1,1-Dichloroethylene [Vinylidene chloride]

1,1,1-Trichloroethane [Methyl chloroform]

1,1,1,2-Tetrachloroethane

1,1,2-Trichloro-1,2,2-trifluoroethane [Freon 113]

1,1,2-Trichloroethane [Vinyl trichloride]

1,1,2,2-Tetrachloroethane

1,2-Dichlorobenzene [o-Dichlorobenzene]

1,2-Dichloroethane [Ethylene dichloride]

1,2-Dichloroethylene, mixed isomers

1,2-Dichloropropane [Propylene dichloride]

1,2,3-Trichloropropane

1,2,3,4-Tetrahydronaphthalene [Tetralin]

1,2,4-Trichlorobenzene

1,2,4-Trimethylbenzene [Pseudocumene]

1,2,4,5-Tetrachlorobenzene

1,3-Butadiene

1,3-Butylene glycol

1,3-Dichloro-2-butene

1,3-Dichlorobenzene [m-Dichlorobenzene]

1,3-Dichloropropene [1,3-Dichloro-1-propene][mixed isomers]

1,3-Dimethyl-2-imidazolidinone [N,N'-Dimethylethylene urea]

1,3-Pentadiene

1,3,3-Trichloropropene

1,3,5-Trimethyl-2,4,6-tris-(3,5-di-tert-butyl-4hydroxybenzyl)    benzene

1,4-Butanediol

1,4-Cyclohexanedimethanol

1,4-Dichloro-2-butene, mixed isomers

1,4-Dichlorobenzene [p-Dichlorobenzene]

1,4-Dioxane [1,4-Diethyleneoxide]

1,4-hexadiene, (Z)-

1,4-Pentadiene

1,5-Cyclooctadiene

1,5-Pentanediol

1,6-Hexamethylene diisocyanate

1,6-Hexanediol [Hexamethylene glycol]

2'-Hydroxy acteophenone

2- Chloroethanol [Ethylene chlorohydrin]

2-Acetylaminofluorene [2-AAF]

2-Benzotriazol

2-Butanol [sec-Butanol]

2-Butoxyethanol [Butyl cellosolve][Ethylene gycol monobutyl    ether]

2-Butyne-1,4-diol

2-Butyne [Crotnylene]

2-Chloronaphthalene [beta-Chloronaphthalene]

2-Chlorophenol [o-Chlorophenol]

2-Ethoxyethanol acetate [2-EEA][Cellosolveacetate]

2-Ethoxyethanol [Ethylene glycol monoethyl ether][Cellosolve]

2-Ethyl-1-hexanol

2-Ethyl-1,3-butylene glycol

2-Ethyl-1,3-propanediol

2-Ethylhexanal

2-Hexanone

2-Hydroxyethyl methacrylate [Glycol methacrylate]

2-Mercaptoethanol

2-Methoxy-1-propyl acetate

2-Methoxyethanol [Ethylene glycol monomethyl ether]

2-Methyl-1-butene

2-Methyl-2-butene [Amylene]

2-Methyl-2-propanethiol [tert-Butyl mercaptan]

2-Methyl-2,4-pentanediol [Hexylene glycol]

2-Methyl pentane

2-Methylhexane

2-Methylnaphthalene

2-Nitroaniline [o-Nitroaniline]

2-Nitrobenzoic Acid

2-Nitrophenol [o-Nitrophenol]

2-Nitropropane

2-Pentanol

2-Pentene [Beta-N-amylene]

2-Picoline [alpha-Picoline][2-Methylpyridine]

2-Propanol [Isopropyl alcohol][Isopropanol]

2-(3-Isobutyl phenyl) proprionic acid

2-(4-Isobutyl phenyl) proprionic acid [Ibuprofen]

2 B-3 Alcohol

2,2'-Methylene bis(6-tert-butyl phenol)

2,2-Dimethylbutane

2,2,4-Trimethylpentane [Iso-octane]

2,3-Diamino toluene [2,3-Toluenediamine]

2,3-Dichloro-1-propene

2,3-Dichlorobutane

2,3-Dimethyl butane

2,3,4,6-Tetrachlorophenol

2,4- and 2,6-Toluene diisocyanate mixture

2,4-D [2,4-Dichlorophenoxyacetic acid]

2,4-di-tert-Butylphenol

2,4-Dichlorophenol

2,4-Dimethyl-4-Vinyl Cyclohexene

2,4-Dimethylphenol

2,4-Dinitrophenol

2,4-Dinitrotoluene

2,4-Toluene diisocyanate

2,4-Toluenediamine [2,4-Diaminotoluene]

2,4,5-Trichlorophenol

2,4,6-Di-tert-butylphenol

2,4,6-Trichlorophenol

2,5-Di-tert-amylhydroquinone [2,5-Di-tert-pentylhydroquinone]

2,6-Di-tert-butyl-p-cresol

2,6-Dichlorophenol

2,6-Dinitrotoluene

2,6-Toluene diisocyanate

2,6-Toluenediamine [2,6-Diaminotoluene]

3-Methyl-1,4-pentadiene

3-Methyl-2-butanone [Methyl isopropyl ketone]

3-Methyl pentane

3-Methyl pyridine [beta-Picoline]

3-Nitro-o-xylene

3-Nitroaniline [m-Nitroaniline]

3-Pentanol

3-Pentanone [Diethyl ketone]

3-(4-Isobutyl phenyl) proprionic acid

3-(Dimethylamino)propylamine

3-(Triethoxysilyl)-1-propanamine [3-Aminopropyl)    triethoxysilane]

3,3'-Dichlorobenzidine

3,3-Dichloropropene

3,3,3-Trichloro-2-Metyl-1-Propene

3,4-Dichlorobutene-1

3,4-Toluenediamine [3,4-Diaminotoluene]

4'-Isobutyl acetophenone

4-Acetoxy acteophenone

4-alpha-Cumylphenol

4-Bromophenyl phenyl ether [p-Bromo diphenyl ether]

4-Chlorophenyl phenyl ether

4-Hydroxy acetophenone

4-Isobutyl ethyl benzene

4-Isobutyl phenyl ethenol

4-Isobutyl styrene

4-Methyl morpholine

4-Nitro-o-xylene

4-Nitroaniline [p-Nitroaniline][4-Nitrobenzenamine]

4-Nitrophenol [p-Nitrophenol]

4-Vinylcyclohexene

4-(Diglycidamino) phenyl glycidyl ether

4,4'-Methylene-bis-(2,6-diethylaniline)

4,4'-Methylene bis(2-chloroaniline)

4,4'-Methylene diphenyl diisocyanate
[MDI][Methylenebis(phenylisocyante)]

4,4'-Methylenedianiline [p,p'-Diaminodiphenylmethane][MDA]

4,4'-Thiobis(6-tert-butyl)phenol

4,6-Dinitro-o-cresol [4,6-Dinitro-2-methyl phenol]

7,12-Dimethylbenz[a]anthracene

Acenaphthene

Acenaphthylene

Acetaldehyde [Ethanal]

Acetamide

Acetates

Acetic acid

Acetic anhydride

Acetone [2-Propanone]

Acetonitrile [Methyl cyanide]

Acetophenone

Acetyl chloride

Acetylene

Acridine

Acrolein [2-Propenal]

Acronitrile-Butadiene-Styrene Polymer

Acronitrile-Butadiene Polymer

Acrylamide

Acrylic acid

Acrylic Copolymer

Acrylonitrile [2-Propenenitrile]

Acryloyl chloride

Adiponitrile [Hexanedinitrile]

Al Compounds

Alcohol Sd No.3a Absolute

Aldrin

Alkyl benzenes

Alkyl naphthalenes

Alkylalkanolamines

Allyl alcohol

Allyl chloride [3-Chloropropylene][3-Chloropropene]

Allyl methacrylate

alpha-Hexachlorocyclohexane [alpha-BHC]

alpha-Methylstyrene

alpha-Pinene Polymers

Aluminum

Aluminum chloride hexahydrate

Aluminum silicate

Aluminum silicate, hydrated

Ammonia, gas

Ammonium acetate

Ammonium Acetone Disulfonate

Ammonium bicarbonate

Ammonium chloride

Ammonium hydroxide [Ammonia solution]

Ammonium oxides

Ammonium phosphate

Ammonium sulfate

Ammoniun phosphate, dibasic

Amyl acetate

Aniline

Anthracene

Antimony

Antimony trioxide

Aroclor 1242 [PCB 1242]

Aromatic 200

Arsenic

Ash

Atrazine

Azeo Oil

Barium

Barium metaborate

Barium Oxide

Barium sulfate

Bentone 38 organophillic clay

Benzal chloride [Dichloromethyl benzene]

Benzene

Benzoic acid

Benzophenone

Benzoyl peroxide

Benzo(a)pyrene

Benzo(b)fluoranthene

Benzo(k)fluoranthene

Benzo[g,h,i]perylene

Benzyl alcohol

Benzyl chloride

Benz[a]anthracene

Beryllium

Beta-cis-amylene [2-Pentene-cis]

beta-Hexachlorocyclohexane [beta-BHC]

beta-Myrcene

beta-Pinene, alpha-Pinene

beta-Pinine Polymer

Bis-(2-chloroethoxy)methane [Dichloromethoxy ethane]

Bismuth

Bisphenol A-Epichlorohydrin copolymer

Bisphenol A diglycidyl ether [Epoxide A]

Bisphenol A [2,2-bis(4-hydroxyphenyl)propane)]

Bis(2-chloroethyl) ether [Dichloroethyl ether]

Bis(2-chloroisopropyl) ether [2,2'-Oxybis(2-chloropropane)]

Bis(2-ethylhexyl) phthalate [Di-2-ethylhexyl phthalate]

Brass Foundry/Silica

Bromine

Bromodichloromethane [Dichlorobromomethane]

Bromoform [Tribromomethane]

Bromomethane [Methyl bromide]

Brown/Red Clay

BTEX

Butyl benzyl phthalate

Butyl glycolate

Butyl methacrylate [2-Methyl butyl acrylate]

Butyric acid [Butanoic acid]

C12-C20 Parrafins

C4-6 Dicarbonic acid, mixture

C6-C12 Aliphatics

C6 Alkenes/Alkenes

C9-C10 Alkyl Benzenes

Cadmium

Cadmium hydroxide

Cadmium sulfide

Calcium

Calcium carbonate

Calcium chloride

Calcium hydroxide

Calcium nitrate

Calcium oxide

Calcium resinate

Calcium sulfate

Calcium zinc resinate

Caprolactam

Caprylene [1-Octene]

Carbazole

Carbon

Carbon black

Carbon dioxide

Carbon disulfide

Carbon monoxide

Carbon tetrachloride

Carboxy Methyl Cellulose

Catalyst Tlf 2370c

Catechol

CD-dimers

Cellite

Cellulose

Cement

Chlordane

Chlorine

Chloroacetone

Chlorobenzene

Chlorobutanes

Chloroethane [Ethyl chloride]

Chloroform

Chloromethane [Methyl chloride]

Chloroprene-Sulfur polymer

Chloroprene [2-Chloro-1,3-butadiene]

Chlorothalonil

Chlorotoluene, mixed isomers

Chromium

Chromium oxide

Chromium trioxide

Chrysene

CI Pigment Blue 15 [Copper Phthalocyanine]

CI Pigment Green 36

CI Pigment Green 7

CI Pigment Yellow 14 [Benzidine yellow OT]

cis-1,2-Dichloroethylene

cis-1,3-Dichloropropylene [cis-1,3-Dichloropropene]

cis-4-Methyl-2-pentene

cis-Polybutadiene

Clay

Coal tar creosote

Cobalt

Concrete

Copper

Copper acetylide

Creosote

Cresols, mixed isomers

Crotonaldehyde

Crotonaldehyde, trans- stereoisomer

Crude Oil Soilds (Parrefins)

Crushed Drums

Cryolite [Sodium aluminofluoride]

Cumene [Isopropyl benzene]

Cyanides

Cyanides (Amenable)

Cyanides (Cyanohydrins)

Cyanogen bromide [Bromine cyanide]

Cyclohexane

Cyclohexanol

Cyclohexanone

Cyclohexylamine

Cyclopentadiene

Cyclopentane

D-Limonene

Dacthal [2,3,5,6-Tetrachloroterephthalic acid][DCPA]

Decalin

delta-Hexachlorocyclohexane [delta-BHC]

Deuterated Toluene

Di-n-butyl phthalate

Di-n-butylether [n-Butyl ether]

Di-n-octyl phthalate

Diacetone alcohol

Dibenzofuran

Dibenz(a,h)anthracene

Dibromochloromethane [Chlorodibromomethane]

Dichlorobenzene, mixed isomers

Dichlorodifluoromethane [CFC-12]

Dichloropropane, mixed isomers

Dicyanodiamide

Dicyclopentadiene

Dieldrin

Diethyl phthalate

Diethylene glycol-trimethylpropane-adipate polymer

Diethylene glycol dimethyl ether [Diglyme]

Diethylene glycol monobutyl ether [Butyl carbitol]

Diethylene glycol monomethyl ether [Methyl Carbitol]

Diethylenetriamine

Diisobutyl ketone [Isobutyl ketone]

Diisopropylfluorophosphate [DFP]

Dimethyl adipate

Dimethyl disulfide

Dimethyl gluterate [Pentanedioic acid, dimethyl ester]

Dimethyl hydrogen phosphite [Phosphonic acid, dimethyl ester]

Dimethyl methyl phosphonate

Dimethyl naphthalene

Dimethyl phthalate

Dimethyl succinate [Butanedioic acid, dimethyl ester]

Dimethyl sulfate

Dimethyl sulfide [Methyl sulfide][Thiobismethane]

Dimethyl sulfoxide

Dinitro-o-xylenes (3,4 & 3,5)

Dinitrotoluene, mixed isomers

Dinitroxylenols

Dinoseb [2-sec-Butyl-4,6-dinitrophenol]

Diphenyl ether [diphenyl oxide]

Diphenylamine

DIPRENE

Dipropylene glycol methyl ether

Dirt/Sand/Soil/Rocks/Gravel/Debris

Distillates, petroleum, solvent-refined light paraffinic

Disulfoton

Ditrimethylol propane

Dust/Lime/Metal

Echinocandin B

Endosulfan

Endosulfan I [alpha-Endosulfan]

Endosulfan II [beta-Endosulfan]

Endosulfan sulfate

Endrin

Endrin aldehyde

Epoxy resin [Epikote 862]

Epoxynovalac

Ethanol [Ethyl alcohol]

Ethyl acrylate

Ethyl butyl ketone [3-Heptanone]

Ethyl cyanide [Propionitrile][Propanenitrile]

Ethyl ether [Ethane 1,1'-oxybis]

Ethyl formate

Ethyl methacrylate

Ethylbenzene

Ethylene

Ethylene dibromide [1,2-Dibromoethane]

Ethylene glycol

Ethylene glycol butyl ether acetate [Butyl cellosolve acetate]

Ethylene glycol dimethyl ether [1,2-Dimethoxyethane]

Ethylene oxide

Ethylenediamine

Extracts (petroleum), heavy naphtha solvent

Ferric chloride

Ferric Salt Of 3-Nitro

Filter Aid-Carbon

Fluoranthene

Fluorene

Fluoride

Fluoroalkyl carboxylate

Fluorochemical adduct

Formaldehyde

Formamide

Formic Acid

Fuel oil #2

Fuel oil #6

Fumaronitrile

Fumaronitrile [Fumaric acid dinitrile]

Furan

gamma-Picoline [4-Methyl pyridine]

Glutaraldehyde

Glycol ethers

Gylcerin [Glycerol][Propanetriol]

HEAVY ENDS

Heptachlor

Heptachlor epoxide

Hexachloro-1,3-butadiene [Hexachlorobutadiene]

Hexachlorobenzene

Hexachlorocyclopentadiene

Hexachloroethane

Hexadiene Oligomers

Hexamethyldisilazane

High boiling aliphatic hydrocarbons

HOC

HXCDFS

Hydrazine

Hydrocarbon polymer resin

Hydrogen chloride [Hydrochloric acid]

