 for evaluation as potentially recoverable waste streams post rule. If neutralization is the common management practice it may not be cost effective to recover this waste.

Off Site Recovery: SIC codes recovering greater than 30,000 tons off site SIC Code 3312: Steel Works, Blast Furnaces, and Rolling Mills 96% of the shipped quantity has a system type of M011 M019 ( metals recovery). The fifteen highest quantity waste streams contribute to approximately 53% of the total quantity for this system type, and can be summarized by the following:

Emission Control Dust from the Production of Steel in an Electric Arc Furnace o EPA Codes: D006  Cadmium D008  Lead K061  Emission Control Dust/ Sludge from the Primary Production of Steel in Electric Furnaces o Form Codes: B303  Ash, slag, or other residue from incineration of wastes B304  Other dry ash, slag, or thermal residue B306  Dry lime or metal hydroxide solids not fixed B319  Other waste inorganic solids B511  Air pollution control device sludge o Sum of Shipped Quantities: 251,441 tons Most waste streams recovered off site contain the EPA waste code K061. 87 of the 143 ( 61%) of the waste streams contain the K061 waste code. Recommend pulling non recovered waste streams within SIC 3312 that contain the K061 EPA waste code. D 8 SIC Code 3672: Printed Circuit Boards 90% of the shipped quantity has a system type of M011 M019 ( metals recovery). NOTE: there are not many high quantity waste streams for this system type, so it is difficult to determine the major contributing waste streams.

Most waste streams either contain either: a.) form codes B103, B106, or B107; b.) D008 waste code used for solder dross waste with form codes B304, B307, and B319; c.) F006; d.) F007 ( gold solutions); or e.) D011 ( silver solutions). Recommend pulling non recovered waste streams within SIC 3672 that contain one or more of the above codes.

SIC Code 2911: Petroleum Refining 78% of the shipped quantity has a system type of M031 M039 ( other recovery). NOTE: there are not many high quantity waste streams for this system type, so it is difficult to determine the major contributing waste streams.

Waste streams recovered off site by other recovery methods are identified as either oily sludge ( form code B603) or spent carbon ( form code B404). Note, recovery of oily sludge ( form code B603) may already be exempt under prior RCRA regulations. Records were removed in the November, 2002, Economic Assessment if the system type code was M032 ( which includes waste oil recovery). The records remaining on the list have different system type codes ( e. g., M039, other recovery  type unknown). We may wish to remove these records from the analysis given their oily sludge form code ( B603). In addition catalysts are being recovered ( EPA waste codes K171 and K172). Recommend pulling non recovered waste streams within SIC 2911 that are oily sludges ( form code B603) or spent carbon form code B404) as potentially recoverable post rule. In addition pull non recovered waste streams containing EPA waste codes K171 and K172.

SIC Code 2869: Industrial Organic Chemicals, nec 62% of the shipped quantity has a system type of M021 M029 ( solvents recovery). NOTE: there are not many high quantity waste streams for this system type, so it is difficult to determine the major contributing waste streams.

Most waste streams have organic liquid waste form codes ( B201  B219). Recommend pulling non recovered waste streams within SIC 2869 that are organic liquid form codes as potentially recoverable post rule. Include all waste streams with B200 form codes except B205 ( oil water emulsion or mixture), B206 ( waste oil), B207 ( concentrated aqueous solution of other organics), B210 ( adhesives or epoxies), and B212 ( reactive or polymerizable organic liquid) which are unlikely to be recoverable. In addition pull all non recovered waste streams that are spent carbon ( form code B404). D 9 SIC Code 3341: Secondary Smelting and Refining of Nonferrous Metals 53% of the shipped quantity has a system type of M031 M039 ( other recovery). Three waste streams contribute to approximately 98% of the quantity for this system type and can be summarized by the following:

Plastic from Lead Acid Battery Cases Recovered from Battery Breaking Operations o EPA Code: D008  Lead o Form Code: B309  Batteries or battery parts, casings, cores o Sum of Shipped Quantities: 18,251 tons Of the 53 waste streams with metals being recovered off site 27 ( 51%) are reported containing lead ( D008 EPA waste code) primarily from batteries. Recommend pulling non recovered waste streams within SIC 3341 that potentially contain recoverable amounts of lead ( EPA waste code D008) post rule.

SIC Code 3691: Storage Batteries 99% of the shipped quantity has a system type of M011 M019 ( metals recovery). NOTE: there are not many high quantity waste streams for this system type, so it is difficult to determine the major contributing waste streams.

Of the 142 waste streams with metals being recovered off site 116 ( 82%) are reported containing lead ( D008 EPA waste code) primarily from batteries. Recommend pulling non recovered waste streams within SIC 3691 that potentially contain recoverable amounts of lead ( EPA waste code D008) post rule.

SIC Code 2821: Plastic Materials and Resins 82% of the shipped quantity has a system type of M021 M029 ( solvents recovery). NOTE: there are not many high quantity waste streams for this system type, so it is difficult to determine the major contributing waste streams.