Hydrogen fluoride [Hydrofluoric acid]

Hydrogen peroxide

Hydroiodic acid

Hydroquinone

Hydrotreated heavy naphtha

Hyrdrocarbon sludge

Hyrdrocarbons

Hyrdrocarbons (Low Boiling)

Imidazole

Indeno(1,2,3-cd) pyrene

Indole

Ink

Inorganics

Iodine

Iodomethane [Methyl iodide]

Irganox

Iron

Iron oxide

Isoamyl acetate

Isobutyl acetate

Isobutyl Acrylate

Isobutyl alcohol

Isobutyl isobutyrate

Isobutyraldehyde

Isom Reactor

Isooctyl acrylate

Isoparaffinnic hydrocarbons

Isopentane

Isophorone

Isoprene [2-Methyl-1,3-butadiene]

Isopropyl acetate

Isopropyl ether

K-10 Bentonite clay

Kerosene

L-Aspartic acid

L-Limonene

Lanolin

Lauryl methacrylate

Lead

Lead chromate VI oxide

Lead II sulfate

Limonene, racemic mixture [Dipentene]

Lindane [gamma-Hexachlorocyclohexane][gamma-BHC]

Lithium fluoride

Loracarbef monohydrate

m-Cresol [3-Methyl phenol]

Magnesium

Magnesium hydrate

Magnesium oxide

Magnesium resinate

Maleic acid

Maleic anhydride

Malic Anhydride

Malononitrile

Manganese

Meat & Meat By-Products

Mercury

Mesityl oxide

Metal Oxides (Zinc, Brass, Aluminum)

Methacrylic acid

Methacrylonitrile

Methacryloyl chloride

Methanol [Methyl alcohol]

Methoxychlor

Methyl acetate

Methyl amyl ketone [2-Heptanone]

Methyl ethyl ketone peroxide

Methyl ethyl ketone [2-Butanone][MEK]

Methyl ethyl ketoxime [2-Butanone oxime]

Methyl formate

Methyl isoamyl ketone [5-Methyl-2-hexanone]

Methyl isobutyl ketone [Hexone][4-Methyl-2-pentanone]

Methyl isobutyrate [2-Methylpropanoic acid methyl ester]

Methyl methacrylate

Methyl naphthalenes

Methyl parathion

Methyl tert-butyl ether

Methylchrysene (Total)

Methylcyclohexane

Methylene chloride [Dichloromethane]

Mica

Mineral oil, light and heavy

Mineral spirits

Mirror Backing

Misc. Chlorinated Organics

Mixed Alcohols

Mixed Esters & Diols

Molybdenum

Morpholine

Mycelia Solids

n-Amyl alcohol [1-Pentanol]

n-Butyl-n-butyrate

n-Butyl acetate

n-Butyl alcohol [n-Butanol]

n-Butyl bromide

n-Butyl formate

n-Butyraldehyde [Butanal]

N-Ethyl morpholine

n-Heptane

n-Hexane

N-Methyldiethanolamine

N-Methylpyrrolidone [1-Methyl-2-pyrrolidinone]

N-Nitrosodi-n-propylamine [Di-n-propylnitrosamine]

N-Nitrosodiphenylamine [Diphenylnitrosamine]

n-Octyl mercaptan [1-Octanethiol]

n-Propyl acetate

n-Propyl alcohol [n-Propanol]

n-Propylamine [1-Propanamine]

n-tert-Butylphenol-formaldehyde polymer

n-Vinyl-Caprolactam

N-(1-Ethylpropyl)-3,4-dimethyl benzamine

Naphtha [Petroleum benzin]

Naphthalene

Naphtha, light steam-cracked aromatic, piperylene conc. polymd.

Natural rubber [Polyisoprene]

Neopentyl glycol

Neopentyl glycol gylcidyl ether

Nickel

Nickel hydroxide

Nicotinonitrile [3-Pyridinecarbonitrile]

Nitrates

Nitrobenzene

Nitrogen

Nitromethane

Nitrotoluene

Nonyl phenol

N,N'-Dimethyl acetamide

N,N-Diethyl aniline

N,N-Dimethyl-N-octylamine

N,N-Dimethyl formamide

o-Cresol [2-Methyl phenol]

o-Toluidine [2-Methylaniline]

o-Xylene [1,2-Dimethylbenzene]

Octadecyl acrylate

Octadecyl isocyanate

Octadecyl methacrylate

Octane

Octane sulfonic acid sodium salt monohydrate

Oily sludge

Oil/Oils

Organic Esters

Organic Nitrogen

Organic Residues

Organic Tar & Salts

Organophillic clay

Other Misc Organics

Other Organics

Other Polymers

Oxazole

Oxygen

o,p'-DDD

o,p'-DDE [o,p'-TDE]

o,p'-DDT

p-Chloro-m-cresol

p-Chloroaniline [4-Chloroaniline]

p-Chlorophenol

p-Cresol [4-Methyl phenol]

p-Nitrobenzoic acid

p-Toluidine [4-Methylaniline]

Paint

para-Nitrobenzyl bromide

para-Nitrobenzyl ester of PVSO

para-Toluene sulfonic acid

Paraffinic Olefinic Hydrocarbons

PCB's

Peatanane Tech Normal

PECDFS

Pendimethalin

Pentachlorobenzene

Pentachlorobutadiene

Pentachloroethane

Pentachlorophenol [PCP]

Pentaerythritol tetraacrylate

Pentane

Petroleum distillate

Petroleum Hydrocarbons

Petroleum resins

Petroleum Sludges

Petroluem naphtha [Ligroin]

Phenacetin

Phenanthrene

Phenol

Phenol-formaldehyde polymer

Phenoldisulfonic acid

Phenolic Resin

Phenothiazine

Phenyl acetate

Phenylacetic acid

Phenylenediamine, mixed isomers

Phenylenedicarbonyl

Phorate

Phosgene [Carbonic dichloride]

Phosphoric acid

Phosphorus

Phthalazine

Phthalic

Phthalic anhydride

Pigment Blue

Pivalic acid [Trimethyl acetic acid]

PNA'S

Polyacrylic acid [2-Propenoic acid homopolymer]

Polyamide Resin

Polybutylene

Polychloroprene

Polymer

Polymethylene [Isocyanic acid, polymethylenepolyphenylene ester]

Polypropylene glycid glycerol triether

Polypropylene glycol

Polystryene

Polytetrahydrofuran

Polyurethane

Polyurethane resin

Poly(alpha-methylstyrene)

Poly(ethylene terephthalate)

Poly(isoprene) [Rubber]

Potassium acetate

Potassium chloride

Potassium hydroxide

Potassium sulfate

Potassium tetrafluoroborate

Potassium tetrathionate

Production Intermediates

Propyl cellosolve

Propylene glycol methyl ether

Propylene glycol methyl ether acetate

Propylene glycol monopropyl ether

Propylene glycol [1,2-Propane diol]

PYRANS

Pyrene

Pyridine

Pyridoxal-5'-phosphate

p,p'-DDD

p,p'-DDE [p,p'-TDE]

p,p'-DDT

Quartz

Quinoline

Quinone [p-Benzoquinone]

R-11

Rags/Filters

Refractory Brick

Resin acids and Rosin acids, hydrogenated, esters with glycerol

Rosin

Salicyclic acid

Sand/Silica/Glass

sec-Butylamine

Selenium

Silane [Silicon hydride]

Silica gel

Silica [Silicon oxide]

Silica, amorphous [Silica, vitreous]

Silicon

Silicon carbide

Silicon tetrachloride

Silicone oil

Silicones, all

Siloxanes & silicones

Silver

Silvex [2,4,5-Trichlorophenoxypropionic acid][2,4,5-TP]

Sodium

Sodium azide

Sodium bicarbonate

Sodium bromide

Sodium carbonate

Sodium chloride

Sodium cyanide

Sodium hydroxide

Sodium hypochlorite

Sodium iodide

Sodium lactate

Sodium lauryl sulfate

Sodium methylate [Sodium methoxide]

Sodium nitrate

Sodium phosphate dibasic

Sodium phosphate dibasic, 7-hydrate

Sodium phosphate monobasic

Sodium Salts Of Organic Acids

Sodium sulfate

Sodium trifluoroacetate

Solvent naphtha (petroleum), heavy aromatic

Solvent naphtha (petroleum), light aliphatic

Solvent naphtha (petroleum), light aromatics

Solvent naphtha (petroleum), medium aliphatic

Solvents

Soybean oil

Sterigmatocystin

Stoddard solvent

Streptomycin sulfate

Stryene-isoprene copolymer

Styrene-butadiene polymer

Styrene [Vinyl benzene][Phenylethylene]

Succinonitrile [Butanedinitrile]

Sulfate

Sulfide

Sulfur

Sulfur dioxide

Sulfuric acid

Talc

Tar

TCDFS

Terbufos

Terephthalic acid [1,4-Benzenedicarboxyllic acid][p-Phthalic acid]

Terpene hydrocarbons

Terphenyl, hydrogenated

tert-Amyl alcohol [2-Methyl -2-butanol][tert-Pentanol]

tert-Butanol [2-Methyl-2-propanol]

tert-Butyl phenol

Tetrabutyl ammonium hydroxide

Tetrachloroethylene [Perchloroethylene]

Tetraethylamine

Tetraethylene glycol Diacrylate

Tetraethylene pentamine

Tetrahydrofuran

Texanol [Propanoic acid, 2-methyl, monoester with
2,2,4-trimethyl-1,3-pentanediol]

Thallium

Thioacetamide

Thiomethanol [Methyl mercaptan][Methanethiol]

Thiram [Thiuram][Tetramethylthiuram disulfide]

Tin

Tin Hydroxide

Titanium

Titanium dioxide

Titanium dioxide, anatase form

Toluene [Methylbenzene]

Toluenediamine [Diaminotoluene]

Total Kjeldahl Nitrogen

Toxaphene [Chlorinated camphene]

trans-1,2-Dichloroethylene

trans-1,3-Dichloropropylene [trans-1,3-Dichloropropene]

trans-1,4-Dichloro-2-butene

Tributylamine

Trichloroethylene

Trichlorofluoromethane [Trichloromonofluoromethane][CFC-11]

Trichloromethane-deuterated [Chloroform-D]

Triethylamine

Triethylamine Acetate

Triethylenetetramine [Trientine]

Trifluoroacetic acid

Trifluralin

Trimethyl phosphate

Trimethylated silica

Trimethylol propane acetate

Trimethylol propane diallyl ether

Trimethylol propane [2-Ethyl-2-(hydroxymethyl)-1,3-propanediol]

Triphenyl phosphite

Tris Buffer

Tris Buffer W/EDTA 7-Molar Urea

Turpene resin

Turpentine

Ultimate residue

Undecane

Unknown Heavy Ends

Unleaded Gasoline, Rust, Scale, Water

Unspecified Hydrocarbons

Unspecified Organics

Urea

Urethane Polymer

V-PNB Furan

Vanadium

Vanadium Pentoxide

Vermiculite

Vinyl acetate

Vinyl chloride [Chloroethylene][Ethylene Chloride]

Vinyltrimethoxysilanes

Waste Oil

Water

White mineral oil [Paraffin oil]

Xylenes, mixed isomers [Xyenes, total]

Zinc

Zinc oxide

Zinc resinate

Zinc stearate

(1,1-Dimethylethyl)-1,2-benzenediol

(Z)(Z)-2,4-Hexadiene

>C6 Alkenes/Alkenes

Appendix B

Unit Costs for Estimating Affected Industry Baseline RCRA Regulatory
Burden

(Pre-Rule)

B0.	Regulatory Burden Labor Wage Rates

Many of the baseline RCRA regulatory administrative burden elements
consist of labor burden cost.  Thus, a beginning point for estimating
regulatory burden unit costs, is to obtain data on labor unit costs
(i.e., hourly wage rates) to be applied in this RIA (see Exhibit B1
below).  It should be noted that this RIA applies in Appendix C, these
same labor unit costs for the purpose of estimating the
administrative-(paperwork) type conditions of the DSW final rule
exclusions.

Exhibit B1

Labor Wage Rates (2007 $/hour)

Note: These same labor wage rates are also applied in Appendix C to this
RIA

A	B	C	D	E	F (D x E)

Item	Labor Category	National Compensation Survey Category*	Labor Loading
Multipliers (Benefits* + Overhead**)	Unloaded Labor Rate ($/hour)***
Loaded Labor Rate

(2007 $/hour)

1	Office Manager	Managers & Administrators, not elsewhere classified
(nec)	43.4% + 43.6% = 87.0%	$44.00	$90.61

2	Field/ Process Technician	Furnace, kiln, & oven operators, except food
46.7% + 43.6% = 90.3%	$14.91	$31.41

3	Project Manager	Supervisors, production	43.4% + 43.6% = 87.0%	$22.92
$47.20

4	Drafting	Drafter	39.8% + 43.6% = 83.1%	$22.20	$44.57

5	Staff Engineer	Chemical Engineer	39.8% + 43.6% = 83.1%	$38.87	$78.03

6	Legal	Lawyer	39.8% + 43.6% = 83.1%	$58.07	$116.58

7	Clerical	Administrative support including clerical	42.6% + 43.6% =
86.2%	$15.08	$30.88

Explanatory Notes:

* Source for benefits loading factor: US Department of Labor, Bureau of
Labor Statistics, USDL 05-432, March 16, 2005.

** Source for overhead loading factor: Overhead consists of 12% G&A
overhead + 16.6% fixed overhead + 5% insurance + 10% profit estimated
using RACER 2005 defaults (Remedial Action Cost Engineering Requirements
cost estimating system:
http://talpart.earthtech.com/racer_documentation.htm).  General &
administrative (G&A) cost overhead can include expenses such as human
resources, payroll, accounting, sales personnel, executive salaries,
legal fees, office supplies, equipment, communications, administrative
buildings, office space, travel, subscriptions, and other overhead items
related to administrative activities that support operating (production)
labor.  Fixed overhead can include a proportion of the cost of building
services (e.g., medical, safety, recreation, general engineering,
general plant maintenance, janitorial, and cafeteria), electricity,
heating, interplant transportation, warehouses, shipping and receiving
facilities, insurance, and other resources shared throughout the
organization in support of operating labor.

*** Unloaded labor wage rate: US Department of Labor Bureau of Labor
Statistics “National Compensation Survey: Occupational Wages in the
United States”,   HYPERLINK "http://www.bls.gov/ncs/home.htm"
http://www.bls.gov/ncs/home.htm

B1.	EPA ID Number

This RCRA regulatory baseline cost was not estimated in this RIA,
because this RIA assumes that obtaining a USEPA ID number is an
historical one-time sunk cost for all affected RCRA-regulated facilities
included in the datasets used for this RIA.  This RIA does not attempt
to simulate the future annual numbers of new facilities which may begin
generating or recycling or disposing RCRA-regulated hazardous wastes, or
which may begin generating or recycling DSW-excluded hazardous secondary
materials.

B2.	40 CFR 262.34(g) (LQGs) & 262.34(d) (SQGs) & 264.16 (TSDFs)
Personnel Training

Training includes costs for manifesting and hazardous materials handling
training.  These costs are assumed to be incurred for all LQGs and SQGs.
 Facilities classified as CESQGs were not assumed to have training costs
for manifesting as these facilities are not required to manifest wastes
generated or the resulting manifest reporting/storage requirements.
CESQGs were excluded from hazardous materials handling training as
described in 40 CFR 262.16 Subpart B.  The hazardous materials handling
training requirements for LQGs and SQGs include on-the-job training for
emergency response and inspection of emergency response equipment.

Manifest training is estimated to cost $335 per year (2007$).  Training
costs include an estimated 4.0 hours every 3-years for a process
technician and a manager (assuming a 3-year capital recovery factor
(CRF) at 7% is 0.38105).  A turn over of the process technician is
assumed to occur once every 4-years (assumed a 4-year CRF at 7% is
0.29523); seven years for the manager (assumed a 7 year CRF at 7% is
0.18555).  Each year 0.6 hours are included for administrative
requirements associated with the training (i.e., updating records,
refresher/new class scheduling, etc.).  The class training cost per
trainee is estimated as $100 based on current pricing for the training
services from on-line providers.  This unit cost is based on USEPA
Supporting Statement for Information Collection Request Number 820.10
Hazardous Waste Generator Status, January, 2008.

Hazardous materials handling training is estimated to cost $847 per year
for SQGs (2007$) and $2,726 per year for LQGs (2007$).  Training costs
for SQGs include an estimated eight hours per year each for a process
technician and a manager.  Training costs for LQGs include an estimated
eight hours per year each for four process technicians, a manager, and a
branch manager.  Each year 0.6 hours are included for administrative
requirements associated with the training (i.e., updating records,
refresher/new class scheduling, etc.).  The class training cost per
trainee is estimated as $100 based on current pricing for the training
services from on-line providers.  This unit cost is based on USEPA
Supporting Statement for Information Collection Request Number 820.10
Hazardous Waste Generator Status, January, 2008.

B3.	40 CFR 262.40 (Generators), 263.22 (Transporters), & 264.74 (TSDFs)
RCRA Recordkeeping

These costs are assumed to be direct labor costs for a staff engineer to
conduct annual record keeping associated with RCRA hazardous waste
management.  Labor hours and labor cost (2007$) are estimated based on
DPRA professional judgment:

CESQGs = 3.0 hours at a cost of $234 per year per-facility

SQGs = 6.0 hours at a cost of $468 per year per-facility

LQGs = 9.0 hours at a cost of $702 per year per-facility

B4.	Manifest Exception Reports

This RCRA regulatory baseline cost was not estimated in this RIA because
it is an unpredictable, infrequent occurrence.

B5.	40 CFR 262.41 (LQGs) & 40 CFR 264.75 (TSDFs) RCRA Biennial Reporting

Biennial reporting as well as other generator recordkeeping and
reporting is required for all LQGs and TSDFs.  There are no reporting
Biennial reporting requirements for SQG or CESQG facilities.  Annual
costs for biennial reporting is estimated to cost $364 for a LQG
facility (2007$).  The average facility is estimated to fill out 11 GM
forms for the reporting cycle.  The reporting labor is estimated at 1.37
hours of a project manger level, 3.57 hours of a staff engineer level,
and 0.61 hours of clerical labor.  This activity along with manifest and
annual reporting of recycling activity requirements covers the costs for
documenting two other conditions - “no land placement” and “track
offsite shipments”.  This unit cost is based on Supporting Statement
for USEPA Information Collection Request Nr. 976.13 “The 2007
Hazardous Waste Report,” September 18, 2007

B6.	40 CFR 264 Subparts I to DD (TSDF) Storage Requirements for
Accumulated Hazardous Waste

This RIA assumes that plant and equipment investments for both hazardous
waste and “hazardous secondary materials” storage are sunk costs, so
no incremental effect (i.e., cost savings) is estimated in this RIA for
the DSW final rule exclusions.

B7.	40 CFR 270 RCRA “Part B” TSDRF Permit Renewal Costs

Savings to onsite and offsite recyclers may result from no longer
needing to renew their 40 CFR 270 RCRA hazardous waste TSDF permits.
The maximum duration that a RCRA permit is valid is 10 years; therefore,
a TSDRF facility is required to renew the 40 CFR 270 “Part B”
portion of the RCRA permit application a minimum of once every 10 years.
 Recyclers (TSDRFs) who become excluded from RCRA regulation under the
DSW final rule have two options concerning not renewing their RCRA 40
CFR 270 TSDRF permits:

Option 1: the TSDRF may do nothing and just let their permit expire
according to its current 10-year expiration date

Option 2: the TSDRF may file a termination request to the
RCRA-authorized state agency.

This RIA does not assign a cost under option 2, so this RIA assumes
option 1.

	The Part B application is composed of a general facility section and
the technology specific section for storage and/or disposal of the
hazardous waste.  Facilities reclaiming metals, solvents, or acids
onsite may not require a TSDRF permit for their facility or for one or
more particular recycling units at their facility affected by the DSW
rule, as these wastes will no longer be considered solid wastes.
Therefore, the facility would not be a RCRA TSDRF.  The facilities
potentially affected by the DSW rule would not need to resubmit the Part
B application to renew the TSDRF RCRA permit.

	Costs for preparing and renewing the RCRA Part B application are from
Estimating Costs for the Economic Benefits of RCRA Noncompliance, USEPA
Office of Regulatory Enforcement, Sept 1997,
http://www.epa.gov/epaoswer/hazwaste/gener/f006/s0004.pdf.  The general
facility portion of the Part B application estimated cost was $43,693
($56,559 inflated to 2007$; inflated from 1994$ to 2002$ using a 1.127
multiplier and inflated from 2002$ to 2007$ using a 1.148646184
multiplier from: Table 1.1.9 Implicit Price Deflators for Gross Domestic
Product, Bureau of Economics Analysis last revised January 30, 2008.
The technology specific section of the permit has estimated costs of
$9,371 ($12,130 inflated to 2007$) for container systems and $8,780
($11,365 inflated to 2007$) for tank systems.

	The update of the Part B application is estimated to cost 25% to 50%
the original preparation cost.  All TSDRF facilities would be required
to submit the general facility portion of the Part B application.  In
general, it is assumed that TSDRF facilities reclaiming metals would
require the container systems technical requirements of the Part B
application and the solvent and acid reclamation facilities would
require the tank system technical requirements of the Part B
application.  Exhibit B3 below provides an estimate of the number of
baseline (pre-rule) RCRA hazardous waste recycling facilities (TSDRFs)
by material type which incur RCRA Subtitle C Part B permit renewal
costs, and which may realize associated Part B cost savings under the
DSW rule.

Exhibit B3

2003 Estimate of the Baseline (Pre-Rule) Count of Offsite Recycling
Facilities

130	25

4	Estimate #1 (maximum estimate):

Total Number of Recycling Facilities Based on Reported Shipments (i.e.,
Row 1 – Row 2 – Row 3)	307	150	113

5	Estimate #2 (minimum estimate):

Total Number of Recycling Facilities Based on Reported Waste Receipts
from Offsite (source: USEPA 2003 RCRA Biennial Report, Exhibit 3.9)	106
47	40

6	Average annualized potential RCRA Part B permit renewal cost savings
per-recycling facility (see text above this Exhibit for data source; the
range reflects the 25% to 50% data source reference range); range
midpoint applied in this RIA	$2,445 to $4,890/year per-facility

[midpoint= $3,668]	$2,418 to $4,836/year per-facility

[mp= $3,627]	$2,418 to $4,836/year per-facility

[mp=$3,627]

7	Potential RCRA Subtitle C Part B Permit Renewal Annual Cost Savings:

Min estimate ((Row 5)x(minimum of Row 6 in same column))

Max estimate ((Row 4)x(maximum of Row 6 in same column))

Range midpoint applied in this RIA	$0.26 to $1.50 million/year

[mp= $0.88 mill/yr]	$0.11 to $0.73 million/year

[mp= $0.42 mill/yr]	$0.10 to $0.55 million/year

[mp= $0.32 mill/yr]

B8.	40 CFR 262 Subpart B (Generators), 263 Subpart B (Transporters) &
264 Subpart E (TSDFs) RCRA Hazardous Waste Shipment Manifests (EPA Form
8700-22)

In general, under the current hazardous waste regulations, wastes are
tracked through the use of a hazardous waste manifest which accompanies
each waste shipment.  Manifesting costs were estimated using the
Supporting Statement for Information Collection Request (ICR) Number
801.15 "Requirements for Generators, Transporters, and Waste Management
Facilities Under the RCRA Hazardous Waste Manifest System.", December
30, 2004.  Costs were estimated using the labor rates in Exhibit B1 of
this RIA Appendix, and miscellaneous costs were inflated to 2007$.  The
manifesting cost incurred by the generator per manifest was determined
to be $48 for SQGs and LQGs (2007$).  The cost for non-hazardous
shipping papers under a reclamation agreement were estimated to be
comparable to a SQG’s shipping RCRA manifests.  All pre rule shipments
were assumed to require hazardous waste manifests (including same-NAICS
recycling transportation shipments).  Post-rule shipments are all
assumed to require non-hazardous shipping papers, except for the portion
of the residuals assumed to be characteristically hazardous (95% of
metals recovery residuals, 85% of solvent recovery residuals, and 75% of
acid regeneration residuals).

B9.	Preparedness & Prevention

Preparedness and prevention costs are included in personnel training
(Appendix B, section B2), contingency plan (Appendix B, section B10),
and emergency plan (Appendix B, section B11).

B10.	40 CFR 262.34(g) (LQGs) & 264 Subpart D (TSDFs) Contingency Plan

Contingency planning costs are estimated to cover the requirements as
stated in 40 CFR 264 Subpart D relating to the development of TSDF
contingency plans.  LQGs are required by 40 CFR 262.34(g)(4)(C)(2)(v) to
prepare and maintain the same contingency plan as TSDFs.  The cost
includes labor burden of eight hours for a staff engineer and 3.36 hours
for clerical support for an average per-facility expense of $733/year
(2007$).  This cost is incurred on an annual basis and is based on USEPA
Supporting Statement for Information Collection Request Number 820.10
Hazardous Waste Generator Status, January 2008.

B11.	40 CFR 262.34(g) (LQGs), 262.34(d) (SQGs) & 264 Subpart D (TSDFs)
Emergency Plan

Emergency plan costs are estimated to cover the requirements as stated
in 40 CFR 264 Subpart D relating to the development of a contingency
plan.  LQGs and SQGs are required to prepare and maintain a emergency
plan.  The cost for a LQG facility  includes labor burden of 4.4 hours
for a staff engineer, 0.34 hours for legal review, and 2.16 hours for
clerical support, and $23 in copying and postage, for a total expense of
$481 (2007$).  The cost for a SQG facility  includes labor burden of 1.1
hours for a legal review, 0.1 for a managerial review, and $5 in copying
and postage, for an average per-facility expense of $94 per year
(2007$).  This cost is incurred on an annual basis.  This unit cost is
based on USEPA “Supporting Statement for Information Collection
Request Number 820.10 Hazardous Waste Generator Status”, January 2008.

B12.	Closure

See Appendix C, Section C9.

B13.	Post-Closure

See Appendix C, Section C9.

B14.	Accumulation Time

Unit costs are a combination of hazardous waste disposal, recycling,
transport and testing costs presented in Appendix D, Sections D1 and D3.
 Because hazardous residuals from DSW-excluded recycling still must be
managed in an environmentally-responsible manner, this RIA assumes that
residuals are managed in RCRA Subtitle C units.  Consequently, this
baseline cost element nets-out the estimated future annual cost for
managing as RCRA hazardous wastes, the quantities of future annual
recycling residuals.

Appendix C

Unit Costs for Affected Industries to Meet the 12 Conditions of the DSW
Final Rule Exclusions

(Post-Rule)

C1.	No Speculative Accumulation

The generator status of a facility may change when recycled wastes are
no longer counted as hazardous waste under the DSW exclusion.  The
non-recycled quantity of hazardous waste a facility generates will
determine its post-rule generator status and influence its accumulation
time requirements.  A change in generator status from being a LQG to
either SQG, to CESQG, or to non-generator status, results in longer
accumulation time for residuals and secondary materials from 90 days for
LQGs to 180/270 for SQGs to 360 days as the assumed time limit based on
speculative accumulation requirements for CESQGs.  The extended
accumulation time translates into fewer shipments, fuller truck loads,
and a decreased frequency of minimum disposal/recycling and
transportation charges that result from acceptance of small loads of
wastes/secondary materials.

	Under this existing rule, a material is accumulated speculatively if
the person accumulating it cannot show that the material is potentially
recyclable and has a feasible means of being recycled.  The person
accumulating the material must show that during a calendar year
(beginning January 1) the amount of material that is recycled, or
transferred to a different site for recycling, must equal at least 75%
by weight or volume of the amount of that material at the beginning of
the period.  This provision already applies to secondary materials not
otherwise considered to be wastes when recycled, such as materials used
as ingredients or commercial product substitutes, materials that are
recycled in a closed loop production process, or unlisted sludges and
byproducts being reclaimed.  These restrictions on speculative
accumulation have been an important element of the RCRA recycling
regulations since they were promulgated on January 4, 1985.  In the cost
estimates of this RIA, it is assumed that recycled materials are shipped
offsite at least once per year.

	To estimate the impacts associated with changes in accumulation time,
the following cost elements need to be estimated:

Offsite metal recovery, solvent recovery, other recovery (represented by
acid regeneration as a proxy), and residual hazardous and nonhazardous
landfill costs on a per ton or minimum charge basis to estimate cost
savings resulting from avoided minimum recycling process and handling
charges because larger truck shipments are being received and processed;
and

Disposal transportation, recycling transportation, and waste
characterization testing unit costs and minimum charges to estimate cost
savings resulting from fewer shipments and avoided minimum
transportation charges because larger loads are shipped.

Unit costs are a combination of disposal, recycling, transport and
testing costs presented in Appendix D, Sections D1 and D3.

C2.	Generator Notifies USEPA Initially & Every 2-Years

Based on DPRA professional judgment, costs were estimated for generators
to complete an initial and biennial (every two years) re-notification of
RCRA exclusion for their recycled wastes.  This RIA assumes that each
notification (i.e., initial and subsequent biennial re-notification)
requires a labor burden of:

0.64 hours (38 minutes) project manager

1.06 hours (64 minutes) staff engineer

0.14 hours (8 minutes) clerical support

for an average per-facility labor burden of 1.84 hours (110 minutes) per
notification action.  Multiplying these labor hour estimates by the
respective 2007 wage rates from Exhibit B1 yields an average cost
estimate of $122 for each notification action (2007$).  An additional $5
per notification in miscellaneous copies and postage cost is also
included.  This RIA converts this per notification cost into an average
annualized cost by dividing by two years (i.e., ($122 per notification
action) / (notification required initially and every two years) =
$61/year per facility).

	Note: The assumed identical average labor time per-facility for both
initial notification and re-notification may be a source of cost
over-estimation in this RIA for this condition (i.e., a source of
industry net cost savings under-estimation), as evidenced by two
alternative estimates of notification labor time contained in two
relevant existing “Information Collection Request” (ICR) supporting
statements associated with two existing RCRA-related notification forms:

ICR for RCRA “Notification of Regulated Waste Activity” (EPA Form
8700-12; “Instructions and Form” document dated July 2006 at
HYPERLINK
"http://www.epa.gov/epaoswer/hazwaste/data/form8700/8700-12.pdf"
http://www.epa.gov/epaoswer/hazwaste/data/form8700/8700-12.pdf .  This
ICR estimates “The reporting burden for information collection
requirements associated with initial notification requirements is
estimated to be approximately 2.00 hours [120 minutes]. The burden
estimate includes time for reading the regulations and preparing and
submitting the initial notification. The reporting burden for
information collection requirements associated with subsequent
notification is estimated to be approximately 1.00 hour [60 minutes].
The burden estimate includes time for reading the regulations, preparing
and submitting a subsequent notification.”

ICR for the “RCRA Subtitle C Site Identification Form“ (EPA Form
8700-13 A/B, revised Oct 2005; available in docket ID nr.
EPA-HQ-RCRA-2005-0003 at http://www.regulations.gov): This ICR estimates
20 minutes to prepare a Site ID Form and 10 minutes to update it.  These
numbers are probably more appropriate for this DSW final rule exclusion
condition (rather than the Notification of Regulated Waste Activity
ICR), because the burden estimates in the Biennial Report ICR reflect an
assumption that reporters on a regular submittal cycle will develop
efficiencies from submitting the Site ID form, unlike the Notification
ICR, which does not include this assumption.  One particular efficiency
is that, with notifications submitted on a regular cycle, there will be
fewer updates needed per submittal and hence less time burden in
comparison with notifications occurring more or less randomly as is the
case with notifications addressed by the Notification ICR.  Most of the
data elements are easily collected (e.g., name, address, NAICS code, the
type of exclusion, etc.) and information on regularly submitted forms
will be pre-populated and not need much, if any, updating from cycle to
cycle.  There also will be little or no learning curve for sites from
cycle to cycle.