Most waste streams have organic liquid waste form codes ( B201  B219). Recommend pulling non recovered waste streams within SIC 2821 that are organic liquid form codes as potentially recoverable post rule. Include all waste streams with B200 form codes except B205 ( oil water emulsion or mixture), B206 ( waste oil), B207 ( concentrated aqueous solution of other organics), B210 ( adhesives or epoxies), and B212 ( reactive or polymerizable organic liquid) which are unlikely to be recoverable. 53 Sippel, 1999, Personal Communication, Noranda, Ontario, Canada. 54 Jarvis, 1999, Personal Communication, Eritech, North Carolina 55 Average distances to landfills and recyclers were previously estimated at 200 and 600 miles, respectively, based on a review of BRS data ( DPRA, 1999. Regulatory Impact Analysis of the Proposed Rule for F006 Wastewater Treatment Sludges). The assumed incremental charge of $ 50 per ton is a proxy for this cost; actual costs would E 1 Appendix E MEMORANDUM Date: November 14, 2002 To: Paul Borst, EPA/ OSW/ EMRAD, Tom Walker, IEc From: Dave Gustafson, and Craig Simons, DPRA Re: Analysis of Market Changes between 1997 and 1999 This memo presents a differential cost analysis between Subtitle C metals recovery and Subtitle C landfill for generators, comparing cost experiences in 1997 versus 1999. Also presented is an overview of the potential market affects regarding decisions to recycle solvent based waste versus sending the wastes to fuel blending.

Within the market things are changing. Currently we assume that since they recycled in the past they will do it in the future. Table 1 presents pricing charts for four key metals, as well as prices for landfilling, price indices for industrial chemicals, and petroleum. With landfill prices increasing,, metals prices decreasing, and solvent prices decreasing, at least between 1997 and 1999, the Agency needs to know what the overall affect is on generators' decision to recycle versus dispose of the wastes generated. The wastes considered are those wastes which may be affected by EPA exclusions, brought about by the ABR court decision. In short, we want to determine how to change the analytical framework for what wastes will be recycled. For example, should the Agency maintain the current assumption that 100 percent of 1997 metal and solvent recovery quantities will switch back to recycling or use some alternative assumption?

During the period from 1997 through 1999 key recyclable metals copper, chromium and nickel experienced price declines ranging from 15 to almost 30 percent, making them less attractive to recycle. However, at least partially offsetting the effect of the metal price declines, landfilling prices increased approximately 25 percent.

To identify how changes in costs may affect recycling versus landfilling decisions we look to the recycling of copper bearing waste, the arrangements for which we know the most about. When this material is sent directly to the smelter, which only happens on a limited basis, the smelter would typically charge a processing fee, which has been reported to range from approximately $ 200 per ton53 to $ 300 per ton. 54 For purposes of this assessment a processing charge of $ 300 per ton is assumed, with an additional charge of $ 50 per ton associated with increased transportation costs. 55 56 Then, depending on the practice of the smelter, payment would be made depend on load sizes, pickup arrangements and other factors. 56 1999 dollar basis, adjusted for 1997 calculations using GDP IPD 57 Sippel, 1999, Personal Communication, Noranda, Ontario, Canada. 58 USGS Mineral Commodity Summaries: Copper, January 2002 59 Environmental Cost Handling Options and Solutions ( ECHOS), Environmental Remediation Cost Data Unit Price, 4th Annual Edition, published by R. S. Means and Delta Technologies Group, Inc., various years.

E 2 to the generator based on the assay value of the copper, which may be approximately 90 percent of the total value. 57 With this construct the breakeven point, above which the material may be attractive from a monetary standpoint, depends heavily on the copper content of the waste, the market price for copper, and the cost for landfilling. As indicated in Table 1, the average price for copper, based on USGS data58 was estimated to be $ 2,140 per ton in 1997 and $ 1,518 per ton in 1999. Subtitle C landfill disposal costs ( with stabilization) are estimated at $ 241 and $ 304 per ton in 1997 and 1999, respectively. 59 The breakeven point for copper bearing sludge, below which the material would be more economical to landfill would be calculated as:

CC = ( R  L) /( C * 0.9)

Where: CC is the copper content of the waste considered for recycling, expressed as a decimal; R is the per ton processing fee charged by the recycler ($ 300) plus incremental transportation costs, assumed to be $ 50, 1999 basis; L is the landfill cost per ton ( Subtitle C with stabilization); C is the price of copper, and 0.9 is the portion of the assay value of the copper in the sludge which is assumed to be paid to the generator.

Given the assumptions presented previously, the breakeven copper content would be approximately 5.2 percent in 1997. In 1999 the breakeven copper content actually falls to 3.4 percent because the affect of the increased cost for landfilling outweighs the decreased price for copper. At least for copper waste, it appears that recycling was more attractive from a monetary standpoint in 1999.

Unfortunately we have not been able to make similar calculations for other metals, most notably nickel, chromium and lead due to a lack of information on recycling arrangements. However we note that the decline in copper prices was far greater, in percentage terms, than for the other metals. Based on this observation it would not seem that the changes in metals prices, when considered in concert with landfill prices, would adversely affect generators decisions regarding recycling their metal bearing wastes. E 3 To examine the cost implications for nickel, chromium and lead generators we use the same general construct as for copper. That is, generators are assumed to pay a fee for recycling and in return are reimbursed for 90 percent of the assay value of the metal in the waste. This is for illustrative purposes only, to show the relative attractiveness of recycling in 1999 versus 1997.