C3.	Notification Signed by Corporate Official

As an option in addition to the above described one time notification of
exclusion, it is assumed that certification of the one-time notification
of exclusion will take extra time for the generator’s staff engineer
to set up a meeting and brief the generator’s office manager on the
new DSW exclusion rule and the implications of his/her signature on the
one-time notification.  This cost is a one-time initial cost, unless
changes occur in the name, address or USEPA ID number of the facility or
a change in the type of material(s) recycled, which would require
submission of a revised notice with new certification (frequency and
annual count of future re-certifications not estimated in this RIA).
This RIA estimates an average per-facility labor time burden of:

0.5 hour (30 minutes) office manager

1.0 hour (60 minutes) staff engineer

to acquire a signature by a corporate official, totaling 1.5 hours (90
minutes) average added time per notification for certification.
Multiplying the labor hour estimates by the respective 2007 labor wage
rates from Exhibit B1 yields an average added cost estimate of $123 for
certification of the one-time notification (2007$).  If added to the
average $122 cost per facility for a one-time notification as estimated
above, yields a one-time certified notification cost estimate of $251
per facility.  Analogous to the method applied in item C2 above, this
RIA converts this $123 certification cost into an average annualized
cost by dividing by two years: (i.e., ($123 per certification action) /
(certification required initially and every two years) = $62/year per
facility).

C4.	Generator Submits Petition to USEPA to Demonstrate Materials are Not
Solid Wastes

A petition to be granted a variance from classification as a solid waste
was estimated using the CFR 260.31(b) and 260.33(a) rules regulating
fertilizer byproducts as a proxy. The labor burden was estimated using
labor hour estimates from the "Supporting Statement for USEPA
Information Collection Request Number 1189.14 Identification, Listing,
and Rulemaking Petitions", September 13, 2004 and the labor rates listed
previously.  A total labor burden of 146 hours for a staff engineer
multiplied by the average labor wage rate for 2007 (from Exhibit B1),
plus additional $22 for copying, shipping and communication cost was
assumed, yielding an average cost estimate of $11,415 per variance.  The
labor burden includes presentation of the following elements: economic
viability of the product; industry wide prevalence of the practice; the
handling of the material prior to reclamation; the time line of storage,
handling, reclamation, and reuse; describe reclamation location and
process; the reuse process; describe the reclaimer/recycler; and any
additional relevant information.

C5.	Maintain Records of All Offsite Shipments for Recycling

Cost for recording and maintaining records of recycling activities are
included in the general administrative duties described above.
Additional record keeping costs for the DSW rule are not anticipated.

C6.	Confirmation of Shipment Receipt

Costs for generators maintaining records of offsite recycling shipments
and confirmation receipts are included in recordkeeping costs described
in Appendix B, Section B2.

C7.	Recycler Has Liability Insurance for Accidents

This RIA assumes no additional costs will be incurred because all
affected industrial facilities are assumed to currently have liability
insurance for accidents as part of standard industry practice.

C8.	Recycler Has Financial Assurance for Closure

To estimate this condition, financial assurance costs were estimated in
this RIA using the OSW’s Sept 2000 "Unit Cost Compendium" (UCC).  The
costs to determine the financial assurance mechanism, develop the
financial test, setup the surety bond, and estimate the required funds
necessary were annualized over a ten year period using a capital
recovery factor at 15% (i.e., 0.19925).  The costs were inflated from
1999$ to 2005$ using a CPI factor of 1.194.  The annualized set up costs
is estimated as $384 (2005$).  An additional fee for the surety bond is
estimated to cost 1.5% of the value of the following average closure
cost assumptions per-facility, and a $826 (2005$) annual fee for the
bond.  Costs inflated from 2005 to 2007 dollars using Table 1.1.9
Implicit Price Deflators for Gross Domestic Product, Bureau of Economics
Analysis last revised January 30, 2008 of 1.0591.  (Note: the
“RACER” data reference cited belw = Remedial Action Cost Engineering
Requirements cost estimating system:
http://talpart.earthtech.com/racer_documentation.htm):

Metals recycler	$3,340:	Source: RACER 2005: Two 20 foot by 20 foot by 10
feet high holding pads one open side, a cost of high pressure wash at
137.5 SF/hour, $1.76/square foot, $338 Mob/Demob charge.

Solvent recycler	$2,266:	Source: RACER 2005: 2 1000 gallon AST holding
tanks, triple rinse two 55 gallon drums, associated piping.  Pressure
Cleaning, 40 SF per hour, $4.62/sf, $338 Mob/Demob charge.

Acid recycler	$2,266:	Source: RACER 2005: 2 1000 gallon AST holding
tanks, triple rinse two 55 gallon drums, associated piping.  Pressure
Cleaning, 40 SF per hour, $4.62/sf, $338 Mob/Demob charge.

For facilities currently recycling RCRA hazardous waste, the estimate
for the added cost of requiring financial assurance is estimated to be
an average cost of $1,397/year plus 1.5% of closure costs.  Off-site
recyclers are assumed to pass through 100 percent of these costs back to
their customers.  On average, it is estimated that 6.5 generators ship
waste to each recovery facility based on 2003 Biennial Report data.
Off-site financial assurance and closure costs are divided by 6.5 to
estimate the cost passed through to the generator.

C9.	Materials Must be Contained

This RIA assumes no additional costs because assumes all affected
facilities will ensure containment (a) to avoid CERCLA liability costs,
and (b) to avoid RCRA corrective action for leaks/spills.

C10.	Residuals Derived from Recycling Managed in
Environmentally-Protective Manner

This RIA assumes that future annual generation of hazardous residuals
from DSW-excluded recycling processes will be managed as RCRA hazardous
wastes, according to the baseline RCRA regulatory requirements itemized
in Chapter 6 and in Appendix B (section B14).  Therefore, this RIA
assumes this exclusion condition represents baseline requirements, and
nets-out the continued future cost for managing recycling residuals as
RCRA hazardous wastes, from the Chapter 6 baseline cost that will be
eliminated.

C11.	Generator Exercises Due Diligence Reasonable Efforts to Ensure
Offsite Recycling is Legitimate

A condition for Exclusion 2 is that generators need to exercise due
diligence or reasonable efforts to ensure recycling is legitimate.  This
RIA’s due diligence unit cost estimate is based on the assumption that
the due diligence condition is somewhat similar, but not identical, to
real estate due diligence or facility environmental compliance reviews,
but different in that the generator would not be required to conduct an
actual facility visit and could rely on information provided by the
recycler (e.g., company brochures) and publicly-available information.
On average, each due diligence event is estimated to require a labor
burden of 20 hours of a staff engineer at the generator facility, plus a
facility environmental data report, per each due diligence event:

Labor:	The generator’s labor cost per event is estimated at ((20 staff
engineer hours/event) x ($78.03/hour labor rate from Exhibit B1)) =
$1,661 per event.

Report:	The facility environmental data report summarizes various
listings of the recycling facility in federal, state, and local
environmental files and databases at an estimated cost of $100 per
event.

For purpose of this RIA, an average annual of one due diligence review
event is assumed to occur for each affected generator facility, at an
estimated average unit cost of $1,761 (2007$) per generator facility
(i.e., $1,661 labor + $100 report).  However, because of the fact that
industrial companies often enter into multi-year contracts and business
relationships with their suppliers and vendors, this unit cost
assumption may be over-estimated in this RIA based on the annually
recurring assumption per generator.  In addition to initial audits,
companies often perform repeat audits on a regular schedule.  Although
the exact period of time between audits can vary depending on factors
such as the nature and complexity of the vendor’s operations, the
relationship between the two companies, or the generator’s access to
audits performed by trade groups or consortiums, re-audits are usually
performed every one to five years.  The midpoint of this re-audit
frequency range is every 3-years, suggesting that this RIA’s annual
re-audit assumption over-estimates the average annual unit cost per
generator by 300% (i.e., (3-years)/(1-year)).

	On the other hand, data collected by OSW from organizations which offer
environmental facility auditing services suggest that the per-event
average unit cost could be higher than the $1,661/event unit cost
estimate of this RIA, ranging between $2,000 to $8,000 per due diligence
event.  Applying the midpoint annual re-audit frequency of 3-years per
generator, to the $2,000 to $8,000 per event unit cost range, provides
an average annualized unit cost range of $670 to $2,670 per year per
generator.  The midpoint of this range is $1,670 per year per generator,
which suggests that the $1,661/year per generator unit cost estimate
developed and applied in this RIA is a reasonable assumption.

C12.	Export of Materials for Recycling Requires Notice & Consent &
Annual Reporting

Costs incurred by generator to notify foreign recycling facility of the
requirements of the DSW exclusions.  This RIA does not estimate the
annual fraction (percentage) of affected hazardous secondary materials
which may be exported for recycling.  However, this is a baseline RCRA
Subtitle C requirement (40 CFR 262.53 & 262.56) so no incremental cost
impact is expected.

Appendix D

Unit Costs for Industrial Disposal & Industrial Recycling

This appendix summarizes methods for estimating several categories of
unit costs:  Industrial disposal, onsite and offsite industrial
recycling, managing industrial recycling residuals, and, finally,
managing and generation of recycling residual waste.

D1.	Industrial Disposal Unit Costs

Unit costs for the year 2005 were reported in RACER 2005 cost estimating
software (RACER = Remedial Action Cost Engineering Requirements cost
estimating system: http://talpart.earthtech.com/racer_documentation.htm)
for RCRA Subtitle C hazardous waste commercial landfill disposal costs.
These unit costs were inflated from 2005 to 2007 dollars using the GDP
Price Deflator from January 2008 (1.059):

The cost reported in ECHOS was inflated to $223 per ton for bulk
hazardous waste with stabilization (2007$).

RCRA Subtitle D non-hazardous waste commercial landfill costs were
estimated using the National Solid Wastes Management Association 2004
annual survey.The US national average tipping fee for non-hazardous
disposal was reported as $37 per ton in bulk quantities inflated to 2007
dollars.

Earl Finnder of the US Filter Company estimated that electroplaters pay
approximately $260 to $300 per ton for Subtitle C landfill disposal.

The RACER 2005 unit cost was used as an average disposal cost for
hazardous waste.  The RACER 2005 disposal cost for hazardous is
presented as a 30-city average of US major cities.  The landfill
disposal costs assumed under baseline are presented in Exhibit D1 below.
 A minimum charge for hazardous waste disposal is estimated as half a
full load (nine tons) at $2,004.  No minimum charge is assumed for the
disposal of waste in RCRA Subtitle D landfills as there is no regulation
of non-hazardous waste storage times; therefore, each non-hazardous
waste load will be a full 18-ton load (see Exhibit D1 for unit costs).
The cost estimates for landfill management are overstated, particularly
for smaller generators, because other forms of hazardous waste are
usually generated by a single facility.  These wastes may be shipped
with the reclaimable waste to the landfill in the same truck if the
wastes are compatible, resulting in lower per-unit transportation costs
due to a generator’s ability to take advantage of economies-of-scale
and avoid incurring the minimum landfill charge on multiple loads.

Exhibit D1

RCRA Subtitle C & Subtitle D Landfill Unit Costs (2007$)

Cost Element

($/ton)

Subtitle C Landfill with Stabilization 1

$223/ton ($2,004 minimum charge)

Subtitle D Landfill 2

$37/ton

1 Costs inflated from 2005 dollars to 2007 dollars.

2 Costs inflated from 2004 dollars to 2007 dollars.

Transportation Costs

Exhibit D2 below presents estimates of hazardous waste transportation
costs (excluding manifesting costs which are estimated separately) based
on unit costs reported in RACER 2005 cost estimating software for van
trailers and tanker trucks (RACER = Remedial Action Cost Engineering
Requirements cost estimating system:
http://talpart.earthtech.com/racer_documentation.htm).  These unit costs
were inflated from 2005 to 2007 dollars using the GDP Price Deflator
from January 2008 (1.059).  Costs are based on distance and maximum
truck load size of 18 tons for van trailers and 5,000 gallons for tanker
trucks.  A minimum of four loads per year is assumed based on the
maximum accumulation period of 90 days for hazardous waste landfill
disposal and 180 days for recycling based on accumulation time
regulations.  Otherwise, the number of loads per year is calculated by
dividing the total annual generation quantity by the assumed maximum
truck load size of 18 tons.  The RACER 2005 shipment fee of $1,000
(2007$) is used to determine transportation unit costs below 200 miles
for hazardous waste.  For example, the transportation cost for shipping
waste 100 miles is calculated by dividing the minimum shipment fee by
100 miles ($1,000/100 miles = $10.00/mile).  Shipping distances vary
when shipping to Subtitle C landfills (338 mile average) compared to
recycling facilities (521 mile average).  The distances presented
reflect estimates for shipments of F006 wastes from the USEPA December
2001 draft report, Evaluation of Cost and Economic Impacts of F006
Recycling Rulemaking Options, for landfill and metals recovery
facilities as a proxy for the transportation distances within the same
industry (4-digit NAICS code) and residual disposal.

	Non-hazardous waste transportation costs (excluding manifesting costs)
also were estimated based on bulk hazardous waste transportation cost
reported in RACER 2005.  Costs are based on distance and maximum load
size of 18 tons.  Due to the relatively close transportation distances
estimated for RCRA Subtitle D landfills, a unit cost of $3.30 per mile
($0.183 per ton-mile) was used.  The transportation cost is estimated to
be less than the hazardous transportation unit cost due to the regularly
scheduled, full 18-ton, bulk non-hazardous waste shipments.  For
non-hazardous waste and post-rule recycling, no minimum number of loads
is assumed.  The number of shipments per year is calculated by dividing
the total annual generation quantity by the assumed maximum truck load
size of 18 tons.

Exhibit D2

Waste Transportation Unit Costs (2007$)

Cost Element

Baseline

Van Trailer

Tanker Truck

Loading/Unloading

Hazardous Waste Minimum Charge

Hazardous Waste Shipping

       200-299 miles

       300-399 miles

       400-499 miles

       500-599 miles

       600-699 miles

       700-799 miles

       800-899 miles

       900-999 miles

       1,000+ miles

Non-Hazardous Waste

$37.89/ton

$1,063/shipment

$4.06/mile

$3.76/mile

$3.39/mile

$3.21/mile

$3.16/mile

$3.03/mile

$3.03/mile

$3.31/mile

$3.17/mile

$3.30/mile

$50.20/ton

$1,000/shipment

$3.77/mile

$3.26/mile

$3.31/mile

$3.40/mile

$3.21/mile

$3.13/mile

$3.09/mile

$3.08/mile

$3.04/mile

POTW discharge

Weighted transportation costs are presented in Exhibits D3 and D4:

Transport to Subtitle C landfills:	The weighted average transportation
unit cost to Subtitle C landfill is $6.34/mile and the weighted average
distance is 338 miles.

Transport to solvent recycling:		The weighted average transportation
unit cost to a solvent recovery facility is $10.03/mile and the weighted
average distance is 521 miles.

Transport to Subtitle D landfills:	The assumed average transportation
unit cost to a Subtitle D landfill is $3.30/mile and an average distance
of 50 miles.

Transport to Fuel blending:		The assumed average transportation unit
cost to a fuel blending facility is $4.24/mile and an average distance
of 577 miles.

Transport to acid recovery:		The assumed average transportation unit
cost to an acid recovery/acid neutralization facility is $4.10/mile and
an average distance of 405 miles.

Transport to metals recycling:		The estimates for metals recovery
distances from facilities identified in the USEPA report “Evaluation
of Cost and Economic Impacts of F006 Recycling Rulemaking Options”
from December 2001 were used to model recycling and RCRA Subtitle C
landfill distances.