The breakeven recycling charge for these metal bearing wastes, below which the material would be more economical to landfill would be calculated as:

R = L + ( MC * ( M * 0.9))

Where: R is the per ton processing fee charged by the recycler plus incremental transportation costs; L is the landfill cost per ton ( Subtitle C with stabilization); MC is the metal content of the waste considered for recycling, expressed as a decimal; M is the price of the metal, and 0.9 is the portion of the assay value of the metal in the waste which is assumed to be paid to the generator.

For purposes of illustration we consider wastes which have a three percent metal content. Given these assumptions, the results are presented in Table 2. What is notable is that for all of the metals the " breakeven" recycling fee in 1999 would have to be from 4 to 23 percent higher in 1999 versus 1997 for the generator to be more likely to dispose of the waste in a landfill. Stated differently, for nickel wastes, in 1997 the generator would be indifferent between recycling and disposal given a recycling fee of $ 411 per ton. In 1999 this breakpoint would actually increase to a fee of $ 451 per ton. Recycling fees are not at this level and consequently price variations cannot explain the switch in waste management from recycling in 1997 to disposal in 1999.

For solvent bearing wastes the decision to recycle or dispose depends on both the value of the solvents and their value to cement kilns as fuel. As shown in Table 2, industrial chemicals, as measured by the producer price index, declined in value by approximately 6 percent between 1997 and 1999. However residual fuel prices also declined by approximately 8 percent. Consequently the change in prices would not seem to affect generators' decisions to dispose through fuel blending.

In conclusion we recommend that the Agency continue to use the assumption that 100 percent of the 1997 waste streams which went to recycling ( but did not in 1999) would again be sent to recycling as a result of the change in regulatory status for these wastes. We believe it is more likely that additional wastes ( beyond these 1997 wastes) will be recycled because of any regulatory exclusions. In short, the above assumption serves as a conservative proxy. E 4 Table 1. Overview of Prices for Major Recycled Metals, Industrial Chemicals and Land Disposal Commodity Price/ Unit Year 1996 1997 1998 1999 2000 Copper ($/ ton) 2,180 2,140 1,572 1,518 1,764 Nickel ($/ ton) 6,804 6,284 4,200 5,454 7,836 Chromium ($/ ton) 9,500 10,400 9,460 8,860 8,860 Lead ($/ ton) 976 930 906 874 872 Industrial Chemicals ( PPI) 127 126 121 119 129 Subtitle C Landfill ( w. stabilization) ($/ ton) 241 241 304 318 Residual Fuel # 6 ($/ bl) 19 18 13 16 26 Recycling Fee ($/ ton) 350 350 350 350 GDP IPD 0.956 0.974 0.986 1.000 1.023 Sources: Metals Prices form USGS; Industrial Chemicals PPI from Bureau of Econ Analysis; Landfill prices from R. S. Means. E 5 Table 2. Analysis of Breakeven Points for Recycling, 1997 versus 1999 1997 1999 Copper recycling (% cu for breakeven) 5.2% 3.4%

Nickel recycling breakeven fee ( 3% Ni waste) ($/ ton) 411 451 Chromium recycling breakeven fee ( 3% Cr waste) ($/ ton) 522 543 Lead recycling breakeven fee ( 3% Pb waste) ($/ ton) 266 328 F 1 Appendix F State Hazardous Waste Generation Taxes and Fees State imposed hazardous waste generation taxes and fees have been identified for facilities located in 27 states. These state taxes and fees are listed in Table F 1. Further analysis needs to be conducted for eight states identified in the Table F 1 to determine if " recovery" is included under their regulatory definition of " treatment." F 2 Table F 1. State Hazardous Waste Generator Taxes and Fees State Non size Specific Tax or Fee Tax or Fee Size specific Taxes and Fees*

Description LQG > 2,000 tons/ yr LQG 1,000

2,000 tons/ yr LQG 500  1,000 tons/ yr LQG 250  500 tons/ yr LQG 50  250 tons/ yr LQG 13.2 50 tons/ yr SQG 1.3  13.2 tons/ yr CESQG < 1.3 tons/ yr AZ Generators of waste that retain the waste on site for disposal or who ship it off site to a facility owned or operated by that generator $ 4.00/ ton AR Monitoring/ inspe ction fees $ 500/ yr $ 500/ yr $ 500/ yr $ 500/ yr $ 500/ yr $ 500/ yr $ 150/ yr $ 0/ yr CA Generator fee and generator waste reporting surcharge $ 71,432/ yr $ 53,573/ yr $ 35,717/ yr $ 17,858/ yr $ 3,572/ yr $ 1,429/ yr $ 177/ yr $ 0/ yr CO Hazardous waste TSDF annual operating fee ( assumed off site passed on to generator): Class III ( resource recovery) $ 2.50/ ton CT Hazardous waste generator tax $ 9.59/ ton DE Fee for off site treatment. Unclear if treatment equals recovery in this state?

($ 16/ ton) Further Analysis Needed GA Hazardous waste management fee $ 1/ ton $ 1/ ton $ 1/ ton $ 1/ ton $ 1/ ton $ 1/ ton $ 100/ yr $ 0/ yr ID Hazardous waste fee $ 30.00/ ton Table F 1. State Hazardous Waste Generator Taxes and Fees State Non size Specific Tax or Fee Tax or Fee Size specific Taxes and Fees*

Description LQG > 2,000 tons/ yr LQG 1,000

2,000 tons/ yr LQG 500  1,000 tons/ yr LQG 250  500 tons/ yr LQG 50  250 tons/ yr LQG 13.2 50 tons/ yr SQG 1.3  13.2 tons/ yr CESQG < 1.3 tons/ yr F 3 IL Fee for on or off site treatment. Unclear if treatment equals recovery in this state?

($ 7.19/ ton) Further Analysis Needed KS Generator annual monitoring fee $ 5,000/ yr $ 5,000/ yr $ 5,000/ yr $ 1,000/ yr $ 1,000/ yr $ 500/ yr $ 500/ yr $ 100/ yr KY Generator hazardous waste assessment $ 2.00/ ton ( on site)

$ 4.00/ ton ( off site)

ME Off site " handling" fee ( assume handling =

recovery) $ 30.00/ ton MN Quantity fee and tax and statewide program fee $ 3,290/ yr $ 3,290/ yr $ 3,290/ yr $ 3,290/ yr $ 13.50/ ton $ 52.20/ ton $ 115.41/

ton $ 274.72/

ton MS Pollution prevention fee for generators $ 2,500/ yr $ 2,500/ yr $ 1,500/ yr $ 1,500/ yr $ 1,500/ yr $ 500/ yr $ 250/ yr $ 250/ yr MO Hazardous waste fee.

For category tax,

unclear if treatment equals recovery in this state? [$ 0.7 ( ton) 2 +

$ 20/ yr] $ 1.00/ ton MT Generator fee. Did not have " Class"

definition. Assumed middle class/ fee. $ 600.00/ yr Table F 1. State Hazardous Waste Generator Taxes and Fees State Non size Specific Tax or Fee Tax or Fee Size specific Taxes and Fees*

Description LQG > 2,000 tons/ yr LQG 1,000

2,000 tons/ yr LQG 500  1,000 tons/ yr LQG 250  500 tons/ yr LQG 50  250 tons/ yr LQG 13.2 50 tons/ yr SQG 1.3  13.2 tons/ yr CESQG < 1.3 tons/ yr F 4 NE TSDF fee assessment.

Unclear if treatment equals recovery in this state? ($ 1.92/ ton) Further Analysis Needed NV Fee for off site treatment. Unclear if treatment equals recovery in this state?

($ 40.20/ ton) Further Analysis Needed NH Hazardous waste fee $ 60/ ton $ 60/ ton $ 60/ ton $ 60/ ton $ 60/ ton $ 60/ ton $ 60/ ton $ 0/ ton NJ Manifest processing fee ( assumed 18 tons shipped per manifest) $ 0.50/ ton Hazardous waste generator biennial reporting fee and inspection and compliance review fee $ 2,981/ yr $ 2,981/ yr $ 2,981/ yr $ 2,981/ yr $ 2,681/ yr $ 2,428/ yr $ 651/ yr $ 67/ yr NM Generation fee and business fee $ 20/ ton $ 2,500/ yr $ 20/ ton $ 2,500/ yr $ 20/ ton $ 2,500/ yr $ 20/ ton $ 2,500/ yr $ 20/ ton $ 2,500/ yr $ 20/ ton $ 2,500/ yr $ 250/ yr $ 200/ yr $ 100/ yr $ 0/ yr NY Special assessment on off site generation,

treatment or disposal.

Unclear if treatment equals recovery in this state? ($ 16/ ton) Further Analysis Needed Hazardous waste program fees for generators $ 40,000/ yr $ 40,000/ yr $ 20,000/ yr $ 6,000/ yr $ 6,000/ yr $ 1,000/ yr $ 0/ yr $ 0/ yr NC Generator fee $ 0.50/ ton $ 0.50/ ton $ 0.50/ ton $ 0.50/ ton $ 0.50/ ton $ 0.50/ ton $ 25/ yr $ 0/ yr Table F 1. State Hazardous Waste Generator Taxes and Fees State Non size Specific Tax or Fee Tax or Fee Size specific Taxes and Fees*

Description LQG > 2,000 tons/ yr LQG 1,000

2,000 tons/ yr LQG 500  1,000 tons/ yr LQG 250  500 tons/ yr LQG 50  250 tons/ yr LQG 13.2 50 tons/ yr SQG 1.3  13.2 tons/ yr CESQG < 1.3 tons/ yr F 5 OH Hazardous waste treatment and disposal fee. Unclear if treatment equals recovery in this state?

($ 24/ ton) Further Analysis Needed OK Annual fee for off site recycling $ 4.00/ ton Generator fee $ 100/ yr $ 100/ yr $ 100/ yr $ 100/ yr $ 100/ yr $ 100/ yr $ 25/ yr $ 0/ yr OR Annual hazardous waste generation fee $ 45.00/ ton Annual activity verification fee $ 525/ yr $ 525/ yr $ 525/ yr $ 525/ yr $ 525/ yr $ 525/ yr $ 300/ yr $ 0/ yr SC Annual hazardous waste fee Annual nonhazardous waste fee $ 34.00/ ton $ 13.70/ t TN Annual generator fee $ 900/ yr $ 900/ yr $ 900/ yr $ 900/ yr $ 900/ yr $ 900/ yr $ 550/ yr $ 0/ yr TX Facility fee assessment.