Transportation distances for fuel blending, and acid recovery/acid
neutralization were determined after review of 1999 Biennial Report data
of facilities shipping the wastes and the receiving facilities.  A
distribution for shipping was generated using potential transportation
ranges of 250, 350, 450, 550, 650, 750, 850, 950, and 1050 miles:

For waste streams with facilities tending to ship within-state the
transportation distribution was skewed to the 250 and 350 mile range.

For waste streams with facilities tending to ship out-of-state the
transportation distribution was skewed to the 450 and 650 mile range.

An average distance of 1,000 miles for incineration managed waste
streams was estimated due to the limited number of facilities available
providing the service.  Based on a review of the 1999 Biennial Report
data, no incineration managed waste streams were shipped within state.

Exhibit D3

Weighted Average Transportation Unit Costs to Subtitle C Landfills for
SIC 3471 Generators (2007$)

Percentile

(%)	Distance to Landfill or Stabilization for Top 95% of Waste Shipped

(miles, n = 75)	Average Distance per 10th Percentile

(miles)	Weighted Distance to Subtitle C Landfill (miles)	Unit Cost

($/mile)	Weighted Unit Price ($/mile)

0	38	---	---	---	---

10	129	83.5	8.35	$13.48	$1.35

20	147	138	13.8	$8.16	$0.82

30	166	156.5	15.65	$7.19	$0.72

40	175	170.5	17.05	$6.60	$0.66

50	234	204.5	20.45	$5.50	$0.55

60	283	258.5	25.85	$4.98	$0.50

70	348	315.5	31.55	$4.52	$0.45

80	434	391	39.1	$4.37	$0.44

90	636	535	53.5	$3.65	$0.37

100	1627	1,131.5	113.15	$3.38	$0.34

Total =

338.45

$6.34

Exhibit D4

Weighted Average Transportation Unit Costs to Metals Recovery (Secondary
Smelting) for SIC 3471 Generators1  (2007$)

Percentile

(%)	Distance to Metals Recovery Facilities for Top 95% of Waste Shipped

(miles, n = 51)	Average Distance per 10th Percentile

(miles)	Weighted Distance to Metals Recovery

(miles)	Unit Cost

($/mile)	Weighted Unit Price ($/mile)

0	7	---	---	---	---

10	32	19.5	1.95	$56.78	$5.68

20	193	112.5	11.25	$9.84	$0.98

30	231	212	21.2	$5.22	$0.52

40	329	280	28.0	$4.35	$0.43

50	372	350.5	35.05	$4.23	$0.42

60	481	427	42.7	$3.91	$0.39

70	567	524	52.4	$3.69	$0.37

80	846	706.5	70.65	$3.43	$0.34

90	1,253	1,049.5	104.95	$3.20	$0.32

100	1,802	1,527.5	152.75	$3.13	$0.31

Total =

520.9

$10.03

1 These values were used as a proxy for metals recovery distances and
transportation unit costs.

Waste Characterization Testing

Ongoing characterization of hazardous waste and recycled materials is
estimated to include sampling labor burden and waste characterization
analytical costs.  The sampling is estimated to require a labor burden
of 2 hours of field technician labor.  The analytical costs were
estimated using RACER 2005 cost estimating software at a cost of $284
per sample (2007$).  One sample is collected for each waste or recycled
materials load for a total cost of $346 (2007$).  Note: RACER = Remedial
Action Cost Engineering Requirements cost estimating system:
http://talpart.earthtech.com/racer_documentation.htm.D2.	Offsite
Industrial Recycling Unit Costs

Offsite Metal Recycling

Recycling cost estimates were taken from a previous USEPA rulemaking
titled Regulatory Impact Analysis of the Final Rule for a 180-Day
Accumulation Time for F006 Wastewater Treatment Sludges, 12 Jan 2000;
http://www.epa.gov/epaoswer/hazwaste/gener/f006/s0001.pdf.  In that RIA
recycling costs for recovering metals from F006 wastewater treatment
sludges were estimated from 1993 cost data provided in Exhibit 7-1 of
Cushnie, George C., CAI Engineering, "Pollution Prevention and Control
Technology for Plating Operations," prepared for NCMS/NAMF.

	Exhibit D12 below presents the estimate from the above report for the
metal recycling unit costs being paid by F006 sludge generators.
Transportation costs were subtracted from the estimated recycling costs.
 1997 unit transportation prices reported in 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, were used to estimate transportation
costs in that analysis.  Differences in average unit recycling costs in
Exhibit D12 are the result of variability in the amount various
recyclers charge generators.  A major factor contributing to the
differences in recycling costs is metal content (i.e., concentration and
type of metals present in the waste).  The generally lower costs for the
small facilities that recover metals may be due to the fact that these
facilities tend to generate single-metal wastes which are more amenable
to recycling.

	In OSW’s F006 180-Day Accumulation Final Rule 2000 RIA
(http://www.epa.gov/epaoswer/hazwaste/gener/f006/s0001.pdf), an average
unit recycling cost of $0.20/lb was assumed as an upper-end typical
price charged by a metals recovery facility based on the 1993 data
provided in Cushnie.  One recycler that was contacted provided an
average 1998 price of approximately $0.10/lb. For that analysis, impacts
are evaluated based on average recycling prices ranging from $0.10/lb to
$0.20/lb ($200/ton to $400/ton).  In some cases, when the metal value is
very high, the charges can be somewhat lower.  Minimum charges are at
least sometimes avoided when the recycler actually picks up the F006
electroplating wastewater treatment sludge directly from the generator.
For purposes of this rule making, a unit cost of $345 per ton (2007$) is
assumed for commercial metals recovery.  This value is the mid-point of
the estimated range of $200/ton to $400/ton range inflated from 2002$ to
2007$.  The commercial unit cost is assumed to include all capital and
annual expenditures necessary for the metals recovery system.  Metal
salvage value was considered separate from the recycling unit cost.

	No minimum charge is assumed for transfers of bulk shipments within the
same company.  It is assumed that transfers are typically occurring
within the same parent company and that they would not charge a minimum
fee, unlike a commercial metal recovery facility.  A commercial offsite
metal recovery facility will have a minimum charge of approximately half
of a full load (nine tons) for accepting small waste quantities for
recycling.  The minimum charge is estimated to be $3,101 (9 tons x
$345/ton).  The minimum charge equates to $0.17/lb for a 9-ton load,
$0.52 per pound for a 3-ton load, and $1.55 per pound for a 1-ton load
which are in the range of values reported by F006 recyclers in Exhibit
D12 if the unit costs are inflated from 1993$ to 2007$.  A minimum
recycling charge is applied in the cost estimate if the generator ships
less than 9 tons per truck load to the recycling facility at the end of
its accumulation time period.  Changes in generator status pre- and
post-rule will allow longer accumulation time periods resulting in
larger truck loads and fewer minimum charges.  Shipments above 9 tons
are charged $345/ton.

Exhibit D12

Estimated Offsite Metals Recycling Costs (1993$)

Generator Type* & Waste Shipment Average Size	No. of unit cost data
points	Average truckload size (tons/load)	Transport

average unit cost	Offsite Recycling

average unit cost

	($/lb)	($/ton)	($/lb)	($/ton)

Small LQG - small shipment

(<13.2 tons/year)	31	1 ton	$0.49	$980	$0.02	$40

Small LQG - large shipment

(13.2 to <60 tons/year)	36	3 tons	$0.11	$220	$0.20	$400

Large LQG shipment

(60 tons/year or greater)	20	9 tons	$0.06	$120	$0.17	$340

Average of three shipment size categories =	(1+3+9)/3 =

4.3 tons	$0.15	$300	$0.22	$440

Explanatory Notes:

* Assumes all facilities are LQGs and ship 4 times per year.  This data
may include SQGs which ship at a maximum of 2 times per year.  If these
facilities are SQGs, the average transport unit cost is $0.25/lb and
average recycling unit cost is $0.26/lb  Assumptions:

Step 1:	Used 1993 cost data provided in Exhibit 7-1 of Cushnie, George
C., CAI Engineering, "Pollution Prevention and Control Technology for
Plating Operations," prepared for NCMS/NAMF.

Step 2:	Eliminated seven data records from Cushnie that do not provide
either shipping distance, quantity shipped, or unit cost.  Based on
inspection, four records eliminated as statistical outliers.

Step 3:	Assumed the following distances:

Category < 500 miles = 250 miles,

Category 500 to 1,000 miles = 750 miles,

Category 1,000 to 1,500 miles = 1,250 miles,

Category 1,500 to 2,000 miles = 1,750 miles, and

Category 2,000 to 2,500 miles = 2,250 miles.

Step 4:	Assumed LQG and 90-day storage if > 26,400 lbs generated
annually.

Step 5:	Assumed a full shipment size of 15 tons based upon USEPA’s
Common Sense Initiative report.

Step 6:	Assumed minimum of 4 shipments/year (i.e., 90-day storage limit)
for LQGs.

Step 7:	Used 1998 ECHOS transportation unit price estimates ($/mile) for
van trailer transportation of hazardous waste.  Assume transportation
prices have not changed significantly since 1993 given that increased
labor costs are likely being balanced by historically low fuel costs.

Step 8:	Used 1998 ECHOS minimum charge for van trailer transportation of
small hazardous waste loads of $732 per shipment as a minimum cost.
Assumed $2.64/each super-sack for loading on to the truck.  Assumed
transportation prices have not changed significantly since 1993 given
that increased labor costs are likely being balanced by historically low
fuel costs.

Offsite Solvent Recycling (Distillation) Costs

Commercial offsite solvent recovery costs were developed using US Army
Corp of Engineers Public Works Technical Bulletin 200-01-04, 19 Aug 1999
(USACE Tech Bulletin).  Recycling costs include handling and
transportation of the solvent waste stream.  The cost estimate is a
service contract with one recycling facility for annual management of
1,000 gallons at a cost of $4.23 per gallon ($976/ton, 2007$).

	No minimum charge is assumed for transfers of bulk shipments within the
same company.  It is assumed that transfers are typically occurring
within the same parent company and that they would not charge a minimum
fee, unlike a commercial metal recovery facility.  A commercial offsite
solvent recovery facility will have a minimum charge of approximately
half of a full load (2,500 gallons or 10.425 tons) for accepting small
waste quantities for recovery.  The minimum charge is estimated to be
$10,171 (10.425 tons x $975.65/ton).  A minimum recycling charge is
applied in the cost estimate if the generator ships less than 10.425
tons per truck load to the recycling facility at the end of its
accumulation time period.  Changes in generator status pre- and
post-rule will allow longer accumulation time periods resulting in
larger truck loads and fewer minimum charges.  Shipments above 10.425
tons are charged $976 per ton.

Offsite Acid Recycling Costs (Used in this RIA as Proxy for Other Types
of Recycling)

Other recycling includes a mixture of waste forms.  In 2003, the
predominant waste forms recycled include very dilute aqueous waste
(W101), spent concentrated acid (W103), other organic liquid (W219),
contaminated soil (W301), batteries, battery parts, cores, casings
(W309), and other sludges from wastewater treatment or air pollution
control (W504).  The largest quantity waste form is other organic liquid
(W219) which is dominated by one waste stream that involves a
“catoxid” reactor system that converts miscellaneous organic liquids
into hydrochloric acid to be used in making ethylene dichloride.  The
second largest quantity waste form are very dilute aqueous waste (W101)
which primarily involves the recycling of water at wood preserving
plants.  The remaining four waste forms are reported in relatively equal
quantities.  Acid regeneration is used as a proxy for the cost of other
recycling category given spent concentrated acid (W103) is a predominant
waste form and that most of the largest quantity waste form (W219)
involves the generation of hydrochloric acid.

	Commercial offsite acid recovery costs were estimated using Pilot of
the Pollution Prevention Technology Application Analysis Template
Utilizing Acid Recovery System prepared by Zero Discharge Technologies,
Inc for the USEPA Region 1, October 1999.  Commercial offsite acid
recovery was estimated using the system capital cost and operation and
maintenance costs curves with an additional 30% for commercial profit.
A capital cost of roughly $17,500 to $31,800 for recycling systems sized
at 20 and 65 gallons per day (gpd) were utilized for this estimate
(1999$).  A factor of 1.5 was assumed to cover installation and startup
costs for the systems.  An annual expenditure of $639 for operation and
$1,418 for repair and maintenance was estimated per system, respectively
(1999$).  Each system was assumed to operate with a through-put of 25 to
160 tons of acid recoverable waste per year.  Larger systems are
composed of multiple units in 20 and 65 gallon increments.  Smaller
systems would be composed of a 20 gallon unit, with reduced operational
period (see Exhibit D13 for cost equations).  Capital costs were
annualized using a 10-year life for the equipment at a 15% discount
rate.  Costs are assumed to be the same for recycling at offsite
(“sister”) facilities owned by the same company within the same
industry.

	A range of facility sizes for offsite recycling operations was
estimated using 1999 Biennial Report data.  Acid recovery facilities
were identified using the offsite USEPA ID (receiver) of waste streams
with the reported management system of acid recovery (M031).  The
average acid recovery facility size used is 250 tons per year.  A
facility size of 250 tons per year is estimated to have an unit acid
recovery cost of $180 per ton (2007$).  Unit costs for facilities sized
above 250 tons per year begin to reach asymptotic limits, with a minimum
unit cost for acid recovery of approximately $163 tons per year.
Commercial offsite recovery unit costs do not include transportation and
handling.

	No minimum charge is assumed for transfers of bulk shipments within the
company.  It is assumed that transfers are typically occurring within
the same parent company and that they would not charge a minimum fee,
unlike a commercial metal recovery facility.  A commercial offsite acid
recovery facility will have a minimum charge of approximately 50% a full
load (2,500 gallons or 10.425 tons) for accepting small waste quantities
of waste for recycling.  The minimum charge is estimated to be $1,879
(10.425 tons x $180.25/ton).  A minimum recycling charge is applied in
the cost estimate if the generator ships less than 10.425 tons per truck
load to the recycling facility at the end of its accumulation time
period.  Changes in generator status pre- and post-rule will allow
longer accumulation time periods resulting in larger truck loads and
fewer minimum charges.  Shipments above 10.425 tons are charged $180 per
ton.

Exhibit D13

Estimated Acid Regeneration Offsite Recycling Costs (2007$)

Cost Element 1	Annual Expenditure ($/ton)

Capital Expenditure (Annualized)2	($136.87* (Recycled Waste Quantity) +
$3,105) * 1.30

Operation & Maintenance	($21.33* (Recycled Waste Quantity) + $1,810) *
1.30

1 Costs inflated from 1999$ to 2005$.

2 Costs annualized over 10 years at 15% discount rate using a CRF of
0.19925.

D3.	Unit Costs for Managing Industrial Recycling Residuals

Following most recycling processes, residuals may remain in the
equipment or may be generated as a by-product or co-product that require
disposal via landfilling, incineration, or other disposal method.  These
wastes face handling and characterization costs as well.  These costs
are typically paid by the generators of the residuals, but in the case
of commercial recyclers, the cost for recycling residual management may
be passed-on to their customers who initially generated the waste being
recycled by the commercial recycler.

Landfill Costs

Exhibit D14 summarizes four different unit costs applied in the
breakeven test for estimating disposed waste and residual landfill costs
pre- and post-rule:

Subtitle C landfill with stabilization unit cost has been developed to
estimate management of disposed electroplating wastewater treatment
sludge (F006), spent petroleum refining catalyst (K171 and K172),
lead-bearing materials, and metal recovery residuals.  Unit costs for
2005 were reported in RACER 2005 cost estimating software (RACER =
Remedial Action Cost Engineering Requirements cost estimating system:
http://talpart.earthtech.com/racer_documentation.htm) for RCRA Subtitle
C commercial landfill disposal costs.  The cost reported in RACER was
$210 per ton for bulk hazardous waste with stabilization (2005$).  The
unit cost was inflated to $223 per ton (2007$) using the GDP Price
Deflator January 2008.  Because the above-mentioned wastes contain
metals, stabilization of these metals is included for meeting land
disposal restriction treatment standards.  The RACER 2005 unit cost was
used as an average disposal cost for hazardous waste.  The RACER 2005
disposal cost for hazardous is presented as a 30 city average of major
cities across the United States.  The landfill disposal costs assumed
under baseline are presented below.  A minimum charge for hazardous
waste disposal is estimated as half a full load (i.e., nine tons = half
load) totaling $2,004 (2007$).