Unclear if treatment equals recovery in this state? ($ 4.80/ ton) Further Analysis Needed Generation fee assessment $ 2/ ton $ 2/ ton $ 2/ ton $ 2/ ton $ 2/ ton $ 2/ ton $ 100/ yr $ 100/ yr $ 0/ yr VT Hazardous waste generation fees $ 28.00/ ton WA Hazardous waste education fee $ 35.00/ yr WV Generator fee. Unclear if treatment equals recovery in this state? Further Analysis Needed Table F 1. State Hazardous Waste Generator Taxes and Fees State Non size Specific Tax or Fee Tax or Fee Size specific Taxes and Fees*

Description LQG > 2,000 tons/ yr LQG 1,000

2,000 tons/ yr LQG 500  1,000 tons/ yr LQG 250  500 tons/ yr LQG 50  250 tons/ yr LQG 13.2 50 tons/ yr SQG 1.3  13.2 tons/ yr CESQG < 1.3 tons/ yr F 6 WI Tonnage fee and manifest fee ( assumed 18 tons shipped per manifest) $ 0.26/ ton References: U. S. Army Corps of Engineers, HTRW Center of Expertise Information  TDSF, Section 8.2, obtained from http:// www. environmental. usace. army. mil/ library/ pubs/ tsdf/ sec8 2/ sec8 2. html on September 11, 2002.

Minnesota Pollution Control Agency, Small and Large Quantity Generator License Fees and Generator ( Superfund) Tax, Waste/ Hazardous Waste # 1.03b, March 2002.

* These size categories do not fit for all states. For cost modeling purposes, taxes and fees for states with different size categories are approximate for certain size categories. G 1 Appendix G Example Cost Calculation: 1999 On site Metals Recovery ( 2001 $)

Pre Rule Cost Calculation Post Rule Cost Calculation Cost Inputs Total Quantity of Hazardous Waste Generated 25 tons hazardous waste/ yr Total Quantity of Hazardous Waste Generated ( 25 tons hazardous waste/ yr)  ( 25 tons recovered waste/ yr)+ ( 25 tons recovered waste/ yr* 0.32 fraction as residuals * 0.95 fraction characteristically hazardous) = 7.6 tons hazardous waste/ yr ( recovered waste quantity no longer hazardous by definition)

Generator Status If ( tons hazardous waste/ yr > 13.2 tons/ yr) then LQG Generator Status If ( 1.3 tons/ yr < tons hazardous waste/ yr < 13.2 tons/ yr) then SQG Quantity of Waste Recovered On Site 25 tons recovered waste/ yr Quantity of Waste Recovered On Site 25 tons recovered waste/ yr Estimated Residual Quantity 32% of recovered waste quantity will be residual ( 0.32) * ( 25 tons recovered waste/ yr) = 8 tons residual/ yr Estimated Residual Quantity 32% of recovered waste quantity will be residual ( 0.32) * ( 25 tons recovered waste/ yr) = 8 tons residual/ yr Estimated Hazardous Residual Quantity 100% residual is listed & characteristically hazardous;

( 1.00) * ( 8 tons residual/ yr) = 8 tons hazardous residual/ yr Estimated Hazardous Residual Quantity 95% residual is characteristically hazardous;

( 0.95) * ( 8 tons residual/ yr) = 7.6 tons hazardous residual/ yr Estimated Nonhazardous Residual Quantity 0% residual is nonhazardous;

( 0) * ( 8 tons residual/ yr) = 0 tons nonhazardous residual/ yr Estimated Nonhazardous Residual Quantity 5% residual is nonhazardous;

( 0.05) * ( 8 tons residual/ yr) = 0.4 tons nonhazardous residual/ yr Appendix G Example Cost Calculation: 1999 On site Metals Recovery ( 2001 $)

Pre Rule Cost Calculation Post Rule Cost Calculation G 2 Estimated Recovered Product Quantity 20% of recovered waste quantity will be recovered metals product ( 0.20) * ( 25 tons recovered waste) = 5 tons recovered metal Estimated Recovered Product Quantity 20% of recovered waste quantity will be recovered metals product ( 0.20) * ( 25 tons recovered waste) = 5 tons recovered metal Number of Off site Hazardous Waste Residual Shipments per Year Given LQG then maximum of ( 4 shipments or 8 tons hazardous residual/ 18 tons per truck) = 4 hazardous waste shipments per year Number of Off site Hazardous Waste Residual Shipments per Year Given SQG and > 200 miles then maximum of ( 1.33 shipments or 7.6 tons hazardous residual/ 18 tons per truck) = 1.33 hazardous waste shipments per year Number of Off site Nonhazardous Waste Residual Shipments per Year ( 0 tons nonhazardous residual/ 18 tons per truck) = 0 nonhazardous waste shipments per year Number of Off site Non Hazardous Waste Residual Shipments per Year ( 0.4 tons nonhazardous residual/ 18 tons per truck) = 0.02 nonhazardous waste shipments per year Distance to Nearest Offsite Hazardous Waste Landfill 338 miles Distance to Nearest Offsite Hazardous Waste Landfill 338 miles Distance to Nearest Offsite Non hazardous Waste Landfill 50 miles Distance to Nearest Offsite Non hazardous Waste Landfill 50 miles Location of Generator Oregon Location of Generator Oregon Cost Calculations ( costs are positive and revenues are negative)

On site Metals Recovery Cost ($ 308/ ton) * ( 25 tons recovered waste/ yr) = $ 7,700/ yr On site Metals Recovery Cost ($ 308/ ton) * ( 25 tons recovered waste/ yr) = $ 7,700/ yr Residual Off site Hazardous Landfill Cost maximum( ($ 312/ ton) * ( 8 tons hazardous residual per yr) or ($ 2,246/ load) * ( 4 Hazardous Waste Shipments) = $ 8,984/ yr Residual Off site Hazardous Landfill Cost maximum ( ($ 312/ ton) * ( 7.6 tons hazardous residual per yr) or ( ($ 2,246/ load) * ( 1.33 Hazardous Waste Shipments) = $ 2,987/ yr Residual Off site Nonhazardous Landfill Cost ($ 111/ ton) * ( 0 tons nonhazardous residual per yr) = $ 0/ yr Residual Off site Nonhazardous Landfill Cost ($ 111/ ton) * ( 0.4 tons non hazardous residual per yr) = $ 44/ yr Appendix G Example Cost Calculation: 1999 On site Metals Recovery ( 2001 $)

Pre Rule Cost Calculation Post Rule Cost Calculation G 3 Waste Characterization Testing Cost ($ 1,410/ load) * ( 4 Hazardous Loads + 0 Non Hazardous Load) = $ 5,640/ yr Waste Characterization Testing Cost ($ 1,410/ load) * ( 1.33 Hazardous Loads + 0.02 Non Hazardous Load) = $ 1,903/ yr Manifesting Costs ($ 236/ shipment) * ( 4 shipments/ yr) = $ 944/ yr Manifesting Costs ($ 89/ shipment) * ( 1.35 shipments/ yr) = $ 120/ yr Loading Costs ($ 2.57/ ton) * ( 8 tons residual) = $ 21/ yr Loading Costs ($ 2.57/ ton) * ( 8 tons residual) = $ 21/ yr Residual Waste Transportation Costs ($ 3.73/ mile)*( 4 hazardous waste landfill shipments/ yr)*( 338 miles to hazardous landfill/ hazardous waste shipment) + ($ 2.16/ mile)*( 0 nonhazardous waste landfill shipments/ yr)*( 50 miles to nonhazardous landfill/ nonhazardous waste shipment) = $ 5,047/ yr Transportation Costs ($ 3.73/ mile)*( 1.33 hazardous waste landfill shipments/ yr)*( 338 miles to hazardous landfill/ hazardous waste shipment) + ($ 2.16/ mile)*( 0.02 nonhazardous waste landfill shipments/ yr)*( 50 miles to nonhazardous landfill/ nonhazardous waste shipment) = $ 1,676/ yr Salvage ( Recovered Product) Value ($ 4,770/ ton metal) * ( 5 tons recovered metal/ yr) = $ 23,850/ yr Salvage ( Recovered Product) Value ($ 4,770/ ton metal) * ( 5 tons recovered metal/ yr) = $ 23,850/ yr Hazardous Material Training Cost Given LQG then $ 9,794/ yr Hazardous Material Training Cost Given SQG then $ 2,191/ yr Manifest Training Cost Given LQG then $ 1,828/ yr Manifest Training Cost Given SQG then $ 1,828/ yr Biennial Report/ General Administrative Duties Cost Given LQG then $ 2,430/ yr Biennial Report/ General Administrative Duties Cost Given SQG then $ 1,215/ yr Contingency Planning Cost Given LQG then $ 2,796 Contingency Planning Cost Given SQG then $ 0 Initial Waste Characterization Cost $ 6,160 Initial Waste Characterization Cost $ 6,160 Exclusion Filing Fee ( One time Expenditure) $ 0 Exclusion Filing Fee ( One time Expenditure) $ 639 Appendix G Example Cost Calculation: 1999 On site Metals Recovery ( 2001 $)

Pre Rule Cost Calculation Post Rule Cost Calculation G 4 State Facility Tax/ Fee Given Oregon and LQG then: $ 525 activity verification fee/ yr State Facility Tax/ Fee Given Oregon and SQG then: $ 300 activity verification fee/ yr State Generation Tax/ Fee Given Oregon then: ($ 45 generation fee/ ton)*( 25 tons recovered waste/ yr) = $ 1,125/ yr State Generation Tax/ Fee Given Oregon then: ($ 45 generation fee/ ton)*( 7.6 tons residual/ yr) = $ 342/ yr Total $ 29,144/ yr $ 3,276/ yr Incremental Costs $ 25,868/ yr H 1 Appendix H Example Cost Calculation: 1999 On site Solvents Recovery ( 2001 $)