Subtitle D landfill unit cost is used to estimate the disposal cost of
non-hazardous residuals from recovery processes.  RCRA Subtitle D non
hazardous commercial landfill costs were estimated using the National
Solid Wastes Management Association 2004 annual survey.  The national
average tipping fee for non-hazardous disposal was $35 per ton in bulk
quantities ($37 per ton inflated to 2007$).  No minimum charge is
assumed for the disposal of waste in Subtitle D landfills as there is no
regulation of non-hazardous waste storage times; therefore, each
non-hazardous waste load will be a full 18-ton load.

Specialized stabilization technology (Super Detox) by Envirosource is
used for baseline management of electric arc emission control dust
(K061).  USEPA granted a multi-site delisting of this technology in
1995.  Electric arc furnace emission control dust (EAF) K061 waste is
disposed by Envirosource using a stabilization technology called Super
Detox®.  Estimates for disposal of EAF range from $100 to $175 (1999$)
to $150 to $200 (2002$) per ton.  A disposal cost of $150 per ton was
selected based on these numbers and inflated to 2007 dollars ($183 per
ton) from 1999 dollars for this estimate.

Acid hazardous waste landfill unit cost was developed for disposal of
residuals from acid recovery processes.  Acid recovery residual costs
were assumed to be disposed at a hazardous waste landfill.  Unit costs
for off-site residual disposal were estimated using RACER 2005 cost
estimating software.  RACER 2005 lists costs for disposing of acidic
liquid wastes at $1.50 per gallon (2005$).  The residuals density was
assumed to be 1 ton per cubic yard, for a unit cost of $381 per ton
(2007$) using the GDP Price Deflator from January 2008.  A minimum
charge of half a load is assumed for acid liquid waste disposal,
totaling $3,971 (2007$).

Exhibit D14

Recycling Residuals Disposal:

RCRA Subtitle C and Subtitle D Landfill Unit Costs (2007$)

Cost Element1	($/ton)

Subtitle C Landfill with Stabilization 	$223/ton

$2,004 minimum charge

Subtitle D Landfill	$37/ton

EAF Disposal (Super Detox®)	$183/ton

Acid Disposal	$381/ton

$3,971 minimum charge

1  Costs inflated from 1999 dollars to 2007 dollars for EAF disposal and
from 2005 to 2007 dollars for all other costs.

Fuel Blending/Energy Recovery and Incineration

Fuel Blending/Energy Recovery was assumed as the management method for
residuals generated from solvent recovery processes and for the disposal
of organic liquid wastes.  These wastes are assumed to energetic and
have a minimum 4,000 BTU energy value, which would provide for a self
sufficient burn and require less additive fuel for incineration.
Energetic incineration costs were estimated using RACER 2005 unit costs
(RACER = Remedial Action Cost Engineering Requirements cost estimating
system: http://talpart.earthtech.com/racer_documentation.htm) for
incineration of wastes with thermal energy values greater than 2,000 BTU
and the Assessment of the Potential Costs, Benefits, & Other Impacts of
the Hazardous waste Combustion MACT Standards: Final Rule, USEPA OSW,
July 1999.  The reported costs were averaged for an estimated unit cost
of $225 per ton ($2007).  A minimum charge of half a 5,000 gallon tanker
truck or 10.42 ton disposal load was assumed for disposal by
incineration.  The minimum charge is estimated as $2,352 ($2007).  An
incineration unit cost of $571per ton is assumed for bulk materials such
as spent activated carbon.

Waste Shipment Loading/Handling Cost

Cost for loading/handling waste streams and residuals disposed offsite
were estimated based on unit costs reported in the RACER 2005 cost
estimating software (RACER = Remedial Action Cost Engineering
Requirements cost estimating system:
http://talpart.earthtech.com/racer_documentation.htm).  Three
waste/residual streams are assumed; solids, sludges, and liquids.
Solids, such as electric arc furnace dust, can be loaded with front end
loaders into roll-off bins.  Sludges, such as solvent recovery
distillation bottoms, are contained in 55 gallon drums for handling.
Liquids, such as acid recovery residuals, condensed acids with other
impurities, are pumpable and stored in tanks and containers prior to
loading into a tanker truck.  Solid waste, sludge waste, and liquid
waste loading/handling unit costs are estimated to be $0.47 per ton,
$37.89 per ton, and $50.20 per ton, respectively.

Initial Waste Characterization & Waste Shipment Characterization Costs

Initial characterization: An initial physical and chemical
characterization cost is incurred once for each hazardous waste or
recovered waste.  Generators may no longer incur this cost under the DSW
rule exclusions.  This cost element consists of two sub-elements:

The initial characterization includes a cost of $1,417 for an average 20
hours of staff engineer employee time to collect, prepare, and submit an
average of three analytical samples (i.e., (20 hours) x ($70.83/hour)).
The estimated labor hours are from “Supporting Statement for
Information Collection Request (ICR) Number 0820.10: Hazardous Waste
Generator Standards”, January 2008.

Average analytical cost of $852/facility for analysis of three samples
(i.e., ($284/sample) x (3 samples)); source: RACER 2005 unit costs
inflated to 2007 dollars (RACER = Remedial Action Cost Engineering
Requirements cost estimating system:
http://talpart.earthtech.com/racer_documentation.htm).

The generator per-facility per-waste stream average unit cost annualized
over 3 years at 15% CRF is estimated at $1,056 ($2007) per waste stream.

Shipment characterization:  Waste characterization costs are also
assumed for all recovery or hazardous waste disposal shipments.  As the
number of shipments decrease with longer accumulation times provided by
the DSW exclusions, waste characterization costs may be expected to
decrease.  This cost element consists of two sub-elements based upon
RACER 2005 software:

Average cost of $62 per waste shipment for two hours process technician
labor burden per-shipment to collect, prepare, and submit the analytical
sample (i.e., (2.0 hours) x ($31.41/hour) ($2007).

Average analytical cost of $284 for analysis of each waste stream for
disposal purposes (e.g., TCLPs, BTU values, or other regulated
constituents).

Total cost per shipment for waste characterization is estimated as $346
($2007).

D4.	Methodology for Estimating Industrial Recycling Residual Waste
Generation & Management

This section presents the methodology used to estimate metal, solvent,
and acid recycling waste residual generation quantities and disposal
management practices and recovered product quantities.  It was developed
using 1999 Biennial Report data for the 2003 DSW proposed rule.  Records
in the 1999 Biennial Report for generators reporting waste management
with system types M013 (secondary smelting), M021
(fractionation/distillation), and M031 (acid regeneration) were
reviewed.  Due to the limited number of facilities reporting wastes
managed with system types M013 and M031, all such facilities were
reviewed.  Facilities reporting management by system type M021 were
divided into five groups.  The five groups of facilities are
approximately equal in number with one group containing the smallest
generators based on quantity of waste managed by system type M021, the
next group containing the next smallest generators, and so on. The data
are divided into five groups based on quantity of waste managed to try
and capture any variation in residual generation and management based on
generator size.  Six facilities were randomly selected from each group.
The groups were divided as follows:

<1.1 tons/year managed

1.1 to 5 tons/year managed

5 to 13.5 tons/year managed

13.5 to 55 tons/year managed

>55 tons/year managed

Exhibit D15 below presents the data results.  The following assumptions
were made regarding the waste recycling processes:

Recycling systems for acid and solvents are closed loop.  That is no
losses from spillage or waste are assumed.  This is a simplification of
the actual process as many processes may include settlement tanks or
other open-air sections that may allow evaporation or spillage.

All ineffective products are removed with the process residuals.  An
effectiveness factor or assay value is included to estimate the
“purity” of the recovered solvent, acid, or metal.

Metals:	For the metals recovery process, 32% of the waste quantity
processed by the metals recovery unit is assumed to be waste residual.
20% of the waste stream is assumed recovered metal in higher quality
wastes and 5% in lower quality disposed wastes.  The remaining 48% or
63% (for lower quality disposed wastes) of the waste stream mass is
assumed to be components that are volatilized (e.g., water vapor) in the
recycling process.

Solvents:	Mass is assumed to be balanced in the solvent recovery
process.  No additives or precipitants are assumed into the process, or
the change in product/residual mass in comparison to the total mass is
minor.  For the solvent recovery process, 33% of the waste quantity
processed by the recycling unit is assumed to be waste residual.  The
remaining 67% of the waste stream is assumed recovered solvent.

Acids/other:	Mass is assumed to be balanced in the acid recovery
process.  No additives or precipitants are assumed into the process, or
the change in product/residual mass in comparison to the total mass is
minor.  For the acid recovery process, 26% of the waste quantity
processed by the recycling unit is assumed to be waste residual.  The
remaining 74% of the waste stream is assumed recovered acid.

Exhibit D15

Estimate of Hazardous Waste Recycling Residuals as Percentage of Waste
Recycled

Statistical Measures	H010 Metal Recycling	H020 Solvent Recycling	H039
Other recycling

1. No. Data Points	7

23

18

2. Range of Percentages	0.42% to 84%

0.46% to 140%

0% to 105%

3. Average Percentage (applied in this RIA for impact estimation)	32%

33%

26%

4. Standard Deviation	+/-33.92%

+/-32.13%

+/-31.92%

Metal recovery:	Total of 19 facilities reporting wastes managed by
secondary smelting (M013).  A total of seven facilities were used in the
percent residual calculation.  Residual waste streams could not be
identified for the remaining facilities.  The management system type
reported for the residuals identified for secondary smelting (M013)
system processes are:

M061 (fuel blending),

M111 (cementitious stabilization)

M112 (other stabilization)

M119 (stabilization - type unknown), and

M132 (landfill).

Five of seven waste generating facilities managed their secondary
smelting residuals by stabilization (M111, M112, and M119).  The likely
final deposition of the stabilized wastes are in a RCRA Subtitle C
hazardous waste landfill.

Solvent recovery:	Residuals generated by fractionation/distillation
(M021) system processes were reported managed by the following system
types:

M042 (incineration - sludges)

M051 (energy recovery - liquids)

M061 (fuel blending), and

M081 (biological treatment).

A total of 28 facilities were reviewed, of which five facility residual
waste streams could not be identified.  Fuel blending (M061) was
reported by 17 of 22 facilities for management of fraction/distillation
(M021) residuals.  An additional three facilities managed
fractionation/distillation residuals by other co-burning or incineration
systems (M042 and M051).  The likely final disposition of
fractionation/distillation residuals is energy recovery.

Acid recovery:		Residuals generated by acid regeneration (M031) system
processes were assumed to be similar in form to the spent acid waste
stream.  That is, the contaminants (generally metals) were concentrated
in a smaller portion of the waste stream for management.  The disposal
quantities of these residuals were identified by their description and
management system type.  A total of 23 facilities were reviewed, of
which five facility residual waste streams could not be identified.
Residuals were reported managed by:

M039 (other recovery - type unknown)

M042 (incineration - sludges)

M043 (incineration - solids)

M051 (energy recovery - liquids)

M077 (chemical precipitation)

M104 (solvent extraction)

M109 (sludge treatment - type unknown)

M121 (neutralization only)

M134 (deepwell/underground injection), and

M136 (NPDES discharge to surface water).

Chemical precipitation (M077) was reported by seven of eighteen
facilities for management of acid regeneration residuals.  One
additional facility reported management by neutralization only, which is
similar to chemical precipitation.

Unit Costs for Managing Recycling Residuals

In the cost estimates, metal recovery residuals are assumed to be
managed by stabilization and disposed in RCRA Subtitle C hazardous waste
landfills.  Solvent residuals are assumed to be managed by energy
recovery.  Acid recovery residuals are assumed to be managed by chemical
precipitation.  Cost assumptions for management of acid recovery
residuals include stabilization and landfill disposal of precipitates
and sewer discharge of neutralized wastewater.

	If recycled materials are no longer hazardous, they no longer carry the
label of being a listed waste, if applicable.  Residuals from the
recycling of listed wastes will no longer be considered
“derived-from” wastes and no longer regulated under RCRA 40 CFR
261.3(c)(2)(I).  A condition of the DSW final rule exclusions is the
“listed” waste definition will no longer be attached to residuals
and management depends upon if the waste is characteristically hazardous
only.  To estimate the implementation impacts (i.e., cost savings) from
not regulating residuals derived from recyclable materials as hazardous
unit costs are needed for residual hazardous disposal (hazardous
landfill, fuel blending, and acid precipitation/ dewatering/
stabilization/ landfill) and residual nonhazardous disposal
(nonhazardous landfill, fuel blending, and acid precipitation/
dewatering/ stabilization/ landfill).  In addition, estimates for the
amount of residuals generated and the fraction that is
characteristically hazardous or “listed” hazardous are needed.
Landfill unit cost estimates are presented earlier in this chapter.

Recycling:	Offsite recycling fees already include the cost of residual
management.  Residual management costs only are needed for estimating
the full cost of onsite recycling.  For facilities currently recycling
waste, the  estimated incremental cost savings from larger residual
hazardous waste disposal shipments resulting from longer accumulation
times and residuals being defined as nonhazardous is calculated within
the cost analysis using nonhazardous disposal costs and calculated
reductions in the number of shipments/loads per year..

Fuel Blending:	Fuel blending was assumed as the disposal method for
solvents and solvent still bottoms.  Fuel blending costs were estimated
using RACER 2005 unit costs (RACER = Remedial Action Cost Engineering
Requirements cost estimating system:
http://talpart.earthtech.com/racer_documentation.htm) for incineration
of wastes with thermal energy values greater than 2000 BTU and the
Assessment of the Potential Costs, Benefits, & Other Impacts of the
Hazardous waste Combustion MACT Standards: Final Rule, USEPA OSW, July
1999.  The reported costs were averaged for an estimated unit cost of
$225 per ton ($2007).  A minimum charge of half a disposal load was
assumed for disposal by fuel blending.  The minimum charge is estimated
as $2,352 ($2007).

Acid Precipitation/Dewatering/Stabilization/Landfill:	Disposal of acid
liquids costs were estimated using RACER 2005 cost estimating software.
Mineral acids disposal was used as a proxy for acid waste disposal, with
stabilization, at a landfill.  The cost is estimated as $378 per ton
($2007).

Residual Characteristics:  Residuals generation from metals recovery was
estimated using 1999 Biennial Report data.  Waste streams at selected
recycling facilities were reviewed by comments, disposal system type,
and origin to determine the likely waste streams generated from the
recycling operations.

Metals:		Approximately 32% of the metals recovery mass was identified as
residuals in the Biennial Report data.  The recovered metals are assumed
to be 20% of the mass for waste streams currently recycled and 5% of the
mass for waste streams currently disposed.  The remaining mass fraction
is volatilized out the stack in the smelting process.  The hazardous
fraction of the residuals were determined by reviewing the waste codes
for the waste streams reporting metals reclamation.  Waste streams
reporting characteristic codes were assumed to have residuals that would
be characteristically hazardous waste.  95% of the metals recovery
residual waste volume and frequency of waste streams are estimated to be
characteristically hazardous with the remaining 5% containing listed
hazardous wastes which are assumed in this RIA to become non-hazardous
post-rule.

Solvents:	33% of solvent recovery mass was identified as residuals and
67% as recovered solvent in the Biennial Report data.  For currently
disposed organic liquids the residual fraction was doubled to 66% to
reflect a lower percentage of potential solvent quantity for recovery.
The hazardous fraction of the residuals was determined by reviewing the
waste codes for the waste streams reporting solvent recycling.  Waste
streams reporting characteristic codes were assumed to have residuals
that would be characteristically hazardous waste.  For solvent
recycling, approximately 85% of the residual waste volume is estimated
to be characteristically hazardous with the remaining 15% containing
listed hazardous wastes which are assumed in this RIA to become
non-hazardous post-rule.