Pre Rule Cost Calculation Post Rule Cost Calculation Cost Inputs Total Quantity of Hazardous Waste Generated 25 tons hazardous waste/ yr Total Quantity of Hazardous Waste Generated ( 25 tons hazardous waste/ yr)  ( 25 tons recovered waste/ yr)+ ( 25 tons recovered waste/ yr* 0.33 fraction as residuals * 0.85 fraction characteristically hazardous) = 7.0 tons hazardous waste/ yr ( recovered waste quantity no longer hazardous by definition)

Generator Status If ( tons hazardous waste/ yr > 13.2 tons/ yr) then LQG Generator Status If ( 1.3 tons/ yr < tons hazardous waste/ yr < 13.2 tons/ yr) then SQG Quantity of Waste Recovered On Site 25 tons recovered waste/ yr Quantity of Waste Recovered On Site 25 tons recovered waste/ yr Estimated Residual Quantity 33% of recovered waste quantity will be residual ( 0.33) * ( 25 tons recovered waste/ yr) = 8.2 tons residual/ yr Estimated Residual Quantity 33% of recovered waste quantity will be residual ( 0.33) * ( 25 tons recovered waste/ yr) = 8.2 tons residual/ yr Estimated Hazardous Residual Quantity 100% residual is listed & characteristically hazardous;

( 1.00) * ( 8.2 tons residual/ yr) = 8.2 tons hazardous residual/ yr Estimated Hazardous Residual Quantity 85% residual is characteristically hazardous;

( 0.85) * ( 8.2 tons residual/ yr) = 7.0 tons hazardous residual/ yr Estimated Nonhazardous Residual Quantity 0% residual is nonhazardous;

( 0) * ( 8.2 tons residual/ yr) = 0 tons nonhazardous residual/ yr Estimated Nonhazardous Residual Quantity 15% residual is nonhazardous;

( 0.15) * ( 8.2 tons residual/ yr) = 1.2 tons nonhazardous residual/ yr Appendix H Example Cost Calculation: 1999 On site Solvents Recovery ( 2001 $)

Pre Rule Cost Calculation Post Rule Cost Calculation H 2 Estimated Recovered Product Quantity 67% of recovered waste quantity will be recovered solvent product ( 0.67) * ( 25 tons recovered waste) = 16.8 tons recovered solvent Estimated Recovered Product Quantity 67% of recovered waste quantity will be recovered solvent product ( 0.67) * ( 25 tons recovered waste) = 16.8 tons recovered solvent Number of Off site Hazardous Waste Residual Shipments per Year Given LQG then maximum of ( 4 shipments or 8.2 tons hazardous residual/ 18 tons per truck) = 4 hazardous waste shipments per year Number of Off site Hazardous Waste Residual Shipments per Year Given SQG and > 200 miles then maximum of ( 1.33 shipments or 7 tons hazardous residual/ 18 tons per truck) = 1.33 hazardous waste shipments per year Number of Off site Nonhazardous Waste Residual Shipments per Year ( 0 tons nonhazardous residual/ 18 tons per truck) = 0 nonhazardous waste shipments per year Number of Off site Non Hazardous Waste Residual Shipments per Year ( 1.2 tons nonhazardous residual/ 18 tons per truck) = 0.07 nonhazardous waste shipments per year Distance to Nearest Offsite Energy Recovery Facility 577 miles Distance to Nearest Offsite Energy Recovery Facility 577 miles Distance to Nearest Offsite Non hazardous Waste Landfill 50 miles Distance to Nearest Offsite Non hazardous Waste Landfill 50 miles Location of Generator Oregon Location of Generator Oregon Cost Calculations ( costs are positive and revenues are negative)

On site Solvent Recovery Cost $ 43.49 * ( 25 tons recovered waste/ yr) + $ 1,615 = $ 2,703/ yr On site Solvent Recovery Cost $ 43.49 * ( 25 tons recovered waste/ yr) + $ 1,615 = $ 2,703/ yr Residual Off site Energy Recovery Cost maximum(($ 291/ ton) * ( 8.2 tons hazardous residual per yr) or ($ 338/ load) * ( 4 Hazardous Waste Shipments) = $ 2,386/ yr Residual Off site Energy Recovery Cost maximum ( ($ 291/ ton) * ( 7 tons hazardous residual per yr) or ( ($ 338/ load) * ( 1.33 Hazardous Waste Shipments) = $ 2,037/ yr Appendix H Example Cost Calculation: 1999 On site Solvents Recovery ( 2001 $)