Acids:		26% of the acid regeneration mass was identified as residuals
and 74% as recovered acid in the Biennial Report data.  The hazardous
fractions of the residuals were determined by reviewing the waste codes
for the waste streams reporting acid regeneration.  Waste streams
reporting characteristic codes were assumed to have residuals that would
be characteristically hazardous waste.  For acid regeneration,
approximately 75% of the residual waste volume is estimated to be
characteristically hazardous with the remaining 25% containing listed
hazardous wastes which are assumed in this RIA to become non-hazardous
post-rule.

Appendix E

Data for Estimating State Government Hazardous Waste Fee Revenues

Exhibit E1 below displays the state government hazardous waste
generation taxes and fees identified in this RIA for industrial
hazardous waste generator facilities in 31 states.  The two primary data
references consulted for this RIA did not contain sufficient data,
without further analysis outside the scope of this RIA, for eight states
(DE, IL, NE, NV, NY, OH, TX, WV) to determine if “recovery” is
included under their regulatory definition of “treatment.”  For only
one of the 31 states for which there are fee data (CO) an annual
operating fee is charged to hazardous waste TSDFs, but this RIA simply
assumes this fee is passed on to the generator and includes it with the
generator fee impact estimate.  In the typical preferred management
hierarchy of reuse, recycling, energy recovery, treatment, and disposal,
these states may not tax or assess fees on preferential forms of
management.

Exhibit E1

State Government Hazardous Waste Taxes & Fees

A	B	C	D	E	F	G	H	I	J	K	L

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

1	AL	NA=Not available	NA

	2	AK	None	$0

	3	AZ	Generators of waste that retain the waste onsite for disposal or
who ship it offsite to a facility owned or operated by that generator
$4.00/ton

	4	AR

	Monitoring/inspection fees	$500/yr	$500/yr	$500/yr	$500/yr	$500/yr
$500/yr	$150/yr	$0/yr

5	CA

	Generator fee & 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

6	CO	Haz waste TSDF annual operating fee (assumed offsite passed on to
generator): Class III (resource recovery)	$2.50/ton

	7	CT	Haz waste generator tax	$9.59/ton

	8	DC	NA	NA

	9	DE	Fee for offsite treatment.  Unclear if treatment equals recovery
in this state ($16/ton)	Further Analysis Needed

	10	FL	NA	NA

	11	GA

	Haz waste mgt fee	$1/ton	$1/ton	$1/ton	$1/ton	$1/ton	$1/ton	$100/yr
$0/yr

12	HI	NA	NA

	13	ID	Haz waste fee	$30.00/ton

	14	IL	Fee for on- or offsite treatment.  Unclear if treatment equals
recovery in this state ($7.19/ton)	Further Analysis Needed

	15	IN	NA	NA

	16	IA	NA	NA

	17	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

18	KY	Generator haz waste fee	$2.00/ton (onsite)

$4.00/ton

(offsite)

	19	LA	NA	NA

	20	ME	Offsite handling fee (assume handling = recovery)	$30.00/ton

	21	MD	NA	NA

	22	MA	NA	NA

	23	MI	NA	NA

	24	MN

	Quantity fee and tax & 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

25	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

26	MO	Haz waste fee. For category tax, unclear if treatment equals
recovery in this state [$0.7/ton + $20/yr]	$1.00/ton

	27	MT	Generator fee.  Did not have “Class” definition.  Assume
middle class/fee.	$600.00/yr

	28	NE	TSDF fee.  Unclear if treatment equals recovery in this state
($1.92/ton)	Further Analysis Needed

29	NV	Offsite treatment fee.  Unclear if treatment equals recovery in
this state ($40.20/ton)	Further Analysis Needed

30	NH

	Haz waste fee	$60/ton	$60/ton	$60/ton	$60/ton	$60/ton	$60/ton	$60/ton
$0/ton

31	NJ	Manifest processing fee (assumed 18 tons shipped per manifest)
$0.50/ton	Haz waste generator biennial reporting fee & inspection &
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

32	NM

	Generation fee & 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

33	NY	Special assessment on offsite generation, treatment or disposal.
Unclear if treatment equals recovery in this state ($16/ton)	Further
Analysis Needed	Haz 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

34	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

35	ND	None	$0

	36	OH	Haz waste treatment & disposal fee.  Unclear if treatment equals
recovery in this state ($24/ton)	Further Analysis Needed

	37	OK	Annual fee for offsite recycling	$4.00/ton	Generator fee	$100/yr
$100/yr	$100/yr	$100/yr	$100/yr	$100/yr	$25/yr	$0/yr

38	OR	Annual haz 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

39	PA	NA	NA

	40	RI	NA	NA

	41	SC	Annual haz waste fee. Annual non-haz waste fee	$34.00/ton

$13.70/ton

	42	SD	NA	NA

	43	TN

	Annual generator fee	$900/yr	$900/yr	$900/yr	$900/yr	$900/yr	$900/yr
$550/yr	$0/yr

44	TX	Facility fee.  Unclear if treatment equals recovery in this state
($4.80/ton)	Further Analysis Needed	Generation fee	$2/ton	$2/ton	$2/ton
$2/ton	$2/ton	$100/yr	$100/yr	$0/yr

45	UT	Haz waste generation fees	$28.00/ton

	46	VT	NA	NA

	47	VA	NA	NA

	48	WA	Haz waste education fee	$35.00/yr

	49	WV	Generator fee.  Unclear if treatment equals recovery in state
Further Analysis Needed

	50	WI	Tonnage fee & manifest fee (assume 18 tons shipped per manifest)
$0.26/ton

	51	WY	NA	NA

	Explanatory Notes:

NA = Data not available.

* The 8 generator size (tons/year) categories do not fit all states.
For this RIA, taxes/fees for states with different size categories are
approximated to the 8 categories.

Sources of state government hazardous waste fee/tax data:

US Army Corps of Engineers “Treatment, Storage & Disposal Facilities
for Hazardous, Toxic, and Radioactive Waste”, HTRW Center of Expertise
Information - TDSF, Section 8.2,
http://www.environmental.usace.army.mil/library/pubs/tsdf/sec8-2/sec8-2.
html, 11 Sept 2002.

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

 Concerning peer review of RIAs, USEPA’s 2006 peer review guidance
states “Generally, if a RIA applies accepted, previously peer-reviewed
methods in a straightforward manner, it would not undergo an additional
peer review.  RIAs prepared to support “major” or ”economically
significant” regulations typically do not utilize innovative or
untried economic methods.  It is unnecessary to conduct peer reviews of
straightforward applications or transfers of accepted, previously
peer-reviewed economic methods or analyses.  The procedures used to
transfer or adapt an economic work product are generally established by
separate economic guidance documents which have be peer reviewed.
Therefore, RIAs that are developed using these procedures do not
normally undergo an additional peer review, even those prepared in
support of “major” and “economically significant” rules.”
Source: Section 2.2.6 (page 35) of USEPA Science Policy Council, “Peer
Review Handbook”, 3rd Edition, document ID nr. EPA/100/B-06/002, May
2006,
http://www.epa.gov/peerreview/pdfs/Peer%20Review%20HandbookMay06.pdf.

 Concerning public review, USEPA’s 2006 peer review guidance states
“Peer review and public comment are not the same. Public comment
solicited from the general public through the Federal Register or by
other means is often required by the Administrative Procedure Act, other
relevant statutes or both. Public comment may also be solicited for
policy purposes.  The Agency takes public comment on some strictly
scientific products and almost all regulatory decisions. Public
commenters usually include a broad array of people with an interest in
the technical analysis or the regulatory decision; some are scientific
experts (who may provide some peer input), some are experts in other
areas, and some are interested non-experts.  The critical distinction is
that public comment does not necessarily draw the kind of independent,
expert information and in-depth analyses expected from the peer review
process.  Public comment is open to all issues, whereas the peer review
process is limited to consideration of specified technical issues.
While it may be an important component of EPA’s decision making
process, public comment does not substitute for peer review.”  Source:
ibid, section 1.2.8 (page 14).

 Skewness = Skewness is a measure of data symmetry, or more precisely,
the lack of symmetry.  A distribution, or data set, is symmetric if it
looks the same to the left and right of the center point of the data
range.  Source: National Institute of Standards and Technology,
“Section <IP_ADDRESS>. Measures of Skewness and Kurtosis”  in the
Engineering Statistics Handbook at:   HYPERLINK
"http://www.itl.nist.gov/div898/handbook/eda/section3/eda35b.htm"
http://www.itl.nist.gov/div898/handbook/eda/section3/eda35b.htm

	According to the “National Analysis” summary statistics presented
in each biennial data year issue (i.e., 1991, 1993, 1995, 1997, 1999,
2001, 2003, 2005) of OSW’s RCRA Hazardous Waste Biennial Report
(http://www.epa.gov/epaoswer/hazwaste/data/biennialreport/index.htm),
the universes of RCRA-regulated  hazardous waste (a) generators, (b)
managers, (c) shippers, and (d) receivers are skewed according to three
complementary numerical indicators of skewness based on annual tonnage
hazardous waste generated in each data year (illustrative percentages
below based on 2005 data year universe of 38.347 million tons generated
by 16,191 LQG generator facilities in around 600 NAICS 4-digit generator
industries in 56 US states/tribes/territories):

Facility skewness:  Top-1 facility generated 11%; top-5 facilities
generated 30% .

Industry skewness:  Top-1 industry (NAICS 3251: Basic Chemical Mfg)
generated 55% ; top-5 industries generated 81% .

State location skewness:  Top-1 state (TX) generated 40% ; top-5 states
(TX, LA, OH, MS, IL) generated 67% .

  Since its enactment in 1980, the RFA has required every Federal agency
to prepare “regulatory flexibility analyses” for any public
notice-and-comment regulation (i.e., proposed rule) it issues, unless
the agency certifies that the proposed rule “will not, if promulgated,
have a significant economic impact on a substantial number of small
entities” (i.e., SISNOSE) subject to the terms and conditions of the
rule.  The 1996 SBREFA amendment to the RFA strengthened the RFA’s
analytical and procedural requirements.  For additional information
about RFA/SBREFA see: http://www.epa.gov/sbrefa

 RIS = EPA Publication Number: 530-R-92-021.  This document is not
currently available in electronic format.  RCRA Online Number: 50309.
Title: “RCRA Implementation Study Update: The Definition of Solid
Waste”, 15 July 1992; Description: Reexamines the EPA definition of
solid waste in an attempt to clarify EPA's RCRA mandate. Explores
resource recovery, recycling regulations, and implementation issues, and
presents a plan for change. Summarizes meetings held to solicit
industry, interest group, and other government branch input on the
definition of solid waste and hazardous waste recycling regulations
(source:
http://yosemite.epa.gov/osw/rcra.nsf/ea6e50dc6214725285256bf00063269d/1a
b72d5921fa644c85256a7e00762b62!OpenDocument).

 Pages 61562 to 61563 of the Federal Register announcement for OSW’s
28 Oct 2003 proposed revisions to the RCRA “Definition of Solid
Waste” provide a synopsis of the following seven 1987-2000 series of
DC Circuit Court decisions:
http://www.epa.gov/epaoswer/hazwaste/dsw/abr-rule/abr-rule.pdf

1987: American Mining Congress v. USEPA (“AMC I”)

1990: American Petroleum Institute v. USEPA (“API I”)

1990: American Mining Congress v. USEPA (“AMC II”)

1993: US v. ILCO

1994: Owen Electric Steel Co. v. USEPA

2000: American Petroleum Institute v. USEPA (“API II”)

2000: Association of Battery Recyclers v. USEPA (“ABR”)

 OSW’s long-term “vision” of the future of the RCRA waste
management program is discussed in the document “Beyond RCRA:
Prospects for Waste and Materials Management in the Year 2020,” which
is available on USEPA’s website at:
http://www.epa.gov/epaoswer/osw/vision.htm

 OSW’s 27 June 2003 economic analysis in support of the October 2003
DSW proposed rule is available to the public as document number
EPA-HQ-RCRA-2002-0031-0002 (274 pages) at http://www.regulations.gov.

 OSW’s “Definition of Solid Waste” (DSW) October 2003 proposed
rule website: http://www.epa.gov/epaoswer/hazwaste/dsw/abr.htm

 For background information about USEPA’s RCRA solid and hazardous
waste regulations as they pertain to industrial recycling, see: (a)
USEPA Office of Solid Waste, “Introduction to: Definition of Solid
Waste and Hazardous Waste Recycling (40 CFR §§261.2 and 261.9)”, Oct
2001, EPA530-K-02-007I, 23 pages;
http://www.epa.gov/epaoswer/hotline/training/defsw.pdf, and/or (b)
USEPA’s webpage about RCRA hazardous waste recycling at:
http://www.epa.gov/epaoswer/hazwaste/recycle/hazrecyc.htm

 The Cement Kiln Recycling Coalition (CKRC; 2002-0031-0548) commented
that the 2007 DW RIA “[O]nce again simply assumes without supporting
facts that the [DSW final rule] will not affect energy recovery from
hazardous wastes in cement kilns and does not adequately analyze the
degree to which the rule will adversely affect this desirable
practice…  EPA has ignored or underestimated the extent to which the
proposed rule would encourage energy-bearing hazardous secondary
materials to move away from energy recovery in cement kilns and towards
other less-regulated forms of recycling.”  However, there is not
apparently an industry-wide consensus that the DSW final rule may be
expected to have an adverse impact, as evidenced by two commentors (ETC
& SOCMA) on our prior 2003 and 2007 RIAs who offered the following
contrary statements of why it is reasonable to expect a negligible
impact in relation to the physical/chemical characteristics of hazardous
wastes managed by energy recovery:

The Environmental Technology Council (ETC, ID nr. 2002-0021-0119) who
claimed to be “speaking from direct experience in the industry in
managing [hazardous] wastes on a daily basis for over 20 years”:
“There is no reason to believe that generators will be encouraged to
shift the management practices for [hazardous wastes managed by energy
recovery].  The aqueous inorganic treatment already realizes RCRA
exemptions associated with the wastewater treatment exemptions.  In
addition, wastewater streams are often dilute and do not contain
significant quantities of recoverable constituents.  It is therefore
doubtful that any of this volume will go to [materials] recovery.
Likewise, the volumes currently managed by energy recovery are being
done so at a savings and also as a recycling practice.  Many states and
TRI view energy recovery as recycling.  There will be little incentive
for generators to switch their management practices and invest capital
in alternate recovery processes for these streams.  In addition, other
than the BTU value, these wastes contain few components that have
[materials] recovery value, which is why they are managed by energy
recovery or fuel blending currently, as opposed to solvent recovery.
The average solids content of fuel-blended waste is about 30%, and many
cement kilns are feeding other higher-solids content waste through pails
or coal injection systems.  In addition, many fuel-blended streams have
substantial water content and other organic liquid components that form
azeotropes and are not amenable to solvent recovery.  At most, 50,000
tons of this [current energy recovery] volume might be routed to other
[materials] recovery, but even this is doubtful.”

The Synthetic Organic Chemical Manufacturers Association (SOCMA, ID nr.
2002-0031-0471.2) claimed that “Smaller businesses have little
leverage with or access to the larger reclamation facilities.
Frequently, smaller volume waste streams must be incinerated because
commercial reclamation facilities prefer to handle high volumes …
Overall, the cleaner a waste solvent is the more value it has either for
subsequent use and application as a solvent or for energy recovery.
Thus, the ability of a toll contractor to use existing equipment to
reclaim even smaller volumes of solvents from toll manufacturing
operations is economically a meaningful option to pursue.  Relatively
cleaner [waste] solvents also typically have a higher BTU value and
hence can have greater value for energy recovery.”