Pre Rule Cost Calculation Post Rule Cost Calculation H 3 Residual Off site Nonhazardous Energy Recovery Cost ($ 291/ ton) * ( 0 tons nonhazardous residual per yr) = $ 0/ yr Residual Off site Non Hazardous Energy Recovery Cost ($ 291/ ton) * ( 1.2 tons non hazardous residual per yr) = $ 350/ yr Waste Characterization Testing Cost ($ 1,410/ load) * ( 4 Hazardous Loads + 0 Non Hazardous Load) = $ 5,640/ yr Waste Characterization Testing Cost ($ 1,410/ load) * ( 1.33 Hazardous Loads + 0.07 Non Hazardous Load) = $ 1,974/ yr Manifesting Costs ($ 236/ shipment) * ( 4 shipments/ yr) = $ 944/ yr Manifesting Costs ($ 89/ shipment) * ( 1.40 shipments/ yr) = $ 125/ yr Loading Costs ($ 2.57/ ton) * ( 8.2 tons residual) = $ 21/ yr Loading Costs ($ 2.57/ ton) * ( 8.2 tons residual) = $ 21/ yr Residual Waste Transportation Costs ($ 2.94/ mile)*( 4 hazardous waste shipments/ yr)*( 577 miles to hazardous energy recovery/ hazardous waste shipment) + ($ 2.94/ mile)*( 0 nonhazardous waste shipments/ yr)*( 577 miles to nonhazardous energy recovery/ nonhazardous waste shipment) = $ 6,786/ yr Residual Waste Transportation Costs ($ 2.94/ mile)*( 1.33 hazardous waste shipments/ yr)*( 577 miles to hazardous energy recovery/ hazardous waste shipment) + ($ 2.94/ mile)*( 0.07 nonhazardous waste shipments/ yr)*( 577 miles to nonhazardous energy recovery/ nonhazardous waste shipment) = $ 2,375/ yr Salvage ( Recovered Product) Value ($ 1,543/ ton solvent) * ( 16.8 tons recovered solvent/ yr) = $ 25,922/ yr Salvage ( Recovered Product) Value ($ 1,543/ ton solvent) * ( 16.8 tons recovered solvent/ yr) = $ 25,922/ yr Hazardous Material Training Cost Given LQG then $ 9,794/ yr Hazardous Material Training Cost Given SQG then $ 2,191/ yr Manifest Training Cost Given LQG then $ 1,828/ yr Manifest Training Cost Given SQG then $ 1,828/ yr Biennial Report/ General Administrative Duties Cost Given LQG then $ 2,430/ yr Biennial Report/ General Administrative Duties Cost Given SQG then $ 1,215/ yr Contingency Planning Cost Given LQG then $ 2,796 Contingency Planning Cost Given SQG then $ 0 Initial Waste Characterization Cost $ 6,160 Initial Waste Characterization Cost $ 6,160 Appendix H Example Cost Calculation: 1999 On site Solvents Recovery ( 2001 $)

Pre Rule Cost Calculation Post Rule Cost Calculation H 4 Exclusion Filing Fee ( One time Expenditure) $ 0 Exclusion Filing Fee ( One time Expenditure) $ 639 State Facility Tax/ Fee Given Oregon and LQG then: $ 525 activity verification fee/ yr Given Oregon and SQG then: $ 300 activity verification fee/ yr State Generation Tax/ Fee Given Oregon then: ($ 45 generation fee/ ton)*( 25 tons recovered waste/ yr) = $ 1,125/ yr State Generation Tax/ Fee Given Oregon then: ($ 45 generation fee/ ton)*( 7 tons residual/ yr) = $ 315/ yr Total $ 22,213/ yr $ 1,308/ yr Incremental Costs $ 20,905/ yr E 1 I 2 Appendix I Example Cost Calculation: 1999 On site Acid Recovery ( 2001 $)

Pre Rule Cost Calculation Post Rule Cost Calculation Cost Inputs Total Quantity of Hazardous Waste Generated 30 tons hazardous waste/ yr Total Quantity of Hazardous Waste Generated ( 30 tons hazardous waste/ yr)  ( 30 tons recovered waste/ yr)+ ( 30 tons recovered waste/ yr* 0.26 fraction as residuals * 0.75 fraction characteristically hazardous) = 5.8 tons hazardous waste/ yr ( recovered waste quantity no longer hazardous by definition)

Generator Status If ( tons hazardous waste/ yr > 13.2 tons/ yr) then LQG Generator Status If ( 1.3 tons/ yr < tons hazardous waste/ yr < 13.2 tons/ yr) then SQG Quantity of Waste Recovered On Site 30 tons recovered waste/ yr Quantity of Waste Recovered On Site 30 tons recovered waste/ yr Estimated Residual Quantity 26% of recovered waste quantity will be residual ( 0.26) * ( 30 tons recovered waste/ yr) = 7.8 tons residual/ yr Estimated Residual Quantity 26% of recovered waste quantity will be residual ( 0.26) * ( 30 tons recovered waste/ yr) = 7.8 tons residual/ yr Estimated Hazardous Residual Quantity 100% residual is listed & characteristically hazardous;

( 1.00) * ( 7.8 tons residual/ yr) = 7.8 tons hazardous residual/ yr Estimated Hazardous Residual Quantity 75% residual is characteristically hazardous;

( 0.75) * ( 7.8 tons residual/ yr) = 5.9 tons hazardous residual/ yr Estimated Nonhazardous Residual Quantity 0% residual is nonhazardous;

( 0) * ( 7.8 tons residual/ yr) = 0 tons nonhazardous residual/ yr Estimated Nonhazardous Residual Quantity 25% residual is nonhazardous;

( 0.25) * ( 7.8 tons residual/ yr) = 2.0 tons nonhazardous residual/ yr Appendix I Example Cost Calculation: 1999 On site Acid Recovery ( 2001 $)