  USEPA Office of Solid Waste, Economics, Methods & Risk Analysis
Division (EMRAD), “RCRA Hazardous Waste Delisting: The First 20 Years
(Program Evaluation)”, prepared by Abt Associates and Glenn Farber
(EMRAD Regulatory Impact Analyst), June 2002, 32 pages;
http://www.epa.gov/epaoswer/hazwaste/id/delist

 SQGs:  The exclusion of SQGs from this analysis reflects the RCRA
exclusion of SQGs from reporting to the RCRA Hazardous Waste Biennial
Report.  Consequently, USEPA does not collect regularly updated data on
RCRA waste volumes generated by SQGs.  Omission of explicit data on SQGs
does not necessarily mean that this analysis excludes small and medium
size companies for the following  reasons:

Not all SQGs necessarily represent small or medium size companies, and
not all LQGs represent large companies, based on either (a) company
employee count or (b) company annual sales revenues, two alternative
measures used by the Small Business Administration to define “small
business” (http://www.sba.gov/size).

Furthermore, many SQGs are not in the same industries and markets with
LQGs; for example, the top-5 largest LQG industries in 2003 based on
annual tons waste generated are (1) NAICS 3251 Basic Chemical Mfg, (2)
NAICS 3241 Petroleum & Coal Products Mfg, (3) NAICS Waste Treatment &
Disposal, (4) NAICS 3252 Resin, Synthetic Rubber, Synthetic Fibers &
Filaments Mfg, and (5) NAICS 3311 Iron & Steel Mills & Ferroalloy Mfg,
all of which are capital-intensive industries predominantly populated
with relatively larger size companies (source: Exhibit 1.9 at:
http://www.epa.gov/epaoswer/hazwaste/data/br03/national03.pdf).  In
contrast, SQGs are predominantly in different industries; for example,
the top-5 SQG industries in aggregate constituting 98.3% SQGs and only
1.7% LQGs are (1) NAICS 8111 Automotive Repair & Maintenance, (2) NAICS
3231 Printing & Related Support Activities, (3) NAICS 332 Fabricated
Metal Product Mfg , (4) NAICS 4411 Motor Vehicle & Parts Dealers, and
(5) NAICS 5111 Print Publishing Industries, based on estimated
establishment counts in OSW’s July 2003 economic impact analysis for
the RCRA spent solvent industrial wipes proposed rule (see page 90 of
document ID nr. EPA-HQ-RCRA-2003-0004-0004 at
http://www.regulations.gov).

Although there is not necessarily a high degree of correlation in any
single industry between RCRA regulatory status (i.e., LQG, SQG, CESQG)
and facility size measured by employee count or annual revenues,
comparison of respective RCRA biennial hazardous waste generation
volumes (i.e., tons per year) indicate that SQGs are probably much
smaller in average size than LQGs.  Consequently, most SQGs send their
wastes offsite for treatment, disposal or recycling by commercial
hazardous waste management facilities because they lack economy-of-scale
to manage the wastes themselves, and for other business reasons.  Based
on 1997 data (source: Steven Brown, Margaret James & Gary Light, ICF
Consulting, “SQG Up-Date” 31 July 2000 memorandum to Peggy Vyas,
OSW), there are about 114,000 SQGs which generate a total of between
600,000 to 930,000 tons/year of RCRA hazardous waste, which represents
an average SQG waste size of 5.3 to 8.2 tons/year.  As an example, if
this average SQG volume consisted of spent solvents, it would be
equivalent to 24 to 37 barrels per year, or 2 to 3 barrels per month (@8
lbs/gallon and @55 gallons/barrel).  Compared to the 17,700 LQGs which
generate 30,176,000 tons for an average LQG waste size of 1,705
tons/year (as of 2003) --- which represents 7,750 barrels per year or
646 barrels per month of spent solvent as an example waste material ---
SQGs are only 0.3% to 0.5% the size of an average LQG.  OSW does not
expect SQGs will experience an adverse disproportional effect of the DSW
final rule if SQGs lack economy-of-scale to justify capital investment
in new generator controlled  recycling operations, because SQGs are
alternatively eligible for DSW offsite transfer recycling exclusion
(i.e., Exclusion 2 in this RIA).

 According to USEPA’s Biennial Report website (as of March 2008), the
2007 Biennial Report data will not be published on the internet until
December 2008:
http://www.epa.gov/epaoswer/hazwaste/data/biennialreport/index.htm

 In its comments to the Docket on OSW’s 26 March 2007 DSW re-proposal
(comment ID nr. 2002-0031-0548), the Cement Kiln Recycling Coalition
(CKRC) specifically requested that OSW analyze “the degree to which
the [DSW revisions final] rule will adversely affect this desirable
practice [of energy recovery from hazardous wastes in cement kilns]”
and .”would encourage energy-bearing hazardous secondary materials to
move away from energy recovery in cement kilns and towards other
less-regulated forms of recycling.”

  The RCRA hazardous waste program ICRs from which unit costs are
applied in this RIA are ICR 2106.01, ICR 801, ICR 820, ICR 976, ICR
1189.14, ICR 1572, and ICR 1573.  USEPA ICRs are available from OMB’s
Federal agency ICR inventory at:
http://www.reginfo.gov/public/do/PRAMain

 Although OSW did not independently evaluate their claims, five public
commentors on OSW’s 2003 and 2007 DSW RIAs challenged the
reasonableness of assuming that hazardous waste generators may invest in
onsite recycling.  Four of the five commentors are industrial
associations and companies which represent a large fraction of the
industries which may be most affected by the DSW final rule: (a)
American Chemical Council commentor ID nr. 2002-0031-0093, (b) IPC
Association of Connecting Electronics Industries commentor ID nr.
2002-0031-0112, (c) International Metals Reclamation Company Inc
commentor ID nr. 2002-0031-0178, and d) PPG Industries Inc commentor ID
nr. 2002-0031-0203.  They indicated that a baseline disposal switchover
to future onsite recycling scenario is not reasonable because (a)
facilities within a single NAICS code industry are unlikely to be able
to recycle them at all if they cannot recycle them in already
DSW-excluded closed loop processes, and because of the unavailability of
(b) investment capital, (c) industrial facility space, (d) technical
expertise, and (e) skilled labor business constraints for some
individual industrials facilities, and because (e) it is more likely
that a company in another industry will have the required
economies-of-scale expertise and infrastructure to reclaim significant
quantities of secondary materials from a different industry, for
example, no chemical plant is likely to build a metal processing,
beneficiation or smelting operation to address its secondary
metal-bearing material flows (comments are available at
http://www.regulations.gov according to their commentor ID numbers for
docket nr. EPA-HQ-RCRA-2002-0031).

 For example, a manufacturer of optical photoconductors in Chesapeake VA
reportedly in the late 1990s shifted its offsite disposal (at offsite
cement kilns for energy recovery incineration destruction) of spent
tetrahydrofuran (THF) solvent – “highly unstable and explosive,
forming peroxides in the presence of oxygen” --- to onsite recycling
via a distillation-based technique that recovers the spent THF solvent
for onsite reuse.  Source: “Safe Recovery of a Hazardous Solvent”,
Chemical Engineering, Oct 2001, p.95,
http://www.che.com/articles/2001/EngKirk/EngKirk10012001_04.html.

 Source: USEPA Office of Chief Financial Officer,
http://www.epa.gov/cfo/futures/env_scen.htm.

 See pages 55 to 56 of ETC’s 25 Feb 2004 comments on OSW’s 2003 DSW
proposed rule at: http://www.etc.org/ETC_Detailed_Comments.pdf

 Additional background information about the US cement manufacturing
industry and its energy consumption is available at:
http://www.energystar.gov/ia/business/industry/Cement_Energy_Guide.pdf,
LBNL-54036, Ernest Orlando Lawrence Berkeley National Laboratory, Energy
Efficiency Improvement Opportunities for Cement Making, An Energy Star
Guide for Energy and Plant Managers, Ernst Worrell & Christina Galitsky,
Environmental Energy Technologies Division, Sponsored by the USEPA, Jan
2004.

 Page 139 of USEPA’s  “Guidelines for Preparing Economic Analyses”
(report no. EPA-240-R-00-003, Sept 2000; ), provides a descriptive
distinction and definitions of “distributional effects” and “real
resource effects”.
(http://yosemite.epa.gov/ee/epa/eed.nsf/webpages/Guidelines.html/$file/G
uidelines.pdf).

 In addition to hazardous waste spent solvents, there are reportedly at
least 10 other categories of hazardous and non-hazardous wastes and
industrial by-product or secondary materials which are also used as
fuels by cement manufacturing plants (Source: William Gabbard & David
Gossman, “Hazardous Waste Fuels and the Cement Kilns”, ASTM
Standardization News, Sept 1990):

Industrial and commercial paint solids/residues & blended paint wastes

Solvent recycling residues (i.e., process still bottoms, distillation
cuts/fractions and residues such as oils & resins)

Metal working and machining spent lubricants, spent coolants, spent
cutting fluids

Used oil

Petroleum refining residues

Industrial wastewater treatment plant sludge (aka “filter cake”)

Wood chips

Used tires

Agricultural wastes such as rice hulls

Low organic level aqueous streams if matched with high Btu waste oils

 Sulfuric acid is a non-discretionary by-product of smelter SO2 recovery
in metallic ore (sulfides) roasting in the production of copper, nickel,
lead, zinc, molybdenum and gold.  Approximately 10%of the US sulfuric
acid market is supplied by smelter acid, the remainder coming from
virgin acid production (via elemental sulfur burning, acid sludge
burning and stack gas desulfurization).  As of 1999, the following 14
metallic ore smelters had a sulfuric acid by-product production capacity
of 4.765 million short-tons per year: 1. Asarco, East Helena MT, 2.
Asarco, El Passo TX, 3. Asarco, Hayden AZ, 4. Big River Zinc, Sauget IL,
5. Chino Mines, Hurley NM, 6. Climax Molybdenum, Ft. Madison IA, 7. Doe
Run, Herculaneum MO, 8. Kennecott Utah Copper, Magna UT, 9. Langeloth
Metallurgical, 10. Langeloth PA, 11. Newmont Gold, Carlin NV, 12.
Pasminco, Clarkesville TN, 13. Phelps Dodge Miami, Claypool AZ, 14. Zinc
Corp, Monaca PA.  Source: “Chemical Profiles,” Chemical Market
Reporter, publication of the Schnell Publishing Company at:
http://www.the-innovation-group.com/ChemProfiles/Sulfuric%20Acid%20(smel
ter).htm

 Source: Office of Management & Budget (OMB) Circular A-4: Regulatory
Analysis, 17 Sept 2003, p.26;
http://www.whitehouse.gov/omb/circulars/a004/a-4.pdf.

 USEPA Office of Environmental Information (OEI), “Guidelines for
Ensuring and Maximizing the Quality, Objectivity, Utility, and Integrity
of Information Disseminated by the Environmental Protection Agency”,
EPA/260R-02-008, Oct 2002,
http://www.epa.gov/quality/informationguidelines/documents/EPA_InfoQuali
tyGuidelines.pdf

 Source: OSW, “An Assessment of Environmental Problems Associated with
Recycling of Hazardous Secondary Materials”, 11 Jan 2007, Docket
document ID nr. EPA-HQ-RCRA-2002-0031-0355 available at
http://www.regulations.gov and at
http://www.epa.gov/epaoswer/hazwaste/dsw/abr.htm.  OSW conducted the
2007 recycling damage study in response to public commentors on the 2003
DSW proposed rule.  OSW summarized the recycling damage case study
findings in the 2007 DSW supplemental proposal (Federal Register,
Vol.72, No.57, 26 March 2007, pp.14180-14182), and provided the study
report and its appendices as background documents to the March 2007 DSW
supplemental proposal.

 Source: Figure 4-1: Injury and Fatality Rates in US Coal Mines,
1931-1996 (p. 23)  in “Productivity Change in US Coal Mining”, Joel
Darmstadter, Resources for the Future, Discussion Paper 97-40, July
1997: http://www.rff.org/Documents/RFF-DP-97-40.pdf.

  http://www.epa.gov/epaoswer/hazwaste/data/biennialreport/index.htm

 Source: USEPA Fall 2007 Regulatory Plan and Semiannual Regulatory
Agenda: Part Two - Regulatory Agenda; the 31 OSWER actions are listed on
pages 14 & 15;
http://www.epa.gov/lawsregs/documents/regagendabook-fall07-pt2.pdf.  The
15 RCRA-related actions in the Fall 2007 regulatory agenda consist of:

Revisions to LDR standards for K171/K172 wastes; changes to encourage
recycling of K171/K172

Revisions to RCRA financial test criteria

Revisions to export requirements for hazardous wastes destined for
recovery in OECD countries and for spent lead-acid batteries

Addition of hazardous pharmaceutical wastes to the universal waste
program

RCRA incentives for Performance Track members

Standards for Subtitle D management of utility coal combustion wastes

RCRA smarter waste reporting (formerly Reduction of RCRA reporting and
recordkeeping burden, Phase II)

Exclusion for residues from petroleum refineries recycled in
gasification units

Regulation of solvent-contaminated rags and wipers

Management of cement kiln dust

Revisions to F019 listing to exclude wastewater treatment sludges from
the chemical conversion coating of aluminum automobile bodies

Revisions to the definition of solid waste

Expanding the RCRA comparable fuels exclusion

Standards and procedures for electronic hazardous waste manifests

Streamlining hazardous waste management in academic laboratories

 Source: AACE International Recommended Practice No. 17R-97 “Cost
Estimate Classification System” , 12 Aug 1997, and Recommended
Practice No. 18R-97 “Cost Estimate Classification System – As
Applied in Engineering, Procurement, and Construction for the Process
Industries”, 15 June 1998; http://www.aacei.org/technical/rp.shtml.

 ANSI = American National Standards Institute.  ANSI standard Z94.0 was
originally published in 1972, then revised as Z94-1983 in 1983, revised
as Z94.0-1989 in 1990, and revised again as Z94.2 in 1998.  The ANSI
Z94.2 standard is one element of the set of 17 standards (i.e., Z94.1 to
Z94.17) are for the field of industrial engineering, which is concerned
with the design, improvement, and installation of integrated systems of
people, materials, information, equipment, and energy.   Industrial
engineering draws upon specialized knowledge and skill in the
mathematical, physical, and social sciences, together with the
principles and methods of engineering analysis and design, to specify,
predict and evaluate the results obtained from such systems.  Additional
background information about ANSI Z94 standards is available from the
Institute for Industrial Engineers at:
http://www.iienet2.org/Details.aspx?id=2644.

 Since 2003, the US dollar price of copper has increased fivefold, for
zinc fourfold, and for lead sevenfold. Source:  “Growth in Base Metal
Prices Set to Continue”, Gill Montia, Metal Markets, Brite Media, 23
July 2007;
http://www.metalmarkets.org.uk/2007/07/23/growth-in-base-metal-prices-se
t-to-continue/

 Establishment and Firm Size: 2002 Economic Census: Administrative and
Support and Waste Management and Remediation Services Subject Series,
Nov 2005, report nr. EC02-56SS-SZ:
http://www.census.gov/prod/ec02/ec0256ssszt.pdf

 An October 1998 report “National Hazardous Waste Constituent Survey:
Summary Report” which summarizes the survey methodology and data
findings for OSW’s 1996 National Hazardous Waste Constituent Survey
(NWHCS) is available at:
http://www.epa.gov/epaoswer/hazwaste/id/hwirwste/pdf/summary.pdf.

 Additional summary information and data for the 1993 RCRA Biennial
Report are available at:
http://www.epa.gov/epaoswer/hazwaste/data/br93.htm

 Source: page 21 of “Draft Documentation for the Data Files for the
National Hazardous Waste Constituent Survey”, prepared by Westat,
Inc., 30 March 1998 at
http://www.epa.gov/epaoswer/hazwaste/id/hwirwste/pdf/datadoc5.pdf

  Note that onsite recovery cost estimates are not needed to estimate
implementation impacts for currently regulated hazardous waste recycling